New-York tribune. [volume] (New York [N.Y.]) 1866-1924, 1875-05-27
THE SUPPLEMENTARY COMPLAINT.

THE SUPPLEMENTARY
RKvIEw OF THE FINANCIAL HISTORY OF THE COM
PANY AND PRESENTATION OF ITS CONDITION.
THR CORPORATION ASSERTED TO HAVE BEEN
INsoLvENT MORE THAN A YEAR-REAsoNs PUT
FORWARD FOR APPOINTING A RECEIVER.
The supplementary complaint which is referred
10 In Mr. Browns affidavit, and which, with that a-
davit the order appointing receiver was based is
long document Astounding In details The action Is
brought the of the people Of the State OF New
York against the Erie Railway Company by Daniel
Pratt Acknowledgement The Introductory part of the
amended supplementary complaint Is purely formal,
rectng the character of the corporation and the extent
of its possessions The important points Of the
complaint are as follows
The defendant the Erie Railway Company, created
with capital stock Of 1883 shares OF common st0cE
of 500 each and s557 shares of preferred stock OF
500 each The common stock OF the Company nae peen
shares The amount OF Rre.rIsa Seb amnan was
add"- y, special act of the Legislature ol
Ma Mc fun de- debt amounts TO- s17gI16 So Table
Of exhibit contains satspsnt OF the The disposon
der the socaled second consolidated mortgage OF the
said Company. Whereas the said Company is in form
mar the sad Company has only realized therefr0m at the
rate OF about 40 cents IN the dollar The pant cnages
authority of law, and that they are void That the
Of dealing with the sad BOMBS on the par OF d
said McHenry the said London Banking ASSOCIATION, ana
others as stated in the said table, was ana is tuauehs
and unlawful, and that eacn VI thc VI
WcHenry and others and fraudulent and unlaT,
nl THAT neither the bonds nor any part tnelcO hciu
by bona tde holders Tor faue ana sit e !, IL ogiv
ab. any amount in respect OF te Donds II y ,h oy
liable for the amount OF money actually received .ner
bonds whereof there arc oessnd.ug san as
10 the so-caued e0nvertlbe gef pOn4s lie ''s
belief az 20 the validity thereof the extent 70 which
tbs said Company justly liable in respect theeo Fam
% IN reSnect Of ts leased lines is S9s672 81 and the
plan Informed and believes that the sewers cse
the game natures The plaintiff is also informed ana De-
eyes that the Company is liable rs garantor IN respoGt
OF the leases upon some or an OF te Donus Va ' '
several Companies now outstanding 49,. ., r,so
The plaintiff is informed ana believes Una. ' ne md
.rr,d debts of the Company now outstanding lue ano
unpaid and shortly to become due amount 10 Sz,oae,
sci So. OF this sum 81 Os6esl -. rs que 20 %
ahorers employees, and agents OF all KINDS lOr wages,
and has due and unpaid for about two months 10
the great prejudice OF the SAID COMPANY 70 ne are
so due dependent upon the recep. deSf
the sum Of "a is due for supplies necessary nor
the operation and maintenance OF the rotl' "on SUI
has renamed many months due and unpaid Inc SUMS
ahove mentioned and due for services rendered ana sup
mics FURNISHED to the Company constitute IN equity
preferential charge the property ana %
Pomnany and as the plaintiff is advised, should De 50
segarded and dealt with by the Court A., c...rr
there are very many actions pending against the COM
many in this and other States, involving large Cno
thousand the plaintiff Is not at present aa
ysed OF the description OF suc or s
character amount OF claims , , ~ Mi
claims against the Company OUTSTANDING put NOT IN s
10 a vesy large amount; bui the reai s.n, nmrnn~n
snonnt whereof the plaintiff at present uhhhown'
There are also outstanding against the oohpany Jus
meuts unpaid and unsatisfed but " "n.' a'oun' 'H'
nialntir Is not at present advised. a, - ,o-, ,o,,.,,
Ttr directors Of the Company in the year 1873 peev
An IN he for the OF the Company 80 10 49,
hsssef a large amount Of stock In companies owning
scaed coal Lands In the State d Pennss Yah,a, pa az
m the whole about the sum OF %, "a
nich amount 81 $40 % applied TO the purchase
NJ said stock balance 1861 ISL d. was
% ~t xpuses incurred by said Companies III the man
asernept aud development OF the same Inc rtoc ~
nirchased is at present source OF revenue MoIc
alla AT
we're uIra ptres-in violation OF the charter % lAe com
many and that such purchase constitutes Jhst gouo
Tor the forfeiture thereof -. o.,
In the month Of May 1874. the directors Oh te oon
pany In order perfect and control thio ,lc e.,
rraiIad from the City OF Ncw-lOf 10 the Cay Oh Gil
raso ia the siatc Of Illinois, entered in;N all are
mnnt with the Atlantic aud Great western HA.io"a