The Daily Ardmoreite. [volume] (Ardmore, Okla.) 1893-current, 1895-04-11
THAT DAMAGE SUIT.
The Complaint Filed By wnssn n
Brown Against tAs ArdmOrsitS
ct al. His Modest Estimate.

we publish the complaint of Wilson |
Brown, one of the plaintiffs. The
complaint of Edward Brown, the
other plaintiff, is for a like amount,
and is Identical with the following:
United States of America, the Indian
Territory, Southern Judicial Dis
trict-Ss.
In the United States Court, in the
Indian Territory, Southern Judicial
District at Ardmore.
Wilson II. Brown, plaintiff VS.. Solo
mon E. Jackson, Charles ID. Carter,
F. E. Wilson and r. S. w. Parker,
defendants, complaint at law.
Wilson III. Brown. a citizen Of the
United States of America and resi-
dent of the Southern Judicial Dis
trict of the Indian Territory, COM
planning of Solomon E. Jackson, a
citizen OF the United States Of Ameri-
ca, Charles d. Carter, member of
the Chickasaw Nation of Indians, F.
L. Wilson and r. S. w. Parker, citi-
zens of the United States OF America,
all residents of the Southern Judicial
District of the Indian Territory, for
cause Of action says:
That heretofore, tO-wit, on the 22d
day of March. 1895, plaintiff, Wilson
ii. Brown, was and for long time
prior thereto had been member Of
the firm of Brown Bros, firm COM
posed of Wilson II. Brown and Ed
ward Brown, conducting and manag-
ing the Wisn0r Hotel in the town Of
ArdmOre, Indian Territory.
That F. E. Wilson and r. S. w.
Parker, on said last named date and
for a long time prior thereto, were
/ partners engaged in the editing, pub
fishing and circulating Of a certain
daily newspaper in Ardmore, In
Ian Territory, known is the ARD
MOREITE.
That said firm OF Brown Bros. about
June 10. 1874. made and entered into
contract with the defendants,
solomon T. Jackson and Charles ID.
! Carter, contracting, renting and leas-
iag from them for the term of three
years, the WiSnor Hotel, in ArdmOre,
Indian Territory; that in pursuance
Of said contract said firm of Brown
Bros. enter into, upon and took pos
session of said hotel, and since said
date have conducted and operated
the same in compliance with said
contract; that during the time said
firm Of Brown Bros. conducted said
hotel, the same was a paying invest
ment and profitable to them.
Plaintiff AYERS that the defendants,
Solomon <. Jackson and Charles ID.
Carter, filed in the United States
court for the Southern Judicial Dis
trict a certain action against Brown
Bros, wherein they sought to set
J aside said contract and have a re-
ceiver appointed to take charge OF
said hotel; and prior TO an opportun-
ity being afforded this plaintiff as d
, defendant therein to assert and win
dicate his rights, and before any dis
position had been made OF said suit
on the 22d day Of March, 1895, the de
PENDANTS, Solomon E. Jackson, Charlie:
D. Carter, F. E. Wilson and R. 5. w
Parker, did knowingly, wilfully
falsely and maliciously publish anC
cause to be published of and concern
, ing this plaintiff and Brown Bros. the
following defamatory and libelou.
publication, to-wit:
An application for the appointment
of a receiver for the WisnOr hotel
naming Jackson and Carter as plain
tiffs and Brown Bros. as defendants
shows the cause for a change OF the
; management of that hOstelry. Pend
Ii ing the argument on the application
a compromise between the parties To
the suit was effected. thus causing a
suspension of litigation.
The true cause Of the difficulties
between the defendants and plaintiif:
; are fully set forth and startling
state Of affairs alleged. The petition
after recitiug the terms of the con
tract charges gross violations on part
of defendants, such as Sub-lettlng
portions for public gambling purposes
: miSapprOpriauOn of funds, fdlSlhca-
tion OF accounts and neglect Of duties
1t has been known for some time that
a sDirit of dissatisfaction had arisen
between plaintiffs and defendants
but that such grave charges against
the latter have developed, created M
small degree OF surprise. 1t is under
stood that prosecutions under thu
: statutes furnishing keepers OF gamo
= ling resorts are contemplated. II
this event the people will watch th'
result with interest in order 10 se'
I whether gambling in high places L
= regarded as an offense against th'
. law.
Z That said publication was by tn
I defendants, and each of them, and b.
their procurement composed, edited
published and circulated in the DAHL
] ,,r-,,-r, , daily ncSySuapPr %