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Maps, plates, charts, etc., may be filmed at different reduction ratios. Those too large to be ^nJrely included in one exposure are filmed beginning in the upper left hand corner, left to right and top to bottom, as many frames as required. The following diagrams illustrate the method: Les cartes, planches, tableaux, etc., peuvent dtre fiimis d des taux de reduction diffdrents. Lorsqtie le docum&nt est trop grand pour dtre reproduit en un seul clich6, il est fiim6 d partir de Tangle supdrieur gauche, de gauche d droite, et de haut en bas, en prenant le nombre d'images ndcessaire. Les diagramrres suivants illustrent la mdthode. 1 2 3 1 2 3 4 5 6 # NORTH SHORE RAfLWAY. FURTHER STATEMENT OF 'FACTS. WITH A SUPPLEMENT. By SILAS SEYMOUR, Genkral Consulting Engineer. QUE&EC, FEBRUARY 17th <2 20th 1877. / jSiss^mmmmmi^miifmmmmmmam ■^WMippipip mm NORTH SHORE RAILWAY, -— <-7r-f:5e::ft^-_5K-^ FURTHER STATEMENT OF FACTS, IN RELATION TO CERTAIN MATTERS IN DIFFERENCE Between THOMAS McGREEVY, Contractor, AND SILAS SEYMOUR, General Consulting Engineer, WITH A SUPPLEMENT " The cry is, still they come / / " Macbeth. QUEBEC. FEBRUARY 17th & 20th 1877. ; NORTH SHORE RAILWAY. FURTHER STATEMENT OF FACTS In relation to matters in difference between Silas Seymour, Geiieral Consulting Engineer, and Thomas McGjiEEVY, Contractor for i/ie North Shore Raihvay, On the 10th of May, 1876, I published, in pamphlet form, a " Statemsnt of Facts, " in relation to certain " Special Agreements^ " between Mr. McG-reevy and myself, which had been entered into during the summer of 1875. The first of these Agreements, dated June 21st, 1875, had reference to my obtaining outside parties, who would either furnish Mr. McGreevy with the necessary capital to enable him to carry out, successfully, his original Contract with the North Shore Railway Company, for the construc- tion and equipment of the Road ; or take the Contract entirely off his hands, and repay him the amount of his advances. FURTHER STATEMENT OF FACTS. ^ The second of these Agreements, dated Auc^ust I8th» 1875, and after the Railway Company had virtually abandoned the Road, had reference to the negotiations then being carried on, between Mr. McGrreevy and the Provincial Government of Quebec, respecting an entirely new Contract for the construction of the Road. The " Statement of Fads, " above referred to, was not printed until after I had spent several months, in the vain endeavor to obtain a settlement with Mr. McGreevy, for the extra services which I had performed in his behalf, under these Special Agreements ; and until after it had become clearly evic'ent that he intended to repudiate his engagements ; and force me either to abandon raj claims, or to resort to such legal remedies as might remain open to me. My object in printing such a statement at the time, is fully set forth in the following extract from the " Expla- natory " remarks, at the commencement of the pamphlet. " Th*e following " Statement of Facts " in relation to the several matters therein referred to, has been compiled with much care, from originals and copies of letters, documents, and other memoranda in my possession ; and printed for the exclusive use and convenience of myself and my Agents or Attorneys, in the prosecution or disposal of my claims against the Honorable Thomas McGrreevy, M. P., and Contractor for the North Shore Railway." "No general circulation will be given to the document, by myself at least, either at present, or hereafter, unless it shall be found necessary to do so for the purpose of vindicating my own private character and professional reputation, against lalicious attacks which may be made PURTHEF STATEMENT OF FACTS. 5 upon them by interested parties, in advance of a full development of all the facts in the case, before a Court of Justice." I will now state, with equal frankness, that the present " Furlher Statement of Facts " is published for the purpose of showing that Mr. McGreevy, in his efforts to free him- self from his legale as well as Hotiorab/e engagements with me, has made the most malicious and unwarrantable attacks upon my private character and professional repu- tation ; and, also, that the fact of his having done this, affords me, in my own opinion, at least, the fullest justifi- cation for giving general publicity, not only to the " State- ment of Facta " above referred to ; but to the base and disreputable means which have thus far been resorted to, by himself and his Attorneys, in their attempts to under- mine and destroy my own character and reputation, for the purpose of shielding him fr m his just and legal obli- gations. For my present purpose, it will be sufficient to re fer to the " Legal Proceedings, " (which I have also published in pamphlet form) based upon the Agreement dated August 18th, 1875,* of which the following is a true copy, as acknowledged by Mr. McGrreevy himself, in his testimony in the case. " Quebec, August 18th, 1875." " Dear Sir, In consideration for your extra services, I hereby agree, that if I close an arrangement with the Provincial Grovernment of Quebec, by which the Grovern- ment either takes the North Shore Railway Contract off my hands, or pays me a cash consideration for performing 6 FUKTHER STATEMENT OF FACTS. the Contract. I will pay you five thousand, dollars upon the closing of such an arrangement; also five thousand dollars additional, withii. one year from that date ; —and five thousand dollars additional, wifhin two years fron^ that date ; — making in all, fifteen thousand dollars. Yours truly, (Signed,) THOMAS McaREEVY. General Silas Seymour, Consulting Engineer, &c., Quebec." A reference to these Legal proceedings will show, that my Declaration was dated June 9tl^ 1876, or neai*ly six months after the first insta^nent of $5,000 had become due under the above Agreement ; and that the suit was broughc for the rei^overy of this amount, with interest> and costs. It will also be seen, that the Defendant's Answer, dated July 6th, 1876, contains, substantially, the following allega-? tions : 1st. That inasmuch as I was the salaried Officer of the North Shore Railway Company at the time, any matter or thing done or performed by me, in connection with said Railway, was so done and performed, in behalf of the Railway Company, and not for the Defendant. 2nd. That my continuing to hold office under said Com- pany, disqualifies^ me from rendering any service to the Defendant, in connection with said Railway. 8rd. That I acted adversely to the Defendant's interests, and purposely injured him, both by words and deeds, in connection with these negotiations with the Grovernment ; FURTHER STATEMENT OF FACTS. 7 and j|;he subsequent ratification of the Contract, by the Provincial Legislature. 4th. That I never performed any of the services con- templated, or alluded to in the Agreement of August 18th. 187t ; or was willing to perform the same, or any of them. 5th. That by deceitfidly prelendinfj; that I had performed such SQrvices ; and coaceaiing; from him the fact that I had acted adversely to the Defendant's interests, 1 obtained from him certain payments, to which / ioa& not entitled, and did not earn. It will be soen from the above, that I am cl^arged by Mr. McGrreevy with conduct unbecoming to my profession and official position ; alsp with double dealing', deceit, pre- tense, concealment ; and with obtaining money under false pretenses ; all of which cl^arges and allegations, are to day and havp for several months past, been spread out upon the public records of the Court, ove/ the signature of his Attorneys, Messrs Andrews, Caron and Andrews. I will not pause, at the present moment, tq make any comment upon either the principles, or the animus, which must have predominated in the mind which dictated these charges and allegations ; particularly when it was fully known at the time, that every one of them was false ; and, as the eyent proved, not a particle of evidence was cflfered in the case, to sustain them ; or to remark upon the damaging effect which such false and malicious charges must necessarily have upon my own private character, and professional reputation. It is proposed, however, to give, in this place, and as a matter for future, and most important reference, an extract 8 FURTHER STATEMENT OP FACTS. from Mr. McG-reevy's own testimony in the case, for the purpose of showing the reasons, which at that particular time^ he thought proper to give, under oath, to the Court, for having signed the Agreement of August 18th, 1875 ; and also the nature and extent of the ea;^ra services referred to therein, which, at that time, and from his own point of view, I was expected to perform, under that Agreement. Mvtract from the Testimony of Hon. Thomas McGreevy^ ylveu at Enqaete, Oct. 12th, 1876. " " In August and September 1875, I had occasion to have several interviews with the Plaintiff, with reference to thei proposed arrangement about to be entered into for the construction of the North Shore Railway by the Govern- ment ; and during this time there were frequent negotia- tions carried on between me and the G-overnment, to come to ail understanding in the matter. " One of the principal objects was, that the Government should undertake the crnstruction of the Road, instead of the Kaibvay Company ; and another principal object was, to substitute a cash basis for payments, in lieu of Railway Bonds, and subsidies. It is not true that I, on occasions, sought the assistance of the Plaintiff ; but he sent for me, and told me that the Treasurer of the Province had called on him to assist him in preparing the draft of Contract, Schedules, and Estimates. FURTHER STATEMENT OF FACTS. 9 " I was very desirous that the thing should be put through as soon as possible ; and that there should be no delay, / signed an Agreement, during these iniervieias, with the Plaintiff, upon which this action is based, in order that there should be no delays, as before stated ; knowing that the Plaintiff had the means in his power of keeping it back; which I would not have done under any other circumstances. It was not signed for services rendered, and only for the reason above mentioned^ The following is a copy of the judgment rendered in the above mentioned case, on the 7th of February, 1877 : Copt of Judgment, in Superior Court, for the first instalmentj under Agreement of August IWi 1875. " Considering that the Defendant hath failed to prove the allegations of his plea of Perpetual Exception, in this cause fvled, the same is hence dismissed. " Considering that the Plaintiff hath proved the material allegations of his Declaration ; and more particularly, ihat the Defendant, if he closed an Agreement with the Pro- vincial G-overnment of Quebec, by which the Government either took the North Shore Railway Contract ofl hi« hands or paid him a cash consideration for performing the Contract ; in consideration of the Plaintiff's Extra Services, agreed to pay the Plaintiff five thousand dollars upon the closing of such an arrangement ; also five thousand dollars additional, within one year f^om that date ; and five thousand dollars additional, within two years from that *^,*ip*irr»^ 10 IrURTHEB STATEMENT? CF PACT^. " Considering that the Defendant has closed an arrange^' tnent with the said Government, by which it pays the Defendant a cash consideration for performing the North Shore Railway Contract : "The Court doth adjudge and condemn the Defendant, for the considerations aforesaid, to pay to the Plaintiff the sum of Five tlwumnd dollars, with interest and costs. " Referring the reader to the Pamphlet, hereinbefore men- tioned, for any further particulars respecting my first suit against Mr. McG-reevy, under his Agreement of Atlgust 18th, 1875, I will now proceed to notice the Legal Pro' ceedings, so far as they have progressed, under the iecond suit, which has been instituted for the recovery of the second instalment of $5,000 which became due, under the same Agreement, on the 24th of December, 1876. Or within one year from the date of the closing of the arrange- ment, with the Provincial Grovernment, therein referred to. The Plaintiff's Declaration is this case is dated, Quebec January ISth, 1877, or some twenty days prior to the ren- dering, by the Court, of Judgment in the first case. The Defendant's Answer is dated on the 8th of February 1877, or one day after the rendering of Judgment in the first case. In order to a perfect understanding of the matter, the full text of each of these documents will be given, as follows : PLAINTIFF'S DECLARATION Silas Seymour, of the city of Quebec, in the district of Quebec, Civil Engineer, complaining of the Honorable Thomas McG-reevy, of the same place, Railroad Contractor, by this, his Declaration represents : That the Plaintiff is, and has been for many years, a General Consulting Engineer, acting as such, more espe- cially, in so far as relates to the construction and equipment of Kailways, at Quebec and elsewhere. That the Defendant was, from the 21st of February, 1874, to the 24th of September, 1875, the Contractor for the construction of the North Shore Railway, then being built and constructed by the North Shore Railway Company, a body politic and corporate. That in themonth of August, 1875, the Defendant entered into negotiations with the Government of the rrovince of Quebec, with a view of obtaining from the said Govern ment, the Contract for the building of the said North Shore Railway, on the basis of a cash consideration ; or of being relieved from the Contract already entered into for the construction of the said Railway, w^hich it was then expected would be taken in hand and built by the said Government 12 FURTHER STATEMENT OF FACTS. U ■eft 1^ That, during- the said negotiations, the said Defendant applied to the Plaintiflf, as Greneral Consulting Engineer, as aforesaid, for his aid and assistance therein. That, on the 24th of September, 1875, the said negotia- tions ended ; and a Contract was entered into, between the Government of the Province of Quebec, and the Defen- dant, for the construction of the said North Shore Railway, for a cash consideration to be paid the Defendant for performing the Contract therein mentioned ; which Contract was subsequently ratified and approved by the Legislature of the Province of Quebec, on the 24th December, 1875 ; and the said Government authorized to carry out the same ; and to build and construct the said Road. That, during all the said negotiations, the said Defendant had the aid, assistance, counsel, and advice of the Plaintiff, as General Consulting Engineer, as aforesaid ; and that the Plaintiff rendered the Defendant many and important services in connection therewith ; all which enured to his profit and advantage. That in consideration thereof, the said Defendant, by paper writing, bearing date at Quebec, the 18th of August 1875, promised and bound himself towards the Plaintiff, as follows : " In consideration for your extra services," (to wit, those above mentioned) " I hereby agree, that, if I close an " arrangement with the Provincial Government of Quebec, *' by which the Government either takes the North " Shore Railway Contract off my hands ; or pays me a " cash consideration for performing the Contract, I will " P*y you five thousand dollars, upon the closing of such " an arrangement ; also five thousand dollars additional, ii plaintiff's declaration 13 *' within one year from that date ; and five thousand " dollars additional, within two years from that date ; " making in all, fifteen thousand dollars. " That, in view of the premises, there is due by the Defendant, to the Plaintiff, the sum of five thousand dollars ; being the second instalment due under the afore- said Agreement, or paper writing, and therein mentioned as the sum of five thousand dollars additional, payable within one year from the aforesaid date, of the 24th De- cember, 1875 ; and which said sum, or second instalment became due and payable, by the Defendant to the Plaintiff, pn the 24th day of December last ; and which said sum the Defendant refuses and neglects to pay, though often there- unto requested. Wherefore, the Plaintiff prays that, by the Judgment of his Honorable Court, the Defendant be condemned to pay to him the said sum of five thousand dollars, with interest and costs, distracted in favor of the undersigned. (Signed), ALLEYN & CHAUVEAU, Attorneys for Plaintiff, Quebec, January 15th, 1875. DEFENDANT'S ANSWER. And the said Defendant, for answer unto the Demande of him the said Plaintiff, in the Declaration of him the said Plaintiff in this cause fyled contained, not confessing or acknowledging any of the matters or things in the said Declaration set forth alleged to be true, by this his Perpe- tual Exception F^remptoire en Droit, saith, that the Plaintiff by Law, cannot at any time have or maintain any action against the said Delendant, for or by reason of the matters and things in the said Declaration set forth and alleged, or of any or either of them, because he says : That during all the times in which the Plaintiff, in his said Declaration alleges that he performed services for the Defendant, he the Plaintiff was a paid officer of the North Shore Railway Company, recei-ving as such officer a large annual salary ; and any lawful matter by the Plaintiff, during the said periods, in relation to or connected with the said North Shore Railway, or its construction ; or in relation to the contract for the construction thereof, done by the Plaintiff, was so done as such paid officer of the said Company ; and for the said Company, and not for him the said Defendant, or in his, the said Dcnfendant's interest. That the holding, by the Plaintiff, of the said office, defendant's answer. 16 disqualified him from legally rendering the said Defendant any services in connection with the said Railroad, its con- struction, or the contract for its construction ; and in fact the said Plaintiff did not render the said Defendant any services, or in any manner advance the interest of the Defendant in the premises; but on the contrary, acted adversely ; and opposed his wishes and desires, in reference to the matters in relation to the Defendant's Contract for the construction of the said Road, and the ..ttification by the Legislature of this Province, of the Contract between the said Defendant and the said Government. Wherefore the said Defendant prays the dismissal of the Plaintiflf's action in this beha^** with costs. And the said Defendant, for further plea to the said Declaration, saith, that he the said Plaintiff, deceitfully pretending that he had rendered him, the Defendant, assistance and services, which in facthe had not, and could, not lawfully render, obtained from the Defendant a sum of two hundred dollars, paid by him, the Defendant to J. Gr. Colston, Esquire, Advocate, at the request, and upon the written order of him, the said Plaintiff; and also obtained from him, the Defendant, two negotiable pormissory notes, dated at Quebec the first of May, eighteen hundred and seventy -six, for the sum of twelve hundred dollars each, payable, respectively, three and four months after their said dates ; and which said notes, he the said Plaintiff, has negotiated, and received the proceeds thereof; and never gave any legal consideration for the saAe. And the Defendant avers, that the said notes, and the said moneys were exacted and given ; and the \.. 16 FURTHER STATEMENT OF FACTS. letter by the said Defendant signed, dated at Quebec, the eighteenth day of August in the year one thousand eight hundred and seventy five, upon which the riaintifTs action is founded, and declared uppn in his Declaration, w^ere solicited by the said Plaintiff, and written and con- sented by the Defendant, and by the Plaintiff received, as a bribe ; and with the corrupt intention that he, the Plaintiff, should fail in his duty, as such officer of the said North Shore Railway Company, in its relations with the said Defendant ; and not exact from the said Defendant a strict and faithful performance of the said Defendant's contract, as Contractor for the sfiid Eoad. And the Defendant further alleges, that the Plaintiff did corruptly obtain from hiin, the Defendant, the said v^ritings and promises, with the distinct understanding between them, that he, the Def^dant, would be aided by him, the Plaintiff, in evading an honest and faithful exe- cution of his said contract for the said Railway. And the said Defendant, yielding to the suggestions of the said PlaintiflF, agreed with him to make him the said several promises. And he, the said Plaintiff, with the corrupt view of receiving the amount of the said sums so pro- mised, undertook to aid and assist him, the Defendant, in evading a faithful execution of his, the Defendant's con- tract for the construction of the said Road. And so the Defendant saith, that all the understandings and promises mentioned in the said Plaintiff^s Declaration, were without legal consideration, and were corruptly and immorally solicited, exacted, stipulated for, and recei^ned by him, the Plaintiff, as a bribe; and were so by the Defendant made and given, upon the understanding that defendant's akswer. IT he, the Plaintift; would assist the Defendant, in an unfaith- ful and imperfect execution of his agreement as Contractor for the said Railroad ; and are therefore illegal, null, and void. All which allegations, the said Defendant doth hereby aver to be true, and Well founded in fact and in law ; and the same will verify, prove and maintain, v/hen and as this Honorable Court shall direct. "Wherefore the said Defendant humbly prays that, for the causes aforesaid, by the Judgment of this Honorable Court, the action of the said Plaintiff in his behalf, be hence dismissed with costs ; of which costs, the under- signed Attorneys, pray distraction in their favor. Quebec, 8th February, 1877. (Signed,) ANDREWS, CARON & ANDREWS, Attys. for Defendant- 0^ ■ 18 FURTHER STATEMENT OF FACTS. In connection with the latter part of the foregoing " Answer " by the Defendant, I desire the reader to refer immediately back to the testimony given under the sjlem- nity of an Oath, in relation to the same matter, and by the name Defendant, on the 12th October, 1876. In order to bring these remarkable documents /ace ^o/^fce with each other, it will bo better, perhaps, to print the following extracts from each, in parallel columns ; so that, like twin jfroduclions of the same prolific parentage, they may become familiar with ei.ch others features, and general characteristics ; for certainly, at first sight, they will not be able to recognize their vear relationship. Extract from Mr. McGreevy's " Testl- mony. " October mh, 1876. " 1 was very anxious that the thing," (to wit, the Government Contract), •' should be put through as soon as possible ; and that there should he no delays. I sijned an Agreement during these interviews ivilhllie Plainlilf, upon which this action is based, in order that there should be no delays, as before staled, knowing that the Plainlilf bad the means in his power of iiee{)ing it back ; which I would not have done under any other circumstances. It was not signed for services rendered, and only I /he reason above mentioned. " Extract from Mr. McGreevy's wer. " February m, 187/. Ans' *' And the Defendant avers, that the said notes, and the Faid moneys were given ; and the letter by the Defendant signed, dated Quebec, ISth August, 1875, upon tvhicli the Plaintiffs action is founded, and declared upon in his declaration, were solicited by the said Plainlilf, and written and consented by the Defendant, and by the Plaintiff" received as a bribe ; and with the cor- rupt intention that he, the Plaintiff, should fail in his duly, as such oflicer of the North Shore Railway Company in its relations with the said Defen- dant ; and not exact from the said Defendant, a strict and faithful per- formance of the said Defendant's Con- tract as Contractor for the Road. " It will be remembered that this Answer w^as prepared by the Defendant's Attorney's, and probably at the De- fendant's dictation, the day after it was known that tha ■ McauEEVY, versus mookekvy 19 Court had decided, with reference to the first case : " that the Defendant hath fulled to prove the A/leg-alions of lihplea : " and also " that the Plaintiff hath proved the mnterial alU j;a- lions of his Declaration;" and, ilnally, that- " The Court doth adjyd>>e and eondemn the Defendant, for the considera- tions aforesaid, to pay to the Plaintiff the sum of Five thousand dollars, with interest and co^Js^ It would certainly, and very naturnlly be expected, that a D'j-ence in an exactly similar case ; and prepared under the immediate negative inspirations of such a decision from the Court, would contain some points and allegations upon which to base a last, and most probably a ^^ forlorn Hope,'' that were not contained in the Defence to the first action under the same Agreement ; but I must confess, that, even with my somewhat intimate knowledge of the Defendant's real character; which knowledge has been acquired during the past few years of the most painful and humiliating business intercourse and relations with him, I was not quite prepared to witness such a degree of moral obliquity and turpitude, as are exhibited in the above " Evidence " and " Defence "' in this case. As to how far these remarks will apply to Attorneiis, or Counsellers at Law, who have deliberately affixed their signatures to a Defence of the above nature, fw the face of the sworn statements of their ow?i client, I will leave for others than myself to judge. The important facts, that for several months previous to the date of the Agreement in question, I had ceased to exercise any control whatever, over the character of the work embraced in the Defendant's Contract with the Railway Company ; and also, that, at the date of the 20 FURTHER STATEMENT OF FACTS. Agreement, the Railway Company had practically censed to exist, by reason of haying declared its inability to progress with the work under existing arrangements ; and having at the same time, invest L the Provincial Government with full power to make such Arrangements with the Contractor, as it might think proper, in the public in- terest; all of which facts, although fully proven, and even admitted by the Defendant, upon tlie first trial, seem to have been entirely forgotten, or intentionally ignored, by the DefendaDt and his Attorneys, in the preparation of their Defence in the second 3uit, under the same Agreement, It seems also, to bestill more extraordinary, that the Chief point of Defence set up in the present suit, should have been entirely forgotten, or intentionally ignored by the Defen- dant and his learned Attorneys and Counsel, in th" Answer to, and trial of the first suit under the same Agreement. The further important fact seems also to have been entirely overlooked by the Defence, in both cases, to wit : that in aiding the Defendant in his negotiations with the G-Dvernment, the riaintifF was dei)riving himself of his salary as Consulting Engineer of the Road, during its etitire construction ; an equivalent for which, and nothing more, wa provided for in the Agreement of August 18th 1875. CONCLUDING REMARKS, My « Explanatory " to the " Statement of Facts, " herein- before referred to, closed with the following remarks : " I will venture to add however, that if the facts as herein set forth, afford any indication of the nature of the prin- ciples which have heretofore governed, and still govern the Honorable Thomas McG-reevy, in his business transac- tions ; and in his ideas of honesty and fair dealing with his fellow men, it is a mystery to me, hovv^ he has reached the present exalted social, political, and financial positions which he claims to enjoy. " Feeling anxious, if possible, to obtain a solution of this problem, I shall watch, with more than ordinary solicitude, the result of the application of the same principles, as already initiated, in the carrying out of the great and important Undertaking, with which he has been entrusted by the Provincial Groven.ment. " I will now close the present » Further Statement of Facts,'' with only the additional remarks ; that I shall continue to watch with equal, if not greater solicitude, the result of the applanation of the same, or if possible, more corrupt prin- ciples, as already not only initiated, but fully developed by Mr. McGreevy, in his repudiation of his solemn Agree- ment of August 18th, 1875. -r^r 22 FUrtTIIER STATEMENT OF FACTS. i have always had an abiding, and I hnmbly trust, a religious faith, in the doctrine of retributive justice ; and also, in the doctrine o^ future, and, to a certain extent, oi pr^'.sent rewards and punishments. But I will frankly confess, that if the course taken in this matter, by the Honorable Thomas McGreevy, M. ?., and Government Contractor for the North Shore Railway, shall prove successful on his part ; and at the same time destructive, as it must consequently proves to my own private character and professional reputation ; my faith will be very considerably shaken, as to the theory o{ present rewards and punishments ; but it will, at the same time, be very much strengthened, as to" the nature and extent of the rewards and punishments, that are quite sure to be meted out, in iloidX future world, to which we are all so rapidly, and so certainly hastening. If Mr. McGrreevy chooses to continue to occupy the position of a prominent party to 2i gigantic scheme of bribery and corruption, such as his Attorneys aver, and solemnly declare, in his Answer, that he is able to prove before the Court, at any time when called upjn to do so, I shall certainly not object ; but he must excuse me from volun- tarily accompanying him down to these depths of infamy and disgrace. Feeling, as I sincerely do, an abiding consciousness of having, in the most perfect honor and good faith, performed all, and 3ven more than I undertook, or than Mr. McGreevy could ^ave expected me to do, under the Agreement in question ; and that in doing this, I not only benefitted him to the extent of several hundred thousand dollars ; but also carried out, to the fullest extent, the expressed wishes and desires of the Uailwaj Com]; any, whose servant CONCLUDING REMAKES 23 and salaried officer I was ; while, at the same time, I acted in the most perfect good liiith towards the member of the Provincial G-overnment, who was conducting- the neo-o- tiations with Mr. McGreevy, I shall most certainly continue my efforts to obtain such justice from him, as the laws of the land will accord to me ; not only for the services which I rendered to him under the Agreement in question ; but also for the great damage which he has inflicted upon me, by reason of his fraudulent representations, in connection therewith. Even during the short space of time that has already intervened, since these atrocious calumnies have been spread upon the public records of the Court, thev have been caught up by the news-paper Press, and spread through the entire country like wild-fire; accompanied by comments and remarks, that are calculated to, and must necessarily inflict an irreparable injury upon my personal character, and professional reputation , which are noW' and always have been my only working capital ; and without which, pure and nsullied, no Civil Engineer can hope for success in his Profession. By immediately supplying the Press, and the leading business men of this Country, the United States, and Europe, v/ith a well authenticated " Statement of Facts'' in the case, I may perhaps counteract the evil to some extent ; but it never can be fully remedied. SILAS SEYMOUR. General Consulting Engineer. Quebec, February 17th 1877. SUPPLEMENT. ■■ 'innnoQtjw ■ LATEST EDITION OF FACTS. " A few more of the same sort left:' Old Razor-Strop-Man. Inasmuch as events have occurred, since the foregoino- " «^«^^^^^^" has been put in type, which may have an important bearing upon the matter, I hare felt it my duty to stop the Press, for the purpose of placing before the Public, the latent ^^ Facts ^^ in this most remarkabl . Case. After I had respecfully declined to accede to any terms of settlement with the Honorable Thomas Mcareevy, that did not recognize his full obligation to carry out his Agreement of August 18th 1875 ; and also a full and un- qualified retraction by him, of all his slanderous allega- tions against me, in connection therewith : • And after the Defendant had been served with a notice to appear in Court, on Monday morning, February 19th, 1877, and answer certain interrogatories, {Fails et Articles) with which he was furnished, in relation to the truthful- ness or falsity of the allegations contained in the Plaintiff's SUPPLEMENT. 'm '1' II Li I I*! De'jjaration, and the DefendanCs Answer, in the Case now pending: And after it had become gene rally known, that 1 was preparing the foregoing " Further Statement of Facts", for the purpose of placing all these matters in their true light before the Piiblic ; and thus counteracting, as far ?n, possi- ble, the injury which I was sustaining from the general circulation of his libellous calumnies, against my private character and professional reputation : And after I had sent to the Editor of the Quebec " Morn- ing Chronicle^ " the following communication upon the subject : " Sir, — I have observed in a recent issue of the Chronicle; and also in the Montreal and other papers, allusions to the matters in difference between Mr. McGreevy and myself, respecting the North Shore Eailway ; all of which are calculated to injure my private character and profes- sional reputation. " May I ask that the Chronicle, and other papers throughout the country, will kindly refrain from any fur- ther remarks of this nature, until I can furnish to the Press, and the Public generally, a well authenticated " Statement of Facts " in the case ; which I hope to have ready lor general circulation, within a dny or two. Very respectfully, S. Seymour. General Consulting Engineer. " Quebec, Feb. 17, 1877. After the occurrence of the above mentioned events, it ii.^ pears to have been suddenly discovered by the Honorable Thomas McGreevy, M. P., and Government Contractor for LATEST EDITION OF FACTS. 8 ' the North Shore Railway, that his Parliamentary duties imperatively required his immediate presence in Ottawa, the Capital of the Dominion. The Local column of the Quebec " Morning Chronicle'' of Monday, Feb. 19th, 1877, therefore contained the followino" important item of information : ♦' Personal.— Hon. Mr. McGreevy, M. P. for Quebec West, w^as to have left for Ottawa on Saturday evening, to attend to his sessional duties." The Editorial column of the same paper, was also headed with the following double-leaded, and startling announce- ment : '• We are authorized by Mr. Meareevy to state, that the plea fyled in the Court House, and illuded to in the Press, was not authorized by him, and was done without his knowledge or consent." When the Case of Seymour versus McGreevy, was called in the Superior Court, at half past ten, on the same eventful Monday morning, Mr. F. W. Andrews, Q. C, of the Law Firm of Andrews, Caron and Andrews, a fine venerable looking Gentleman, who I am assured, wrote the " Flea fyled in the CoTirt,' to which allusion is made in the above News- Paper Editorial ; and whom, / knoiv, heard, and paid the closest attention to every word of his Honorable Client's testimony, as given at Enquete on the 12th Oct., 1876, in the first suit, and under the same Agreement; which testimony, as has already been shown, belies jthe entire latter portion of the Plea : This G-entleman, after having, as I am credibly informed, consulted fully with his asso- ciate Counsel in the Case, arose in response to the above call, and applied to the Honorable Court for a postponement 'if' rm 4 SUPPLEMENT. oi' the Case, upon the ground that the rule which had been personally served upon Mr. McGreevy, three days previously, ordering him to answer certain interrogatories therein mentioned, had issued prematurely ; by reason of which, he had taken the responsibility of advising his Honorable Client, that it was his privilege and duty to obey the ca/l of his Country, instead of the Sumnio?is of the Court ; and that the Expected Witncsa had consequently left for ( )ttawa. After a most scathing and earnest argument and pro- test, by Mr. Tv. AUeyn, Q. C, of Messrs. Alleyn and Chau- veau, my own Attorneys, the Honorable Court thought proper to postpone a further hearing in the Case, until March 9th, 1877. If it had been the desire or intention, of the Defendant to make any responsible denial, or explanation of the calumnious Plea in question, with a view of shielding himself from the responsibilities connected therewith ; and at the same time, protecting me, as far as it was then possible, from further injury therefrom ; it is quite evident that he had been furnished, by my oivn Attorney, with a most favorable opportunity of doing so, by appearing in Court, and answering the interrogatories which had pre- viously been propounded to him. Instead of doing this, however, it will be seen, that by the deliberate and concurrent action of the Honorable Defendant, and his learned and venerable Attorney, and Counsel, I am compelled to rest, so far as the records of the Court are concerned, for several weeks to come, under the public charge and allegation of having been a party, LATEST EDITION OF FACTS. $ with the Honorable Thomas McGreevy, M. P., and Gorvern- ment Contractor for the North Shore Railway, to a vile con^ spiracy to defraud my employers ; and also of havi/io- corruptly accepted a bribe, for the same dishonorable purpose. Ref.'rring a moment, however, to the most extniordinary, and totally irresponsible announcement contained in the Editorial column of the " Morning- Chronicle^ above re- ferred to, it would appear, that the celebrated P/ea, or Answer in question, has been placed in a most anomaLs> if not embarrassing- position. If any reliance is to be placed in the Newspaper Ediforial above referred to, this Plea has been driven from the' protectingroof of its reputed Father, or God-Father which- ever ho may be ; and the poor Bantling, or Orphan, is now wandering about, like " Japhet in search of a Fathe-'^ • or perhaps, more legally speaking, like ^ Defence in search of a Defendant, in the vain endeavor to induce some k nd hearted and charitable individual, to afford it shelter and protection. Feeling as I do, a great interest in this poor and forsaken Outcast ; notwithstanding it has been the cause of the deepest injury to me, I will, if such shall prove to be the case, be most ^hankful to any responsible party who will either acknowledge its paternitv ; or furnish such reliable information as will lead to their early dis- covery. So far as I am personally concerned, however, the Honorable Defendant, and all parties in interest, may rest assured, that no News-paper Editorial ; nor any legal quibble, which either he, or his Attorney, and Counsel may pro- II 6 SUPPLEMENT. mulgate, or resort to, will divert me from my settled purpose to pursue this whole matter to its legitimate conclusions ; under the full conviction that : •' Thrice armed is he whose cause is just." SILAS SEYMOUR. Quebec, February 20th, 1877.