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William H. Swanson, Ceoss Examination. 527
counts of the witness were, and where they were 1 had.
Mr. Willis: Well, we will see about that.
By Mr. Willis:
Q. Now, give me the name of the bank, banks or trust companies in which the money, gross receipts of the St. Louis place was deposited. A. You have picked out the hardest one first.
Q. Because it is the first one on my list. That is the only reason. A. In giving the names of banks now, I 2 may not remember whether they are state banks or national banks, but their descriptive name will identify them. One in St. Louis was the Kepublic. Whether it was the Republic National or Republic something other than that, I don't recall.
Q. Mr. Swanson, by way of parenthesis, I am referring now to the months of November and December, 1908. A. Oh, that I could not give you. I don't know. I don't know those months. The best that I could do from memory would be to give you a list of banks in the various places where I had done business at different times. 3
Q. My question had reference to the months I named. A. I had overlooked that, Mr. Willis. I did not realize that.
Q. Notwithstanding the gratuitous instruction from the attorney — A. (Interrupting) : I believe, Mr. Willis, I understood that without the suggestion.
Q. One moment. (Continuing) : From the attorney for the Government. I will ask you whether you are willing to give me the names of the banks in which the money referred to, the gross receipts, wrere deposited in the months of November and December, 1908? A. For 4 reasons of future litigation that might make those of value to me, and also of value to others, I prefer keeping them if I can.
Q. Then you decline to give me the names of the banks? A. On that ground, yes, sir.
Q. Mr. Swanson, how many reels were you purchasing during the month of December, 1908, for all of the exchanges then operated or controlled by you? A. That would be impossible for me to answer from memory.