Richmond dispatch. [volume] (Richmond, Va.) 1884-1903, 1886-07-23

pected 70 WlthdraW tpeir patiohsSe
from those whose names appear on that
list.n
That there is . certain secret society
in the city Of Richmond called the
Knights of Labor, which has branches
in other parts of the State that this
society numbers several thousand MEM
bers in the city Of Richmond; that the
said w. II. Mullen is an officer OF sod
secret society Of very high rank that
there are o.her trades unions in this
city, which embrace large numbers OF
members that said secret society and
said trades unions are greatly ia.
fluenced by the publications of said
Labor Herald, and almost every
member Of each refuses to deal
with any person whose name is put
upon said "Black List" that your
orator believes the said Mullen, Healy,
Jones, and Lewis will continue to pub
lish bis name on each Saturday in said
"Black List" unless enjoined there
from, and that in so doing they are en-
deavoripg to destroy your orators busi-
ness as a commission merchant, and
your orator believes they will thereby
deter persons from trading with him
that in driving your orators customers
away from him they are doing him an
irreparable injury, for which no ade-
quate compensation can be recovered at
law.
That by eDjoiniDs the said Mullen,
Hcaly, Jones, and Lewis from publish
ing your orators name on said Black
List" only your orator will not receive
complete relief for the following req.
sons
They have published your orators
name in each Saturdays issue Of said
Labor Herald for thirteen weeks, and
thus many persons have come to know
that your orator is under the censure
end ban of those who have established
the boycott Of Baughpan Brothers. So
long, therefore, as said committee, CON-
posed Of said Crump, Wilde, and Shell
ton, declare said boycott Of Baugbman
Brothers to exist, all persons who know
that your orators name has beer on
said " Black List" and all per-
sons who know that your ora
tors name is not on said "Black
List" merely because the Court
has ordered it to be stricken off know
also that your orator remains under the
ban and cersure Of those who estab-
lished said boycott, and they will be
deferred from dealing with your orator
as efeotually as though his name ap-
peared on said I" Black List" and the
same is true Of the continued publica.
tion of any a" Black List" If the said
Mullen, Healy, Jones, and Lewis are
permitted to continue the publication Of
any Black List" it only calls atten-
tion to the fact that your orators name
is not on the same because the Court
has ordered it to be stricken off, and
for that reason only, and it only en-
pbasizes the fact that your orator
is under the ban and censure
of the boycotters, and would do bin
greater injury than for his name to be
left on said "Black List" And the
said complainant alleges that he is law
fully entitled to trade with the said
Baughman Brothers, and to buy from
and to sell to them any goods, wares,
and merchandise that he or they may
desire to buy or sell to each other, and
that without being interrupted by the
said defendants in any manner, and
particularly by the said publication Of
the " "Bleck List" aforesaid, and the
announcement that the said firm Of
Bsngbman Brothers is "uoycotted,"
which serves the purpose, and is in
tended to servo the purpose, OF de-
priyir 6 this complainant of the custom of
a large class of his customers, and to
punish him in that way for trading
with the said Baughman Brothers, as
he has lawful right to do.
The complainant further alleges that
he is Iemediless at law, for it would be
impossible for him to show at law what
number Of customers, however great,
he has lost by the conduct of the de-
fendsnts, and that it is to avoid mul-
tiplicity of suits that he brings this suit
in equity. And the said complainant
shows and alleges that his said busi-
ness as commission merchant is
worth much more than $500, and
that the said boycott" threat
ems to destroy it entirely. Your
orator shows, therefore, that he cannot
obtain complete or efiectual relief un-
less the Court shall enjoin said commit
tee from making declaration that said
firm Of Baughman Brothers is boy
cotted," and unless the said Mullen,
Healy, Jones, and Lewis are enjoined
and restrained from making any publi-
cation that said firm Of Baughman Bro
theirs is "boycotted," and from making
publication of any Black List" at all.
In tender consideration whereof your
orator prays that the said W. F.
Crump, G. W. Wilde, j. NJ. Shelton,
William ii. Msllen, James A. Healy,
Perry Jones, and John N. Lewis be
made parties defendant hereto and re-
quired to answer the same on oath;
that the said Crump, Wilde, and Shell
ton may be restrained and eDjoined
from making any publication or decla.
ration whatever that the said firm of
Baugbman Brothers is 4" "boycotted ";
that the said Mullen, Healy,
Jones, and Lewis may be re-
strained and enjoined from making
any publication in said Labor
Herald, or in any other place that said
firm of Baughman Brothers is "boy-
cotted," or from advising or counsel
ling in said Labor Herald that said firm
shall be boycotted ~; that said Null
len, Hesly, Jones, and Lewis may be
restrained and enjoined from publish.
ing in said Labor Herald or else where
said I" Black List" or any other list Of
the customers Of Baughman Brothers;
that they may be restrained and en-
joined from publishing your orators
name in the future on said Black
List" or from publishing it in any way
for the purpose Of deterring his GUS