The Ogden standard. [volume] (Ogden City, Utah) 1902-1910, 1909-09-02
md that Salt Lake CITY and Ogden

accessible places for the people in
said territory To do their trading.
These defendants DENY that by rea-
son Of the promises aforesaid or the
acts of these defendants, OF any of
them, rs alleged in said complaint
In refusing to grant a rate of one fare
for round trip 10 persons living in
the territory aforesaid 10 come to Og-
den City at the time alleged. arc dis
criminatory or Illegal as to the NOR
chants. professional men or citizens
OF ogden. or 10 the Intermountain -Four
State Fair Association. or TO any 9th.
er persons, or at all.
Further answering the said com
plant. these defendants allege that
the early settlers and pioneers OF the
region now constituting the State of
Utah were almost exclusively men,
bers of the Mormon or Latter-Day
Saints church: that they originally
came into this region In a consider
able body. and as an organized church.
and established their headquarters at
Salt Lake City and gradually spread
from that rs a centor TO the surround
ing country establishing many towns
and communities within and without
the present boundaries of the State
of Utah. that said settlements OF the
LatteT-Day Saints now extend not only
throughout the state OF Utah, but over
a large part of Idaho, Wyoming. Ne
vada, Colorado. Arizona. Republic Of
Mexico Oregon. Montana and British
America, and that the said Latter.Day
Saints people wherever located con-
sttute a single body and church or
ganizatiou That Salt Lake City was
IssH. IL 1l-l-- 4, 80 L.. !
church at the time OF the original set
tlement OF said Mormon people In the
intermountain region, and II has con-
tinued TO be their capital city at which
there has been continuously located,
and still exist. the Offices and head
quarters OF the President and princi-
pal officers and governing bodies of
said church That said Salt Lake City
was so established as the capital city
of said church before 1t became the
capital of the territory of Utah. or of
the State of Utah That, by reason OF
the settlement of said region bv the
members of said church they have
i within the territory now constituting
the State of Utah, a large majority
Of people, and have had a controlling
influence in building up the various
cities and towns within said region
That. by reason of the establishment
of said church Of It's capital city in
Salt Lake City, it has resulted in
developing in that city a large popu-
lation and a vast amount of business;
that the said city now contains, as
these defendants arc informed and be-
lieye. and allege the fact TO be, a pop
ulatlon Of about 100000 people. that
the next city in size to Salt Lake City
in said state is Ogden. with a popula
ton. as these defendants are inform
ed and believe, Of not exceeding 90
600 people. That. as a result OF the
growth and development OF Salt Lake
City, II constitutes not only the rellg
ious center and capital Of the Mormon
church. but Is the capital OF the state
and the center of great mining. COM
mercial, banking and other industries
of the state and surrounding country
That ever since the settlement of said
city the said Mormon church as a
part OF Its policy and the teaching OF
its faith, has held in April and OctO-
Der of each year, at said Salt Lake
City, its general Semi-Annual confer
ences of the entire church. and which
a large proportion Of It's members
wherever they may he located. reeu-
larly attend. That the said policy of
holding said conferences in said city
was established by the said church
wholly Independent Of. and free from
any control or influence of either of
these defendants and before either Of
them was organized or had an exist.
ence. That there regularly attend said
conferences many thousand people
coming from all the localities afore-
said In which the members OF said
church are located, 50 that the said
gatherings Of said Mormon church. at
said Somi-Annual conferences. are
wholly distinct and exceptional from
any other gatherings or assemblies
within the said state OF Utah, and pro-
duce a largely increased travel over
the lines of railroad of these defend
ants over and in excess of any other
gatherings whatsoever within the said
state of Utah, That the facts afore.
said constitute substantially disslm-
liar circumstances and conditions from
those existing at said Ogden CITY on
the occasions referred TO IN said petit
tion. and Justify and make reasonable
and lawful the rates established and
now in effect in the transportation of
visitors 10 said conferences. These
defendants further allege that rates TO
the State Fair held at Salt Lake City
annually are not given or extended for
any sum or rate less than that that
Is offered and extended to the said Fair
annually held at Ogden City. These
defendants further allege that the
State Fair Association, through It's Of
licers habitually fix tho period of their
annual fair at Salt Lake City in the
early part of October and at the same
time Of the assembling Of the October
Semi-Annual conference of the Latter
Day Saints church. and thus secure for
persons attending such fair the same
rates as are granted TO all persons dur
ing the period that the reduced rate
Is In existence on account OF said con-
ference. That the action OF said State
Fair Is wholly independent Of and be-
yond the control and has never been
influenced in any manner whatsoever,
by these defendants. or either of them,
and that the advantage OF the rate Sc.
cured to the persons attending the
State Fair arc wholly incidental 10
the period fixed and the assembling
of the members OF the said church at
their said Semi-Annual conferences in
October Of each year.
These defendants further allege that
the fact that reduced rates are intro
duced for limited period II and from
Salt Lake City on account of the said
semi-annual conferences of the said
church does not impose upon it any
obligation TO establish or introduce