The times dispatch. [volume] (Richmond, Va.) 1903-1914, 1913-09-23

(Which is hardly probablc) that tho
aforesaid so-cnllcd iicenso IS not void
Tor all, or some, or tho four reasons
above given. then II is voidable and
should be vo!dcd for the Same four
reasons above set out. and for the fur
fhet reason that tho defendant and
supposed liccnsce Is a corporation, and
u,n only do such things and acts rs
are authorized by Its charter. and no
where does this charter authorize II
to sell intoxicating liquors. or init
mate that such was ever contemplated
w its ipcorpOrators or that branch OF
tho State government granting its
charter: tho contrary. the charter
Itself viii show that the objects ana
purposes OF the said corporation arc
Tho opposite and directly IN conflict
with tho sale OF intoxicating liquors,
and therefore. the attempt on the part
ot the defendant herein to conduct any
such business or any act in pursuance
thereof Will be ultra wires.
YOUR complainant further represents
that for each. and for all of the arore-
slid reasons. IL the defendant under
takes To sell Intoxicating liquors at all
AT any place. such place Will become
common nuisance under and BY rir-
tue Of tho law OF this State and
should he abated.
Your complainant further represents
that it is the purpose and intention OF
tho said defendant. on the 9th day
4 October next. 10 begin the sale OF
intoxicating liquor AT several places
III what is known ms the State Fair
grounds "a place about a mile in lengeh
.nG about one half mile In breadth ~
It's wides; poinO. under the one So
called license aforesaid. all OF which
yuur complainant represents is con-
trary to and in defiance OF law, and
should the court he OF the opinion that
the so-callcd license aforesaid Is good
or valid even when only one bar or
place Of business can be conducted ur
der The one license. ana ever, one
over and above the first ono would be
Il common nuisance and under the law
Should be abafcd
Complainant IL Interested.
Tour complainant is a highly inter
osted party in the subject matter and
objects OF this suit because she is III
tc.cSt,d in the welfare. education. mo-
rails and general welfare OF all her cit
liens because il is the purpose and
intention OF the defendant 10 sell in
,oSicli.rE LIQUOR under this so-called
license, mt and during the State Fair.
from October TO II, inclusive--a time
and place highly improper and at which
the greatest possible harm. injury and
degradation Will be suffered by the
citizens or ttlS complainant. because
The State Fair is a large public func
tiou for the purpose of educating the
people OF this State in advertising her
resources and industries by exhibiting
The same 10 the best possible advan-
taEe and because, il intoxicating liquor
is 10 be sold your complainant is en-
titled 10 have and wants all the pub
lie revenue that should come 10 il and
requests tina; II separate license be re-
CURED of each and every place where
intoNi eating liquor is to be sold.
Your complainant further represents
under this honorable court that the
aforesaid defendant proposes and in
tends beginning the sale OF intoxicating
liquors under the aforesaid so-called
license at several places the said
Fair Grounds on October t next. the
same day the State Fair will begin.
and will continue to sell through the
entire fair, which your complainant al
leges are not suitable. convenient and
appropriate places for conducting such
business as contemplated by law.
Question of Population.
This complainant hereby charges and
alleges that there are not within a
radius OF one-haif mile of the place.
places or any OF them. where the de-
PENDANT proposes 10 conduct & retail
liquor business, 500 or moro inhabi-
tants; that there is no police protec-
tiun there paid for by tho public; that
the Virginia State Fair Grounds is not
a suitable, convenient and appropriate
place for conducting the business OF
selling intoxicating liquor: that the
aforesaid so called license issued 10 the
said defendant is not valid. but is void
that the defendant under its present
charter is not authorized, and has not
the power to conduct n bar or place for
the sale OF ntox icating liquors. even
though il may have valid liquor IL
ccnse. and that it cannot conduct more
than one bar or place of business un-
der one license even though the said