Imperial Valley press., 1919-06-24

whole industry i'm the state, follows
In the Superior Court on the Stat
Of California, in and for the County q
Imperial.
4. Voorting, plaintiff. vs. l2.Herla
Valley Milk Producers Association,
corporation. defendant
COMPLAINT FOR IN]UHCi.o%
ETC.
Plaintiff complains Of defendant
and for cause of action alleGcs;
At all the dates and times herein
after mentioned. the plaintiff was
and is in the dairy business in AN
perial Valley. California, and IS tie
owner OF a herd of milk cows, I5cre-
in;
At all the dates hereinafter men
toned. Harris Weinst0Cs Was aad Is
the Market Director Of the State OF
California.
The defendant is now and at al
the dates and times herein men
toned, since the 18th dav Of March,
1918. has been q nOn-proflta1le ce-
operative corporation, organized and
existing under and pursuant TO the
provisions of Title NH, Part N, D.
vision First. of the Civil Code Of the
State Of California.
"
At all the times hereafter men
toned one J, NJ. Henderson. Jr.. was
banker and money lender. residing
and having his principal office and
yliee of business in the City Of Sac
ramento, State Of California.
At the date Of The organization of
said defendant association, 10 VII:
The 18th day Of March, 1918, and
fer a long time prior, also subsequent
to such date, said J. N. henderson,
Jr., aided and abetted by the SAID
Harris Weinstock, and fer the Pur-
rose Of furthering his own personal
selfish interests. and wholly regard
less Of the interests Of the plaintiff
and of ell persons who became mem
hers Of the defendant assoc alton, Was
engaged in deEoting all OF nearly al
of his time and talents and large
sums of money il organizing the Sc
called Mix Producers Associations
throughout the State of California,
including the organization OF sa1a de-
fendant.
Said J. II. Henderson, il. aided and
abetted bv the said Harris "slastock
as aforesaid, travelled from place e
place throLChout the State OF tGiitoT-
MIA during the period aforesaid. max
ing addresses and appeals - t22
dairymen of the State oi California,
ard conducting q cam p2lgE o. prop
uganda calculated L MAKE me 1z-'yy'-
men of the State O.. California sGs-
picious of the then eT sting c--a.Il-r-
les in the Stete Of California ard To
create a belief in the m.1ls of J.o
dairymen of the State o. California
that they could, # they would. organ
ize milk r~0ducers' association, ana
by so organizing, manufacture from
the milk and cream produced by tnemi
butter and other creamery products, g,
equal If not superior in quality 10
that then being produced By the best
equipped privately owned custom
crearaeries then existing and II op-
GRAFTON in TIE State Of California,
and of marketing such products 50
produced by them at a higher price
than was then being obtained 1cr
like products by the said custom
creameries, and, IN particular. there
by obtaining FOR the dalTymen Wno
formed such associations. g very much
s higher price for their milk and cream
than they were then obtaining from
the said creanleries, and. incidentally,
driving out Of business all Of the sa'c
custom creameries.
VI
There has at no time been any de-
nand or necessity whatsoever -0r the
organization Of the defendant ass0-
citation, or Of anv milk producer as
sociation in the State of California.
TIE plaintiff is informed and believes,
and, so believing, alleges the Ia-- 10
be, that the history Of the Nix pro-
ducers' Associations throughout the
United States shows shat such aaso-
ciati0ns have been ard are uniformly
inefficient unprofitable and ccoac@4-
cally unsound.
The manufacture Of butter and
other dairy products rs tie same IS
now carried on i'm the large, mod
err and well-equipped privately owned
and managed custom crcamer.es which
are found throughout the State of
California and elsewhere lI the Unit
cd States, is a very highly developed
Industry. calling for hi"b order Cr
skill in the production OF the manu-
featured product, and especially {
knowledge Of market conditions. iG
sluding conditions affecting price.
which can only BE acquired hy YEAR
,f experience and by develoning ;
aiehly specialized managerial arr
selling organization. The methods O.
marketing dairy products by the larg
Z ustom creameries in the State O
California have been so DEVELOPS
hat it is now possible for them
aarket the high grade Of d"irv pro
reed by them not only in the mar
cts Of California. bnt in those If Ne
aaa. Arizona and in paints cas-
fherever it IS found that the les
rice therefor is ohtainahle wltlou
ing deterioration Of such p, ducts.
The purchasers of butter and da.r
roducts todaq and at a the time
prein alleged, demand and have do
,anaed q grade Of butter and ctbe
airg products which can only ha pre-
seed hy the use Of aquiDmcut an
ants employing the latest improve
,nitary pasteriziug and cooiln