Pine Bluff daily graphic., 1894-09-10

retained out of any sum of money
 that may be or become due to said
 water company from said city.
 VI. The plaintiff. farther ayers
 and charges that the defendant. Pine
 Bluff Water, Gas and Electric Light Company, and it's predecessors, who have owned and operated said
 water works, in'satd city, since the date of it's completion, have, in tvio- lation of said ordinance and con tract, persistently failed. neglected
 and refused to keep all fire hydrants
 rented to the plaintiff (pIafntiff is
 now renting 1SS hydrants) supplied
 with water, and maintained in effect
 ual working order, and have neglect ed. failed and refused to supply or furnish the plaintiff effective fire streams for the extinguishment of fires and for flushing water closets and gutters in and through said city; and havp refused to allow the chief of the fire department of said city to have control of the fire hydrants by dismantling the same and rendering them for great period of time. so that the city could not in any man- ner use them. and by shutting off the fire pressure. from said city; and have failed and neglected as in the contract proceeded to furnish at all times gratiutous water =sf6rs four drinking fountains for man and beast at four public places in said cityi and have neglectedS failed and refused to furnish the said city of Pine Bluff and the. .iahabitants there of, 2 sufficient + supply Of water pumped from wells bored or driven in the. ground; and have neglected, failed and refused to furnish the said city Of Pine Bluff, and it's inhabitants from such wells water clarified by settlement or filtration for public or private uses, which water the said city ahd its inhabitants then and there needed for public and private uses, and of which needs the water company were at all times duly and lawfully notified And hare neg lected, failed and refused, after said water works WAS completed and in operation, to furnish a supply of water for both domestic. and fire purposes for more than thirty days, and in fact SD failed for months at tfme. and do now in this respect make default to the great danger, damage and WrOng, veXation and annoyance of said. city and it's in habitarits and consumers Of water.
 And the plaintiff further ayers and charges that the water witch has been furnished the plaintiff and con sumers and inhabitants of said city, though a scant amount and az times none whatever, was not clarified by settlement or filtration. and oft times and now the plaintiff and inhabit-- ants of said city have been compelled to receive from the hydrants and mains, water unfit for'domestic and private nses. being almost or duife black. so the plaintiff charges that the.said water works company per sistently, wrongfully aud in viola tion of the intent, provisions, con- ditions and agreements of said or dinances and contract and against the vexpress requirements thereof, furnished the said city and the in- habitants thereof, with unsettled unfiltrated and unwholesome water. That the water now being furnished the inhabitants of said city by de- fendant and which has been so fur nished for a long space of time, isnot settled, clarified or filtered, neither is it wholesome, and is at times pos, lively unfit for domestic purposes,
 VIE Plaintiff further avers that the defendant and it's predecessors in failing Q cffectually operate and maiAtaip.its. YA,ter works iii said city of Pine Bluff, for q long continu- ous period of time and now, have in- fiicted upon the plaintiff and. inbab itants of said city by willfullX and. negligently violating its said con tract, q serious wrong and injury in this; in its failure to.furnish sufficient streams of water for eXtinguishing fires, many business houses and buildings. .as also hotels and priSa tx, residences in said city have been burned And on many occasions the water pressure was so weak and intellectual that the fire department of the plaintiff failed to cause water to be thrown into the second story of ali ordinary building, and neta- bly in the case-o: the burning of the Gallagher House. the water pressure furnished by the water company for the extinguishment of this fire was so low and intellectual that it'was not thrown but little beyond the end of the hose. And as to domestic ser- vice occasions have been numerous
 when the water could not be had in the second story in buildings in the city and consumers have often been compelled to suffer the dust of the