The Laurens advertiser. (Laurens, S.C.) 1885-1973, 1902-01-22
tive under the Constitution and laws of
the United StatnR i'm that

the United States. in that
First. The said Acts undertake in
contravention OF Section 8, Article 1, of
the Constitution of the United States,
and The Acts of Congress in pursuance
thereof to prohibit and render invalid,
null and void all arrangements, con-
tracts, or agreements whatsoever be
tween persons, firms or atoms,
which intentionally or unintentionally
tend to lessen full aud free competition
in the Importation or sale Of articles i'm
ported into the State or in the manufac-
ture or sale Of articles Of domestic
growth or of domestic raw material.
Second. The said Acts undertake in
contravention of Section 1. of Article
XIV, an amendment of the Constitution
of the United States, to prohibit and
render invalid, null and void all arrange.
ments, contracts or agreements whatso.
ever between persons, firms or corpora.
lions, which, Intentionally or uninten.
tionally, tend TO advance, reduce or con.
troll the price or the cost to the producer
or to the consumer OF any articles i'm
ported into the State or manufactured
or grown therein.
Third. The said Acts undertake in
contravention of Section g., Article /, Of
the Constitution of the United States,
and the Acts of Congress in pursuance
thereof, and of Section 1, Article XIV,
in amendment of said Constitution, to
prohibit and rende invalid, null and
void all arrangements and contracts be.
tween persons, firms or corporations that
may Intentionally or unintentionally
lessen or affect in any manner full and
free competition in any tariffs, rates,
tolls premiums or prices in any branch
Of business, trade, or commerce. or may
seek TO control the same.
10 A,S tls, Joco~J,-k fx.---
and alleges that in and by the public
laws and statutes Of the State Of South
Carolina, to wit, Chapter XIV, Sections
l,465 and 1,471 of the Revised Statutes
OF 1893, 1t was declared Iby the State of
South Carolina that foreign corporations,
duly incorporated under the laws of any
State of the United States, would be per
United tn locate and carry on business
in the State of South Carolina in like
manned as the natural born citizens of
the states of the United States might do
under the law existing at the time, and
that any such foreign corporation carry.
ing on business and owning property in
the tate of South Carolina should en-
JOY all the privileges and immunities of
owning property and carrying on bust
ness in like manner as individnAle, nat
ural born citizens of such States OF the
United States and as domestic corpora.
btOhS luCOI pOId GU III Inc Sta,S OI SOuth
Carolina might do. That in
of such public laws and statutes this dc
fendant entered the State Of South Caro-
lima and purchased and acquired prop
erty and carried on business therein, but
has only acquired and carried on the
same as natural born citizens of tn.
States Of the United States might do
and as domestic corporations OF the
state Of South Carolina might do, and
L tl.of utrnh 10 A.l a.. 1T aL--
in given, when accepted and acted upon
by this defendant constituted a con.
tract between the State of South Caro-
lima md this defendant, which the said
State of South Carolina has by its said
Acts referred TO and set forth in the
tenth article OF said complaint sought to
imp ir and violate, against the provisions
of Section 10, Article |, of the Constitu
ton Of the United States.
20 And this defendant further shows
and alleges that in and by the said Acts
referred to in Article 10 Of the said com
plant the property rights of this defend
ant in he State of South Carolina, &C
CURED in pursuance of the invitation to
and contract made with this defendant,
by said public laws and statutes refer
red to in Article 10 of this answer, are
made subject to impairment and destruc
ton at any time If this defendant should
mako any, arrangement. contract or
agrt ement which should unintentionally
have the effect of in any wise tcndingto
advance, reduce or control the plico or
cost to the producer OF the consumer of
any article imported, manufactured of
grown in this State, or tending to lessen
full and free competition in the i'm.
portation or sale Of the same, or
of in any wise affecting full and free
competition in any tariff, rates, tolls,
premiums or prices in any branch of
trade, business or commerce wherein
and whereby said Acts referred to in
said Article 10 of said complaint have
impaired said contract, and have further
abridged the rights, privileges and i'm
munltles so by contract granted and
! given to this defendant, and sought to
further deprive his defendant of it's
property without due process Of law
and to deny to this defendant the equal
protection of the laws of the said State
of South Carolina, in contravention of
and of Section 2, Article Nv, of the
Constitution Of the United States, and
Of Section 1, Article XIV, of the ar.
ticles in amendment ssof said Constitu.
ton.
81. And further answering, this de.
fendant alleges and shows that the said
Acts of The General Assembly referred
10 In hrtlcle III OF SAID complaint are null
and void, and imperative as in contra |
v~ention Of Sections o and 6 OF Article 1
of the Constitution of the State Of South |
Carolina, in that the said Acts abridge |
the rights, privileges and immunities of |
this defendant and deprive it of it's prop
erty without due process Of law and
deny TO this defendant tho equal protec
ton of the laws and impair the obliga
ton OF tho contract 30 entered into with
this defendant, as hereinbefore In this |
answer more specifically set forth and
alleged
Wherefore defendant prays that said
complaint be dismissed. 1
State Of New York, County of N,wf
York Personally appeared Samuel Il. /
Morgan and, having been duly sworn,
made oath that he mas read the forego.
ing answer, and thai IT, same is true to
ais own knowledge, except as TO the
matters therein stated on information
nd belief, and as TO such matters he
believes IL to he true
Deponent further saith that tho said
Virginia Carolina Chemical Company is
a corporation, and that deponent is an
officer thereof to wit, president.
SAMUEI II. MoRaAN