Norwich bulletin., 1922-08-09
LEGAL NOTICE

streets in front of and near the plaintiffs i premises, ill front of or near the houses ployes, and along the streets where the | plaintiffs employees pass to ana rom their work and the said ptckets nave followed and caused others to follow the | plaintiffs emnloyes upon the public | streets in an annoying and intimfdatlng | manner, and for the purpose and with 1 the result Gin many instances) or thereT l by compelling said employees to leave the | plaintiffs employment or to deSlSt from | returning to or to refrain from entering 1 the plaintiffs employment and for the l further purpose of in]uring ana running the business and good will of. the plain tiff And the plaintiff shows that the acts aforesaid still continue and it is in formed and believes and therefore ayers will continue indefinitely and until the business of the plaintiff is irreparably in jured and damaged unless restrained as hereinafter prayed.
 Thirteenth On or about July 17th, A. D. 1922, and on other days and dates between said July 17th, A. D. 1922, and the date, of this complaint. by reason of the picketing heretofore mentioned, the approaches to the plaintiffs said mill and the five gates or entrances to the
 plaintiffs said mill were picketed by the defendants and persons melted by them, and 1t has been necessary to call for certain public officers, to4wit: deputy sheriff and many special deputy sheriffs of said Windham County, to move the crowd of pickets who were shouting in- sulting remarks and epithets at the workers, and the pickets were only kept moving by said officers.
 Fourteenth: The plaintiff further shows that on or about the 1st day of August, A. D. 1922 one of the plaintiffs em- ployes was threatened by the defendants that we shall make your life pretty short" if the said employe did not stop working at this scab mill"
 Fifteenth: The plaintiff desires to op- crate it's said plant to it's. full capacity. but it shows that, although. it has at tempted to do so, said operation has been rendered practically impossible by reason of the acts aforesaid, and that it is op- erating it's said plant only under the greatest difficulty and only to a. very lir-.-ed extent. The plaintiff further shows that it has been delayed in fulfill amount of money and is unable to accept new business by reason of the acts herein complained of. It further shows that unless it is permitted to operate it's said plant in the usual way according to law and without molestation, the damage accruing by reason of said acts will be l irreparable. The plaintiff further shows | that, despite the efforts Of the deputy sheriffs as aforesaid, the acts of intinni- dation heretofore mentioned continue, and that the situation has become so acute that the plaintiff cannot be given adequate protection unless this Court in- | terposes it's decree as hereinafter prayed. | Sixteenth: The plaintiff is informed | and believes and therefore ayers that the defendants intend to continue the afore- i said unlawful acts for the purpose of running the plaintiffs business and good | will. And the plaintiff furthec shows | that the repeated and continued viola | tions of it's rights and the. rights of it's | employees by the defendants as above set | forth constitute a continued illegal, ma l licious and unjustihable interference with 1 it's business, property and other rights | are causing it irreparable damage and
 that unless said defendants are enjoined | NfloWN zs-.H l after contained, said violations will con- | tnue and will cause the plaintiff ire i parable damage and will lead to a mutt | plicity of suits
 i Seventeenth: The plaintiff has no | adequate remedy at law.
 The plaintiff claims:
 An injunction restraining the offend | ants, their respective agents associates | concert with the aforesaid defendants or any of them e in their behalf whether
 or not specifically named as defendants
 in the complaint from CD inducing or
 enticing any person now or hereafter | having contract of employment with
 the plaintiff to break the same .(2)- mo- testing. intimidating threatening. annoy
 ing or hindering, either by violence
 threats of violence. insults, indecent talk
 and abusive epithets, annoying language
 acts or conduct, or otherwise. any per
 son now or hereafter in the employ of the
 plaintiff. or willing to enter or desirous !
 manner whatsoever as is calculated tc
 coerce any such persons from. remaining
 in or entering said employment (3)
 molesting, interfering with or otherwise
 annoying any such persons, in any man.
 ner whatsoever, in proceeding to and
 from his or her place of abode upon the
 plaintiffs rgemiseS or in pursuing his or
 her way about the streets; (4) picketing
 either singly or in squads. or establish
 ing or maintaining any patrol or patrols
 or picket or pickets Or causing others tC picket, loiter, assemble congregate ei
 ises of the plaintiff or the vicinity oi
 the abode of any empioye or person will.
 ing to become or desrous of bCccning ar
 er@toye of the plaintiff, or on any street
 his hway or sidewalk along or across e ! by which said employees or persons pa $:
 in going to or from the premises of. tht plaintiff and their respectiye. ,abodes; (51
 entering into or continuing in any
 scheme. designing or conspiring amonf themselves or with others organized oi acting for the purpose of interfering yiti or injuring the plaintiffs business. VII or property, by molesting. intimi dating, obstructing, annoying or other wise interfering with any person. or per sons now or hereafter in the employrnen of the plaintiff or agreeable to CT desirou of entering the same (s) committing - any act of violence whatever or tres 9 passing in any way whatever upon tn
 premises of the plaintiff.
 5 Charles E. Aver of Killingiy, Connect . cut, is recognized in the sufficient sum Q y $10o to prosecute &c.
 Dated at Plainfeld. Connecticut, thi 2 Ith day of August. A. D 1922
 HARRY F. BACK. E Justice of the Peace. g State of Connecticut, County of Ne, = Haven. ss., New Haven, Aug. 7th, A, [ l. 1922.
 I, Harry Richardson. being dv, h sworn. depose and say that I am tn l. Superintendent of the plaintiff in tf l. foregoing writ and complaint, and that d have full knowledge of the facts state # in the foregoing complaint and that tn
 HARRY RICHARDSON. s Superintendent of The Aldrich Brother e Company.
 e Subscribed and sworn to by Harr e Richardson on the day and wear -abo1 d JAMES H. WEBB. ], Judge of the Superior Court d State of Connecticut, County of Ne ,- Haven, ss., New Haven, Aug. 7th, A. i i 1922.
 ,e Personally appeared, on. the day ar ir date above written: Harry Richardson !, Plainfield. Connecticut as principal ar 1- Charles E.. Aver of Killingly Connect is cut. as surety, ana acknowledged ther m selves bound unto Albert Wilson, loser n. Rocheforte,, Rhoades Paine, Micha ,g, Henry Parr, Adolph Monty, John Fla tss nigan, Henry Wood, Albert Lecla, o, Blanche Goodreau, and Industrial Uni, r No. 24. all of said Town of PlainfeI eb and Abraham Binns, Commorant of sa ,5 Town of Plainfield- in bond of SI O 1i, that they will answer all damages .n case the plaintiff in the above and for to going action in which an injunction e.oo applied for, shall fail to prosecute at said action to effect
 M Mat JAMES H. WEBB. ';r A Judge of the Superior Court.
 The above and foregoin~ original " at and complaint in the action of T