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William Nolan stated:

'I went with the L. L. Hosiery Company about 1897. During all of this time that I was with them, up to the year 1905, they purchased their dyestuffs from the firm Metz & Company. Some time in, I think, 1905, I forget the exact month, a Mr Edward Sheppard came to my house, No. 720, East Clearfield Street, Philadelphia, and represented to me that he was a salesman for the Farbenfabriken Company and asked me if I could make a change in the dyeing department of the mill of L. L. Hosiery Company where I was working, and, instead of buying my dyeing stuff from Metz & Company buy it from the Farben Company. I did not do the buying of this dyeing stuff myself, but it was bought through the office, then sent to me, and I was in a position to say it was good proper stuff or else turn it down as bad and say it could not be used. Mr Sheppard said to me at this first meeting that, if I could succeed in having their dyeing material used instead of that of Metz & Company, whose dyeing material we had been using, he would put the dyeing material in at a certain price, whereas the real and true price would be considerably lower, and the difference between the price at which he would bill it to the L. L. Hosiery Company and the real price he would hand to me in cash as my share of the transaction. I told him to go ahead and send a sample to the office so that I could use it and be in a position to recommend its use in the dye shop.

'In two or three days afterwards a can of, I think, ten or twenty pounds of dyeing stuff came to the office of the L. L. Hosiery Company and was sent to me in the dye shop. I tried it and found it to be good stuff, and I recommended to the head of the firm that they use this dyestuff instead of the kind they had been getting from Metz & Company. This was an acid black dye. From that time on up to the time I left the service of the L. L. Hosiery Company, on my recommendation, they used this acid black dye of the Farbenfabriken Company. They would use on an average about fifty pounds a week-perhaps a little more. I did not know at the time about how much the mill was paying for this a pound, but I have since learned that it was fifty-six cents a pound.

'About three months after Mr Sheppard first saw me at my house, and about three months after we began using this dye, according to my agreement with Mr Sheppard, he came to see me at my house and paid me cash fifty dollars. He explained to me that this was not the whole amount to which

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I was entitled, but that his boss (meaning Mr Alfred Keppelman, the Philadelphia manager of the Farbenfabriken Company) had put up a kick and would only allow him to pay me this much. I afterwards learnt that the truth of the matter was that Mr Sheppard, as the salesman for the Farbenfabriken Company, had been given the entire difference, or nearly the entire difference, between the real price or value of the acid black and the price at which it had been billed to the L. L. Hosiery Company, so that he, Mr Sheppard, could give the same to me according to his original agreement made with me; but that, instead of doing this, Mr Sheppard had retained the balance himself and had actually paid me only about one-half the amount he should have paid me according to our agreement.

'From that time up to the time I left the L. L. Hosiery Company some time in 1909, a period altogether of about three and one-half to four years, at stated intervals of about three months, Mr Sheppard would call at my house, No. 720, East Clearfield Street, Philadelphia, and pay me in bank notes a sum of money which generally was about fifty dollars, claiming that this was my share of the money coming to me under our agreement. During all of this time, too, this sum of money only represented about a half of what I was entitled to get under the terms of our agreement, and I have been credibly informed since that it really represented only about a third of what I should have gotten.'

Richard Pilson stated:

'I never used so very much of the dyestuff of the Farbenfabriken because I never thought very much of it, but at the different mills where I did use it, this Company paid me five, ten and fifteen cents a pound for all of their dyestuffs I used. I recall an interesting incident with reference to the dyer employed by A. & Sons ahead of me and whom I succeeded as dyer. His name was Benjamin Rhodes. He had been employed by A. & Sons for about two years. Certain dyestuffs had been sent into the mill from the main office in Baltimore by Mr A., to be used in dyeing goods by Mr Rhodes. Mr Rhodes thought this dyestuff was not from the people that he wanted to buy from and who were protecting him. He sent it back to Mr A. and told Mr A. it was too inferior to be used. Mr A. kept it at the office in Baltimore for a few weeks and then changed the tags on it. I think he changed the tags to show it was gotten from the Cassella Company, and then sent it back again to the mill and told Mr Rhodes

that it was a new dyestuff gotten from the Cassella Company and asked him to try it. Mr Rhodes used it and sent word to Mr A. that it was the best dyestuff he had ever used. Mr Rhodes wanted to get his dyestuff from the Cassella Company. Mr A. himself came to the mill as soon as he got this word, I think it was Monday morning, and shut the door of the mill in the face of Mr Rhodes, who was discharged from that moment.'

Alfred Selbmann stated as follows:

The five companies that I got dyestuff from were as follows --The Farbenfabriken of Elberfeld Company; the Berlin Aniline Works; the Cassella Colour Company; the . . Company; and the ... Company. In return for my ordering dyestuff from these particular Companies, I would receive money or graft from their various agents as follows:

'My arrangement with the Farbenfabriken Company was that I was to get five cents on every pound used from their Company. This would amount in the average, in my opinion, to about two hundred pounds a week . . . I therefore received from them ten dollars, on the average, every week. This money would be paid me by James Gladfelter, the salesman from the Farbenfabriken of Elberfeld Company, who would come to my house or else send for me to come to a hotel in Reading and would pay me the money every month. My arrangement with the Berlin Aniline Works was the same, viz. that I should get five cents on every pound used from this Company. We would use at this works, in my opinion, about two hundred pounds, on the average, a week from the Berlin Aniline Works. I received, therefore, from them about ten dollars each week, which would be paid me monthly by Mr Feldman, the manager, and at other times by Mr George Carmany, a salesman for that Company. This would be paid me also at my house or at a hotel. From the Cassella Colour Company I do not remember ever receiving anything, as we used very little of their dyestuff.'

Leonard K. Townson stated:

'My first personal contact with the dye goods manufacturers and with their paying the dyers commissions, which are known among the dyers themselves as graft, was at the C. Mill in 1910. I have often been in positions, of course, before this where I have seen this graft handed out and paid, but I had never been in a position of authority myself to receive it. I was head dyer at the C. Mills. While I was there I

bought dyestuffs from the Cassella Colour Company, the Farbenfabriken of Elberfeld Company, and the Berlin Aniline Works. My business with the Cassella Company would amount to about five hundred pounds a month; and on this they paid me five cents a pound. This is considered the safe basis, which all houses are willing to deal under with the dyer.... The amount of dyestuff that I used altogether from the Farbenfabriken of Elberfeld Company was about two hundred pounds, upon which they paid me only on the straight basis of five cents a pound. . . . The amount of dyestuff I got from the Berlin Aniline Works was six hundred pounds altogether, on which they paid me only on the straight basis of ten dollars. The way that colour was rated-it being sold as a fast colour, when it was a direct black-I should have gotten thirty cents a pound on this, according to all the rules of the dyers. Instead I was only paid ten dollars.'

Christopher Eisfeld stated:

'During all the time that I worked as boss dyer in the employ of the L. L. Hosiery Company of Frankford, Philadelphia, I received graft from the Philadelphia office of the Farbenfabriken of Elberfeld Company amounting to from ten to twelve cents per pound on all the dyestuff furnished by that Company to my employers, the L. L. Hosiery Company. My employers used, I suppose, about a thousand pounds of black dye every two months, and about sixty pounds of various other colours every week. My graft, therefore, which was paid to me by the Farbenfabriken Company, would amount to about one hundred and ten dollars every two months on the black dyestuffs, and about six or seven dollars each week on the other colours. This graft was paid to me personally by the manager of the Philadelphia office of the Farbenfabriken of Elberfeld Company, Mr Alfred J. Keppelman. The graft was also sometimes paid to me by the salesmen of the Farbenfabriken of Elberfeld Company, Mr Litchfield and Mr Sheppard. It was always paid to me at my home by these men, at my address, 1906, East Venango Street, Philadelphia.

'From about the middle of July to the middle of October 1910, Mr. Sheppard, the salesman, instead of paying me the graft which was due me, kept it, and then came around to my house at the above address and paid me only half that which was due to me on the dyestuff that he himself had sold me, keeping the other half for himself. In other words, he offered me seventy-five dollars and kept seventy-five dollars himself in his own pocket, whereas the whole one

hundred and fifty dollars was due me on the dyestuff that Mr Sheppard had sold my employers.

'I immediately stopped giving any further orders for the dyestuff to the Farbenfabriken of Elberfeld Company. Whereupon Mr Litchfield, the other salesman, paid me a visit to find out why his Company did not get any more orders, and I explained to him the treatment I had received from Mr Sheppard, and I also told Mr Litchfield that I was willing to go to Mr Keppelman and explain to Mr Keppelman the treatment Mr Sheppard was giving me. Mr Litchfield advised me not to do this, telling me he would fix the matter himself without Mr Keppelman knowing anything about it. A few days later Mr Litchfield came to my house and told me that Mr Sheppard could not pay me all the money that was due to me from him (Sheppard), but asked me if I was willing to accept five dollars a week each week until I was paid off this graft money that was due me and which Mr Sheppard had kept. This, of course, was in addition to the other graft money that was due me on the regular dyestuffs I was getting all the time for my employers, and which was being paid me regularly at my house by Mr Litchfield and Mr Keppelman. Thinking that Mr Sheppard might have need of this money himself, I accepted this offer of five dollars a week and was paid five dollars for two weeks, which was sent me by mail-a five-dollar bill in two envelopes for two weeks. No letter or writing was in these envelopes. After these two payments, the payments were discontinued, and I waited a few more weeks to give Mr Sheppard a chance to do the right thing, and then I wrote to Mr Keppelman a letter explaining my bad treatment by Mr Sheppard.

'In the meantime, I had given Mr Litchfield an order for five hundred pounds of wool black, to be used by my employers in dyeing, for which order Mr Litchfield paid me sixty dollars two weeks later. Mr Sheppard, however, did not come up with any further money on account of what he owed, and I again wrote to Mr Keppelman about it; and Mr Keppelman wrote me a letter saying he would come up to see me the following Sunday at my house. In the meantime, Mr Litchfield came to my house and paid me fifty dollars from Mr Sheppard and told me he would bring the ten dollars balance owed by Mr Sheppard the next week. I told Mr Litchfield that I had informed Mr Keppelman about the matter, and Mr Litchfield told me I had no business to do this.

'On the following Sunday, about the middle of December 1910, Mr Keppelman came to my house and asked me not to

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