The Cairo bulletin. (Cairo, Ill.) 1???-1928, 1911-03-03
4 ss.,EIEfnEYaYM

lof said directors, consisting of the
complanants In this bill and the late
Daniel Hartman, deceased, "sirenu.
ously and persistently declined to con.
sent to or approve the execution OF
srch a lease by tie Cairo & Thebes
Railroad Co. to said 81. s.ou:s, iron
Mountain e Southern Railroad Co,
for the reason that the same was I'm
direct violation Of the terms and pre-
visions OF said written agreement Of
Jan. 2, 1906, and or the resolution or
the said stockholders OF the Cairo &
Thebes Railroad Co.. adopted at their
meeting held on said I'd day OF Janu-
airy, 1906"
1t is further recited that for the
purpose OF procuring the execution
of said contract or lease the Louis
Vile 4 Nashville Co Illegally and
arbitrarily caused the stockholders OF
said Cairo & Thcbes Railroad CO. to
attempt, on the goth day OF Febrii-
ary, 1911, to remove yorr orators
from their position as directors OF
said Cairo & Thebes Railway Co..
that tho meeting OF said stockholders
held on said Goth day of February,
1911, was not legally called anu held
and That your orators respective
terms OF office as directors or said
Cairo 4 Thebes Co. had not expired
| At the time and have not yet expired:
that the attempted removal OF your
orators as such directors was In yio-
alton OF the law OF the state Of lni-
.'nois and Of the bylaws Oh the said
Cairo & 'Thebes Railroad Co. ansf
that your orators had done and nave
done nothing to in any manner iusii-
tx their attempted removal as such
directors.
Your orators further represen; un-
ITO your honor that said Eg1ert a.
Smith, VIM. S. Dewey, Edward &.
Pink and J. Bruce Magee have lille.
gally, and in violation of the terms
Of the said agreement OF Jam 2, 1907,
and of said resolution of the stoea-
| holders OF said Cairo & Thebes Rail-
road Co., adopted Jan 2, 1906, aide,
and abetted the said Louisville &
| Nashville Railroad CO. in bringing
about and causing the execution OF
said contract or lease between the
Cairo & Thebes Railroad Co and the
st. Louis, Iron Mountain & Southern
| Railway Co., and yorr orators fur
| ther allege that said Louisville &c
| Nashville Railroad Co., at said meet
ing OF stockholders OF the Cairo &c
/ Tnebes Railroad Co., held on the Goth
day Of February, 1911, kept and re-
tanned the said Egbert A. Smith, VIM.
s. Dewey, Edward G. Pink and J.
LTHce Magee in Office as directors
/ aud Illegally pretended and attempted
to elect as directors in place OF your
orators ami the said Daniei Mar,man,
deceased, the following named per-
sons, to.wit Milton II, Smith, VINO
was and Is the president OF the
Louisville G. Nashville Co; ]. II, Ellis
/ VINO was and is the secretary OF said
company; Charles Hayden, who was
and is the comptroller of said COM
1 a rhn nu &C.
the general counsel OF said company
and w. l.. Pomeroy and l.. |. Stoltz.
| who were and are employees o. said
Cairo & Thebes Railroad co.
| "Your orators further represent
| that the said removal Of your orators
1 from the board OF directors OF said
cairo & Thebes Railroad Co., the re-
tention Of said l2gbert A. Smith, VIM.
s. Dewey, Edward G. Pink and j.
Bruce Magee, and the said election TO
said board OF said Milton H. Smlta,
| J. H. Ellis, II. l.. Stone, Charles Hay
don, w. L. Pomeroy and L. ID. Stoitz,
We're all illegally attempted and done
| for the purpose OF assisting said
/ Louisville & Nashville Railroad Co.
in procuring the unlawful execution
of said contract ana tease between
said Cairo C Thebes Railroad Co ana
said St Louis, Iron Mountain &
! Southern Railway Co, as aforesaid"
Various other matters are set forth
! In detail, among them that the Louis
willie & Nashville Co has advanced
100000 for the building OF tie
J Cairo & Thebes railroad; that on
Feb. 90 1911, mortgage was exe-
, cuted by the Cairo & Thebes Co. to
the Columbus Trust Co, OF Lou.svi.se.
/ KY, TO secure the payment Of coupo~
bonds to be issued by the Cairo &
/ Thehes Co. for $1,000 each. not to eS-
ceed 1900 in number, to be dated
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II