Kansas City journal. [volume] (Kansas City, Mo.) 1897-1928, 1897-04-07

Nall. and the attorneys for the said Sallie
E. Hilmon well knew that this plaintiff
entted to- connue its afa Guy hnf In The stat
| of Kansas, and to receive certificate OF
authority from the said McNall. as super
intendent of insurance of the said state of
| Kansas. for the year ending February 2S.
| 1895, the said Webb McNall, for the pur-
pose. aforesaid. and for the purpose of in
| timidating this plaintiff in the, defense of
| said action. and coercfng it to pay said
| fraudulent claim. did then and there, un-
arbstary PSt 1PPrsssvey re and
SO doing, refuse to issue to this plaintiff
such certificate of authority TO continue
| its business in the state of Kansas as
| among other things. to be published in the
newspapers statement in substance as
Topeka. Kas., March g. 1897.
=" John E. Lord, General Agent Mutual
Life Insurance Company, of New York.
dear Sir:-Replying TO your request
| for license to do business in this state for
the i ensuing year, after d i. you had had filed your
| the sum of 800 in payment of fees had been
rendered to this department; | will say that
dealt fairly with the plaintiff. Mrs. sallie
+. Hillmon, in refusing to pay the death
loss and in the litigation of the same, per-
tanning to her deceased husband; hence,
| this department refuses to issue to the
Mutual Life Insurance Company. of New
for the ensuing year. Your check in the
sum of 800 is herewith returned. Very
| respectfully, WEBB M'NALL.
Superintendent
This plaintiff further says that there
after. on or about the = day of March,
further minimizing this piaintiff p1e in the
defense of said fraudulent claim and in
ducing, coercing and compelling it to pay
TO arrest or cause to be arrested and pros
ecuted; any agent or officer of this
plaintiff who should do. or attempt to do.
any business for it. in any. manner. within
the state of Kansas, and for the purposes
aforesaid did aver and state that should
it, this plaintiff, attempt TO do any busi-
ness in this state, that it should never as
long as he, the said McNall, was slperin-
tendent of insurance of the state of Kan
sas, receive any certificate to do business
In the state of Kansas. but he would drive
this plaintiff out of the state and ruin and
destroy its business therein.
That. by reason of the. wrongful and
oppressive acts of the said McNall. as
aforesaid. by refusing the certificate afore-
TO, the amount of $4,000 in this among
other things. to-wit: That by reason of
said unlawful acts of the said McNall. it
was unable TO do any business in the state
of Kansas from the Bird day of March, 1897,
and that the profits on the new business
procured and done in the state of Kansas,
from said Srd day of March. 1897, had it
not been for said wrongful acts of the said
this plaintiff to at least $4,000. That. by
reason of said wrongful acts, this plaintiff
was compelled to support and maintain at
great expense. to-wit, at the cost and eX-
pense of the sum of 5000, a large number
of agents and agencies already established
In the state of Kansas, who weie by the
unlawful acts of said McNall, prohibited
and prevented and intimidated from doing
business for this plaintiff from the said
time in the said state. That the unlawful
acts of the said McNall caused a large
number of policies in plaintiffs company
10 lapse, to its great damage, on account
thereof in the sum of 5000. That it was
otherwise damaged, by reason of the un-
lawful and lawful acts of the said McNall,
to the extent of 50, 900.
That, by reason of the said wrongful
acts of the said defendant. Webb McNall.
as aforesaid, the conditions and covenants
of said bond, Exhibit a. have become
broken, and a cause for action has accrued
thereon TO this plaintiff against the said
defendant. McNall, and each and all of the
sureties on said bond, and they. and each
of them. have become liable to the plaintiff
for its damages as aforesaid sustained and
alleged.
Wherefore. said plaintiff prays Judgment
against the said defendants. and each and
all of them. In the sum of $50. 900. alleged, as
aforesaid, and for costs of this suit.
GEORGE J. BARKER,
.'E. +. WARE,
WILLIAM r. SMITH,
-. W. GREEN.
Attorneys for Plaintiff"