Richmond times-dispatch. [volume] (Richmond, Va.) 1914-current, 1915-04-13
SEEKS INJUNCTION
AGAINST JITNEYS
CONTINUED From Frs, pare1

the tracks of your complainant are
laid and It's cars are operated and
have engaged by using said motors in
the business of generally carrying pas.
sengers for hire between points in the
city OF Richmond and along the
streets thereof for the fixed fare of 5
cents for each passenger. and have held
themselves out by advertisement and
by notices on said cars TO the public
generally, to carry any persons desir-
Ing to ride in such cars between diff
fercnt points in the city of Richmond
for said fare. in exactly the same man
ner as such passengers are carried by
complainant on its electric street rail-
way cars.
JITNEYS OPERATING WITHOUT
SPECIFIC FRANCHISE
None OF said defendants has OBJ
taincd the consent Of the corporate au-
thorities OF the city of Richmond for
the conduct of the business In which
they are engaged upon tho streets OF
said city as provided by law. and no
one OF said defendants has complied
with the provisions Of the Constitution
and laws OF this State, compliance
with which is made condition prece-
dent to the right of said defendants or
on the streets of the city Of Richmond
IN competition with your complainant;
said defendants claiming. as your com :
plainant Is advised. that they are not
required to comply with said consti-
tut!onal or statutory provisions or to
obtain the consent of tho corporate au-
thorities oc the city OF Richmond as
a condition precedent TO the conduct
Of their business
Complainant is advised and AYERS
that the defendants. in operating mo
tor cars and other similar vehicles as
general common carriers OF passengers
for hire along the streets of the city of
Richmond without first obtaining the
consent OF the municipal authorities
thereto In the manner prescribed by the
Constitution and laws of the State OF
Virginia. are engaged in an unlawful
use OF said streets: that the business
which they are undertaking to con-
duct. being without authority Of and
In conflict with the law. constitutes a
common nuisance by which the com
plainant is specially damaged"
DILL ENUMERATES
SPECIAL DAMAGES
The bill proceeds to enumerate the
special damages which the complain
ant Is compelled to suffer rs the result
OF the alleged illegal traffic. claiming,
among OtHeT tnlnSS.
That by reason Of this traffic which
Is carried on without authority the
defendants are depriving the complain
ant OF large amounts of revenue which
1t would otherwise receive from the
conduct OF it's business.
That defendant jtney companies in
their unauthorized use Of the streets
arc operating their cars upon that por-
ton of the streets upon which the
compliments tracks are laid within
the space between Its tracks and two
feet on either SIDE wearing out that
portion of the streets which the COM
plninant Is required to maintain, caus-
ing it great damage and requiring 1t to
cXpend large sums of money in the
discharge Of it's duties and in com
pliance with it's franchise to maintain
such portions of streets
ORsTRUCT STREETS AND
BLOCK PUBLIC TRAFFIC.
Fly that the unlawful operation of
numerous cars on the streets on which
the complainant is authorized and re-
uuired to operate its street railways,
the defendants are unlawfully obstruct-
Ing the complainant in the discharge of
It's public duties. making 1t difficult to
render the reasonably adequate, safe
and convenient service required of II
by franchise. increasing the difficulty
Of maintaining schedules. subjecting
the complainant to heavy loss from &C
cident. and to the danger of heavy fines
and penalties for failure to discharge
It's obligations as a public carrier in