The Montgomery advertiser., 1906-11-24

its trafic, and which said cars
 are amply sufficient. and have ns,,, sufiicisnt to 'tT transport ana haul all oi It's patrons, but the whole number of said cars so owned by 1t are necessary to ad furnish fo it's ift patrons and the tray. cling public a reasonably sufticient and frequent schedule over Its said lines; that to furnish separate cars, and run uis ans fo@s for tSs Ss white s and cSiorsd races would require of your orator the im- mediate purchase of at least q like ad- ditional number of thirty cars. and an pose of . large sum. to wit, $1o5,eOo; that in the hrst place the manufactur- CTS of cars arc largely behind with their. orders. and even If it were reas- ture on the part of your orator. it would be several months. to wit. six months, before such a large number of cars could be manufactured and deliv- cred to your orator and placed in op-
 Few Negro Patrons.
 Third-That the population of the
 y ast se sensSs Ta. ssis oTsr tS people, a majority of which were ne- city since the last census has in races, by probably as much as a5 per cent: that very few of the negro pop- ulatiCn patronfxe the lines of your or ator, and that your orator only has a 2s.0Oo or 5l.o00 from which to derive It's patronage; that the city of Mont gornery is as compared with other cities hiIly ana broken. and practically point. run over steep grades and up andf down prectpitpts hills; that the cost and expense of doubling the num- frs.v.s.n Snd rn,sfse.gn,.s ..a,1fIvssr t,s aoss. bie the number of switches and turn- outs, and doubling the amount of car barn and shop facilities, and doubling ate Its said cars, AB we'll as other great cost and fncrease of expenses, would result in all of your orators lines be- ing operated at great loss, and great 1t to default in tic payment of the interest on it's bonded Indebtedness, and subsequent insolvency and bankruptcy. and consedtent displacement by your
 Fourth--That if your orator could afford the large expenditure of money and waste and loss in so operating it's
 that t co6 iSss such o grsst sSen lSss as above enumerated tt would still be physically impossible for 1t to comply with the provisions of said ordinance, in that. all of it's above mentioned lines. with two exceptions. to wit. the above mentioned Belt Line and Elec- tric Park Line. terminate at points at which there are no loops, 'Y's' or turn cars what are commonly called trail- CTS. CT cars without motors thereon.
 Hasn't Get Traslers.
 That your orator only has at the present time a small number, to wit six. traiiers, all of which are built for summer use on extra occasions, and are not enclosed. and are not suitable N fa aIyan If vnnr nra4nr had "a .,,ess~Gs.-S number of trailers to attach one to each of it's motor cars. such open traiiers could not be used for either season would be an unjust discffmina- tion to said race so required to use tho same. and if pulled from one end of the line to the other 1t would, on account of the condition. of It's tracks, have to push the same back through the city of Montgomery in front of the motor car. which would be ex- ttEemely dangerous not only to and to said ears. but to the vehicles and travelling public on the streets of the city.
 states that none of its motor cars it now has in It's possession are Of suffE- cient capacity to pull a trailer in ad. dltion to It's regular load. except the said large double motor four .u truck luck cars cannot pull trailer for a longer period than. to wit. four hours. with- out the boxes or axle bearings of the and that furthermore. the source from which your orators lines get its aiee- trio current is not prepared and could not become prepared within a long eriod of, to wit. six months. and at q great expense of to wit. $50, ,OOO. to furnish your orator with sufFlcient adoltiona current to run double the it number or cars now being operated by, 
 ContracFs Tor seheanIeu.
 z lIth.-5Tnat your orator IS now un- der contract or obligation with the Htghland Park Improvement Company, q corporation, to furnish between the city of Montgomery proper end inc suburb of Highland Park, a schedule, towtt, the schedule now icing main. nssS talaed oprstIan S1 saiS iins that t Is also Club, corporation, to operate oa what Is known as the oak Park line the schedule now being maintained on said line. both for the carriage of white people and that lour orator is also under a special contract with the City Council of Montgomery in several to 1t over some, of its lines to operate | reasonable, schedule over said lines and that it is under an implied obli gation to said. City Council of Mont schedules, and that by the provisions of It's charter and by opera .iou of law, it is obligated to the State | 1f Alabama, and to the public to main tain on all of it's lines a reasonably schedule, and that to adopt the scheme of dividing It's said sched- ile between the races and operate every alternate car for white people, | md the other cars TOT colored peopls s, would result in making the schedule 1f its said oars only half as frequent as at the present time for each of said races and would be unreasonable and | would result In great injustice. in harm and detriment to the public, as we'll as great financial oss and disaster to your orator.
 That on the present day, towtt, the ,3rd day of November, 1906, the police ,fAeers and patrolmen of the city of Nontgomery have stopped completely he operation of all of your orators ines in the city of Montgomery, by arresting and taking in charge all 0f Inc motormen and conductors, and 1 nave so interrupted the operation of your orators lines that at the present lime ali of your orators cars are 1 3tanding idle in the central portion of | he city of Montgomery, and practi- | sally all of the employees of your ora .or are under arrest in charge of the police department of the city of Mont gomefy under charge of violating the hereto attached as Exhibit, "B."
 UmHaVVfuI Interference.
 'eYour orator alleges that the con. luct of the said officials of the city oe in so arresting or caus-