Denver labor bulletin., 1917-08-18

and circulating said official labor newspaper and
in carrying plaintiff S said business and trade,
and further then and there SO charging and stat
ing, aforesaid in substance, 4 will read two
letters and checks" which believe, and which
are believed to be true, and reading the same,
which letters purported to be from some person
(not named) in the employ of said coal corpora
ton which contained the assertion that Houston
(meaning this plaintif) is in the pay of The Colo
rado Fuel and Iron company, in my opinion, and
other scandalous and defamatory remarks, and
the second letter stating, in substance, that My
opinion and belief about Houston being paid by
the Colorado Fuel and Iron company has been
confirmed and I inclose herewith two photo
graphs of two checks to prove it, and other
scandalous and defamatory remarks, and reading
said alleged Photographic checks which purported
to be made and signed by said coal company
maker and each directing bank to pay plaintiff,
as payee, large sum of money.
III.
That said alleged photographs of checks were
false defamatory, spurious, counterfeit and fake
photographs, and such checks had ever been
drawn, or received by plaintiff, made
payable to plaintiff, ever cashed by plaintiff,
in any manner or form whatsoever.
w.
That said alleged letters and checks are in the
possession and under the control of said defend
and and plaintiff cannot obtain possession there
of to reproduce set the same forth YER
batin herein.
".
utterances and readings and each of them, as
aforesaid, uttered and publicly read by
defendant of and concerning this plaintiff, and
his said trade and business (thru which he at
all times sought and now seeks to gain his
hving) with malice and insult toward plaintiff,
and with wanton and reckless disregard OF
plaintiffs rights and interest as the editor and
large co-owner (Which he was and isl OF said
newspaper and intended and calculated to
bring plaintiff and his said newspaper into public
contempt and hatred. to impair confidence OF
organized labor and of the working classes and
peoples in the integrity of plaintiff and said
newspaper as the representative and mouthpiece
OF said classes and peoples (Which it had been and
then was) and to degrade and injure plaintiff in
said business.
That because of said scandalous utterances and
readings, and each of same, and the consequences
thereof, this plaintiff has suffered injury to his
integrity and honesty aforesaid and to his said
business and trade, and has been brought into
public scandal. nfamy and disgrace, to the dam
age of the plaintiff in the sum OF ten thousand
(SIo,ooo) dollars
Wherefore, plaintiff demands judgment against
said defendant:
I. For the sum of thousand (SIo,ooo)
dollars, together with interest thereon at the rate
of eight $50 per cent per annum from the date
of the filing of this complaint.
a. For body judgment and execution
against the person of said defendant James F.
Moran, that he may be imprisoned (because of
the malice and fraud herein shown) until said
Judgment is fully paid and satisfied.
3. For costs and disbursements of said action.
and for general relief.
RINN & ARCHIBALD.
Attorneys for Plaintiff.
STATE OF COLORADO,
County of Boulder-ss.
Clint c. Houston. of lawful age, being first
duly sworn. upon his oath deposes and says: that
he is the plaintiff in the above entitled action,
that he has read and knows the contents of the
above and foregoing complaint, and that the mat
ters and things therein alleged are true OF his
own knowledge.
(Sgned) CLINT c. HOUSTON.
Subscribed and sworn to before me this 9th
day of August A. D. 1917
ELLEN BENSON.
(N. P. SeaD Notary Public