The Birmingham age-herald., 1911-01-15

section of the United States, and pur- porting to set forth defendants agree ment to carry, together with connect destinations, including in many in stances, the aforesaid European ports, which spurious bills of lading were substantially the same in form as de- fendant's bills of lading, and which were calculated to deceive persons deal ing with them into believing them de- fendant's bills of lading for the cotton which they purported to represent.
 And plaintiffs aver that, during said period of time, to-wit: five years, said firm of Knight, Yancey & Co.,, continued 10 issue such spurious bills of lading and the same to attach to drafts drawn by said firm of Knight, Yancey & Co.,. on purchasers of cotton from them, or the agents of the purchasers, and such drafts to negotiate and thereby obtain large sums of money thereon-approxi- mately the amounts called for thereby. And the plaintiffs aver that such prac tices of Knight, Yancey & Go, were. during said time, fully known to defend ant, and with such knowledge defendant. during such period, wrongfully caused cot ton shipped by Knight, Yancey & Co.,, under it's genuine bills of lading, issued long after the times when said fraudulent bills of ading were issued, to be delivered to the holders of such spurious bill of lading, well knowing that said cotton so shipped had been classified and marked | Od hx caid of Knight. Yancey & Co.,. to correspond, as far as practicable, with the cotton called for by the spurious bills of lading, | with the purpose and intent on the part of said Knight, Yancey & Co.,. to induce the holders of such spurious bills of lad ing to believe that such cotton had been shipped under such spurious bills of lad | ing, and that such spurious bills of lad ing were. in fact. defendants genuine bills of lading.
 "Plaintiffs further aver that defendant caused such deliveries to be made, well knowing that the holders of such spu- rious bills of lading were ignorant of Re fact that such bills were spurious, And with the intent and purpose on the part of the defendant of aiding and con- cealing the fact that said firm of Knight, Yancey & Go. were in the habit of ne- gotiating and obtaining money on drafts I drawn by them with such spurious bills of lading attached thereto purporting to be the bills of lading of defendant
 Cansed Wrong Impression
 And plaintiffs further aver that de- l fendant became and was a party to the fraudulent practices of said firm of Knight, Yancey & Co., herein set forth, in that it was the custom and habit of defendant by and through it's agents who were therein acting within the line and scope of their employment, in cases where inquiries were made of defendant by or at the instance of the holders of forged bills of lading issued by said firm of Knight, Yancey & Co.,, purporting to be defendants bills of lading as to the ,l whereabouts of the cotton called for by such forged bills of lading, to notify said firm of such inquiries, and to make such replies as would and did induce the be- lief that the said bills of lading were defendants bills of lading calling for cot ton actually shipped over defendants line of railroad.
 And plaintiffs further aver that, dur ing the period aforesaid to-wit; five years. said firm of Knight. Yancey X Co.,. continued to issue said spurious bills of lading, purporting to be defendant s bills of lading for cotton received by il for shipment, under an agreement or un- derstanding' with defendants agents, who were therein acting in the line and scope of their employment, that defendant would cause it's connecting carriers to deliver to the holders of such spurious bills of lad ing cotton shipped by said firm over de fendants line of railroad, and thereby conceal the negotiation of such spurious bills of lading by said firm.