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 FEW WORDS IN ANSWER 
 
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 TO THE 
 
 6 1937 
 
 
 
 
 ATTACK MADE BY BISHOP DOANE 
 
 ON 
 
 THREE BISHOPS AND FOUR LAYMEN, 
 
 IN HIS 
 
 " PROTEST, APPEAL AND REPLY 
 
 »; 
 
 TRENTON: 
 PRINTED AT THE TRUE AMERICAN OFFICE. 
 
 1.852. 
 
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CIRCULAR. 
 
 It is not our design to reply to Bishop Doane in regard to 
 all the matters contained in his pamphlet entitled " A Protest, 
 Appeal and Reply," at this time. We think, however, it due 
 to ourselves to say a few words only, for the purpose of shew- 
 ing that this reply is susceptible of being met and overcome by 
 proof, and that we rely upon the proper tribunal, to which an 
 appeal has been made, for a complete vindication of what we 
 have said or done in regard to him. Nor is it necessary to 
 defend the three venerable and pious prelates whom he char- 
 acterizes in his pamphlet as the " triumviral papacy of 
 Virginia, Maine and Ohio," and as " a triumvirate of 
 tyrants," from the charges he makes against them of " uncanon- 
 ical, unchristian and inhuman conduct " nor from the impu- 
 tation that "the real secret of their earnestness' to have the 
 "presentment made by the Convention, was the anxiety to save 
 "their own three votes for use upon the trial" Against all 
 such attacks and insinuations those highly respected and 
 eminent divines are abundantly able to defend themselves, and 
 they no doubt will do it in their own way and their own good 
 time. We think, however, that the Bishop's friends may 
 well say to him in relation to these attacks as Travers said to 
 the Earl of Northumberland : 
 
 t! This strange passion doth you wrong, my Lord?'' 
 
 Bishop Doane accuses the three Bishops of offering him the 
 alternative of "a presentment" or of complying with their 
 letter. See page 11 of his pamphlet. He says : — They (the 
 
three Bishops) must have the very investigation which they 
 advise and urge, "which they have described and recom- 
 mended," which they have pointed out, " or else the under- 
 signed must be presented." Now the three Bishops have made 
 no such alternative ; the simple alternative of the three 
 Bishops is, that the Convention of his own diocese must make 
 an enquiry, or that they will make an enquiry whether a 
 presentment ought to be made. 
 
 As to the mode adopted by the three Bishops, he complains 
 that they write him a letter " advising and urging" him to 
 call a special Convention for the purpose of a full investigation 
 of all that has been or may be laid to his charge." This he 
 protests against as uncanonical. The third canon passed in 
 General Convention in 1844, expressly declares " that the 
 presentment of a Bishop may be made by three Bishops." Now 
 if it is canonical for three Bishops to make a presentment, is 
 it uncanonical to write a friendly private letter informing him 
 that under a certain contingency they may be compelled to do 
 it? There is another charge against the three Bishops, 
 grounded on this point on page 11 of his pamphlet, in these 
 words : " And yet departing from their places, transcending 
 all their rights, invading another diocese and dictating to 
 another Bishop, they prescribe as the condition of not present- 
 ing, thekourse he shall pursue." On this allegation, we, plain 
 laymen, unskilled in canonical lore, desire to make a remark 
 or two, and the first is, that the three Bishops have neither 
 prescribed or dictated anything to Bishop Doane on condition 
 of their not presenting him. The next is, that the three 
 Bishops show clearly by their letter, that instead of interfering 
 with diocesan rights, they sought to sustain them, by throwing 
 the matter into the hands of the Diocesan Convention of New 
 Jersey, because they consider that the most tender way of 
 dealing with the Bishop. We have to say also that the course 
 adopted by the three Bshops was not adopted at our instiga- 
 tion, or by our advice, and that if any one has ground of 
 complaint against the three Bishops for desiring to throw the 
 matter before the Diocesan Convention, it is the laymen. But 
 
 K 
 
we did not, nor do not, complain at the course they adopted. 
 They were placed in the sad alternative of either coming to 
 New Jersey, hundreds of miles from their respective dioceses, 
 at an inclement season of the year, neglecting other duties at 
 home, consuming their valuable time in running through New 
 Jersey to hunt up evidence, (as the Bishops had to do in the 
 New York case,) or else to submit the matter to the Diocesan 
 Convention. We felt for these noble, pure-minded and inde- 
 pendent prelates, and we thought it right that our wishes on 
 that subject should yield entirely to their convenience. 
 
 But again in page 9 of his pamphlet, Bishop Doane says, 
 "He will not listen to their" (the three Bishops) "advice — no 
 special convention will be called, by him, no interference with 
 his equal and inalienable right as one of the Bishops of Jesus 
 Christ, can be suffered by him." 
 
 What is this terrible interference with his equal and inalien- 
 able rights which excites so much of Bishop Doane's ire ? It 
 is that three Bishops have written to him a kind and courteous 
 letter of advice. This Bishop Doane treats "as an interference 
 with his inalienable rights, as an invasion of his Diocese," and 
 for this "uncanonical, unchristian, and inhuman" conduct, 
 what does he propose to do with them ? We see by his cir- 
 cular, calling the special convention. He calls a special con- 
 vention to try the three Bishops for their invasion of his in- 
 alienable rights. Where does the Bishop find the canon of 
 the Church which authorizes such a trial by the convention of 
 New Jersey ? 
 
 He accuses the three venerable prelates of having received * 
 as unquestionable ground for the highest ecclesiastical proceed 
 ing, a document which bears the name of but four persons, and 
 which they have evidently adopted without applying to it a 
 single test as to its truth or accuracy. We take leave to say 
 that this accusation against the three Bishops is wholly un- 
 founded. They could not have done otherwise, without disre- 
 garding their duty as Bishops of the Protestant Episcopal 
 Church. The first complaint is, that the document bears the 
 
 name of but four persons. Our answer is, that in a legal proceed- 
 
 1 * 
 
ing to found a presentment of a Grand Jury, but one witness is re- 
 quired; under the Mosaic law, and in ecclesiastical proceedings, 
 but two witnesses are required to convict a person of a crime, 
 and we are yet to learn that the accusation of one respectable 
 man is not sufficient to ask inquiry, which is all the Bishops 
 asked. 
 
 And again, the Bishops who presented the Bishop of New 
 York, acted on the call of only four or five persons at most, 
 and they were from other and distant dioceses, whereas the 
 four laymen who presented the memorial to the three Bishops 
 were satisfactorily known as communicants of Churches near 
 Burlington. 
 
 The second ground of complaint is, that the three Bishops 
 did not apply a single test as to the truth or accuracy of the 
 document. 
 
 The grossness of the charge will be manifest, from the fact 
 that the Bishops had before them the two oaths of George W. 
 Doane attached to his assignme nt, together with a list of credit- 
 ors and statement of his prope rty, a copy of which had been 
 published, and also the affidavit of Michael Hays against him, 
 which is not noticed by him, although a copy of it was sent to 
 Bishop Doane, proving the truth of one of the charges against 
 him ; either one of these affidavits, in our opinion, is sufficient to 
 justify the action of the three Bishops. 
 
 Besides, the second section of the thirty-sixth canon of the 
 Church makes a public rumor a sufficient ground as against 
 a minister , for the institution of an inquiry as to the truth of 
 .such public rumor." Now, in this case the three Bishops had 
 not only public rumor, but they had no doubt seen the charges 
 which had been published under the name of a respectable cler- 
 gyman in September, 18o0, implicating Bishop Doane, and to 
 which he had given no reply. 
 
 Besides, in Bishop Onderdonk's case, if we do not mistake, 
 the Bishops who made the inquiry into his conduct, and subse- 
 quently presented him, acted on extensive rumors, newspaper 
 attacks circulated through the land unanswered, by editors. 
 
not called before the tribunals of the country as they should 
 have been. 
 
 His next charge against the three Bishops, is in page 11 of 
 the pamphlet, stated thus : " They reject beforehand, the 
 M determination of the convention, that enquiry is unnecessary.'' 
 Again, in page 24, he says : " The undersigned peremptorily 
 " demands as his clear right, that in his case, the convention 
 " of his diocese has set forth in the most emphatic way, its 
 " mind and will as to his presentment, not only for any of the 
 Ci offences contemplated by William Halsted in the resolution 
 " above cited, but as to its further entertainment of them; 
 " and that thus the canonical right of any three Bishops to 
 " make presentment on such charges, is perfectly estopped." 
 If the Bishop's knowledge of canonical law is not much more 
 accurate than his knowledge of the common law, he must be 
 very poor authority for any one to follow. 
 
 The idea of the three Bishops being estopped by the action 
 of the New Jersey convention, is ludicrous in the extreme. If 
 we were disposed to answer this notion as a lawyer, we would 
 say first, "That Estoppels are not to be favored because the 
 truth may be excluded — second, that Estoppels only bind par- 
 ties or privies, and the three Bishops were neither parties or 
 privies to the resolution offered by William Halsted, or to the 
 action of the convention upon it." 
 
 The principle of law to which the Bishop evidently alludes 
 (but which he has so strangely misapplied) is this, "That where 
 the merits of a question have been directly determined by a court 
 of competent jurisdiction, they cannot be tried over again between 
 the same parties." We ask first, have the merits of the ques- 
 tion been determined ? The merits of the question were the 
 truth or falsity of the rumors or charges sought to be inquired 
 into. These the convention refused to inquire into. 
 
 But second, if the merits of the question were tried, were 
 they tried by a court of competent jurisdiction ? What kind 
 of a court is that in which the person accused of the offence, 
 presides and refuses to leave the Bench, when a motion is 
 made requesting him so to do ? What kind of a trial is that 
 
\n which there is no accuser and no witnesses ? William Hal- 
 sted, when he offered the resolution, expressly said, that he 
 was not an accuser of Bishop Doane. He wished the investiga- 
 tion only that he might be put in possession of facts by which 
 to put down the rumors which were in circulation against 
 Bishop Doane. He repelled the charge of being an accuser, 
 but he said in his reply, that if the convention desired to place 
 him in the attitude of an accuser of Bishop Doane, that if they 
 would adjourn for a short time to give him an opportunity 
 of obtaining affidavits, he thought he could obtain sufficient 
 proof to show that the inquiry ought to be made. The con- 
 vention, however, did not think proper' to adjourn, nor to re- 
 quest William Halsted to assume the position of an accuser of 
 Bishop Doane. Thirdly, we ask, is the question now between 
 the same parties ? The question then was between William 
 Halsted and the Bishop — now it is between the three Bishops 
 and Bishop Doane. But lastly, are the charges the same ? — 
 How does the Bishop make out his assumption that the charges 
 are the same which William Halsted contemplated in his reso- 
 lutions? As the whole basis of his argument on this point, rests 
 upon the identity of the charges contemplated in his resolution 
 and those contained in the memorial to the three Bishops, it 
 was incumbent on Bishop Doane to give some proof of his as- 
 sertion, or at least not to make the assumption unless he knew 
 it to be true. We say then, first, that Bishop Doane has not 
 shown the identity of the charges. Second, that William 
 Halsted says distinctly and unequivocally, that many of the 
 charges contained in the memorial to the three Bishops, are 
 not the same as those contemplated by him when he offered his 
 resolution, and that one-half of the charges, and two-thirds of 
 the specifications have come to this knowledge since. In regard 
 to the first charge of borrowing the money of Mr. Stubbs belong- 
 ing to the society for the promotion of christian knowledge. 
 
 The first information William Halsted had in regard to it 
 was not until after the third day of July, 1849, when it was 
 announced to him by a gentleman in New Brunswick. 1 1 is 
 certain then that this charge was not in the contemplation of 
 
 
 
Mr. Halsted, when he offered his resolution. In regard to the 
 third charge. Taking the sum of $7,476 81 of the moneys 
 belonging to the Episcopal funds of the Diocese, without the 
 authority, knowledge, or consent of the convention. Every 
 member who was present at the convention of May 1849, 
 when William Halsted's resolution was passed upon, can bear 
 witness that it was not until that resolution was voted down 
 that the discovery was made, that the Bishop was indebted to 
 the Episcopal fund for means borrowed of Mr. Germain without 
 their consent. 
 
 That was the first information William Halsted had con- 
 cerning it. It is clear, then, that this charge was not contem- 
 plated by Mr. Halsted when he offered his resolution. 
 
 As to charge fourth, "Swearing rashly and unadvisedly 
 in regard to the value of his property ;" and charge fifth, 
 "swearing falsely as to the lists of his creditors, and the amount 
 of the debts due to them respectively." William Halsted 
 declares, and is prepared to prove, that the first information he 
 ever had in regard to the oaths attached to the assignment of 
 Bishop Doane, and to the list of his creditors, or the list of his 
 property, or the value thereof, was given to him by a gentle- 
 man in New Brunswick, after the 3d day of July, A. D., 
 1849, when said gentleman exhibited to said William Halsted, 
 a certified copy of the assignment of Bishop Doane, with affi- 
 davits and lists of creditors, &c, thereto attached. 
 
 It is certain then, that the fourth and fifth charges, as well 
 as all the charges founded upon the list of creditors, the inven- 
 tory of property, and the valuation placed upon the same 
 therein, could not have been in the contemplation of William 
 Halsted when he offered his resolution. What kind of pretence 
 is there made that the Convention in passing upon William 
 Halsted's resolution, set forth " its mind and will" in regard 
 to them when they were not, and could not have been, in the 
 mind of the mover of the resolution ? 
 
 William Halsted asserts that at the time he offered his reso- 
 lution of inquiry, he had in contemplation only six of the 
 charges specified in the Bishop's pamphlet, and that the other 
 
10 
 
 thirteen charges grew out of, or are based upon, information 
 subsequently received. In this state of facts, what becomes of 
 Bishop Doane's doctrine of estoppel ? Let us bring it to the 
 test of common sense and practical experience. Suppose a 
 complaint made to a grand jury, that A B has been guilty of 
 selling liquor on Sunday, and there should happen to be a 
 majority of rum-sellers and rum-drinkers and their friends on 
 the jury, and the grand jury should refuse to hear any wit- 
 nesses or make any inquiry into the complaint, would this 
 conduct of the grand jury prevent a subsequent grand jury 
 inquiring into the same complaint ? Bishop Doane's lawyers 
 and counsellors will tell him it would riot. But if it would 
 not, then we ask, would it prevent an inquiry into the same 
 offence when connected with the additional charges, that the 
 said A B had continued to sell liquor on the Sabbath day ever 
 since the first complaint was made ? And if a grand jury would 
 not be estopped from inquiring into the same or similar matters 
 when the complaint was made by the same individual, would 
 they be authorized to reject it when presented by three other 
 individuals . ; The absurdity of this plea, set up by Bishop 
 Doane to prevent investigation, is too transparent to require 
 further remark. But the tenacity with which he clings to it is 
 sufficient to satisfy every honest mind that investigation into 
 his conduct is the thing he most dreads, and that the appre- 
 hension of inquiry has so distracted his mind and driven his judg- 
 ment from its propriety, as to induce him to set up this refusal 
 of the Diocesan Convention of New Jersey to inquire, not only 
 as a pardon for past, but as " indulgence" for future offences. 
 After this, with what grace can a charge of " Papacy ' be 
 made by Bishop Doane against the three Bishops 1 Again, 
 when arguments so untenable are brought forward by a man 
 of such powerful intellect as Bishop Doane, for the purpose of 
 avoiding inquiry, it goes but to confirm the opinion entertained 
 by many, that he must have adopted many other expedients to 
 avoid investigation before he would have resorted to one so 
 flimsy as this, and that the last Diocesan Convention at Bur- 
 lington was suddenly cut short and adjourned the first day, <it 
 
11 
 
 his instigation, in order to prevent the complaint heing made 
 against him. Why the sudden determination to dispense with 
 the evening service, after notice had been given in the morning 
 that the service would be held with a sermon and collection ? 
 And why the Convention adjourned leaving the Treasurer's 
 Accounts unaudited, has never yet been satisfactorily explained. 
 How far the following extract from the affidavit of Michael 
 Hays, annexed to the memorial sent to Bishop Doane by the 
 three Bishops, may throw light upon this sudden adjournment, 
 we leave our candid readers to judge ; — " And this deponent 
 " further says, that the said George W. Doane, on or about 
 (C the day of October, in the year of our Lord one 
 
 " thousand eight hundred and forty-nine, entered into an 
 u agreement with this deponent, that if he, this depo- 
 u nent, would compromise his liability on his endorsements for 
 " said George W. Doane, without a contested suit at law, in 
 el the best manner he could, that he, the said George W. 
 i( Doane, would secure to him the payment of one-half of such 
 " sum of money, for which said compromise was made, by 
 " paying this deponent the sum of one thousand dollars a year, 
 " with interest, until the said one-half should be paid, and that 
 " the second instalment under said agreement, became due in 
 u January last, and that he called upon the said George W. 
 " Doane, and requested him to pay this deponent the said sum 
 " of money, but the said George W. Doane said he could not 
 " pay until May, but that in May term he should receive his 
 " salary from the schools, and then it should be paid, and that 
 " this deponent should have his money on the tenth of May 
 " certain ; and this deponent called on said George W. Doane 
 " about the twentieth day of May last, and the said George 
 "W. Doane told this deponent he could not pay the said 
 " money. Deponent then said, ' Bishop, this is a disappoint- 
 " ment,' and that if he could not get his money he should first 
 " present him to the Church, and if he could not get redress in 
 " that way, he must resort to the laws, and the said George 
 " W. Doane then said that if this deponent did that, he would 
 " put himself on his defence, and this deponent would get 
 
12 
 
 cc 
 
 nothing. Deponent replied, C I get nothing as it was. I 
 " could do no worse." And the said George W. Doane then 
 " said that this must be the last intercourse between them. 
 " This deponent then left him, and drew up a memorial to 
 " present to the Episcopal Convention, and gave it to a member 
 M of said Convention to present, and he believes that the said 
 " memorial would have been presented to said Convention had 
 " not the said Convention, contrary to all previous practice, 
 " adjourned the first day of its session." 
 
 There is one remark which must present itself to the mind 
 of almost every man who has attentively observed Bishop 
 Doane's conduct in the whole matter, and that is this — if Bish- 
 op Doane is conscious of "his entire and perfect integrity and 
 innocence, as to all and singular the charges made against 
 him," and "challenges the world upon the ground of perfect 
 honesty of purpose," why does he shrink from inquiry ? It is 
 not the character of innocence to shrink from investigation. — 
 It is only "the wicked who flee when no man pursueth." "But 
 the righteous are as bold as a lion." Besides we take it to be 
 the duty of the Bishop to emulate the example of the great 
 head of the Chureh— "to present the Church to himself, a glo- 
 rious Church, not having spot or wrinkle or any such thing." 
 In regard to the propriety of the action of the convention 
 upon William Halsted's resolution, and the propriety of said 
 William Halsted offering it, we quote from a pamphlet of a Rev. 
 Clergyman published in September 1850, entitled "a word 
 of self-defence" on page 5 of said pamphlet. The Rev. 
 gentleman says: — "A gentleman of eminence and character* 
 residing in Burlington, but not belonging to the convention, 
 declared to me that he heard no less than fifteen members say 
 the inquiry proposed ought to be instituted. A Trustee of 
 the college, and one of the Bishop's most faithful friends, 
 whose friendship to him and his institutions had been largely 
 tested by his purse, remarked to me a short time subsequently, 
 that he had no doubt but that a large majority of the conven- 
 
 * This was the lamented Henry Mcllvaine, Esq., recently deceased, who prae 
 tised law in Philadelphia. 
 
3 
 
 tion were in mind thoroughly satisfied with the wisdom and 
 propriety of the resolution." 
 
 And as to the propriety of" the memorial sent by the fonr 
 laymen to the three Bishops, we have been credibly informed 
 and believe, that it was a subject of conversation among some 
 of the Bishops, who attended the recent General Convention 
 at Cincinnati, Ohio, when it was remarked that it was the du- 
 ty of the Convention of New Jersey to institute an inquiry in- 
 to the rumors and charges made against Bishop Doane 5 or that 
 individuals of New Jersey should do their duty. 
 
 Bishop Doane introduces into his pamphlet the history of 
 his embarrassment, which has been repeatedly put before the 
 people in one shape or another for the last iew years. But 
 we think it will not bear examination, and if it would, what 
 has it to do with the points in controversy ! The charges are 
 not that Bishop Doane is embarrassed or that his indebtedness 
 is so great — this may all happen to an honest man, but the 
 substance of these charges is, that he practiced deception and 
 fraud in the manner of incurring some of his debts, and of in- 
 volving third persons in other debts. It will not do for one 
 man to cheat another, and then plead in justification that the 
 act was clone for the sake of charity, or for advancing the 
 Lord's work; or in the pithy language of an old Judge, it will 
 not do "to steal the leather for the purpose of making poor 
 men's shoes." 
 
 Another issue raised by the Bishop for the purpose of blind- 
 ing the unwary, is, that the diocese has grown so much. This 
 is an old piece of stereotyped glorification that the Bishop puts 
 forth every little while in his addresses and elsewhere, and 
 repeats so often that he really appears to believe that the 
 whole increase of the Church in New Jersey is owing to 
 his labors. But we had supposed that "though Paul might 
 plant and Appollos water, that it was God that gave the in- 
 
 crease." 
 
 One object oi Bishop Doane's pamphlet appears to be to 
 raise false issues between himself and the three Bishops, and 
 between himself and us four laymen, so that the real matters 
 
 2 
 
u 
 
 in issue may be obscured in the smoke of the flames he designs 
 to kindle. Hence the bull he has fulmined against the three 
 Bishops. Hence his appeal to all the Episcopal Bishops of 
 the United States in particular, and of u all the world " in 
 general. Hence he wishes to raise a new issue between us 
 four laymen and himself. He charges us with falsehood, 
 malignity and misrepresentation, and to give some pretext for 
 making these denunciations, he assumes that we have made 
 charges against him, and asserted the truth of those charges 
 on our own knowledge. Now T we deny both branches of this 
 assumption. The Bishop knows very well that no layman can 
 present charges against a Bishop upon w^hich he can be tried 
 before the Bench of Bishops, and that such charges can only 
 be presented by the convention of the Diocese or by three Bish- 
 ops. It is apparent, therefore, that we did not present the mat- 
 ter in the document sent to the three Bishops, as the charges on 
 which he w T as to be tried; our only object was, and could legit- 
 imately be, to present to the three Bishops such points of inqui- 
 ry, and give them such information in a brief and condensed 
 form, as would facilitate their inquiries, and aidt hem in mak- 
 ing such charges as they might deem proper to present. And 
 if he had carefully read our communication to the three Bish- 
 ops, he would have found that we did not assert that we knew 
 that the matters set forth in that communication Avere true ; 
 but that we had made such an investigation into them as to 
 satisfy us that they ought to be inquired into. "In order (to 
 quote the language of our communication) that if false their 
 falsity may be made manifest, or if true, that measures may be 
 taken to relieve the Church from the odium they indict upon 
 her." 
 
 But we cannot dwell upon these issues which are foreign to 
 the real object we now have in view, w r hich is to take up 
 Bishop Doane's reply to the charges which lie says have been 
 made against him, and to show that the answers which lie 
 attempts to give are either unsustained by facts, or are wholly 
 evasive and unsatisfactory. 
 
15 
 
 The specification under the first charge of obtaining money 
 under false representation or false promises, is as follows : 
 
 "He obtained money amounting to $1000, of the Rev. Al- 
 fred Stubbs, Treasurer of the "Society for the promotion of 
 Christian Knowledge and Piety," under a representation or 
 promise, that he would give safe and ample security for the 
 same ; and he has not returned the money nor given security 
 therefor." 
 
 In his answer to this charge, he admits he borrowed the 
 money, but says that Mr. Stubbs offered it to him on common se- 
 curity. Will any one pretend that Bishop Doane's bond was 
 common security for the loan of money held in trust ? Would 
 any Court in the country justify a Trustee putting out Trust 
 money on such security ? This was no security, and could 
 never have been contemplated by Mr. Stubbs as such. We 
 have been informed by creditable authority, that Mr. Stubbs 
 said that Bishop Doane promised him at the time he got the 
 money, that he should have the best and amplest security, and 
 though many months had elapsed, the security was not given, 
 and that he did not give even a Bond with warrant of at- 
 torney, until a long time after he had obtained the money, al- 
 though his answer is artfully worded so as to convey that im- 
 pression. 
 
 Bishop Doane says, however, that an arrangement has been 
 made to secure Mr. Stubbs against loss. But he is careful 
 not to tell us when this arrangement was made. If the date 
 had been given it might have turned out to be since Sept. 
 1851, the date of the communication of the undersigned to the 
 three Bishops, and it might show that Mr. Stubbs was indebt- 
 ed to the four Laymen for his security against loss, and that 
 might have been some little consolation for them under the se- 
 vere attack the Bishop is making against them. 
 
 The second charge as stated in the Bishop's Pamphlet is this: 
 
 "He induced individuals to endorse promissory notes for him 
 by false representations and false promises." 
 
 It should be remarked before adverting to the evidence to 
 sustain the charge, that the Bishop in Page 17 of his Pamphlet> 
 
16 
 
 declares "his entire and perfect innocence as to all and singular 
 the charges made against him;" what credit is due to these as- 
 sertions, will appear in the sequel. The proof, however, of the 
 2d charge is found in the following extract from the affidavit 
 of Michael Hays, which was annexed to the document sent by 
 Hie three Bishops to Bishop Doane, but which he is very 
 careful not to notice in his appeal, for it might have interfered 
 with some of his rhetorical flourishes. 
 
 "And this deponent further says, that of the notes endorsed 
 by said deponent for said George W. Doane, four thousand 
 dollars of them were protested, and this deponent endorsed 
 other notes to the amount of four thousand dollars, to take up 
 the protested notes; and this deponent further says, that after 
 he had endorsed said last mentioned notes, he applied to said 
 George W. Doane to obtain from him the four protested notes, 
 for the payment of which he had endorsed the four last men- 
 tioned notes, the said George W. Doane delivered to this 
 deponent two of the said notes, and told him that Mr. Reuben 
 J. Germain had the other two; and then this deponent applied 
 to the said Mr. Germain for said notes, and the said Mr. 
 Reuben J. Germain replied that he knew nothing about them ; 
 and this deponent further says that he has been called upon to 
 pay the said two last mentioned notes, for the payment of 
 which the said George W. Doane had obtained two other 
 endorsements of the same amount from this deponent, to take 
 up said notes, and which notes the said George W. Doane 
 informed this deponent had been taken up and were in the 
 hands of the said Mr. Reuben J. Germain ; and this deponent 
 verily believes that under pretence of getting this deponent to 
 endorse notes for the purpose of renewing notes which he had 
 previously endorsed, and which were coming due, he must 
 have obtained from this deponent, endorsements to the amount 
 often thousand dollars, which were not applied to the payment 
 of the old notes, but were applied by said George W. Doane 
 to other objects, and for other purposes than the payment of 
 the notes they were intended to renew, and by means of which 
 misapplication and misappropriation of said notes, the liability 
 
17 
 
 of this deponent for the said George W. Doane was without 
 this deponent's knowledge or consent, increased to an amount 
 often thousand dollars, at least." 
 
 The proof of the Specification under this charge will be 
 found in the Petition of Michael Hays, addressed to the Epis- 
 copal convention verified by his oath, which is annexed to this 
 pamphlet which was prepared by Michael Hays in his own hand 
 writing, and was handed to one of the undersigned on the first 
 day of the sitting of the last convention at Burlington, with a 
 reque st from the Petitioner that he would lay it before the con- 
 vention ; and which request would have been complied with, if 
 the Convention had not suddenly and unexpectedly, and con- 
 trary to its usual practice, adjourned on the first day. 
 
 And we ask the candid reader to contrast the following 
 language of Bishop Doane in reply to the specification under 
 the second charge, viz: "the undersigned never represented 
 himself to Michael Hays as solvent or able to pay his debts," 
 with the language of Michael Hays as contained in this peti- 
 tion verified by his oath. 
 
 The charge 3d as stated in his pamphlet is as follows : — 
 "Taking the sum of $7,476 ol of the moneys belonging to the 
 Episcopal funds of the Diocese, without the authority, knowl- 
 edge, or consent of the convention." 
 
 The specification is, that "He induced the Rev. Reuben J. 
 Germain, the Treasurer of Convention (who had given no se- 
 curity for the faithful performance of his duty, and was unable 
 to respond to the Convention for a loss of said fund,) to sell 
 out good Stocks, and Bonds, and Mortgages, (bearing an inter- 
 est,) belonging to the Convention, and to loan the proceeds to 
 said Bishop Doane, upon his own notes without security." 
 
 His answer is, he did not induce the Treasurer to sell out 
 good Stock, Bonds, and Mortgages. "There never were any 
 mortgages belonging to the Episcopal fund." We will not aver 
 positively that there were mortgages. What we say is, that at 
 the time we sent our memorial, we believed that every word 
 we uttered was perfectly true. One of the grounds of our be- 
 lief that there were "mortgages," will be found in the Pamphlet 
 
 9* 
 
18 
 
 of the Rev. Clergyman before alluded to, entitled "A word of 
 Self-Defence." On page 12 he makes use of this language : 
 4 "The fact was disclosed and undenied, that good securities in 
 bonds and mortgages, and in stocks, had been exchanged for 
 the Bishop's notes." We might state other reasons for our be- 
 lief that there were mortgages, but it is unnecessary. Sup- 
 pose there were only Stocks and Bonds sold, and the proceeds 
 of the money lent to Bishop Doane on his notes without securi- 
 ty. This is a substantial admission of the charge. But he 
 says that the Stocks were likely to grow worse and the Bonds 
 of doubtful tenure. Both of these assertions we deny, and they 
 are without the shadow of proof. But suppose they were, 
 what right had this Treasurer to sell them without the author- 
 ity of the convention, and before he had given any security for 
 the faithful performance of his duty? But he says, that the 
 Treasurer "was for a long time closely associated in the busi- 
 ness in which he (the Bishop) was engaged," and he might 
 have added, that he was a mere subordinate in one of his 
 schools. But did this association with Bishop Doane, con- 
 fer any right upon him to loan the money of the convention to 
 Bishop Doane without security ? Was it not a breach of trust 
 on the part of Mr. Germain? He, is not perhaps much skilled 
 in business, and might plead perhaps ignorance on this 
 ground ; but this to an honorable mind would only have pre- 
 sented a stronger reason why the money of the Convention 
 should not have been borrowed of Mr. Germain. 
 
 But he says he was carrying on the work of the Church. 
 This we deny ; but if he was, does he hold to the doctrine 
 that we may do evil that good may come — that the end 
 justifies the means? 
 
 Again, he says, '* the Treasurer lent him his uninvested 
 funds temporarily on his notes." What does he mean by this ? 
 He admits he borrowed $7,456 81. Does he mean to say that 
 the whole of this was uninvested funds? If so, what does 
 he mean b> saying that "stocks which were depreciating, and 
 bonds of doubtful tenure were sold*" Were not these before 
 
19 
 
 they were sold, invested funds ? But he says the uninvested 
 funds were lent him temporarily. What does he mean by 
 temporarily ? He stated before the Convention at Burling- 
 ton, in May, 1849, when this indebtedness was first made 
 known to the Convention, and he felt himself compelled to 
 make some apology about it — that the money was not bor- 
 rowed, all at -once, but from time to time through a course 
 of several years. If that statement was true, what becomes 
 of the pretext that it w r as a temporary loan ? He says no 
 objection was made to the undersigned or Treasurer. Who 
 knew 7 it but Bishop Doane and the Treasurer ? He says, " it 
 was considered safe,' 3 By whom ? Again, he says, it has 
 been perfectly secured, as a Committee of the Convention of 
 1850 have reported. Suppose it to be now secure, does that 
 change the nature of the original wrong in taking it ? But we de- 
 ny that it was secure at the time the Committee of the Conven- 
 tion at Newark in 1850, to which he alludes, reported it to 
 be secure. To sustain what we say in regard to the security, 
 we quote from the pamphlet of the Reverend gentleman before 
 alluded to, entitled "Word of Self-Defence, " page 9, w T hich is 
 as follows : " Now as to the security, the Bishop and a friend 
 presented a bond conjointly, obligating themselves to pay $500 
 annually till the debt is liquidated. This, be it observed, if 
 the $1,000 due the society for the promotion of christian 
 knowledge and piety be included, and for which no other 
 security exists, will require, within a fraction of seventeen 
 years to conclude the full return of the funds due. The 
 collateral securities proposed were the assignment of a policy 
 of insurance on the life of the Bishop, for $7,500, and what 
 was said to be an extract from his friend's will, leaving the 
 amount requisite to cover the sum in the event of her death ; 
 the position of her estate being such that the bond could be 
 availing only for her lifetime. But this latter paper was in 
 no way authenticated ; there was not even a name attached to 
 it ; and if the will itself, signed and sealed, had been tendered, 
 Mr. Ryall admitted that in law it could be no valid security. 
 It may be made now, and in good faith, but it may be altered 
 
20 
 
 at any day ; and it is very conceivable that causes may arise 
 which would be deemed a sufficient warrant, both in law and 
 morals, to make the alteration. There is no bond of security 
 that the annuity will be paid on the life insurance, and a year's 
 neglect of this will vitiate the policy. And then again, there 
 is no provision for the payment of the interest, though by 
 canon one-half of the interest is required to be added to the 
 principal, so the promised security, it will be seen, is most 
 dubious and frail." 
 
 Charge 5th. — Swearing rashly and unadvisedly as to the 
 value of his property. What excuse does he give for swearing 
 that property was less than one-quarter of its value? It is that Mr. 
 Cannon and Mr. Aertsen adivsed him to do so. He swears that 
 one hundred and ninety-five bedsteads were only worth $87.50. 
 That the desks, chairs, sofa, engravings, stands, etc., in his 
 library worth but $70 ? And so of most all the other property. 
 Does he hold an oath so lightly that he takes it as a matter of 
 course because somebody advised him to do so ? 
 
 Charge 6th. — Swearing falsely to the list of his creditors and 
 the amount of debts due to them. He swore that a certain list 
 was a true and perfect list of his creditors, and of the amount 
 severally due to them. This list, however, did not state that he 
 was indebted to the Episcopal Convention or to Mr. Germain, 
 Treasurer thereof, for the sum of $7,476.51, or for any other 
 sum of money. His excuse for leaving this debt out of his list 
 is, that the Episcopal fund was not regarded an ordinary debt, 
 and the purpose from the first was entertained to provide for it 
 distinctly. What does he mean by its not being an ordinary 
 flebt ? Does he mean it was an extraordinary debt ? 
 
 It certainly was contracted in a very extraordinary manner. 
 But was it not, nevertheless, a debt ? He swears he had given 
 a true and perfect list of his creditors, and the amount due to 
 them. Was he not, as much, bound to swear to the truth in 
 regard to an extraordinary debt as to an ordinary debt? But 
 perhaps he means by this that he considered it a preferred, 
 debt, because he so subsequently added thathe meant to provide 
 for it distinctly ; and that for this reason it was not put in thQ 
 
21 
 
 list of debts. This is confirmed by his friend, J. C. Garth- 
 waite, in his pamphlet, dated Sept. 30th, 1850, in which he 
 gives an explanation (doubtless by authority of the Bishop) 
 of this transaction, in these words : u Still the Bishop was 
 urgent for some action, for he had always considered this debt 
 from its nature, in a peculiar light, and had kept it out of his 
 schedule of indebtedness.' 1 It was then designedly kept out of 
 the list because it was a debt he meant to provide for dis- 
 tinctly. He says also that these affidavits were made out 
 under the advice of G. S. Gannon, Esq., and Robert Aertsen. Did 
 he tell these gentlemen that he was indebted to the Episcopal 
 Convention in the sum of $7,476.51, and that he kept it out of 
 the list because he was going to provide for it distinctly ? If 
 he really wanted to take their advice and throw the blame 
 upon them — if a false or rash oath was taken, why did he not 
 candidly state to them the true state of the case ? If he had 
 told Mr. Cannon that he was indebted to the Episcopal Con- 
 vention and he did not mean to put that debt on the list of his 
 creditors, he would have been told by that gentleman : Sir, 
 that is a fraud upon the law of New Jersey ; your assign- 
 ment must be made for the equal benefit of all creditors, and 
 any preference of one creditor over another, would be fraudulent 
 and void. He is tasking credulity too far when he asks us to 
 believe that Mr. Cannon and Mr. Aertsen advised him to leave 
 the debt of the Episcopal Convention out of the list. Was 
 it not left out from another motive, and that to con- 
 ceal it from the Convention. It had been kept a secret 
 for years from the Convention. If it had been put in his list, 
 the Convention, which was about to assemble in a few weeks, 
 would become acquainted with the facts. He expected to be 
 able to pay it before the Convention should find it out, and 
 therefore it was not put in. It was only discovered afterwards, 
 and then it was by accident. 
 
 To the specification under the above charge — viz : "Con- 
 tracting debts to an amount exceeding $250,000, when 
 
22 
 
 his whole estate, real and personal, according to his own val- 
 uation, does not amount to one-half that sum. His reply is, 
 that "of this $250,000, the real estate of the undersigned stood 
 for $100,000. '' It would have been more pertinent to the 
 inquiry if he could have said it was good for $100,000. 
 Again, he says, the objection raised, lies against the floating 
 debt of $150,000. Is the specification limited to $150,000 ? 
 Not at all. Again he assumes that the floating debt was only 
 * 150,000, whereas it will be seen by the remarks we have 
 made upon his reply to specification 6, of charge 5, that his 
 floating debts were at the time over $200,000. 
 
 His answer to the specification 6, on page 34 of his pam- 
 phlet, is a mere evasion ; nay, worse, it accuses us of false- 
 hood, when the falsity lies at his own door. The specification 
 is thus : " He omits on his list of creditors, thf name of H. R« 
 " Cleveland, who, he well knew, was at the time a creditor in 
 " trust for the sum of $15,000." Now bear in mind that the 
 gist of the specification is that the name of H. R. Cleveland 
 was omitted " on the list of his creditors." What then is the 
 answer ? It is that " the indebtedness to the estate of H. R. 
 " Cleveland in trust, is acknowledged in the schedule of real 
 " estate, which forms part of the assignment." Suppose for a 
 moment this be true, is that any reason for not placing it in 
 his list of creditors? The schedule of real and personal property 
 does not purport to give a list of or the names of the creditors 
 of George W. Doane, but only the inventory of the real and per- 
 sonal estate, and it is verified by a distinct and separate affidavit, 
 swearing that the " above is a true and perfect inventory of 
 " all his real and personal propert)^with the value thereof, as 
 " near as he could ascertain." Tmr\ follows the words " list 
 of creditors" and then follows the names, 139, with amounts 
 due each, opposite their respective names, and the whole 
 amount summed up in figures and stated to be $155,593.67. 
 Then follows an affidavit that the above is a "true, full, and per- 
 fect list of his creditors, with the amounts severally due to 
 them, according to the best of his knowledge." Is it any 
 
2 
 
 
 
 excuse for such an oath and such a list to say : " The indebt- 
 " edness is acknowledged in the schedule of real estate ?" Is 
 it any answer to say it has been on record in the public office ? 
 Does it afford any shadow of pretence for the allegation he 
 makes, that we " unite in declaring the debt is not acknow- 
 ledged," and that we "make the assertion knowing it to be 
 false?" If we were disposed to throw back upon him the 
 charge of u false, calumnious and malignant representations," 
 we should, we think, find abundant reason, in the eyes of the 
 world, to justify us, but we forbear. We simply deny that 
 we united " in declaring the debt is not acknowledged," and 
 call upon him to prove his assertion. 
 
 But he avers that " the indebtedness to the estate of Mr. 
 Cleveland is acknowledged in the schedule of real estate." 
 What does he mean by this vague and indefinite answer ? Does 
 he mean to say that his indebtedness to H. R. Cleveland in his 
 schedule or inventory of the real estate, is acknowledged? If 
 so, we take issue with him and say it is not acknowledged, 
 either by the language made use of in the inventory, nor in 
 the aggregate amount of the debt of his " creditors as summed 
 up in the list of his creditors." First,then, let us see what is the 
 language of the " inventory of the real estate " in regard to 
 this indebtedness. It is thus : " No. 2. The homestead prop- 
 " erty known as Riverside, fronting on the Delaware River, 
 " and bounded on the east by St. Mary's Hall, on the south by 
 " Pearl street, and on the west by Reed street, subject to a 
 "mortgage to J. Deacon for $ 5,000; also, a mortgage to H. 
 " R. Cleveland, in trust for $15,000 ; also, to a mortgage to 
 "L. Carter, for $10,000, on which about $4,000 has been 
 " k paid, valued at $1,00." Where is the acknowledgment of 
 George W. Doane's indebtedness in the above extract ? He 
 says the property is subject to a mortgage to H. R. Cleveland. 
 He don't say his, G. W. Doane's, mortgage, and for aught 
 that appears in the statement, the property may have been 
 mortgaged by somebody else, and may have been purchased 
 by Bishop Doane, subject to the incumbrance, so that the debt 
 
24 
 
 would not have been a persona! debt of Bishop Doane's, but 
 only a lien upon the real estate. What foundation then, is 
 
 there, for his allegation that we have made a false assertion/ 
 But in the second place we say that this debt of H. R. Cleve- 
 land is not in the amount of his debts as summed up on the 
 list of his creditors. The aggregate amount of his debts as 
 summed up on that list, is only $155,593.67. If this indebt- 
 edness to H. R. Cleveland, which he now says is acknowledged 
 in the schedule of real estate, and the other indebtedness to 
 other persons which stand in the same position in the schedule 
 of real estate as that of H. R. Cleveland, had been included 
 in the amount summed up, then the aggregate amount of his in- 
 debtedness would have appeared to be the sum of $263,723. 00; 
 add to this the debt to the Episcopal fund $7,476.51, makes 
 $273,199.51, that is $135,703.00 more than it is stated to be on 
 his list of creditois. Add $11,500 admitted on page 32 of his 
 pamphlet due to Michael Hays, over and above the amount 
 in his list, $11,500, and $6,600 due to J. Deacon, also omitted 
 on page 33 of his pamphlet, and it makes $291,249.51. 
 
 The same remarks which we have made in relation to the 
 omission to place the name of H. R. Cleaveland on his list of 
 creditors and his reply thereto, are applicable to the reply he has 
 given to "specification. 9 on page 35 of his pamphlet, in re- 
 lation to the omission of the name of I. B. Parker, to whom he 
 was indebted in the sum of $10,800, and in addition to what we 
 said in regard to specification 6, we wish here to notice a Lat- 
 in maxim which he has introduced and applied to us, viz : " Pul- 
 sus in unoy Falsus in omnibus," and he adds, "what an illustra- 
 tion of it." We have shown that all we said in relationto specifi- 
 cations 6 and 9 is true to the letter; but we also say 1 hat if we had 
 been in error, and that if two out of ten specifications which 
 are produced as sustaining one general charge, should happen 
 to be disproved, it would not follow that the "general charge- 
 was false." If a man is indicted and there are several counts 
 in the indictment, and one of them is not sustained, does it fol- 
 low that he is innocent of all the rest ? But we repeal with 
 
25 
 
 full sense of the strength of the allegation we make, that we 
 believe, that in a court of justice where compulsory process 
 can be obtained tor witnesses, every "Charge" against him, as 
 set forth in Bishop Doane's pamphlet, can be sustained. 
 
 Charge Tenth, as stated in his pamphlet, is as follows : 
 "That he induced individuals to endorse notes for him under 
 pretence that they were to renew notes which had been pre- 
 viously endorsed by the said individuals, and after obtaining 
 said notes for such avowed object, appropriating them to other 
 purposes, leaving the old notes they were pledged to renew, 
 unpaid, and thus increasing the liabilities of the said endorser 
 without his consent." 
 
 Specification First. — "He obtained from Michael Hays in 
 the manner set forth in the foregoing charge, to an amount 
 much larger than he would have been willing to endorse for 
 him." 
 
 In his reply, he denies the charge, and gives reasons for so 
 doing, which are wholly unsatisfactory, and do not, in our 
 opinion, in any way sustain his denial. He then says : " The 
 falsehood is transparent." Now the oath of Michael Hays, a 
 copy of which was attached to the document forwarded by 
 the three Bishops, fully sustains this charge and specification ; 
 and thus we have an issue of veracity completely made up 
 between Col. Michael Hays and Bishop Doane, and we have 
 no hesitation in saying that we would rely upon Col. Hays' 
 oath sooner than we would on Bishop Doane's word ; and we 
 do not think there is a man in Burlington acquainted with them 
 both, who would not do the same. 
 
 Further, we have been informed, and believe that Col. H<tys 
 did not declare on oath before the Grand Jury in August, 1850, 
 that he had "no cause of complaint against the undersigned," 
 but that he was sent for by the Grand Jury to come before 
 them, and when he did reluctantly go before them, he asked 
 them what they had sent for him for, " that he had no com- 
 plaint to make to them against Bishop Doane." And the 
 reason why Col. Hays did not desire to make a complaint to the 
 
 3 
 
26 
 
 Grand Jury, wo presume Col. Hays will, in duo time, fully 
 explain. 
 
 Charge Sixteenth. — Notwithstanding he knew he was in- 
 solvent, he lived in a style of sumptuous extravagance wholly 
 beyond his means. 
 
 In his reply to this charge, he endeavors to make the impres- 
 sion on the mind of the reader, that he expended his wife';; 
 mcome in his earnest desire to carry on the work of the Lord : 
 and therefore that the above charge is a " mean, calumnious 
 and malignant falsehood." Now, since he has made such a 
 charge, which, if we were to adopt his classic and refined 
 language, we should call " atrocious," we. will ask him if he 
 was not, shortly previous to his assignment, indebted to a wine 
 merchant in Philadelphia upwards of $1,000 for wine and 
 liquor, &c. ? and is that gentleman's name put upon his list 
 of creditors ? and if not, why was it omitted ? Was it like 
 the debt of the episcopal fund — " Not regarded as an ordinary 
 debt," and therefore " to be provided for distinctly :" 
 
 We shall have a great many more questions to ask when 
 these are answered ; but as we expect the three bishops will 
 take the matter in hand, we will not forestal them in the work. 
 
 In his reply to charge ten, on the thirtyrninth page of his 
 pamphlet, he refers to the affidavit said to have been made by 
 Deacon and Hays before the grand jury. We have been credibly 
 informed and believe that they did not make such an oath as 
 the bishop represents ; and that the oath was that they " had 
 no complaint to make to the grand jury against him ;" and not 
 that they had no complaint against him. This, it will be 
 perceived, is a very material difference; — doubtless, the bishop 
 offered them very weighty reasons for not having a complaint 
 to make to the grand jury. 
 
 Charge Seventeenth. — "That for the purpose of eiabling his 
 agents to borrow money for him, he represented to them that he 
 was indebted to an amount not exceeding $70,000." This 
 charge he does not deny; but says, "The undersigned replies 
 to this, that the amount of indebtedness stated aU^ve as 
 $70,000, was rather an estimate than a statement." 
 
27 
 
 We have already shown m oiu remarks upon his reply to spe- 
 cification 6 in the 34th page of his pamphlet, the debts^amounted, 
 at the time of his assignment, to $291,299 51, and we^have 
 reason to believe they amounted to rising $300,000, for we have 
 heard of some debts that were omitted, and it does not appear 
 that any allowance was made, in his calculation, for interest, 
 — so that it may be safely assumed that a few months after 
 the time he represented to his agents (to enable them 1 to go 
 out and borrow money on the faith of his representations,) 
 that he was not indebted to an amount exceeding $70,000 ; he 
 was actually indebted to an amount exceeding $300,000. 
 
 Have we not said enough ? Is it necessary to take up 
 every charge seriatim and show that his reply is, in almost 
 every instance where he does not admit the charge, an evasion 
 or misrepresentation of the real state of the facts ? 
 
 We regret the necessity of this publication. The majority 
 of the undersigned are unskilled in controversial writing of any 
 kirid, and nothing but an imperative sense of duty could have 
 induced them to have exposed themsel ves to such a contro- 
 versy with any one, — much less, such a distinguished and 
 eloquent writer and controversialist as Bishop Doane. Never- 
 theless, having been drawn into it, we take courage, from the 
 reflection that " The race is not to the swift, nor the battle to 
 the strong." We expected to be assailed with vituperation 
 and abuse. We shall, however, go calmly and fearlessly for- 
 ward in the discharge of our duty, and rely upon the approval 
 of all dispassionate, religious and moral men, when the facts of 
 the case shall be fully investigated. 
 
 We sought not to make public the charges against Bishop 
 Doane. We embodied them in a memorial to three bishops, 
 and sent them to the three bishops for the purpose of asking 
 them to investigate — if they thought them worthy of investi- 
 gation. They sent them to Bishop Doane, and Bishop Doane 
 has published them. Their publicity is the act of Bishop Doane. 
 As he has appealed to the public, not only upon the truth of 
 the charges, but on the truth of his accusations against us, we 
 trust we shall be excused from, saying thus much at present, 
 
28 
 
 and shall leave further vindication of our course to the action 
 of that independent ecclesiastical tribunal, whose duty it is 
 to take cognizance of matters of this nature. 
 
 W. HALSTED, 
 CALEB PERKINS, 
 PETER V. COPPUCK, 
 UENINGTON GILL. 
 
 February 2(5, 18o2. 
 
 COPY OF THE MEMORIAL OF MICHAEL HAYS TO THE 
 DIOCESAN CONVENTION OF NEW JERSEY. 
 
 i( To the Honorable the members of the convention of the 
 Protestant Episcopal Church of the state of New Jersey, 
 at the city of Burlington assembled : 
 
 " The petition of the subscriber respectfully sheweth, 
 That your petitioner having suffered great wrong and losses, 
 to a very great extent, by endorsing and loaning money to the 
 Rev. George W. Doane, he (the said Doane) representing to 
 your petitioner, at the different times of procuring said loans 
 and endorsements, that your petitioner was perfectly safe in so 
 doing, and that he should suffer no loss thereby ; yet, at the 
 same time, the said G. W. Doane well knowing that he (the 
 said Doane) was, at that time, insolvent and unable to pay his 
 indebtedness; but contriving and wrongfully and unjustly 
 intending to injure and bring to great loss your petitioner ; 
 and he (the said Doane) did, at divers times, wrongfully re- 
 present to your petitioner his ability to pay his indebtedness, 
 thereby wrongfully and unjustly through such false representa- 
 tions, induce your petitioner to loan money, and also to endorse 
 for the said G. W. Doane to a large amount, and which said 
 large amount, — to wit, the amount of twenty-three thousand 
 dollars, your petitioner has been compelled to pay ; and your 
 
29 
 
 petitioner further represents, that the said G. W. Doane di" 
 stipulate that if your petitioner would pay the aforesaid amount 
 of money without any contested suit at law, then lie (the said 
 G. W. Doane) would, upon such settlement, remunerate your 
 petitioner to the amount herein set forth and made known to 
 your honorable body, you will take such action on the same 
 as to you shall seem proper and right, and your petitioner, as 
 in duty bound, will ever pray. 
 
 ■■ MICHAEL HAYS. 
 
 " State of New Jersey, / 
 .Burlington county. j 
 
 " Michael Hays, the petitioner 
 above-named, being duly sworn according to law, doth depose 
 and say that the matter and things set forth in the foregoing 
 petition are true to the best of his knowledge. 
 
 " MICHAEL HAYS. 
 
 "Sworn and subscribed this 2oth day of May, 1851, ) 
 before me, one of the justices of the peace of ? 
 said county. ) 
 
 " Samuel W. Earl." 
 
^ 
 
•«-•* 
 
 /