The Connecticut labor news., 1923-09-01

ready and willing to comply with all the laws of the American Federation
 of Musicians
 1 ssOn or about the 12th of June, 1923, the said defendants, together
 with certain other persons, unknown
 to this plaintiff, conspired together 1 for the purpose of injuring and de- stroying the plaintiffs said business, which conspiracy still exists.
 | Pursuant to the said general con 1 splracy and as part thereof the said | defendants refused to permit any
 member of said Local No. 235 or of 1 the American Federation of Music ians to enter the employ of the plain tif's orchestras in said theaters, and refused and prevented members of Local No. 235 to make contracts with | the plaintiff to furnish~music for said theaters, though said members were willing and anxious to make said con tract and to furnish music and furth- CT refused to give any transfer cards so-called, to any member of the American Federation of Musicians, who desired to come to Norwich and
 enter the employ of the said plaintiff as musicians.
 And Ill further pursuance or ob jects of said conspiracy the defend ant Lang, by and with the knowledge and direction of the executive board of said Local No. 235, and of other defendants, on the 10th day of Au-
 gust, 1923, refused to give a contract blank to one Floyd Christman, a member of the local so that said Floyd Christman could make a con- tract with this plaintiff to furnish
 music for the said theaters of the plaintiff, though the plaintiff was ready and willing to abide by all rules and regulations of the American Fed leration of Musicians, and further re- fused permission to any member of Local No. 235 to make any contract with the plaintig to furnish music for the said theaters.
 Under the laws of the American
 Federation of Musicians the plaintiff has the right at any time to hire as leader of an orchestra any member Of conspiracy herein before set forth, the plaintiff is prevented from engag- ing any member of Local No. 235, or of the American Federation of Music ians as a leader, and no member of Local No. 235 can accept any engage ment to furnish music for the plain tiff
 Also on said August I6, 1923, and in furtherance of said conspiracy the defendant Lang, stated<that Local No. 235, would permit no member to make any contract to furnish music for the plaintiff unless he, the defendant, Lang, was engaged as leader and that the contract would contain no (two week clause) and that the plaintiff must give bond, and further that the American Federation of Musicians had ordered Local No. 235 to make no other contract than as above set forth. The defendant Lang, the ex- ecutive board of Local No 235, and the defendants as well as other mem bers of the Local No. 235, knew or should have known that no such con- dition or contract had been demanded of the plaintiff by the American Fed eration of Musicians, but said Lang, the executive board and the other de fendants made said conditions in furtherance of it's said conspiracy.
 "On August 20, 1923, George Tuon
 telotte, member of Local Mo- 235, and former leader of the Broadway Theater orchestra, was requested by the plaintiff to make contract with him to furnish music for the Broad way Theater or Strand Theater, but was not allowed to do so by Local No. 235, and the defendants, in furth- erance of it's said conspiracy.
 "As result of the actions and con spiracy as above set forth the plain tiff has been compelled to hire non- union labor with which to operate the Strand Theater and by reason of employing said labor is unable to secure certain vaudeville acts, Is un- able to secure or engage union nov ing picture operators, to engage union stage hands, or to have legitimate one night stands so-called, such class es and performers being members of organized bodies which are affiliated with the American Federation of Mu- sicians, through and in connection with the American Federation of La bor and refuse and decline to accept employment or to give performances in any theater, the orchestra of music ians of which are members of the American Federation of Musicians which facts were well known the de fendants and each of them and with the result intended by them in the formation and carrying out ot the said conspiracy.