Dodge City times. [volume] (Dodge City, Kan.) 1876-1892, 1884-03-27


third class duly organized under the laws of the
State of Kansas. That plaintiff does now and has
for the two years last past owned and maintained
hotel upon the lots described as aforesaid lex
cept portion of that time not to exceed one year
during which time said hotel was rented) has oper-
ated and run said hotel himself and now owns
maintains and operates hotel on lots 10, II and
Is as foresaid and is erecting lots II and u
aforesaid stone building 50 50 feet in size to be
complete within the next 90 days, and when SO
completed to be used and occupied by this plaintiff
as hotel for the use and benefit comfort and con-
veuience Of this plaintiff and the general public
Plaintiff further elbows that the defendants,
Thomas 9. Nixon and o. A. Bond arc now and have
been for more than two years last past the owners
OF lots no. 10 and 20 on Locust Street in said Dodge
City, and within the coporated limits thereof to-
getber with the buildings thereon situate. Said
lots and buildings so belonging to the defendants
as aforesaid, being and situated seventy-i feet
west OF the hotel and lots described aforesaid as
belonging to the plaintiff and upon the same
street
Plaintiff shows that in order, fiat he may prohta-
bly, and successfully maintain operate and carry
on his said business of hotel keeper at the place
and in the manner as aforesaid it is absolutely
necessary that the neighborhood in which it ia
situate shall be quiet and the people thereof order
ly, respectable and law abiding citizens
Plaintiff shows that during all the time he has
owned, operated and maintained said hotel as
aforesaid it has been first class in its appointments
and except 80 far as II has been affected by acts
of defendants hereinafter mentioned respectable
in character.
Plaintiff shows to the court that the said defend
ants we'll knowing the premises but wilfnlly in
tending to vex and harass this plaintiff and
wilfully and maliciously intending to iniure and
damage this plaintiff in his said business Of hotel
keeping are now and have been for over two years
last past unlawfully, maiciously, persistenty and
wantonly maintaining nuisance in and upon the
said lots described aforesaid as belonging to
said defendants and in the buildings situate there
on to the great annoyance and damage Of this
plaintiff in tOwit that the said defendants have in
said buildings for the two years last past openly
VIGOROUSLY, continually, unlawfully, persistently
and maliciously sold Intoxicating liquors which
has during the last two years been known to the
OK and present sheriff of Ford county, Kansas, up
to this time, and that legal steps was taken by
the former sheriff and none have been taken by
ing them arrested and dealt with according TO law
and said place abated as nuisance and that said
sheriff has publicly declared that he will not in
forCi upon the persons engaged in violating the
prohibtory law. That defendants further con-
irving and maliciously intending to injure and
damage the plaintiff in his said business of hotel
keeper are now and have been for more than two
years last past maintaining gambling house in
said buildings go described as aforesaid as belong
ing to said defendants in that they have set gam
bling tables and gambling devices of various kinds
and permitted them to be set up in said buildings
during all of which time great many persons
have engaged in games of chance for money.
Plaintiff further shows that defendants further
contrive and wilfully and maiciously intending
to injure and damage this plaintiff in his said bust
ness Of hotel keeper have for more than two years
last past In and upon said lots and in said buih-
ings SO described aforesaid belonging to said
defendants, openly, VIGOROUSLY, continually, I'M
lawfully, persistently and maliciOusly maintained
a brothel or bawdy house, and what was known
as, and commonly called dance hall until De-
cember ], 1885,, where large Numbers Of lewd women
lascivious men are invited by defendants, and con-
gregats, ard stay, and there m said building on
said lots, dance, drink, get drunk fight stab. cut,
shoot &c. That said defendants furnish rooms in
their said buildings to many Of said lewd women,
knowingly, for the the purpose of plying their vo-
cation Of prostitution and said rooms were 30 used
By said lewd women to the knowledge of the de-
PENDANTS.
Plaintiff further shows that since the said first
day of December, 1883, said nuisance has been
operated and carried on, as before
stated, by the said defendants, except that dane
ing is not so frequent, but none the less severe.
Plaintiff further shows that said lewd women
cOngregate in front of defendants said building,
and there demean themselves in lewd and las
civious manner in plain view of plaintiffs hotel
That great noises and connections are made in |
and around said buildings of said defendants, by
said persons there staying and congregating and
that loud and vulgar language is often used, and
cures comminged with the cries of women are Of |
common Occurrance and plainly and distinctly |
heard by plaintiff and his patrons at plaintiffs |
said hotel.
Plaintiff avows that the city authorities have |
been cognizant Of said violations of law by said de-
|endants, and have made efforts to suppress |
them, but have received and accepted voluntary
contributions from persons violating the laws |
in amounts as follows: The prostitutes, s. per
month; gamblers, $40 per month for selling
liquors and maintaining saloon, $40 per month,
hat for which said sums the city, by its officers,
protect the persons so violating it, and further,
hat said city has failed and neglected to pass any
ordinances or regulations to suppress or abate
lonses Of ill-fame within the limits of said CITY,
Plaintiff further says, that many Of his custom
and ,,ofro 1oft r
he acts Of defendants, complained of, and many
'thers that would have patronized him, have been
Iept from so doing by said, and account of said
that plaintiff is cognlzant of, and many
lave been kept away, IS plaintiff believes, who are
lot known to plaintiff and that plaintiffs proper
y is decreased in value by reason Of and on ac-
count Of said nuisance.
That plaintiffs wife has been denied the social
COMFORTS of life, for that many of the respectable
aides within her circle have declined to call on
Ter or visit her, by reason of the close proximity
4 said nuisance, so maintained by eaid defen-
ants, whereof, plaintiff says that all the acts Of
he defendants herein complained of, have been
nd are being done at the same time, and in the
anne buildings CONFORMITY together, and that by
eason Of the premises, and in consequence Of the
rievances SO committed by said defendants, his
BUSINESS is being daily injured, and that he is con-
inualy sustaining irreparable loss.
That said defendants will continue this said nui-
anse in future, to the hoss and injury Of plaintiff
not prevented, wherefore, plaintiff prays judy
nent for damages in the sum Of fifteen hundred
oliars as his damages, and further prays that
his honorable court, as he has competent and
dequate remedy at Law, that a temporary injunc-
ion issued restraining the said defendants from
urther carrying on said business and maintaining