Pine Bluff daily graphic., 1894-09-10
SUIT FILED .,ap POSSESSION OF THE WATER WORKS.
  1 thorough Review ot the Diff ferences Between the City: and the
 Company.
Fult Text of the Complaint of
 Plaintiff.

Iu.pursuaHce Of instructions of the s4fy l0uncil. Austin X Taylor filed saif against the Pine Bluff Water, n. Gas and Electric Light Company in A the Jefferson Chancery court last : saturday. afternoon. Me print the complain in full, which is as follows: Iv TIE JEFFERSON CHANCERY GotRT,
 JANUARY TERM, 1895 Yhefity of Pine Bluff, Plaintiff.
 YS.
 Pine Bluff Water, Gas and Electric Light Company, Defendant.
 COMPLAINT.
 Tn plaintiff, the City of Pine Bluff, states that tis municipal eorpo- ration in Jefferson county, Arkansas, Incorporatea and organized as pro- Yialea under and by virtue of the laws of the State of Arkansas, and that the attendant, the Pine Bluff Water Gas and Electric Light Com pang, is a foreign corporation ere afed. organized and existing under and hy virtue of the laws of West Yirginia, and doing business in said eitt and State, and under thestatute laWs of the State of Arkansas, have nanled, constituted and appointed one NJ II Johnson. of the city of Little Rock, Arkansas, as a person upon whom legal process issuing against it may be served.
 Inc plaintiff further states that on ihe l7th day of January, 1887, by Firtne of an ordinance duly and legally passed and adopted by the sltg Council of the said city of Pine Bluff, and by virtue of an ordinance anending the same, which was duly and legally passed and adopted by the the said City Council on the 9th aay of March, 1887, it entered into a certain contract with the Water, Light and Power Company, of........ .es, corporation then doing busi- ness in said city of Pine Bluff. ana which was organized and incor- pofated under and by virtue of the aNs of the State of........................... lef the purpose of establishing, main sallllhg and operating water works Whhin and near the said city of Pine tlpfi, to the end that said city of pine Bluff and it's inhabitants could pfeeure water for public and private uses.
 That the said ordinances were duly ana legally accepted by the said Water, Light and Power Company as contract between it and the said pFllhtlff, as was therein provided and Iequred. And the said city of Pine pun duly and legally agreed and feepted the same on its part as was 'nefcln provided and required.
 ne said ordinances and contract " entered into and agreed to by and netween the plaintiff aad the said Nater' Light and Power Company 'ss as follows, to-wit:
 
 Here the complaint sets out in full soe contract between the city and 'ne water company.)
 
 ne plaintiff further states that ''aer and by virtue of said ordinance ahs contract, that the said Water 'sht and Power Company, having , urea thereby the privilege o s'abllshing and maintaining anf peratlhg water works within anC pe$f the city of Pine Bluff for n tern years and for such purpose tht 'slit 10 use the streets, alleys, side alks and public grounds of said cit, v rlHe Bluff, within it's present anC 'tufe corporate limits, for placing s"Nihg up and repairing mains ,s ufahts and other structures an( pe'lees required for the service o aa'ef and water works, did, in sait 1ss construct, build, erect and pu
 operation a system of wate morEs' and for such purpose hay Aereised and enjoyed the privileg san'ea to it under said contract b, s',S the streets, alleys, sidewalk t, u public grounds of the plaintiff VI placing it's water mains 1sarants, pipes and other structure -'iu devices requisite for it's serylc au ehat it aud its successors an,