The sun., 1902-03-11
combination or conspiracy aforesaid may and
will be uccomplis she'd


combination or conspiracy aforesaid may and
viii be accomplished
PRAYER.
In consideration whereof, and inasmuch
as adequate relief In the premises can only
be- obtained in this court. the United States
OF America prays your honors TO order, ud-
Judge and decree that the combination or
conspiracy, hereinbeiore described - un-
lawful, and that all acts done or To De done
In carrying II out are in derogdtion of the
common rights OF all the people Of the United
states and IN violation Of IA" act OF Congress
OF July ?, 1890, entitled An act 10 protect
trade and commerce against unluwlul re-
stTaiutS and mOnOpOllcS, and that the de-
PENDANTS and each and every one OF them.
and their officers. directors, stockholders,
agents and servants, and each and every
one of them, be perpetually enjoined from
purpose of carrying out the same and, IN
addition, that the several defendants be
respectively enloncd as follow.
First.Ihat the defendants, the northern
Securities Company, its stockholders. on Gers.
directors. ENoCutiv" Committee and its agents
and servants. and each and every one Of
them, be perpctuallv cniOined from pur-
chasing, acquiring, receiving; holding. vot-
ing whether by proxy or otherviscD or iu
any manner acting as the owner OF any or
the shares Of tn" capital stock Of either the
Northern Pacific Railway Company or the
Great Northern Railway COMPANY and TINT
a mandatory Injunction may issue requiring
the Northern Securities Company 10 recall
and cancel any certificates OF stock issued
by Il in purchase Of or in exchange for any
Of the shares of the capital stock OF either
of said railway companies, surrcnderng in
return therefor TO the holders thereof the
certificates Of stock In the respective rail-
way companies in lieu OF which they were
issued
Second-That the defendant. the Northnr
Pacific Railway Company, its stockholders,
officers. directors. agents and servants aud
"a. h and every on" ot them, De perp"tualy
"njoined from IN any manner recognising or
acocrting the Northern SECURITIES Company
a. the owner or holder of any shares Of it.
capital stock. and from permitting such
company TO vote such stock whether by proxy
or otherwise, and from psyinG any dividends
signs. unless authorized by this court, and
from recognizing as valid any transfer, mort
Eagr pledg" or assignment bv such company
Of such stock. unless authorized by this court.
Ihird-lhst the defendant. the, Great
\"rth"rn kallNay COMPANY, - >lo'kh"ldcrsi
officers, directors, agents and servants, aud
each and every one Of them, b" pcrU"tuglN
"nJoin"d from In any. manner rrc"gnniug
or accepting the Northern Securities Tom
paIiN a. IN" owner or holder Of any shares
Of it, capital stock, aud from permitting
,,nch comusny to vote slie ,to'h. Mu.,ner ,,,,
dividends upon such stock to said company
or IT, assigns unless authorized by this court,
aud from recognizing a. valid any transfer,
mortgage. pledge. or assignment ny Su,h
company ol such stock unless authorized ny
Fourth-That the Individual defendants
named and their associate ~ioCkhvId"r~i
and each and every stookhuldrr- oi either ~
SAID railway companies who has exchanged
his stock therein for Ia" stock Il the Northern
Securities Company. b" each, respectively.
pcrprtually cnioiued from n any maun"r
holding. voting. or acting a. th" owner Of
any of the stock ~ TIA" Northern Securities
company. issued IN cNchsng" tor the stock
of either - the said railway cutupauic-, unless
authorized hv this court, and that man
dGtory Injunction may i--u" requiring each
of IA" said defendants 10 surrender any stock
nf th" Northern SECURITIES Company 80 40
uuir"d and held him by HIM, and dC, ,"Ii there
for the stock Of the defendant rallWa. COM
psny in exchange for which the same was
Fifth That the individual defendants
named md their a~~o'Iute stockholders,
uOu~tIrtuE With them, ~ charged 900 Para
graph Viii hereof. and their trustees, agents
every on" or them. he porpotuilly ouloiu"d
from doing any and every act or thing m"u-
toned IN -aid paragraph, or iu iuriherancr
Of tho combination or Cou~ulraDv described
therein, or intended or tending 90 place the
capital stock of the defendant railway COM
paui"s, or III" connecting railway -y-t"m~
operated bV them. or the COmpetltlNc lnt"r-
state or foreign trade or commerce carried
on by them. under tho control legal or prdctl-
cal, of the defendant, the northern Securities
COMPANY, or Of any p'r~ou or persons, or
association or CorpoTdttou, acting Tor or
IN lieu Of said company. iu N" carrying ont
Of IN" unlawful combination or conspiracy
described IN said paragraph
The luif'd States uray~ for such other
and further relief as th" nature OF the cl>"
may require nud IN" court may deem proper
in the premises
TO tho cud therefore. that ~" lnitcd
States OF America may tlfNll me 1'lItI 'N
which il h. Justly entitled in the premises.
may II poaeo your honoT- 10 grant unto u
WritS Of subpoena direct - the laid defend
ants. tho Northern Securities Company. "a"
Northern plCln" RHtlW1N Company. IN"
Great Northern Railway Company. james
mn. William tlOugh u Will. James. and
John kennedy and their H~-uClHt" stock
holders of the Great Mort h"rn RAILWAY COM
pany. aS their names WuN become known ~
complainant and the court bo advised thereof,
i pi"rpOut Morgan. Robert Bacon, tcurge
+ Baker and Daniel : Lamont, and thor
associate stockholders Of the Northern Iac.n'
Railway Company. as their names may he
come known TO complainant and the court
he advised thereof and the persons referred
to in Paragraph NH hereof, a. their names
ruuv become known to complainant aud IA"
court bo advised thereof. and to each uf them.
commanding thcu, and zach Of them, :"
appear herein aud answer but not under OATH
the allegations contained in tho foregoing
Icttiou, and ah.d" hy and perform such
order or decree a~ the court may make iu IN"
premises. and that, pending th" 'uul hearing
Of this case, a temporary RESTRAINING order
may ISSUE cuiuiuiug n" dofeuduuts and thrir
n-sOciatcS. and zach Of them, and their stock
holders. directors. oillc"r-, agents, and ser
wants as horriubrforr pr1v"d
MILTON u pyRpY,
ATTORNEY NJ tn" nit"d Stut'- for th" District
- Minnesota
pHILANBTR 4 kNON.
Ntoru"v-OonorIl Of the United Stat"-
JouN NDH,HpS,
Snlicitur-Gcncrrl of tho United States