1: What is your full name.
P.H. Grinter
2: Mr Grinter you may state what your business is?
I am a civil engineer and land surveyor.
3: Did you ever transact any business her in Independence?
I have.
4: As a land surveyor?
Yes sir.
5: And as a civil engineer?
Yes sir.
6: In what capacity have you acted?
I was city engineer here for several years.
7: As such were you acquainted with, or are you acquainted with the boundaries of the city of Independence, and the boundaries of its additions?
I am.
8: Will you please look at the plat here before you, marked exhibit “A.S.O.”, and state what it is
9: You may answer the question?
This is a plat representing certain lands within the city of Independence.
10: Is there anything in that plat purporting to represent sixty three acres of land purported to be conveyed by one Flourney to one Partridge?
By whom?
11: By one Jones H. Flourney to one Edward Partridge?
12: You may go on and answer the question?
Please let me examine the abstract.
13: Here it is, examine that if you desire and then make your answer?
What is the question?
14: I asked you if there was anything in that plat that purported to represent sixty three acres of land that was conveyed by one Jones H. Flourney to one Edward Partridge at any time?
There is.
15: Please designate it to the reporter?
Here is the land designated on the plat.
16: That is it there?
Yes sir.
17: Well that is hardly definite enough. Please describe the lines on the plat by which the land is bounded?
This entire piece here bounded by the lines marked in blue on the map is the property you refer to.
18: The land on the plat bounded by the lines marked in blue ink?
Yes sir.
19: Now is there any boundary designated on that plat commencing on the south line of the south east quarter section of section three ? from the south east corner of said section, thence north sixteen poles and ten lonks, thence north forty degrees east ten poles, thence north twenty one degrees east fourteen poles, thence north fifteen degrees east twenty poles, thence north forty two degrees east thirty four poles, thence north firty five degrees east thirty poles, thence north sixty four degrees east thirty poles, thence north sixty four degrees east thirty poles, thence north sixty four degrees, east forty poles, thence north seventy degrees, east seventeen poles and fifteen links?
Yes sir, I find the land represented as you have described.
20: Well what ground is that?
20: I told you that that is the land laid down on this plat here, bounded by the blue lines in ink as heretofore described.
21: I want to add to my description on there these words “thence due south one hundred and twenty poles and seventeen links to the place of beginning, contained sixty three acres and forty three one hundred and sixtieths of an acre”?
Yes sir that is correct. That is the land described.
22: Well that is the land bounded by what lines on this map?
It is the land bounded by the blue lines as represented on this map.
23: Do you know where St. John and Dawson’s addition to this city, is located?
I do.
24: St John and Dawson’s addition to the ciry of Independence?
Yes sir. I know its location.
25: Is there anything on this map corresponding to it?
There is. It is indicated there.
26: What, if anything, is there on this map that corresponds with St John and Dawson’s addition to the city of Independence?
The part of this map that is colored yellow represents St John and Dawson’s addition to the city of Independence.
27: Is it within the sixty three acres that you have heretofore described?
Yes sir.
It is.
28: Do you find any other additions inside of this sixty three acre tract bounded by the blue lines?
I do.
29: Is so, what are they?
30: What is it, if any?
Woodson and Maxwell’s addition.
31: Well what others do you find, if any?
32: You may answer the question?
I find with St John & Dawson’s addition “Prospect Place”, – St Johns & addition and Torpey and Serviss’s addition.
33: Well do you find any other land not in the additions?
I do.
34: What land do you find?
I find a certain tract of land to the east of St John & Dawson’s addition, which I suppose is owned by William Chrisman.
35: Is there any other property described in the addition, – not in the addition but any other property other than that what you have mentioned described on that plat as being within the blue lines which you say include the sixty three acres we have referred to?
I do.
36: Well what do you find?
A certain tract marked depot grounds connected with the Missouri Pacific Railway.
37: Is there any other than what you have designated?
I think not. I believe I have mentioned all the lands that are designated in that tract.
38: That is the sixty three acre tract?
Yes sir.
39: Take the witness. Cross examination by P.P. Kelley,
40: What did you say your name was?
Grinter, P.H. Grinter.
41: What did you say you occupation was?
Civil engineer and land surveyor.
42: Did you make that plat Mr. Grinter?
What is that?
43: Did you make the plat from which you have been testifying?
In part I made it.
44: What is that?
I made the plat in part.
45: Is your testimony confined to the part of the plat which you made yourself?
It is.
46: Was that made from actual measurements taken on the ground by you personally?
Yes sir.
47: It was made from actual measurements taken by you?
It was.
48: Well when did you say you made the measurements?
Those measurements have been made at various times within the last few years.
49: Well within how many years?
I will say within the last three years.
50: That is all. I now move to strike out all of the testimony this witness from the record as immaterial, irrelevant and incompetent, and move the court to tax the costs of same to the defendant.