The weekly pioneer and Democrat. [volume] (Saint Paul, Minn. Territory) 1855-1865, 1865-11-03
Copy o. the Complaint.

COPY q the Complaint.
In IEs DIsrRzcf CouRr or r,,r s-corn Jun,.
0AL DDrxzor OF THE STATE OF NuxEsorA,
At RAMSEY County,. ...-..
,t{rc,s IGAATrUs Donxx1Lx
AGAnssr -t 4
Ass Goodrich, Augustus j. Goodr,~h x..,. q
Goodrich. Franklin l. Goodrich, Levh n
Fisher, and the Pioneer PRINTING Com.
pany." = ~oAA1'
Tho complaint of the ahnve NAMED P,.,r.,a
against the above named deferd,uts in thia -.
ton (the said Pioneer Printing COMPANY hein.
the common name of an association comuosaX
Of two or moro persons, associated in business
under said common nance respectfully states
and shows to this court thai tho said defend
ants at said Ramsey county ON the 24th Day of
October, A. D. 1856, contriving and malicious
" intending to ipjure the said plaintiff In his
good name, fame and credit, and 10 bring him
into public scandal, intamy and disgrace, with
and among al his neighbors, and other good
and worthy citisens. and to cause It to be sus-
pected and believed by those neighbors and
citizens that the said plaintiff had been, and
was. guilty Of criminal offence, which would
render him liable to indictment and punish
ment, and tor which he was liable to arrest /;
and that the said plaintiff was evading
an investigation thereof BY claiming and plead
ing his privilege from arrest q member Of
Congress Che said plaintiff being thea and
there and for . long time prior thereto, having
been member ofthe House Of Representatives
in the Congress of the United States) as here.
matter mentioned and to vex, harrass and OPP
press the said plaintiff, they, the said defend
aats, did then and there, falsely and malicious.
" compose and publish and cause and pro.
cure 70 be published in q newspaper called
the "St. Paul PIONEER" printed, issued and
pa6lished at said county, by said defendants,
fa!se, scandalous, malicious. and defamatory
libel OF and concerning the said plaintiff, con-
tanning, amongst other things the false, scands-
lous, malicious, defamatory, and libellous mat
ter following, Of and concerning the said plain
till, that b to say:
We dismiss Donnelly and his ''best speech. I"
God knows we have no desire to Dry into his
private affairs, either social or pecuniary. Ex-
cuse rs from disturbing that cesspool. But we
trust for the honor aud credit of the State
that we may hereafter send to Washington, if
not men of talent. at least some one who can
pass from Minnesota to the capital of the ma
ton without being under the necessity of
pleading his congressional privilege to save
himself from arrest.
The said defendants meaning and intending
to have it understood thereby that the said
plaintiff had committed some criminal offence
which would render him liable to arrest, in
dictnent and punishment, and that the said
plaintiff was endeavering to avoid and evads
an arrest and investigation of an concerning
such offence, by claiming and pleading that he,
the said plaintiff, was privileged from arrest
by reason Of being a member Of Congress.
By means whereof and of the said grievan.
ces committed by said defendants, the said
plaintiff has been and is greatly scAndalized,
and injured In his good name, fame and credit,
to his great damage in the sum of ten thou
sand dollars.
Wherefore the O. id plaintiff demands judgment
against said defendants for his damages afore-
said, In the said sum Of ten thousand dollars,
besides the costs nf this action.
HENRY j. HORN,
BRIsBIN g. WARNEN,
T. SMITH g. GILMAN,
Attorneys for Plaintiff.
STATE OF MINNESOTA &c -
COUNTY OF RAMSEY,
1gnatius Donnelly, OF Dakota county in the
State of Minnesota, being duly sworn, says
that he is the plaintiff above named; that his
foregoing complaint is true, of his own knowl-
edge, except as to matters therein stated on
his information and belief, and Is to those
matters he believes it to be true.
(Signed) IGNATIUS DONNELLY.
Sworn to and subscribed before me this 26th
day of October, A. ID. 1866.
lSealJ w. L. WILSON,
Notary Public, Ramsey county.
Filed OCTOBER %, 1866.
GEO. w. PRESCOTT, Clerk.