Capital journal. (Salem, Or.) 1893-1895, 1895-11-15

fnsht N, ~ ihs smuaf N a. f0g
Tbsl lhsfs sfs elsesa g0istsndins
wbiob bsys bsss drawn by the ds
fendsat corporation gn Ne ifsasafsf ~
ths smouBi N sboat t2,tg saslest
faBds which tbe sofpsrsslon hsd os
deposit with NJ treasurer. 0sofgs WI.
lIsms, and which Wy The treasurer wss
deposited IN the bsukisg oompany of
Williams a Eseiabd, which ssld vii
lIams A Eagisod Banking compsny
has suspended payment, and by fsason
~ such suspension the said checks will
not bs paid snd the funds of the
defendant corporation ~ the amount of
", 400 on deposit with said Williams
a England Banking company cannot
be- made svaIIAble for paymsst " any
u the liabilities of the corporation.
That the said corporation has no
caah on hand TO meet the dsmsnd
made on II on account Of said losses
aud judgments. aud the said corpora.
tIon ia unable 10 pay the same or any
part Of them.
That the said corporation has no
means by which II can raise money TO
meet said demands without pIedging
some Of lts property which IL cannot
do at this time, aud which cannot be
legally done without violating the
laws Of the state Of Oregon and lIcens-
Ing Insurance. companies, Inasmuch as
the pledging Of said property would be
an impairment Of the capital stock and
re- insurance reserve OF the defendant
corporation.
That on account Of the financial de-
preston existing at the present time,
the defendant corporation Is In fact,
now lnsolyent, or In imminent danger Of
insolvency.
That the said corporation cannot, for
want Of money, pay its obligations,
which are now due, and payment Of
which has been duly demanded, and
cannot meet Its obligations, which are
maturing.
That said defendant corporation can
not legally continue to accept insur-
ance risks, or receive Insurance.. premi-
ums.
That on this date the manager and
officers of the defendant corporation,
on account of It's insolvency have
refused to continue the business Of the
corporation and haYe declined to ac-
cept any further fire insurance risks or
premiums for new business.
That on account Of the inability of
the defendant corporation to meet Its
obligations, and on account of the
judgments now outstanding against
said defendant corporation. That 1t is
necessary that some person be ap-
pointed by this court as receiver of
the properties of the defendant corpo-
ration. to take charge of its properties
and collect the same, and pay Its out.
standing Indebtedness.
That unless such receiver is ap.
pointed the property Of the defendant
corporation will be subject to seizure
upon execution, and upon numerous
attachments, and the same will be lost
to this plaintiff and other stockholders
who may choose to become parties to
the suit and contribute to the expenses
thereof.
Wherefore, this plaintiff on behalf Of
himself and other stockholders of said
corporation prays:
That for the purpose Of preserving
the properties Of the defendant corpor-
alton for its creditors and the stock
holders and as well for the protection
OF the rights, interests and properties
of defendant, and to secure as far as
possible the performance of the duties
which said company owes to the pub
lie as fire insurance company as we'll
as to preserve the business and prop
erty from loss by separate execution
and attachments, that the court forth
with appoint receiver Of all and sim
gular the property, rights, assets and
franchises of every nature and where
soever situated, held, owned, or con-
trolled by said corporation, together
with all leasehold rights and con-