The Pacific commercial advertiser. [volume] (Honolulu, Hawaiian Islands) 1885-1921, 1901-08-16

knu fiuSCng, whose real nrSt name ID
to plaintiff unknown. but who IS sued I'M
der the name of Unkind Husting, and
whose real first name when ascertained
plaintiff prays may be inserted herein;
Tinker O'Brien, whose real fl st name Is
to plaintiff unknown, but who is sued
herein under the name Of Tinker O'Br:en,
and whose real first name when ascer-
tanned plaintiff prays may be inserted
herein; Worthless Leach, whose real first
name is to plaintiff unknown, but who is
sued herein under the name of Worthless
Leach, and whose real first name when
asceltained plaintiff prays may be in
serted herein; and John WEIGH are and
at all the times hereinafter named, they
were journeymen plumbers working at
| their trade in the City of Honolulu afore-
said.
That prior to the 9Th day OF August,
| 1901, the defendants, John Moore and
Thomas Call:han, were working for
plaintiff, and that they then left his en-
/ ployment and refused to work for him
| because of the obligations of the contract
| between the defendants hereinafter set
| forth.
| That on or about the Sth day OF Aug
ust, 1901 at Honolulu aforesaid, the de-
| PENDANTS herein, in restraint of trade and
commerce, In the Territory Of Hawaii,
rand in violation of Sec. 3 of the Act Of
| Congress referred to in paragraph l of
| this complaint and conspiring and
combining unlawfully as aforesaid, en-
tered into an agreement, in writing. by
which the defendants, T. F. Davidson, ].
N. Shafer, James Mott, Jr., E. r. Bath,
II. Gehring, w. w. Cross, A Pilas, w.
W. Quinn, w. w. Graham John H. Mott,
| w. j. England. E. Paxton and o. Sellers,
individually and as members of a certain
voluntary association of persons known
as the Master Plumbers Association OF
Honolulu agreed and promised not to
hire or employ as journeyman plumbers
any person or persons except the defend
ants, Patrick O'Donnell, Frederick Hol-
land, Frank Rickenburg, A. Kfster. John
Moore, E. Gould, Thomas Callihan, John
Doe Sullivan, Richard Roe Read, Bad
Slattery, Nogood Smith. Thomas Dixon,
Thankless Montague. Unkind Hastings,
Tinker OBrien, Worthless Leach and
John WEIGH individually and as members
of a certain voluntary association known
as the Journeyman Plumbers Union OF
Honolulu. or such persons as might
thereafter join the Journeyman Plumb
erS' Union aforesaid, and the defend
ants, Patrick O'Donnell, Frederick Hol-
land, Frank Rickenburg, A Kister. John
Moore. E. Gould. Thomas Callihan. John
Doe Sullivan, Richard Zoe Read, Bad
Slattery, Nogood Smith, Tinker O'Brien
Worthless Leach ard John WEIGH agreed
and promised not to work for any person
or firm except the defendants, T F. Dav-
, idson, ]. N. Shafer, James Mott, Jr., E
r. Bath, H. Gehring, W. w. Cross, A
Pilas, W. w Quinn, W. w. Graham, d. DIN
Mott, w. ]. England. E. Paxton. o. Sell
ers. or such persons as should thereafter
join the Master Plumbers Association
: aforesaid.
: Plaintiff further ayers that prior to the
: making Of said contract he had been 9
member of the Master Plumbers Asso
citation, and that he ceased to be mem.
Der thereof on or about the second day Of
August 1901. and plaintiff says that he
: cannot again join said association ever
if the other members thereof would cleo
him because thereby he would become
party to the contract between defendant!
hereinbefore set forth, and thereby, a:
plaintiff is informed and believes, would
render himself liable to the Grim nalF anC
civil penalties of the Act of Congress.
i hereinbefore referred to.
Plaintiff AYERS that the contract be
, tween the defendants hereinbefore SCI
forth and the act of defendants there
| uHueT injuries JIllS pIilntlu III MS DuS1
ness and infiicts a special damage upor
him in that by reason of its existence h
| is unable to obtain any of the defend.
: ants who are journeyman plumbers. tc
work for him, and is thereby unable tc
; sell plumbers goods and supplies or take
contracts or execute work, to PLAINTIFF
great damage in his business in the sun
of 5000
Wherefore plaintiff prays judgment
: against defendants in the sum of SIS OGt
being three times the amount of dam.
age sustained by him, and for his costs
and a reasonable attorneys fee herein.
THOMAS FITCH,
Atty. Ior Plaintiff.
, United States OF America, District OF
|, Hawaii, SIS:
Charles H. Brown, being first duly
plaintiff in the above entitled action, ina
he has heard read the above and forego
{ ing complaint, by his attorney subscrib
: ed, and that the same is true of his OWL
: knowledge, except as to matters therein
stated on information and belief and a.
to those matters that he believes it Il
be true.
CHARLES H. BROWN
I Subscribed and sworn to Before me
? this 18th day of August 1901.
WALTER B. MAILING,
Clerk of u. S. District Court Territory
of Hawaii
|