The New York herald. [volume] (New York [N.Y.]) 1840-1920, 1854-11-18
Supreme Court.

Nov lI-BdrSans rs. Hdyyis-A NeU Book from III,
Great Showman-7ne Wooly Herse in the Supreme Court
The following legal document being rather richer than
such papers usually are is given at length 1t will re-
| pay perusal -
The complaint of TIE above named plaintiff respectfully
showeth that he is the author Of work in course
publication by j. Red6eld Of the city of New York
That he this plaintiff in that work gives the true and
authentic account Of tho various enterprises which
he has been engaged AMI he has aIpeady notified the
public in the newspapers Of the day lat he will do so
and has named the following among other enterprises OF
which he will give the trae history, namely "Joyce
Heth, the reputed nurse OF Washington; The Fejee
Asrmaid;n I" The Wooy Horse;n "The Hoboken Bufa.
10 Chase; /" The Fire Annihilator" sTbe Jenny Lind
distinguished characters with whom he has come in con-
tact &c This plaintiff further says thas heretofore
% aessunts m have In regard to his
until he wrote the said forthcoming work. he has
set right contradcted aud that many Of the facts
are only known to hmse ii s impossible for any other
person to givea correct version Of them This plaintiff
further says that he is to receive large per centage
from the said RedHeld upon each and every volume Of
said work, which he the said Redfeld may SELL and
from the large number of orders which the said Redaeld
has received and s daily receiving for said work. this
deponent believes that several hundred thousand copies
Of said work will be sold provided the interests of this
plaintiff in said publication not unjusy and Illegally
interfered with But now it TO- may Il please this
court the said defendant combining and confederatiug
with divers persons how to nure and oppress this plain
tin In the premises and to inurc and possible wholly
to destroy the benefits and advantages derived and
received by this plaintiff from the publication OF his said
work and to inure and destroy his interest therein is
about publishing work which, is intended to in
ct, aforesaid serious pecuniary injury upon this
plaintiff BY injuring the sale Of his said book,
ter, and to hoa him up rdicuie and contempt and
with this intent the said defendant has ordered to be
printed Eve hundred copies Of show BILL be publicly
exhibited by booksellers and Others OF which follow
M.Autobiosrsrhy e Petite Bunkum the great Yankee
fudge mermaid the woolly horse the whiskered LADY
the Fairy Light Guard, the Hoboken buffalo chase the
sbe be sIschs Of sne the poultry
Greenhcrn the great Our Ned the little Lyksey the
tiRcia ourang -ontang and thirty superb illustrations
are here exhibited without extra charge For sale
price so cents Published by r. 4. Harris No. 102 Mas
sau street New York" And the said Harris proceed
ing to publish the work the rein specified All OF which
matters and things tend to the manifest injury of the
plaintiff in the premises and will him great and
that this plaintiff viii thus sustain such that Il cannot
be properly estimated by doars and cents be made
good to him BY any action for damages In tender
sderation Whereof and inaSmuch this plaintiff has
adequate remedy by the strict rules Of the law
and cannot have adequate relief except BY the nerpos
ton Of the equitable powers Of this court may II please
this court to grant unto the plaintiff injunction re-
straning the defendant, his attorneys counseors
ng, or causing or allowing to be printed published
said handb or book or the contents thereof or any
Part thereof any other handb book Of the same
character an that the said defendant be decreed
deliver up tc manuscript Of the said handbll and book
and all and every copy thereof any part Of the
printed by him. to be cancelled and DESTROYED and that
this plaintiff may have such other further relief in
the premises may be proper and that the issues be
tried in the city and county Of New York.
PLATT, GERARD 4 BUCKLEY, Attys for PltiG
CITY and County of New York, a.-Phineas T. Barpum
the above plaintiff being duly says that the above
complaint is true Of his own knowledge except to the
matters therein stated information and belief and
to those matters he believes IL to be true
PHINEAS T. BARNUM
Sworn to before me, this 14th day of November 1854
SMITH Z. LANE, Commissioner Of Deeds
City an County Of New Fork, 4.-Phineas T. Barnum
the above plaintiff being duly sworn says, that he rete
rates In this affidavit the statement Of the above COM
paint and he further that the performance by the
defendants Of the acts in the said complaint complained
Of will cause to this plaintiff great and irrcmediable
pecuniary injury. PHlNEAS T. BARNUM
Sworn to before me- this 14th day Of November 1854
SMITH L. LANE Commissioner Of Deeds.
Take Notice. that the preceding complaint and aai.
davt motion will be made before Of the Justices
OF this Court at their Chambers in the City Hail. Of the
c,y of New York. the Goth day Of November inst at
nine O'Clock in the forenoon Of that day that nunc
tion issue therein prayed for the plaintiff have
such other or further relief as may be proper.
Dated New York, November 18, 1885,
Yours &c, PI4ATT, GERARD 6 BUCKLEY,
To r. +. HARRIS, Plaintiffs Attorneys