The Virginia enterprise. [volume] (Virginia, St. Louis County, Minn.) 1893-19??, 1907-07-26

ard Moylan, at all said times were
and they now are, policemen, EN-.
ployed and working under pay and
for salaries of and for the said city
o. Virginia, and that it was the duty
Of the said city and it's said police
men, at all said times to reasonably
afford police protection, aud pre-.
vent injury to the persons and pro.
perty and business of the residents
and citizens of said city, and not to
cause injury to the property and
business of said citizens, and not to
deprive any of the citizens or resi-
dents of said city of their liberty and
reputation, without probablean
just cause.
2. That on the 18th day of July,
1907, and for a long time prior there
to, this plaintiff and one Charles
Lung were and they now are en-.
gagged in conducting and manag-
ing a certain hotel and restaurant
business in that certain two story
brick building at or about No. 81
Chestnut Street, in said city of Vir
ginia, under the name of Frisco
Hote;," with said John G. Bokyin
and Charlie Lung as proprietors
and at the times herein mentioned
the said plaintiff and the said
Charlie Lung enjoyed a good and
valuable trade and business in said
"frisco Hotel" and that this plain
tiff's share in the said business was
at all said times remunerative and
valuable to this plaintiff.
3. That in conducting and man.
aging of said hotel business and az
one of of the ways and means to
make the same profitable rooms
and beds therein were and are
furnished to guests for pay and
hire.
| 4. That the said Peter Klimas.
William Mclean, and Bernard NOV.
Ian have prior to the 18th day of
July, 1907, frequently entered into
the said hotel, while the said guests
were sleeping and in their respec-
tive rooms, and on the 18th day of
July, 1907, at about the hour of /
o'clock a. m. the said Peter Klimas,
William Mclean and Bernard NOV.
Ian, as said policemen did unneces-
sarily and against the will of this
plaintiff enter into the said hotel
and the said Peter Klimas, William
Mclean and Bernard Moylan, did
then and there as and while acting
as said policemen, and against the
wishes of this plaintiff, who was
then and there on watch and in the
charge of said hotel, and business,
enter the rooms of certain of the
guests of said hotel, and then and
there awoke and startled and
frightened and annoyed certain of
of the guests of said hotel.
3. That said Peter Klimas, Viii.
liam Mclean and Bernard Moylan,
as said policemen, acting for and
with the authority and the know.
ledge and consent of said city and
it's officers and at time when the
governing officers and mayor and
city council of said city, we'll knew
that the said Peter Klimas, William
Mclean and Bernard Moylan, are
wronefully and without just and
probable cause, molesting and in.
terfering with the said business
and injuring the said hotel bust
ness. do threaten to injure and
modest said hotel business and to
enter the rooms of said hotel while
guests are resting and sleeping in
the night time, and thereby frighten
and scare and interfere with the
privacy of the said guests, and to
drive them away from said hotel
and thus injure the reputation and
business of the said hotel, and there.
by cause this plaintiff as one of the
partners and proprietors of said
hotel and restaurant, irreparab le
damages injury, all 10 the damage
of this plaintiff in the sum of Five
Hundred Dollars.
8. For a second and further cause
of action against the said defend
ants, this plaintiff, re-allepes
assumes and makes a part of this
second cause of action all of the
matter and statements that are
alleged and set forth in the lst, End,
3rd, 4th and 5th, paragraphs in THE
apd the foregoing pages 1 and 2 <of
this complaint and in addition
thereto this plaintiff alleges that on
or about the 10th day of July, 1907
at about the hour of O'Clock a. M:
while the said Peter Kliusas. viii.
liam Mclean and Bernard Moylan
we're acting ae said policemen for;
said city of Virginia and at a time
when the governing body and
officers Of said city we'll knew that
said Peter Klimas, William Mclean
and Bernard Moylan were wrong.
fully interfering with and molest.l
ing and injuring the said hotel
x