Norwich bulletin., 1922-08-09

ham, his deputy, or either constable
 of the Town of Plainfeld, within
 said County, Greeting =
 By authority of the State Of Cennecti- cut. you are hereby commanded to sum mon Albert Wilson, Joseph Rocheforte, Rhoades Paine, Michael Smola. William Carroll, Albert Leclair, Henry Parr. Adoiph Monty, John Flannigan, Henry Wood and Blanche Goodreau, all of the sad Town Of Plainield, both individual ly and az members of a certain volun- tary uninSorporated association known as Industrial Union No. "A. said Industrial Union No. 24. a voluntary unincorporated association which includes in its mem 5ership various textile workers of the class Of employees in the employ of the plaintiff. and as the plaintiff is informed and believes said union has quarters over James Millets store, upon Main street In the Village of Moosup, in said Town of Plainfield. all remaining members and associates of said Industrial Union No. st, and the attorneys, agents, associates and employees of the above named de- tendants, and Peter Rouleau. of said Town Of Plainheld, and Abraham Binns, Commccant of said Town of Plainfield, 10 appear before the Superior Court to ho held within and for the County of Windham on the first Tuesday of Sep tcmber. A. D. 1922. then and there to answer unto The Aldrich Brothers Com pzEy. a corporation organized and exlst- ing under and by virtue of the laws of the State of Rhode Island, and having a manufacturing plant and office in the said Town of Plainheld, in a civil action wherein the plaintiff complains and says
 First; The plaintiff is engaged in the textile manufacturing business and has a plant therefor in the Village of Moosup, in said Town of Plainfeld. and has an office in said Village of Moosup.
 Second: The plaintiff normally employs at it's said plant in said Village of Moosup a large .umher of persons. to wit; seven hundred. and has large amount of money invested in said plant, which in cludes valuable real estate, equipment, machinery and supplies.
 Third The plaintiff ayers and shows that it's business and good will are of great value, and that any interruption of It's business, even for a limited time, is the cause Of irreparable loss and dam age.
 Fourth: The said Industrial Union No. ,4 Is e voluntary unincorporated associa- rion and includes in it's membership va rious textile workers of the class of em- ployes in the employ of the plaintiff, and the plaintiff has information and be- lisves. and therefore ayers that said as- sociatiou is organized and operating in the said Village of Moosup, and Town of Plainheld. and that said association has quarters over James Millet's store, upon Main street. in the said Village of Moosup, and holds meetings in the K. of C. Hall in said Village of Moosup, and elsewhere.
 Fifth. The plaintiff is not informed as to what persons other than the above named constitute the officers and mem UeES or EAlQ | mon. The said ROuleau and Binns are held out 10 the public as the representatives and organizers of the association which is the parent body of said Industrial Union No. 24 the name of which association is unknown to the plaintiff. and the said Rouleau and Binns have been and are active in furthering the acts hereinafter complained of. The other defendants hereinbefore named are entitled and held out to the public as members and representatives of said Union; the remaining members of said Union are too numerous 10 be set forth individually in this complaint and are unknown 10 the plaintiff but said above named defendants individually represent the interest of the ramaining members of said Union, ant by reason of the facts aforesaid the plaintiff joins the aforesaid defendants individually and as represent nE all the remaining members of said Union known as Industrial Union No A thereby joining as defendants all mem- oers or said Industrial Union No. 24 whether or not specifically named.
 Sixth; The plaintiff is informed and believes and therefore ayers that prior % about June 2Sth, A. D. 1922, a few members of said Union or any similar association. and that at all times prior To the commencement of the acts herein. aiter com1iained Of. the greater part oi It's employees were agreeable to and de- Eirous of remaining in the employ of the plaintiff. and the plaintiff shows that al the present time many of it's employees
 
 of said Union or any similar orAaniza- ton. do not wish to become members oi any such organization and are satisfied With the working conditions hours and csie or wages m force at the plant oi the piaintrr. and are desirous of work. Ing in the plaintiffs employ unannoyed unharassed, and unmolested.
 Seventh: On or about June 2Sth, A. D 1922, the defendants or certain of them together with other persons unknown tc me plaintiff. conspred together by un. lawful means. 70 hinder, delay and i'm pede the plaintiff in the performance of It's business. to injure and destroy tht good will, property and business of the plaintiff, to instigate a strike of tht plaintih g employees, unlawfully to induc, the employees of the plaintiff to leave if, employment. and unlawfu1ly to prevent persons destrous of entering and contin ping in the employ of the plaintiff iron entering and continuing the same.
 Eighth On or about June 2Sth. A. D is-z, certain of the emnloyes in th, plaintiffs said mill, including certain O he defendants, persuad ded, as the plain in is informed and believes, others f, ioin them and as the plaintiff is informe, and believes, by threats coerced stil others 10 join them and all left the plain ths employ. and by reason thereof tn operation Of the plaintiffs said mill he cams so restricted. unbalanced and dis organized that 1t became necessary t dose said mill
 Ninth: For a period Of nineteen day A. ,. plaintiff made no attempt to operate 1t 7ld miu or 10 employ any person or per sons except for the purpose of protectin us property. moving and shipping manu tacrured goods. and receiving and storin supplies. coal and the like, but durin Eaid nineteen days the defendants in fur ther pursuance of their conspiracy. ar noyed, importuned- threatened and other wise interfered with and intimidated sue employees Of the plaintiff as were en ployed by 1t during the period afor, said, and also annoyed, importuned an otherwise intimidated such employees ( the plaintiff as were willing to return their employment with the plaintiff
 Tenth; Tho plaintiff shows and avel lnat In pursuance of said eonspiracy fl 1eiendants, particularly certain of u defendants individually named, since tf llth day of July, 4. D. 1922 when fl plaintiff resumed operation of it's sa mill. have continued and still are col unuing and have been and are engage tl In uulawfully causing, persuading ar endeavoring 10 persuade, entice and i, luce the plaintiffs employees who ha, returned 10 their work to leave the er pioy Of the plaintiff and to violate the contracts of employment with the plaf tn e in unlawfully preventing and e ueavorinB 10 prevent all persons desiro st entering the plaintiffs employ fro doing so. and C3) for the purpose of i Initiating the employees of the plainti n navigating, encouraging and directil large numbers of persons to congrega In the vicinity of the plaintiffs said pla and manufactory and to congregate ne and In the vicinity of the places whi The plaintiffs employees are accustom To visit in going to and from their wo ana to congreRate upon the public stree along which they pass and adjacent
 and in the vicinity of the homes of t plaintiffs employees. and elsewhere
 the hours in which said emnloyes a accustomed 10 go to or return from tn, work
 Eleventh And the plaintfff shows th .E....