Omaha daily bee., 1903-03-10

the writ Of injunction was improvldently
granted; that charges Of illegal conspiracy
contained in the bill Of complaint are un-
founded and disproved; that there is no
equity In the bill Of complaint; that the
injunction was Issued without notice, and
that all the material charges in the bill
are fully denied.
President Ramsey Of the Wabash and the
company's counsel began to prepare their
arguments against the answer Immediately
after it was filed and continued busily at
work all day and far into the night.
The answer contained about $4,000 words,
A synopsis follows:
Answer to Injunction.
The answer as filed is a Joint and several
answer of all the defendants named in the
PHI OF. complaint and against which the
injunction issued.
It is a specific denial that the Wabash
railway was ever a union or brotherhood
road employing excll sively union or broth
erhood MEMBERS in its. service, and also
denying that the Brotherhood of Railway
Trainmen and the Brotherhood of Loco
motive Firemen, the organizations involved
in this proceeding. ever. made any demand
or attempt to compel thu Wabash railway
TO place any restrictions upon its employees
as to their connection with any brotherhood
or union.
1t specifically denies that such organiza-
ton ever participated in any way in the
Pullman palace car employees strike I'm 1894,
as charged in the bill OF complaint, ana
admits that the Wabash Railway compny
never mde any distinction In the selection
OF It's employees as 20 whether they were
members of any brotherhood or union since
or prior to the Pullman Palace Car COM
pany employees strike of 1894.
II specifically denies all allegations in the
bill Of complaint that the Wabash Rail-
way company ever had any complaint from
Its employees respecting wages and rules
s~pective service since 1894, but states the
tact to be that the employees In the several
lines of service Of the Wabash company
have for years had grievances and differ
ences with respect to the amount of wages
PAID t ahnd the rules and regulations govern
spectlve lines Of employment.
Origin of Controversy.
That this controversy arises not only
from complaints. of members of the respec-
tive brotherhoods, but from the ranks of
the employees not members of the iespec-
tive brotherhoods involved in the injunc-
ton proceedings, and that the effort on the
part OF the grievance committees and the
Trainmen and the Brotherhood Of Loco
motive Ffremen are as representatives of
over 1.200 of the employees of the Wabash
brakemen and hremen upon its several lines
Of railway In the United States.
Tho answer states that the several en-
LIoyes engaged in the train service OF the
Wabash Railway company have frequently
presented their grievances to the Wabash
officials for adjustment and a settlement,
and tina the officers of SAID company nave
persistently refused to take up and con-
slider or discuss such grievances with the
several employees from time to time during
the last few years., or make any reasonable
permanent rules or regulations governing
the service OF their respective employees,
Of the officials of the company finally
eliminated in presenting, the grievances and
complaint to the several boards of the adj
trstment and grievance committee of the
TWO labor organizatious known as The
| the Rrnfharhnn1 nf Railway TTDinVnnn
Presentation OF Complaints.
The first presentation of their complaints
and grievances through the respective com
mittees ana boards Of said organizations
was about four months ago, and the COM
to take the matters of complaint up with
Joseph Ramsey, tr., of the Wabash Rail,
way company, and during all that period
have been granted brief interviews only
about three different times and at each In
terview they were put OF by. some alleged
excuse or other and compelled to leave
0ithout any satisfaction or definite, UNDER
standing as to what the officers Of the road
would do with reference 70 such complaints.
h defendants deny that the labor or
ganiZattons named in the bill of complaint
have unlawfully or maliciously conspired,
combined or confederated together to force
the complainsnt TO recognize such organ!-
cations as representing and controlling its
employees In all their relations with the
any attempt has been made by said Or
| CARNATIONS to compel the Wabash railroad
lines within the, United States to become
and he operated as exclusively union or
brotherhood, as therein alleged.
1t fs denied that any attempt or demand
has ever been made by said labor orsaniza-
tion or any OF it's officers to prevent the
Wabash from dealing with its employees in
respect to any difference or controversy, or
from adjusting any differences or con-
troversy directly with its employees, or to in
any way compel the complainant to dis
charge, to discriminate against or keep out
of its employ any person or employees what
soever not members of either of said or
ganizations, as alleged in the bill of COM
No Demand Is Made.
It is denied that any demand or attempt
has been made by either of the labor or
CARNATIONS upon the Wabash TO employ ex-
clusively in its service such persons as are
members OF said organization and denies
that said organization in any way unlaw-
fully or maliciously attempts to induce or
compel the said employees OF the Wabash
engaged in the operation of it's trains as
hremen and switchmen TO quit its service in
violation Of any contract or agreement OF
employment, or in violation OF its agree
ment whatsoever existing between such en-
ployes and the Wabash, or that any of the
defendants at any time or in any way IN
lawfully conspired TO attempt maliciously
to interfere with or prevent the operation
OF Wabash trains or prevent that railroad
from carrying out any of its contracts with
shippers for the transportation OF property
or in any way TO prevent the complainant
facilities for Interchange of traffic between
its railroads and other lines Of railroads
| connecting lneTeNlln.
1t Is denied that the defendants attempted
10 cOnspire to prevent connecting lines Of
railways from interchanging trafic with
and affording like facilities TO the COM
plainant as required by the interstate COM
! merce act or the United States and as re-
auired by its alleged agreements between
the complainant company and the connect
ing railway lines in respect to the same, as
therein ALLEGED.
No Desire to violate Law.
1t is denied that the defendants now
wish to compel the Wabash and its con-
Meeting lines or their employees 10 violate
the interstate act, or any agree
ment with reference thereto, or from pre-
venting the Wabash from carrying mails
in accordance with any contracts existing
between the United States and the COM
plainant, or that they Conspired to prevent
or obstruct the Wabash in the discharge OF
its duty as common carrier with respect
70 the state and interstate commerce law.
1t is denied that the Wabash Will be sub
jected TO a multiplicity OF suits and, prose-
cutions resulting in its irrcFs-eble loss
and damage by reason of any act on the
part Of the defendants, as alleged In the
bill Of complaint.
that w. G.. Lee, +. II. Morrissey, 7. r.
Dodge, c. II. wilkins OF any representa-
tive OF the Brotherhood of Railway Train
men, and John j.. Hannahan, Ilmolhy
Shea and F. w. Arnold or any repre-
sentative OF the Brotherhood OF Locomotive
Firemen. within two years past prior 10
the date OF the fling OF the bill or com
plant, or at any other time, unlawfully
and maliciousIy conspired 10 Induce several