Savannah morning news. [volume] (Savannah) 1868-1887, 1881-11-11


the intent to remove and deface and destroy
the tombs and grave stones and graves
In large part of the Cemetery OF your ora
tors so dedicated as aforesaid. to wit: a space
about ten feet in width by two hundred and
ten Ieet In depth, and would have so mutt
lated and desecrated and destroyed the same
had they not been restrained by the tempo
rary restraining order OF this Honorable
Court; and they still threaten to carry out
their Illegal purpose unless restrained by the
order or this Honorable Court, to the irrepara-
pie INJURY or your orators and those whose
dead are buried In said portion Of the ceme-
terry or your orators, and in whose behalf, as
well as their own, your orators have fled this
their bill
And your orators charge that all the pro-
ceedings and threatened actions of said the
Mayor and Aldermen Of the city of Savannah
are not only without authority OF law. but in
utter and reckless violation of and defiance OF
law.
and your orators pray that the said the
Mayor and Aldermen Of the city Of Savannah
and their servants and agents NAV be forever
enJoined from pulling down said walls and
grave stones, and from in any manner
dlverting any portion Of the cemetery OF
your orators from the purposes of its original
dedlcAtlon. and from converting the same or
any part thereof into highway, or extending a
pavement over the same, or any part thereof.
and that your Honor will grant temporary
restraining order until the questions arising
in this cause can be fully heard aud sdjudicated.
nave adequate remedy in the premises, save
in court Of equity, in which such matters
can alone be properly heard and determined,
and to the end that the said the Mayor and
Aldermen Of the city of Savannah and their
agents and servants may be forever enjoined
as above prayed for. May 1t please YOUR
honor 70 grant unto your orators the States
writ of Injunction to be directed to the said
the Mayor and Aldermen or the city OF Savan-
nah restraining them and each OF them and
their agents and servants as above prayed for.
And z.or s% - -
your orators the States writ of subpoena to be
directed to the said the Mayor and Aldermen
or the city of Savannah commanding
them and each of them at a certain
day and under a certain pain therein to be
limited, personally to be and appear before the
Honorable the Superior Court to be held in
and for said county on the first Monday of
March next, and then and there full, true, d.
rect and perfect answer make TO all and singu-
lar the premises, and further to stand to, abide
and perform such further and other direction
and decree therein as to the court shall seem
meet. And your orators pray your Honor to
grant to your orators such other and further
relief in the premises as may be consistent
with justice and equity.
And your orators expressly waive discovery
from the said the Mayor and Aldermen OF the
city of Savannah. And your orators will ever
pray, etc. r. FALLIGANT,
WALTER q. CHARLTON,
Complainants Solicitors.
GEORGIA. CHATHAM COUNTY.-Personally APP
peared Robert H. Footman, who. having been
duly sworn, deposes and says that
the facts set forth in the foregoing
Till Of complaint, so far as they relate to
his own act of deed, are true Of his own
knowledge, and so far as they relate to the
act or deed Of any other person or persons, he
believes the same to be true.
Subscribed and sworn to before me this 9th
day Of November, 1881.
EDWARD F. MELVILLE.
Notary Public, Chatham County, Ga.