Omaha daily bee., 1903-03-10

OF any OlneE nNmber OF SAlO employees 10
become members OF said organization, as
Is alleged, but state that they have invited
and requested certain and many OF the
employees TO become members Of their re-
spective organizations for the purposes as
set out ir che constitution and bylaws of
said respective organizations and not for
any other purposes.
Reques f. Not Unlawful.
They deny that such invitation or request
was unlawful or malicious or the result OF
conspiracy to injure the complainant or It's
employees, as alleged in the bill OF com
plant, and deny that they, together with
+. c. White, II. II, Hecox, George w. Brad
ley, J. Sell, F. g. Shepard, w. Il. Rowe,
ii. McManus and William Mckay, Charles
A. LawtCn. Frederick Englehardt, b. w.
Schafer, Charles j. Anger. c. ii. Niemyer,
A. n. Martin. J. r. Courtney, and A; M.
Jordan, as employees OF the Wabash, within
the last year or at any time unlawfully
combined and agreed with each other that
in case the Wabash refused to recognize
said labor organizations, as such, and as
controlling in all matters concerning the
complainant,s employees and deal with them
as sICh and operate its lines OF railway
within the United states exclusively as
union or brotherhood roads and subject to
the control of said organizations, with a
malicious Intent to iniure the Wabash and
its employees, as alleged, and deny that
they, would order and require the employees
OF the complainant to strike and quit the
compliments service and tie up the com
plainant's lines of railroad in the United
states or enforce such strike by preventing
said employees from returning to work or
others from taking the places. or prevent
ing its connecting lines and their employees
from interchanging traffic with complain
ant through Intimidation. fear, coercion or
other unlawful means, as is alleged.
These defendants further deny all charges
whatsoever of unlawful conspiracy, com.
.blnations, considerations or other unlawful
conniving together whatsoever or any in
tent to do or perform any Unlawful Ict or
thing whatsoever.
Deny Vain Promises.
It is denied tina the defendants recently
or at any time reported to certain OF the
wabash employees that they would get an
they represented to the complainant that
many of its employees were dissatisfied with
the wages paid and the rules and regula-
tons governing their employment but state
the fact to be that at the request OF many
OF the Wabash employees they had been en-
grievances settled and adjusted with the
wabash company and had conferred to-
grievances Jointly and insist upon a fair
consideration thereof and adjustment OF
same by said complainant for and in be-
half OF the employees they represented, and
insisted that such settlement should be
made for said several employees in their re
spective lines OF employment as a whole
and not singly and separately, as they had
heretofore endeavored to bring about.
The defendants deny that the Wabash
crease in the wages, and the notification
OF the rules and regulations governing en-
ployment without Violating its contracts
with many Of its employees and without
seriously interfering with the operation OF
It's different lines, and deny that such con-
cesslons as requested would interfere with
the wabash In the performance of It's duty
t%erstate commerce law or in operating it's
mail trains. as Is alleged.
The defendants further deny that they
ever maliciously threatened to order a
strike, put state that they did represent to
the Wabash that many of its employees had
determined to withdraw from its employ
ment unless II acceded to reasonable de-
mands and requests made by the defend
ants In their behalf in the payment of
wages and changes in rules. but that If a
strike should occur II would be a voluntary
act on the part of the employees.
1t is further denied that any attempt was
made to induce a strike by letters or cir
culars. but IL any infammatory letters or
circulars were sent out 1t was not done by
any, committee or, officer OF said labor or
sanitation or by their approval or consent.
The defendants further deny that the
Wabash is entitled to the relief prayed for
or any part thereof, and now having fully
nswered all the allegations and charges in
the bill of complaint they deny the same
and pray the same advantage as their
and separately pledged or demurred TO each
end every allegation or charge contained
therein.
Unions Voluntary Associations.
The defendants say the Brotherhood of
OF Railway Trainmen are voluntary bene-
ficial associations; that they were organ
Ted for the purpose Of uniting their mem;
intellectual standards, and for the protec-
ton of their interests and promotion of
their general welfare; 1t is the aim of the
brotherhoods TO cultivate a spirit Of har-
mony among the members upon the basis
Of equity and justice. and that the cardinal
principles are protection, charity, sobriety
and industry. With the answer were filed
copies of constitutions, bylaws, rules and
regulations of the brotherhoods.
The defendants state that all differences
and grievances now IN controversy between
t 4 edn fromg Ibe ar rart tae of W a were IN IN
presented to the respective grievance COM
mittees from time to time and were by the
grievance committee presented to the Off
Gals of the Wabash railway and that they
were unable to settle the same and were
referred to the joint protective board,
the Wabash road, and that he refused to
a k up or give the grievances reasonable
consideration or adjust the same with the
said protective board.
The defendants further answer that after
each Of the boards and committees of the
respective organizations had attempted to
adjust their several differences and griev-
ances will the Wabash and had failed 1t
was resolved and agreed between them
that they should thereafter work together
for the good OF all parties whom they rep
resented. A record was kept Of all pro-
and the transcript of this record Is also
filed as a part Of the answer.
Many letters passed between President
Ramsey and the committee having the adj
justment of grievances in charge. Copies
of these letters are filed as an exhibit. The
defendants state that during their attempts
to adjust differences with President Ramsey
II was stated by him that he received them
only as individuals and refused to con-
slider the grievances as being represented
by representatives Of said respective organ
i~zations and that thereupon about l,2O0 Of
the employees executed a written authority
to the defendants TO represent them and
secure an adjustment of grievances. When
this authority was presented to President
Ramsey he refused to consider II. The de-
PENDANTS declared that they had made every
reasonable effort with the Wabash TO ad-
Just their differences. The defendants
| Jointly and seVerally further answering the
said bill of complaint of the Wabash deny
that the said complainant is entitled to
the relief or any part thereof as prayed
pray TO be dismissed with their reasonable
costs in this behalf most wrongfully sus-
tanned.