Great Falls tribune. [volume] (Great Falls, Mont.) 1921-current, 1922-01-20

said prison, produce of the poultry
farm and of ranch known as the val
iton ranch, produce from other farms
and properties connected with SAID
state prison, livestock, farm imple-
ments, tools, machinery and accessories
generally of the said institution.
VI. That the said state prison has
a great number of departments and
enterprises; that each of said depart
ments or enterprises during said time
had a large number Of accounts and
forth in Exhibit "a" questions the con-
department of the said state prison
while in the control of said defendant
during said time.
VII. That by reason Of the great
number of transactions with many in
dividua,s and organizations, concerning
property belonging to the Montana
state prison it is impossible to ascer-
tain the amounts involved in and ma
ing: that copy of the report herein
above referred to is hereto attached
and marked Exhibit A" and by this
reference made part hereof for the
purpose of informing the court of the
nature, number, complexity and I'M
certainty of the various transactions
and also in order that an accounting
may be had as to all of the transac
tions herein questioned; that in order
that the rights of the plaintiff and de-
PENDANT be adjusted defendant should
be required to show all of the trans
actions had concerning the plaintiffs
property since about the month Of Jan
uary, 1911, and especially since the
plaintiff abolished the contract system,
and showing each and every transac
ton involving the rights of said par
ties while defendant was acting as war
den of the state prison which in any
manner relate to the adjustment and
settlement Of the accounts between
plaintiff and defendant and which will
in any manner aid the court in adjust
ing the rights between plaintiff and
defendant
That the matters involved in the ad-
justment of the accounts between plain
tiff and defendant are of great public
ton in one action, and that by. in
Guiding them in one action there will
be great saving of time and expense
to the state.
VIII. That complicated transactions
and accounts covering said period of
years are involved in the charges in
the said report, that accounts of the
said various transactions between the
defendant and other persons are in the
possession of the defendant, and the
facts involving the said transactions
and said charges are peculiarly within
the knowledge of the defendant; that
plaintiff has not complete knowledge
Of the said transactions, and it is i'm
possible to ascertain the full nature
of said accounts or to make certain
that any money that may be found to
be due the state of Montana may be
recovered without an accounting, and
without the aid Of the equitable powers
herein prayed for; that because Of the
said charges multiplicity Of suits
would be necessary to determine the
rights as between the above named
parties in actions at law; that to bring
the various actions at law necessary
to determine the rights of the parties
hereto would necessitate great expense
to the state of Montana and involved
and protracted litigation that might
be prolonged for years: that the proper
adjustment of the rights between plain
tiff and defendant is of great pJhlic