Monday, August 18, 1913: Unsworn, Oral Statement of Leo M. Frank

LEO FRANK MOUNTS THE WITNESS STAND AND MAKES HIS UNSWORN STATEMENT TO THE COURT

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Gentlemen of the Jury:

In the year 1884, on the 17th day of April, I was born in Cuero, Texas.

At the age of three months, my parents took me to Brooklyn, New York, and I remained in my home until I came South, to Atlanta, to make my home here.

I attended the public schools of Brooklyn, and prepared for college, in Pratt Institute, Brooklyn, New York.

In the fall of 1902, I entered Cornell University, where I took the course in mechanical engineering, and graduated after four years, in June, 1906.

I then accepted a position as draftsman with the B. F. Sturtevant Company, of Hyde Park, Massachusetts.

After remaining with this firm about 6 months, I returned once more to my home in Brooklyn, where I accepted a position as testing engineer and draftsman with the National Meter Company of Brooklyn, New York.

I remained in this position until about the middle of October, 1907, when, at the invitation of some citizens of Atlanta, I came South to confer with them in reference to the starting and operation of a pencil factory, to be located in Atlanta.

After remaining here for about two weeks, I returned once more to New York, where I engaged passage and went to Europe.

I remained in Europe nine months.

During my sojourn abroad, I studied the pencil business, and looked after the erection and testing of the machinery which had been previously contracted for.

The first part of August, 1908, I returned once more to America, and immediately came South to Atlanta, which has remained my home ever since.

I married in Atlanta, an Atlanta girl, Miss Lucile Selig.

The major portion of my married life has been spent at the home of my parents in law, Mr. and Mrs. Selig, at 68 East Georgia Avenue.

My married life has been exceptionally happy-indeed, it has been the happiest days of my life.

My duties as superintendent of the National Pencil Company were in general, as follows:

I had charge of the technical and mechanical end of the factory, looking after the operations and seeing that the product was turned out in quality equal to the standard which is set by our competitors.

I looked after the installation of new machinery and the purchase of new machinery.

In addition to that, I had charge of the office work at the Forsyth Street plant, and general supervision of the lead plant, which is situated on Bell Street.

I looked after the purchase of the raw materials which are used in the manufacture of pencils, kept up with the market of those materials, where the prices fluctuated, so that the purchases could be made to the best possible advantage.

On Friday, April 15th, I arrived at the pencil factory on Forsyth Street, at about seven o'clock my usual time.

I immediately started in on my regular routine work, looking over papers that I had laid out the evening before, and attending to any other work that needed my special attention that morning.

At about 9:30 1 went over to the office of the General Manager and Treasurer, Mr. Sigmond Montag, whose office is at Montag Brothers, on Nelson Street.

I stayed over there a short time, got what papers and mail had arrived over there-all the mail for the Pencil Company comes over there to their office-I got that mail and brought it back to Forsyth St.

I then separated the mail and continued along my usual routine duties in the office on Forsyth Street.

At about eleven o'clock, Mr. Schiff handed me the pay roll books covering the plants at Forsyth Street and at Bell Street, for me to check over to see that the amounts and the extensions were correct.

Of course, this work has to be very carefully done, so that the proper amount of money is drawn from the bank.

This checking took me until about 12:30 P. M. , when I made out the amount on slip of paper that I wished to have drawn from the bank, went over to Montag Brothers, had the checks drawn and signed by Mr. Sigmond Montag, after which I returned to Forsyth Street and got the leather bag in which I usually carry the money and coin from the bank, and got the slip on which I had written the various denominations in which I desired to have the pay-roll made out, accompanied by Mr. Herbert Schiff, my assistant, went to the Atlanta National Bank, where I had the checks cashed.

Returning to the factory in company with Mr. Schiff, I placed this bag containing the money for the pay roll in the safe and locked it.

At this time, my wife called for me and in her company and that of Mr. Schiff, I went over to the car and took my wife home to lunch.

After lunch, I returned to the factory and took a tour for about an hour through the factory, after which I then assisted Mr. Schiff in checking over the amounts on the pay envelopes-checking the money against the duplicate slips that we had gotten from the bank, to see that the correct amount had been given us, and I helped Mr. Schiff checking over the money and in filling the envelopes.

This took us approximately until a quarter to six, to fill the envelopes, seal them and place them in the box that we have over there, with two hundred pigeon holes, and which we call our pay-off box.

While I was so occupied with Mr. Schiff in filling these envelopes, a young man by the name of Wright, who had helped us out as a clerk in the office during the past week, came in and I paid him in cash, as Mr. Schiff, I found, neglected to put his name on the pay-roll; I just made out a ticket for the amount of money he drew and put it in the cash box and charged it to the cash box and not to the pay-roll.

At a quarter to six, payment of the help took place, Mr. Schiff taking all the envelopes that were due the help who had worked from April 18th to 24th, inclusive, out to the pay-roll window, which is entirely outside of either my inner office or the outer office and out in the hall beyond--a little window that we have built.

I sat in my office checking over the amount of money which had been left over.

This amount was equal--or should have been equal, to the amount that had been loaned out in advance to help and had been deducted when we were filling the envelopes.

In checking this amount over--as near as I can recollect it, there was about $15.

00--I noticed a shortage of about $1.

20--something over a dollar, at any rate, and I kept checking to see if I couldn't find the shortage, going over the various deductions that had been made, but I couldn't locate it that evening.

After the help had been paid off, during which time as I sat in my office, no one came into my office who asked me for a pay envelope or for the pay envelope of another.

After the paying off of the help had taken place, Mr. Schiff returned and handed me the envelopes which were left over, bound with an elastic band, and I put them in the cash compartment, --which is different from the cash box-a certain cash compartment in the safe, the key to which is kept in my cash box.

I placed them in the safe, and Mr. Schiff busied himself clearing up the books and the files and placing them in the safe.

While he was doing that, I placed in the time clocks, the slips to be used next day.

I took out the two time slips which were dated April 25th, which had been used by the help on Friday, April 25th, and took two slips out to the clock, the ends of which I creased down so that they would fit into the cylinder inside of the clocks; and I noticed that I had neglected to stamp the date on them, so I just wrote on them"

April 26, 1913'"-in other words, I put the date of the day following, which is the way we usually do with the time clock.

After placing these slips in the clock and bringing those back in the office, Mr. Schiff and myself left for home, it being about 6:30.

I neglected to state that while I was sitting in the office, Mr. Schiff was paying off Newt Lee--these are the two time slips I took out-Gentlemen, as I was saying, these two slips that had April 26, 1913, written at the bottom are the two slips I put in the clock on the evening of Friday, April 25th, to be used on the day following, which, of course, was April 26th.

I neglected to mention also, in going over my duties at the factory, that Mr. N. V. Darley was superintendent of labor and of manufacture, it fell to his duty to engage the help and to distribute the help throughout the plant, and to discharge the help in case it was necessary; it was also due to him whether their wages were raised or not.

In other words, he was the man that came directly in contact with the help.

Moreover, he saw that the goods progressed through the factory without stopping, easily, quickly and economically manufactured.

On Friday evening, I got home at about 6:30, had my supper, washed up, then went with my wife to the residence of her uncle, Mr. Carl Wolfsheimer, on Washington Street, where my wife and Mr. Wolfsheimer and his wife and myself played a game of auction bridge for the balance of the evening.

My wife and I returned home and retired at about eleven o'clock.

On Saturday April 26th, I rose between seven and seven-thirty and leisurely washed and dressed, had my breakfast, caught a Washington Street or Georgia Avenue car--I don't recall which-at the corner of Washington and Georgia Avenue, and arrived at the factory on Forsyth Street, the Forsyth Street plant, at about 8:30, is my recollection.

On my arrival at the factory, I found Mr. Holloway, the day watchman, at his usual place, and I greeted him in my usual way; I found Alonzo Mann, the office boy, in the outer office, I took off my coat and hat and opened my desk and opened the safe, and assorted the various books and files and wire trays containing the various papers that were placed there the evening before, and distributed them in their proper places about the office.

I then went out to the shipping room and conversed a few minutes with Mr. Irby, who at that time was shipping clerk, concerning the work which he was going to do that morning, though, to the best of my recollection, we did no shipping that day, due to the fact that the freight offices were not receiving any shipments, due to its being a holiday.

I returned to my office, and looked through the papers, and assorted out those which I was going to take over on my usual trip to the General Manager's office that morning; I then turned to the invoices (Defendant's Exhibits 25 to 34) covering shipments which were made by the pencil factory on Thursday, April 24th, and which were typewritten and figured out on Friday, April 25th, by Miss Eubanks, the stenographer who stays in my office; she had hurried through with her work that day, previous to going home, so she could spend the holiday in the country where she lived;

I didn't get to checking over those invoices covering these shipments on Friday, due to the fact that Mr. Schiff and myself were completely occupied the entire day until we left the factory, with the pay-roll, so naturally, as these invoices covering shipments which were made on April 25th, ought to have been sent to the customers, I got right to work in checking them.

Now, I have those invoices here these papers have not been exhibited before, but I will explain them.

Of all the mathematical work in the office of the pencil factory, this very operation, this very piece of work that I have now before me, is the most important, it is the invoice covering shipments that are sent to customers, and it is very important that the prices be correct, that the amount of goods shipped agrees with the amount which is on the invoice, and that the terms are correct, and that the address is correct, and also in some cases, I don't know whether there is one like that here, there are freight deductions, all of which have to be very carefully checked over and looked into, because I know of nothing else that exasperates a customer more than to receive invoices that are incorrect; moreover, on this morning, this operation of this work took me longer than it usually takes an ordinary person to complete the checking of the invoices, because usually one calls out and the other checks, but I did this work all by myself that morning, and as I went over these invoices, I noticed that Miss Eubanks, the day before, had evidently sacrificed accuracy to speed, and every one of them was wrong, so I had to go alone over the whole invoice, and I had to make the corrections as I went along, figure them out, extend them, make deductions for freight, if there were any to be made, and then get the total shipments, because, when these shipments were made on April 24th, which was Thursday, this was the last day of our fiscal week, it was on this that I made that financial sheet which I make out every Saturday afternoon, as has been my custom, it is on this figure of total shipments I make that out, so necessarily it would be the total shipments for the week that had to be figured out, and I had to figure every invoice and arrange it in its entirety so I could get a figure that I would be able to use.

The first order here is from Hilton, Hart & Kern Company, Detroit, Mich. , here is the original order which is in the file of our office, here is the transcription which was made on March 28th, it hadn't been shipped until April 24th, this customer ordered 100 gross of Number 2 of a certain pencil stamped "The Packard Motor Car Company," 125 gross of Number 3 and 50 gross of Number 4; those figures represent the grade or hardness of the lead in the pencils; we shipped 100 gross of Number 211 1/2 gross of Number 3 and 49 gross of Number 4, the amount of the shipment of Number 3 is short of the amount the customer ordered, therefore, there is a suspense shipment card attached to it, as you will notice, the first shipment on this order took place on April 24th, it was a special order and a special imprint on it, and therefore, the length of time, order received at the factory on March 18th.

In invoicing shipments made by the Pencil Company, our method is as follows:

We make out in triplicate, the first or original is a white sheet, and that goes to the customers; the second is a pink sheet and that goes over to the General Manager's office and is filed serially, that is, chronologically; one date on the top, and from that the charges are made on the ledger, and the last sheet or third sheet is a yellow sheet, which is here, those are placed in a file in my office, and are filed alphabetically.

These yellow sheets I have here are not the yellow sheets I had that day, because they have since been corrected, I am just taking the corrected sheets, I made the corrections,

Miss Eubanks returned on Monday and saw the corrections I had made in pencil on the white sheets, and made another set of triplicates afterwards, and I presume made them correct, I was not there, and I don't know.

These orders are respectively Hilton, Hart & Kern Company, L. W. Williams & Company of Fort Worth, Tex., the Fort Smith Paper Company of Fort Smith, Ark., S. 0.

Barnum & Sons, Buffalo, N. Y., S. T. Warren & Company, South Clarke St., Chicago, Ill. , S. H. Kress Company, warehouse at 91 Franklin St., New York, N. Y.; there is an order that we have to be particularly careful with, because all these five and ten cent syndicates have a great deal of red tape.

These invoices, though they were typed on April 25th, Friday, were shipped on April 24th, and bear date at the top on which the shipment was made, irrespective of the date on which these are typewritten; in other words, the shipments took place April 24th, and that date is at the top typewritten, and a stamp by the office boy at the bottom, April 24th.

Among other things that the S. H. Kress Company demands is that on their orders, you must state whether or not it is complete, the number of the store, and by which railroad the shipment goes.

Here is one from F. W. Woolworth & Company, Frankfort, Ind., take the following illustrations:

Less 95 lbs., at 86 cents per hundred lbs., freight credit; in other words, we had to find out what the weight of that shipment was, and figure out the amount of credit that they were entitled to on the basis of 86 cents for every 100 lbs. shipped.

Then here comes one to Gottlieb & Sons, one of our large distributors in New York, N. Y., they have a freight allowance of 86 per hundred lbs. also, and their shipment amounted to 618 lbs., on Thursday, April 24th.

That was a shipment of throw-outs, or jobs.

I started on this work, as I said, and had gone into it in some detail, to show you the carefulness with which the work must be carried out, I was at work on this one at about 9 o'clock, as near as I remember, Mr. Darley and Mr. Wade Campbell, the inspector of the factory, came into the outer office, and I stopped what work I was doing that day on this work, and went to the outer office and chatted with Mr. Darley and Mr. Campbell for ten or fifteen minutes, and conversed with them, and joked with them, and while I was talking to them, I should figure about 9:15 o'clock, a quarter after nine, Miss Mattie Smith came in and asked me for her pay envelope, and for that of her sister-in-law, and I went to the safe and unlocked it and got out the package of envelopes that Mr. Schiff had given me the evening before, and gave her the required two envelopes, and placed the remaining envelopes that I got out, that were left over from the day previous, in my cash box, where I would have them handy in case others might come in, and I wanted to have them near at hand without having to jump up and go to the safe every time in order to get them; I keep my cash box in the lower drawer on the left hand side of my desk.

After Miss Smith had gone away with the envelopes, a few minutes, Mr. Darley came back with the envelopes, and pointed out to me an error in one of them, either the sister-in-law of Miss Mattie Smith, she had gotten too much money, and when I had deducted the amount that was too much, that amount balanced the pay roll, the error in the pay roll that I had noticed the night before, and left about five or ten cents over; those things usually right themselves anyhow.

I continued to work on those invoices, when I was interrupted by Mr. Lyons, Superintendent of Montag Brothers, coming in, he brought me a pencil display box that we call the Panama assortment box, and he left it with me, he seemed to be in a hurry, and I told him if he would wait for a minute I would go over to Montag Brothers with him, as I was going over there; and he stepped out to the outer office, and as soon as I come to a convenient stopping place in the work, I put the papers I had made out to take with me in a folder, and put on my hat and coat and went to the outer office, when I found that Mr. Lyons had already left.

Mr. Darley left with me, about 9:35 or 9:40, and we passed out of the factory, and stopped at the corner of Hunter and Forsyth Streets, where we each had a drink at Cruickshank's soda water fount, where I bought a package of Favorite cigarettes, and after we had our drink, we conversed together there for some time, and I lighted a cigarette and told him good-bye, as he went in one direction, and I went on my way then to Montag Brothers, where I arrived, as nearly as may be, at 10 o'clock, or a little after; on entering Montag Brothers, I spoke to Mr. Sig Montag, the General Manager of the business, and then the papers which I collected, which lay on his desk, I took the papers out and transferred them into the folder, and took the other papers out, which I had in my folder, and distributed them at the proper places at Montag Brothers, I don't know just what papers they were, but I know there were several of them, and I went on chatting with Mr. Montag, and I spoke to Mr. Matthews, and Mr. Cross, of the Montag Brothers, and after that I spoke to Miss Hattie Hall, the Pencil Company's stenographer, who stays at Montag Brothers, and asked her to come over and help me that morning; as I have already told you, practically every one of these invoices was wrong, and I wanted her to help me on that work, and in dictating the mail; in fact, I told her I had enough work to keep her busy that whole afternoon if she would agree to stay, but she said she didn't want to do that, she wanted to have at least half a holiday on Memorial Day.

I then spoke to several of the Montag Brothers' force on business matters and other matters, and after that I saw Harry Gottheimer, the sales manager of the National Pencil Company, and I spoke at some length with him in reference to several of his orders that were in work at the factory, there were two of his orders especially that he laid special stress on, as he said he desired to ship them right away, and I told him I didn't know how far along in process of manufacture the orders had proceeded, but if he would go back with me then I would be very glad to look for it, and then tell him when we could ship them, and he said he couldn't go right away, he was busy, but he would come a little later, and I told him I would be glad for him to come over later that morning or in the afternoon, as I would be there until about 1 o'clock in the morning, and after 3.

I then took my folder and returned to Forsyth St. alone.

On arrival at Forsyth St., I went to second or office floor, and I noticed the clock, it indicated 5 minutes after eleven.

I saw Mr. Holloway there, and I told him he could go as soon as he got ready, and he told me he had some work to do for Harry Denham and Arthur White, who were doing some repair work up on the top floor, and he would do the work first.

I then went into the office.

I went in the outer office, and found Miss Hattie Hall, who had preceded me over from Montag's, and another lady who introduced herself to me as Mrs. Arthur White, and the office boy; Mrs. Arthur White wanted to see her husband, and I went into the inner office, and took off my coat and hat, and removed the papers which I had brought back from Montag Brothers in the folder, and put the folder away.

It was about this time that I heard the elevator motor start up and the circular saw in the carpenter shop, which is right next to it, running.

I heard it saw through some boards, which I supposed was the work that Mr. Holloway had referred to.

I separated the orders from the letters which required answers, and took the other material, the other printed matter that didn't need immediate attention, I put that in various trays, and I think it was about this time that I concluded I would look and see how far along the reports were, which I use in getting up my financial report every Saturday afternoon, and to my surprise I found that the sheet which contains the record of pencils packed for the week didn't include the report for Thursday, the day the fiscal week ends; Mr. Schiff evidently, in the stress of getting up, figuring out and filling the envelopes for the pay roll on Friday, instead of, as usual, on Friday and half the day Saturday, had evidently not had enough time.

I told Alonzo Mann, the office boy, to call up Mr. Schiff, and find out when he was coming down, and Alonzo told me the answer came back over the telephone that Mr. Schiff would be right down, so I didn't pay any more attention to that part of the work, because I expected Mr. Schiff to come down any minute.

It was about this time that Mrs. Emma Clarke Freeman and Miss Corinthia Hall, two of the girls who worked on the fourth floor, came in, and asked permission to go upstairs and get Mrs. Freeman's coat, which I readily gave, and I told them at the same time to tell Arthur White that his wife was downstairs.

A short time after they left my office, two gentlemen came in, one of them a Mr. Graham, and the other the father of a boy by the name of Earle Burdette; these two boys had gotten into some sort of trouble during the noon recess the day before, and were taken down to police headquarters, and of course didn't get their envelopes the night before, and I gave the required pay envelopes to the two fathers, and chatted with them at some length in reference to the trouble their boys had gotten into the day previous.

And just before they left the office, Mrs. Emma Clark Freeman and Miss Corinthia Hall came into my office and asked permission to use the telephone, and they started to the telephone, during which time these two gentlemen left my office.

But previous to that, when these two gentlemen came in, I had gotten Miss Hattie Hall in and dictated what mail I had to give her, and she went out and was typewriting the mail; before these girls finished their telephoning, Miss Hattie Hall had finished the typewriting of those letters and brought them to my desk to read over and sign, which work I started.

Miss Clark and Miss Hall left the office, as near as may be, at a quarter to twelve, and went out, and I started to work reading over the letters and signing the mail.

I have the carbon copies of these letters which Miss Hall typewrote for me that morning here, attached to the letters from the customers, or the parties whose letter I was answering; they have been introduced, and have been identified.

I see them here-(Defendants' Exhibit 8),

--Southern Bargain House, there was a letter from Shode-Lombard, dye makers, 18 Franklin Street, the American Die Lock Company, Newark, N. J., another letter to Shode-Lombard Company in answer to one of theirs about a die, being in New York, one to Henry Disston & Sons, in reference to a knife which they sent us to be tried out, a circular knife, one to J. B. Mc Crory, Five & Ten Cent Syndicate, one to the Pullman Company, of Chicago, Ill., in reference to their special imprint pencils, which they were asking us to ship as soon as possible, one to A. J. Sassener, another die maker; these letters are copies of the ones I dictated that morning;

I signed these letters, and while I was signing, as Miss Hall brought these letters in to be signed, I gave her the orders which had been received by me that morning at Montag 's office, over at the General Manager's office, I gave her these orders to be acknowledged.

I will explain our method of acknowledgment of orders in a few minutes.

I continued signing the letters and separating the carbon copies from the letters, and putting them in various places, I folded the letters and sealed the letters, and of course I told Miss Hall I would post them myself.

Miss Hall finished the work and started to leave when the 12 o'clock whistle blew, she left the office and returned, it looked to me, almost immediately, calling into my office that she had forgotten something, and then she left for good.

Then I started in, we transcribed, first we enter all orders into the house order book (Defendant's Exhibit 12), all these orders which Miss Hall had acknowledged, I entered in that book, and I will explain that matter in detail.

There has been some question raised about this, but I believe I can make it very clear.

Here is an order from Beutell Brothers Company (Defendant's Exhibit 21); that bears the date April 23rd, up at the top; that was the date when Beutell Brothers in Dubuque, Ia., had that letter typewritten, it was received at the General Manager's office, might have been received Friday, on Friday April 25th, after I had gotten the mail that day there, and remained there until April 26th, when I went over and got the mail again.

Here is one from John Laurie & Sons, (Defendants' Exhibit 23), and here is the one Mr. Dorsey did some questioning about, because of the fact that up here at the top was 4-22, this order was written in pencil, of course it is written in pencil; this is an order from F. W. Woolworth & Company (Defendant's Exhibit 17),

that is a Five & Ten Cent syndicate, as you know, probably the largest in the world, that has over 700 stores, and these stores would be so bulky for one office to handle that the 700 stores are divided into different groups or provinces, and in charge of each group there is a certain office; for instance, there is one at Toronto, for the Canadian stores; one in Buffalo, one in Boston, one in New York, there is one at Wilkesbarre, one at St. Louis, one at Chicago, and one at San Francisco.

Now, this order, by looking at it, I can tell, because I have had reason to look into and know the system of orders used by this syndicate, and I most assuredly have to know it, you notice Chicago, Ill., 4-22, down here, and also store Number 585 (Defendant's Exhibit 17), the Woolworth Company, 347 E. Main St., here again is De Kalb, Ill.

In other words, De Kalb, Ill., is in the jurisdiction of the Chicago office.

These blanks are distributed among these various five and ten cent stores, and the manager of one store, when he wants to order goods, he finds his stock is getting a little low, he makes that out and sends his order in to the Chicago office, at the Chicago office, the buyer looks over it, and sees that the manager has carefully and economically ordered the goods, and then you will notice that little stamp punched through; you see up there, that says:

"Valid, 4-23," in other words, of course, we couldn't have put that on there at our office, but the validation stamp, with 4-23, the date of it, shows it took a day to travel from De Kalb, ll., to Chicago, Ill., and that stamp shows the validation of the order on that date by the head office, and that order is then forwarded by the head office to us.

Now, this order is usually made out by the Manager or by the clerk of the Manager or some one in that F. W. Woolworth store.

Here is one from Wilkesbarre (Defendant's Exhibit 18), itself, that is from the head office itself.

Here is one from St. Joseph, Mo., (Defendant's Exhibit 14), via St. Louis, that bears the validation stamp of the St. Louis head office.

You gentlemen understand these people are great big people, a great big syndicate, and they have to do their clerical work according to a system that is correct.

Now, then, that was the first operation on these orders after we separated them from the other mail, and we hand that on to our Superintendent.

I am showing you about the acknowledgment stamp, because it is important first because it shows the acknowledgment of the order, and who acknowledged it, and secondly, shows the date on which the orders were received at my office.

To the best of my recollection, these acknowledgment cards were given to the office boy to post, after Miss Hall had made them out.

Now, in reference to the work that I. did on these orders, starting here with order 7187 (Defendant's Exhibits 14-24), and continuing through 7197, that is not such an easy job as you would have been led to believe; in the first place, next to the serial number, there is a series of initials, and those initials stand for the salesman who is credited with the order; in other words, if a man at the end of the year wants to get certain commissions on orders that come in, we have to very carefully look over those orders to see to whom or to which salesman or to which commission house or which distributing agent that order is credited, so, therefore, it takes a good deal of judgment and knowledge to know just to which salesman to credit, and sometimes, I can't say that it was incorrect that morning, but it might have been, sometimes I have to go through a world of papers to find just to whom a certain order is to be credited.

Then I enter in (Defendant's Exhibit 12) the various orders here, too, the next column shows to whom the goods are to be shipped; of course that is not very difficult to do, that is just a mere copy.

The store numbers are put down in case the stores have numbers, and then one must look over the order; I notice that one of the orders is one to R. E. Kendall (Defendant's Exhibit 24), at Plum St., Cincinnati, 0., calling for a special, and that has to be noted in this column here, you will notice regular or special, notice here the word special out here opposite R. E. Kendall, that thing has to be very carefully noted also.

Now, in this column is the order number, and that order number is the customer's order number, to which we have to refer always when we ship that order.

Now, in these cases like on these Woolworth orders (Defendant's Exhibit 17), when there is no order number, we put down the date with the month, so in that way that gives it, 4-22, that was the date the order was made out, so we can absolutely refer to it; in this column (Defendant's Exhibit 12), is the shipping point and the date we are going to ship it, and in this column represents the date on which the order was received, and the month, which is April 26th, according to the acknowledgment, corresponding to the acknowledgment stamp.

Now, after that work, after the order was acknowledged and entered in here (Defendant's Exhibit 12), the next step is the filling in on the proper place on this sheet (Defendant's Exhibit 2), which has already been tendered and identified.

Now, the work done by me on that day right here, that was Saturday, Saturday is the second day of the fiscal week, Friday, Saturday, Sunday, Monday, Tuesday, Wednesday and Thursday-Saturday is the second day, and you will notice, gentlemen, there are only two entries there, the work not having been done since I left the factory, there are only two entries there, and the last entry is April 26th, which was Saturday.

Now, then, the information on this sheet is as follows:

I go through the orders and find out the number of gross of pencils which our customers order which fall in certain price groups, that is, to find the number of gross of pencils for which the pencil factory gets 60 cents a gross, and I put them down under the first column, the second under the column RI, which means rubber inserted, and for which we get an average price of 80 cents, I go through the same thing and put the figures all out, in this case, it was 102; then we have a price group on which we get an average of $1.25, and it covers a range in price from $1.00 per gross to $1.40; there were 116 gross of such pencils ordered with these orders which were received that morning.

The next price group are those on which we figure on an average price of $1 75 a gross, and falling within those limits of $1 50 to $1.95 inclusive; in this case, there were 34 1/2 gross; then there is a group between $2.00 and $2.95, averaging $2.50, and there was 100 1/2 gross that day, then $3 00 and over, which we always figure at just $3.00, we have goods that we get $3. 25 for, and some that we get $3.50 for, but we figure them all at $3 00, so it is a conservative estimate.

The reason this is done is this; in the pencil business, just like in all manufacturing businesses, that is manufacturing an article that has to be turned out large quantities, it behooves the sales department to sell as much of your high priced goods as possible, and as few of your cheap goods, and therefore, if you know how many of the cheap goods and how many of the better grade of goods you are selling, it serves as a barometer on the class of goods that is being sold.

You can see that this job takes quite a little figuring and quite a little judgment.

After finishing that work, I went on to the transcription of these orders to these requisitions and notwithstanding an answer that has been made, I wrote these requisitions myself.

(Defendant's Exhibit 25-35).

That is my hand-writing and you can read every one of them through (Defendant's Exhibit 25-35).

Here is one F. W. Woolworth I wrote that one, and another one F. W. Woolworth, I wrote that one, and another one F. W. Woolworth.

Here is one 5 and 10 Cent Store, Sault Ste Marie (Defendant's Exhibit 31), I wrote that one, and here is F. W. Woolworth, De Kalb, Ill. (Defendant's Exhibit 27), and Logansport, Ind.

That is all my handwriting; excepting the amounts that are placed down here under the dates when the shipment of these orders were made, which is in the hand-writing of my assistant, Mr. Schiff.

This part, the amount, date, numbers, addresses, salesman, date April 26th, and the order number, taking the date in lieu of the order number, as I explained previously, that is all my hand-writing everything except that amount there and the subsequent date, that is in my hand-writing and the work on all of those was done on the morning of April 26th.

Miss Hall left my office on her way home at this time, and to the best of my information there were in the building Arthur White and Harry Denham and Arthur White's wife on the top floor.

To the best of my knowledge, it must have been from ten to fifteen minutes after Miss Hall left my office, when this little girl, whom I afterwards found to be Mary Phagan, entered my office and asked for her pay envelope.

I asked for her number and she told me; I went to the cash box and took her envelope out and handed it to her, identifying the envelope by the number.

She left my office and apparently had gotten as far as the door from my office leading to the outer office, when she evidently stopped and asked me if the metal had arrived, and I told her no.

She continued on her way out, and I heard the sound of her footsteps as she went away.

It was a few moments after she asked me this question that I had an impression of a female voice saying something; I don't know which way it came from; just passed away and I had that impression.

This little girl had evidently worked in the metal department by her question and had been laid off owing to the fact that some metal that had been ordered had not arrived at the factory; hence, her question.

I only recognized this little girl from having seen her around the plant and did not know her name, simply identifying her envelope from her having called her number to me.

She had left the plant hardly five minutes when Lemmie Quinn, the foreman of the plant, came in and told me that I could not keep him away from the factory, even though it was a holiday; at which I smiled and kept on working.

He first asked me if Mr. Schiff had come down and I told him he had not and he turned around and left.

I continued work until I finished this work and these requisitions and I looked at my watch and noticed that it was a quarter to one.

I called my home up on the telephone, for I knew that my wife and my mother-in-law were going to the matinee and I wanted to know when they would have lunch.

I got my house and Minola answered the phone and she answered me back that they would have lunch immediately and for me to come right on home.

I then gathered my papers together and went upstairs to see the boys on the top floor.

This must have been, since I had just looked at my watch, 10 minutes to one.

I noticed in the evidence of one of the witnesses, Mrs. Arthur White, she states it was 12:35 that she passed by and saw me.

That is possibly true; I have no recollection about it; perhaps her recollection is better than mine; I have no remembrance of it; however, I expect that is so.

When I arrived up stairs I saw Arthur White and Harry Denham who had been working up there and Mr. White's wife. I asked them if they were ready to go and they said they had enough work to keep them several hours.

I noticed that they had laid out some work and I had to see what work they had done and were going to do.

I asked Mr. White's wife if she was going or would stay there as I would be obliged to lock up the factory, and Mrs. White said,

No, she would go then.

I went down and gathered up my papers and locked my desk and washed my hands and put on my hat and coat and locked the inner door to my office and I locked the doors to the street and started to go home.

Now, gentlemen, to the best of my recollection from the time the whistle blew for twelve o'clock until after a quarter to one when I went up stairs and spoke to Arthur White and Harry Denham, to the best of my recollection, I did not stir out of the inner office; but it is possible that in order to answer a call of nature or to urinate I may have gone to the toilet.

Those are things that a man does unconsciously and cannot tell how many times nor when he does it.

Now, sitting in my office at my desk, it is impossible for me to see out into the outer hall when the safe door is open, as it was that morning, and not only is it impossible for me to see out, but it is impossible for people to see in and see me there.

I continued on up Forsyth to Alabama and down Alabama to Whitehall where I waited a few minutes for a car, and after a few minutes a Georgia Avenue car came along; I took it and arrived home at about 1:20.

When I arrived at home, I found that my wife and my mother-in-law were eating their dinner, and my father-in-law had just sat down and started his dinner.

I sat down to my dinner and before I had taken anything, I turned in my chair to the telephone, which is right behind me and called up my brother-in-law to tell him that on account of some work I had to do at the factory, I would be unable to go with him, he having invited me to go with him out to the ball game.

I succeeded in getting his residence and his cook answered the phone and told me that Mr. Ursenbach had not come back home.

I told her to give him a message for me, that I would be unable to go with him.

I turned around and continued eating my lunch, and after a few minutes my wife and mother-in-law finished their dinner and left and told me good-bye.

My father-in-law and myself continued eating our dinner, Minola Mc Knight serving us.

After finishing dinner, my father-in-law said he would go out in the back yard to look after his chickens and I lighted a cigarette and laid down.

After a few minutes I got up and walked up Georgia Avenue to get a car.

I missed the ten minutes to two car and I looked up and saw in front of Mr. Wolfsheimer's residence, Mrs. Michael, an aunt of my wife who lives in Athens, and there were several ladies there and I went up there to see them and after a few minutes Mrs. Wolfsheimer came out of the house and I waited there until I saw the Washington Street car coming and I ran up and saw that I could catch the car.

I got on the car and talked to Mr. Loeb on the way to town.

The car got to a point about the intersection of Washington Street and Hunter Street and the fire engine house and there was a couple of cars stalled up ahead of us, the cars were waiting there to see the memorial parade; they were all banked up.

After it stood there a few minutes as I did not want to wait, I told Mr. Loeb that I was going to get out and go on as I had work to do.

So I went on down Hunter Street, going in the direction of Whitehall and when I got down to the corner of Whitehall and Hunter, the parade had started to come around and I could not get around at all and I had to stay there fifteen or twenty minutes and see the parade.

Then I walked on down Whitehall on the side of M. Rich & Bros. 's store towards Brown and Allen; when I got in front of M. Rich & Bros. ' store, I stood there between half past 2 and few minutes to 3 o'clock until the parade passed entirely; then I crossed the street and went on down to Jacobs and went in and purchased twenty-five cents worth of cigars.

I then left the store and went on down Alabama Street to Forsyth Street and down Forsyth Street to the factory, I unlocked the street door and then unlocked the inner door and left it open and went on upstairs to tell the boys that I had come back and wanted to know if they were ready to go, and at that time they were preparing to leave.

I went immediately down to my office and opened the safe and my desk and hung up my coat and hat and started to work on the financial report, which I will explain.

Mr. Schiff had not come down and there was additional work for me to do.

In a few minutes after I started to work on the financial sheet which I am going to take up in a few minutes.

I heard the bell ring on the time clock outside and Arthur White and Harry Denham came into the office and Arthur White borrowed $2.00 from me in advance on his wages.

I had gotten to work on the financial sheet, figuring it out, when I happened to go out to the laveratory and on returning to the office, the door pointed out directly in front, I noticed Newt Lee, the watchman, coming from towards the head of the stairs, coming towards me.

I looked at the clock and told him the night before to come back at 4 o'clock for I expected to go to the base ball game.

At that time Newt Lee came along and greeted me and offered me a banana out of a yellow bag which he carried, which I presume contained bananas; I declined the banana and told him that I had no way of letting him know sooner that I was to be there at work and that I had changed my mind about going to the ball game.

I told him that he could go if he wanted to or he could amuse himself in any way he saw fit for an hour and a half, but to be sure and be back by half past six o'clock.

He went off down the stair case leading out and I returned to my office.

Now, in reference to Newt Lee, the watchman, the first night he came there to watch, I personally took him around the plant, first, second and third floors and into the basement, and told him that he would be required, that it was his duty to go over that entire building every half hour; not only to completely tour the upper four floors but to go down to the basement, and I specially stressed the point that that dust bin along here was one of the most dangerous places for a fire and I wanted him to be sure and go back there every half hour and be careful how he held his lantern.

I told him it was a part of his duty to look after and lock that back door and he fully understood it, and I showed him the cut-off for the electric current and told him in case of fire that ought to be pulled so no fireman coming in would be electrocuted.

I explained everything to him in detail and told him he was to make that tour every half hour and stamp it on the time card and that that included the basement of the building.

Now, this sheet here is the factory record (Defendant's Exhibit 7), containing the lists of the pencils in stock and the amount of each and every number; the amount of each and every one of our pencils which we manufacture at the end of any given week.

There are no names there.

We make the entries on this sheet by trade notes.

Here is a sample case containing the pencils which are manufactured at the Forsyth Street plant.

That is just as an explanation of what these figures are.

Well, I expect you have gotten enough of a glance at them for you know that there are a great many pencils and a great many colors, all sorts and styles; all sorts of tips, all sorts of rubbers, all sorts of stamps -I expect there are 140 pencils in that roll.

That shows the variety of goods we manufacture.

We not only have certain set numbers that we manufacture, but we will manufacture any pencil to order for any customer who desires a sufficient number of a special pencil, into a grade similar to our own pencil.

Now, this pencil sheet when I looked at it about half past eleven or thereabouts on Saturday morning, was incomplete.

It had the entry for Thursday, April 24th, omitted.

Mr. Schiff had entered the production for April 18th, 19th, 22nd and 23rd, (Defendant's exhibit 7) but he had omitted the entry for the 24th, and the 24th not being there, of course it was not totaled or headed, so it became necessary to look in this bunch of daily reports (Defendant's Exhibits 4a, 4b, 4c, 4d) which was handed in every day by the packing forelady, sort out the various pencils noted on there, and place them in their proper places.

Before proceeding further on that, I want to call your attention to the fact that we use this sheet (Defendant's Exhibit 7) for two weeks.

You notice two weeks ending down there April 27th, April 17th, and one ending the week later, April 24th.

Mr. Schiff, I notice, put April 17th at the top and the date corresponds to the entries here on the side; these are the dates alongside of each entry.

Now, where we have any special pencil, as a general rule--for instance, take two 10-X special up there; we manufacture two 10-X special for the Cadillac Motor Company.

Now, there is a 660-X pencil (Defendant's Exhibit 7); that 660-X pencil we call Panama, but in this entry it is called Cracker-Jack.

Now, here is another 660-X special (Defendant's Exhibit 7), ours being Panama and this the Universal 660-X special.

In other words, gentlemen, we put (290) the name of the customer, if he wants business in a sufficient quantity.

Well, I had to go through this report for Thursday (Defendant's Exhibit 4a), handed in by Miss Flowers, the forelady of the packing department, as she said, on Friday; I had to go through it and make the entries.

Now, after I made the entries, I had to total each number for itself; that is, the number of 10-X, 20-X, 30-X, etc.

Now, I notice that both of the expert accountants who got on the stand, pointed out two errors.

While those errors are trivial, yet there is enough of human pride in me to explain that those errors were not mine.

Those errors, one of 11/2 gross and one of one gross, in totaling up, these totals here on the 18th and 19th (Defendant's Exhibit 7) those entries were made by Mr. Schiff.

I don't expect he meant to make an error, but they happen to be in his handwriting.

Those totals were already down there for the various days when I got the sheet and I always take them as correct without any checking of his figures.

The only figures that I check are my own figures.

I add my correct figures to his figures and, of course, not having checked the figures, I had to assume he entered it correctly, so I would not have known it.

As I say, my usual method is to take his figures as correct per se.

Now, after I entered them in the total, the next thing I did was to make out the job sheet; the job or throw-outs.

Now in regard to these jobs, if I recall it correctly, was the only error that the expert accountant found in my work on the financial sheet for that day, but it really was not an error, as I will show you.

He didn't know my method of doing that, and therefore, he could not know the error.

When I explain to you fully the method in which I arrived at these figures you also will see they are not in error.

Now among the packing reports that are handed into the office just like Miss Eula May handed this in from the packing room proper, there is another room where pencils are packed, viz.:

the department under the foreladyship of Miss Fannie Atherton, head of the job department.

The jobs are our seconds or throw-outs for which we get less money, of course, than for the first.

You see that Fannie A. (Defendant's Exhibit 4b), that is Fannie Atherton.

That is the job department.

Now, I took each of those job sheets and separated them from the rest of those sheets, finding out how many jobs of the various kinds were packed that week.

Now, this sheet (Defendant's Exhibit 3) shows that there were 12 different kinds of jobs packed that day.

Each of them, you will notice, has a different price.

That is the number of jobs 0-95, or the number of job 114 (Defendant's Exhibit 3); that is the number of the job, not the amount, but the number by which it is sold.

Out here (Defendant's Exhibit 3) you see the amount of that job which was packed; 180 gross, 1 gross, six gross, 24 gross, etc.

Then you will find the actual price we received for each.

Then I make the extensions and find the number of gross of pencils, 180 gross at 40 cents, of course, is $72 (Defendant's Exhibit 3).

In other words, there is the actual number of jobs packed that day, the price we actually got for them, and the extensions are accurate and the totals are correct; the total amount of gross is totaled correctly, the total gross packed and the total amount of the value of those gross are the two figures that are put on that financial report (Defendant's Exhibit 2), 792 gross jobs, $396.

75 (Defendant's Exhibit 3), being absolutely correct, but in getting the average price, you notice 50.

1 cents down below here (Defendant's Exhibit 3), I just worked it approximately, because nobody cares if it costs so small a fraction the average price of those jobs, 50.

1 cents, and six hundredths-that six hundredths was so small I couldn't handle it, so I stopped at the first decimal.

Now, in arriving at the total number of gross and the total value of pencils, which are the two figures really important, I divided one by the other.

I also used, in getting up the data for the financial sheet here, by the way, one of the most important sheets is this sheet here.

(Defendant's Exhibit 4c).

It looks very small, but the work connected with it is very large.

Now, some of the items that appear on here are gotten from the reports which are handed in by the various forewomen.

Now, you saw on the stand this morning Mr. Godfrey Winekauf, the superintendent of the lead plant; there is a report (Defendant's Exhibit 4c) of the amount of lead delivered that week, two pages of it; the different kinds of lead, Number 10 lead, Number 940, Number 2 and Number 930, and so on.

Now, here is a pencil with a little rubber stuck on the end; we only put six inches of lead in that, and stick rubber in the rest.

Now here is the report of L. A. Quinn, foreman of the tipping Plant (Defendants' Exhibit 4d).

He reports on this the amount of work of the various machines, that is, the large eyelet machine, the small eyelet machine and the other machines.

Then he notates the amount of the various tips used that he had made that week.

Now, we have, I expect, 22 different kinds of tips, and one of them is a re-tip, and we never count a re-tip as a production.

Now, this was made out (Defendant's Exhibit 7) for the week ending April 24 by Mr. Irby, the shipping clerk, that is, the amount of gross of pencils that he ships day by day.

There were shipped 266 gross the first day, which was Friday in this case, Friday the 18th of April, 562 gross the 2nd day, which was Saturday, a half day, the 19th of April; 784 gross on Monday which was April 21; 1232 gross (that was an exceptional day) were shipped on Tuesday April 22nd; 572 gross shipped on Wednesday, April 23rd, and 957 gross, also a very large day, shipped on April 24th, a total of 4374 gross.

Now, there is another little slip of paper (Defendant's Exhibit 4a) here that requires one of the most complicated calculations of this entire financial, and I will explain it.

It shows the repack, and I notice an error on it here, it says here 4-17, when it ought to be 4-18; in other words, it goes from 4-17 through 4-24.

That repack is gotten up by Miss Eula May; you will notice it is 0.

K'd by her.

Miss Eula May Flowers, the forelady, packed that; that is the amount of pencils used in our assortment boxes or display boxes.

That is one of the tricks of the trade, when we have some slow mover, some pencil that doesn't move very fast, we take something that is fancy and put some new bright looking pencils with them, with these slow movers.

That is a trick that all manufacturers use, and in packing these assortment boxes, which are packed under the direction of Miss Flowers, we send into the shipping room and get some pencils which have already been packed, pencils that have been on the shelf a year for all we know, and bring them in and unpack them and re-pack them in the display box.

Therefore, it is very necessary in figuring out the financial sheet to notice in detail the amount of goods packed and just how many of those pencils had already been figured on some past financial report.

We don't want to record it twice, or else our totals will be incorrect.

Therefore, this little slip (Defendant's Exhibit 4a) showing the amount of goods which were repacked is very necessary.

That was figured by me, and was figured by me on that Saturday afternoon, April 22nd.

There were 18 gross of 35-X pencils selling for $1.25; 18 gross for $22.

50.

It shows right here, I figured that out.

That is my writing right down there.

Eighteen gross 35-X, $1.25, $22.50; 10 gross of 930-X figuring at $25.00; that added up, as you will see, to $70 00.

In other words, there were 40 gross of pencils, 36 gross of which sell in our medium price goods; 86 gross 35-X; 10 gross 930-X, $2.

50, that is a high price goods.

Therefore, the repack for that week was 36 gross medium priced goods and 10 gross of high price goods.

I will show you now where the $70 00 is and where the 36 gross is, and where the 10 gross figured in the financial sheet (Defendant's Exhibit 7a).

There is a little sheet stuck up here in the corner attached to the record--the factory record of pencils manufactured during that week.

That shows the production, divided into the following classes; cheap goods, the very cheapest we make, outside of jobs, those we figure at 60 cents a gross.

Then there is the rubber insert, those we figure 85 cents a gross, and then the job and then the medium; the medium being all goods up to a certain grade that contains the cheap lead, and the good being all those that contain a better class of lead.

In this case, Mr. Schiff had entered it up to and through Wednesday, and had failed to enter Thursday, and I had to enter Thursday, and to figure it.

This sheet shows the total of the three classes of goods packed from day to day.

Now, I have had very few clerks at Forsyth Street, or anywhere else, for that matter, who could make out this sheet (Defendant's Exhibit 2) successfully and accurately.

It involves a great deal of work and one has to exercise exceptional care and accuracy in making it out.

You notice that the gross production here is 2765 1/2.

That gives the net production.

The gross production is nothing more than the addition, the total addition, the proven addition of these sheets containing the pencils packed.

This other little sheet behind here represents the pencils packed the week of April 17--that week's production.

Now, this little sheet (Defendant's Exhibit 7a)

I had to work on, showing pencils that were repacked, going into display boxes, and the numbers, and subtracted that from total amount 46 from 2765 1/2, which leaves 2719 1/2; in other words, I just deducted the amount that had been taken out of the stock room and repacked from the total amount that was stated to be packed, showing the amount of repacked goods.

Now all I had to do was to copy that off, it had been figured once.

The value of the repack was $70.00; that was mere copying.

Now, the rubber insert entries, I got those that morning, the number of pencils packed during the week ending April 24th; that is Thursday, April 24th; that insert rubber is a rubber stuck directly into wood with a metal tip or ferret to hold it in.

I have to go through all of this data, that being an awfully tedious job, not a hard job, but very tedious; it eats up time.

I had to go through each one of these, and not only have to see the number, but I have to know whether it is rubber insert or what it is, and then I put that down on a piece of scratch paper, and place it down here, in this case it was 720 gross.

Then the rubber tipping, that means tipped with rubber; that is the rubber that is used on the medium priced pencils that have the medium prices, we ship with the cheap shipping.

I had to go through this operation again, a tedious job, and it eats up time; it is not hard, but it is tedious.

I had to go through that again, to find out the amount of tip rubber that was used on this amount of pencils.

Then I had to go through the good pencils.

Now, it has been insinuated that some of these items, especially this item, if I remember correctly--that when I have gotten two of the items, I can add it all up and subtract from the total to get the third by deduction, but that is not so.

Of the pencils that still remain unaccounted for, there are many pencils that don't take rubber at all.

There are jobs that don't take rubber on them, plain common pencils, going pencils that don't have rubber on them at all, and I have to go through all of that operation, that tedious operation again that eats up so much time.

Then there is the lead of the various kinds that we use; there is a good lead and cheap lead, the large lead and the thick or carbon lead, and the copying lead.

That same operation has to be gone through with again.

Now this sheet (Defendant's Exhibit 3) (exhibiting) is where the expert accountant said I made a mistake.

I had to go through with each of those pencils to see if they were cheap rubber or if they were good lead or copying lead.

So I had to go through this same operation and re-add them to see that the addition is correct before I can arrive at the proper figure.

The same way to find the good lead and the cheap lead, the large lead and the copying lead; that operation had to be gone through in detail with each and every one of those, and the same with each of the boxes, and that is a tough job.

Some of the pencils are packed in one gross boxes and some in half-gross boxes, and, as I say, we use a display box, and there are pencils that are put in individual boxes, and we have to go through carefully to see the pencils that have been packed for the whole week, and it is a very tedious job.

Now in these boxes there is another calculation involved, and then I have to find the assortment boxes, but that is easily gotten.

Then I have to find out whether they are half-gross boxes or one gross boxes, and then reduce them to the basis of boxes that cost us two cents apiece; reduce them to the basis of the ordinary box that we paid two cents a box.

After finding out all the boxes, then I have to reduce that to some common factor, so I can make the multiplication in figuring out the cost at two cents.

That involves quite a mathematical manipulation.

Then I come to the skeleton.

Skeletons are no more than just a trade name.

They are just little cardboard tiers to keep one pencil away from the other, that is all a skeleton is.

I have to go through and find out which pencils are skeletons.

If it is a cheap pencil they are just tied up with a cord, and there are pencils in a bunch, and there are pencils that we don't use the skeleton with.

That must all be gone through and gotten correctly, or it will be of no worth.

Then comes the tip delivery, which is gotten from this report from Mr. Lemmie Quinn that I showed you before.

Then there is another entry on this sheet of the tips used and I can give you a clear explanation of the manner that I arrive at that.

You can't use tips when you don't have some rubber stuck in it, so I just had to go through the rubber used to find that.

Then we have what we call ends; there are a few gross of them there.

Then the wrappers.

Pencils that are packed in the individual one dozen cartons don't take wrappers; they are in a box.

Pencils that are packed in the display boxes don't take a wrapper; they just stick up in a hole by themselves.

The cheap pencils are tied with a cord and they don't take any wrapper, so the same operation, the same tedious operation, had to be gone through with that to get at the number of wrappers, and then the different number of gross and the number of carton boxes used in the same way.

On the right hand side of this sheet you notice the deliveries (Defendant's Exhibit 3).

There is the lead delivery from the Bell Street plant and the Forsyth Street plant.

This doesn't mean the amount of lead used in the pencils packed for this week only, but it shows the amount of our lead plant delivery, for information.

Then the slat delivery, that is not worked out that week; that is not worked out simply because that is Mr. Schiff's duty to work that out and that is a very tedious and long job and when I started in to do that I couldn't find the sheet showing the different deliveries of slats from the mill, so I let that go, intending to put that in on Monday, but on Monday following I was at the police station.

I took out from this job sheet (Defendant's Exhibit 4b), the correct amount of gross packed--791 as figured there-correct value $396.75, as shown on this sheet, and the average is that one, that I didn't carry out to two decimal places; I didn't carry it to but one.

Then from the pay roll book I got the pay roll for Forsyth Street and Bell Street, and then as a separate item took out from the pay roll book total, separate the machine shop, which that week was $70.00.

The shipments were figured for the week ending April 24th on th

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