Daily Kennebec journal. [microfilm reel] (Augusta, Me.) 1870-1975, 1914-12-17
STATE OF MAINE.
KENNEBEC, SIS. SUPREME JUDICIAL
COIJRT IN EOTTTTY

1
COURT IN EQUITY,
National Electric Controller Company
VS.. Consolidated Life Securities Company.
To the Supreme Judicial Court in Equity:
The National Electric Controller CONF
pany, a corporation organized and exist
ing under and by virtue of the laws of
the state Of Illinois, with its principal
business Office located In the City of
chicago, County of Cook, and State of
illinois, In behalf of itself and of all
other creditors Of the Consolidated Life
securities Company, who may wish to
Join in this Bill of Complaint against the
consolidated Life Securities Company,
corporation organized and existing un-
der the laws of the State OF Maine, To-
Gated at Augusta. in the County of Ken
nebec, says:
First: That the Consolidated Life Sc
curlties Company is corporation exist
with a capital stock of Two Million Five
Hundred Thousand (s2,500. 100000 Dollars
olVloed into two hundred and fifty thou
SAND shares of stock of the par value of
Ten $1,000 Dollars each, of which stock
one-half are preferred shares and one
haif are common shares.
Second: That the National Electric
controller Company, the plaintiff herein,
recovered judgment against the said
consolidated Life Securities Company in
the superior Court of the County Of
COOK ana state of Illinois on the third
and costs, which said judgment is in full
force and effect, no portion of which has
been paid.
Third: That this Plaintiff is informed
and believes and so charges the fact to
be that the said Consolidated Life Sc
curities Company is owing large sums OF
money to other creditors which 1t has
not paid, and which it refuses to pay.
Fourth: That the said Consolidated
Life Securities Company has ceased do
ing business and has left no assets
which the Plaintiff has been able to dis
of its said Judgment or any portion
thereof
| Fifth: That a large number of persons
which the Plaintiff is informed and be-
lieves and charges the fact to be are
more than one thousand in number, have
subscribed for preferred stock of said
consolidated Life Securities Company,
Tor Which they have paid little or MOTH
ing or value, and upon which they are
| legally and equtably owing large sums
| OF money. And this Plaintiff shows that
there are no assets and there is no way
| by which 1t and the other creditors of
said Consolidated Life Securities Com
pany can secure the amounts owing to
them by said Company unless the stock,
Consolidated Life Securities Company
shall be compelled to pay the amounts
owing by them upon their respective
stock holdings, and this Plaintiff shows
Sixth: That the said Consolidated Life
Securities Company is in danger of be-
| coming insolvent and that in justice and
equity its affairs should be closed up:
Seventh: That a Receiver should be
appointed with power to collect from the
| stockholders of said Consolidated Life
Securities Company the amounts unpaid
upon their respective stock holdings and
that this Plaintiff has no plain, ade-
quate and complete remedy at law.
| WHEREFORE. this Plaintiff prays:
l. That Receiver may be appointed
for the said Consolidated Life Securities
in Chancery and as by and under the
statute in such case made and provided.
to conserve, protect and collect all the
assets Of said Company, to take charge
of all books, documents and every kind of
property whatsoever belonging to said
Company and to marshall the assets of
said, Company, and to collect from the
stockholders of said Company the
stock holdings and to distribute the sums
$50 collected and the assets to this Plain
tiff and other creditors of said Company
| who shall by this Court be held to be
entitled to distributive shares thereof,
and to wind up the affairs OF said cor
poration.
q That an Injunction both temporary
and permanent issue restraining the SAID
/ corpora ton, its officers and agents and
! attorneys from receiving any moneys,
i paying any debts, selling or transferring
any assets of the corporation or exercis-
ing any of Its privileges or franchises.
I 3, That the defendant may make full
answer to this bill but not under oath,
answer under oath being hereby waived
A. That this Plaintiff may have such
further and other relief as the nature OF
the case may require.
s. That this Honorable Court wifi issue
its writ of subpoena in accordance with
the provisions of the statutes requiring
the Consolidated Life Securities Company
to appear and answer as therein REQUIRED
and to stand and abide by such orders
and DEGREES as to this Honorable Court
may seem meet
And that an injunction both temporary
and permanent may issue restraining
said Defendant as herein before prayed
for.
i g. And that this Plaintiff may have its
reasonable costs.
Dated, Augusta, Maine, this End day OF
December, A. D, 1914
NATIONAL ELECTRIC
CONTROLLER COMPANY
BY E. NJ. Thompson, Its Solicitor.
E. NJ. THOMPSON,
Solicitor for Plaintiff.