hensive "of 8 complaint The following matter is " compro tk nem of one hundred thanand damiagess "The vefelm. ariact out ioluintif ellegee to have been ant lar rai fondncted by menbera Shanghel Atwnieipel Police on premises at Now 105, North, Road on Apri titeves," being outside of Tonnuavice ussd therefore saithout the Jurlediction "of the Seldtement onthe We copy of the complaint ain't feceleed 4 ropy ing, petition, nine that te atatencente ave merely miki che paint, The Petition The petition states that Huang Gee-tong is a citizen of the United States, and lessee of the premises situated at No, 104 North Szechuen Road, where he is conducting, the sole proprietor a hat manufac turing factory under the name and style of the Kwoon Mee Hat Factory.
The defendant (the petition con= tinues) isa body politic of limited powers, organized and existing une der and by virtue of treaties enter into between the Republic of China, the Empire of Great Britain, the United States of America and other powers, and is subject to the isdiction of the Court of Foreign Consuls, The complaint alleges that,.on for about April 20 of this year, memo hers of the Shanghai Municipal Police Force and other servants em. ployed by tie defendant, "wilfully, wrongfully, maliciously," wantonly, without due process of Law, and without permission of the plaintiff forcibly broke into and entered premises at No, 104 North Szechuel Road of which plainti' is the lessee ud occupant. by threats, me Uimidation, forse and vinlenee, took possession' thereof and wilfully, wrongfully, maliciously, wantonly, without due process of law and without the consent of the plaintiff, then and there with prove earclessnest and reckless indifference—to Plaintiffs property rights, conducted a search of the entire tuid pres mises "False Representations"
The petition goes on to allege thet, on yr about April 29, members of the SMP. and other servant employed by the Council "by fal representations" secured from the International Mixed Court a search warrant to enter and search the plaintiffs premises, Further, that or about the same day members of the and other servants of the Council represented to. the Judge of the United States Court for China that the plaintiff's premises were leased by an American citizen, and falsely represented that those premises were in the Inter= national Settlement; that they also falsely represented to the Judge of the United States Court that the American lessee bad sublet the premises to a Chinese citizen wits occupied tem, and that they had secured a loyal "cure warrant from Mixed Court to search the pre mises pecanes it wise believed ted that gambling was carried, on there by Chinese, ard "there requested and obtained a visa iMegal warrant by the United States Court." The petition further alleyed that the police were well aware that the premises were not in the Seltlement and were not with= in the jurisdiction of the Settle men authorities, and that they also knew that the premises were leased to an American citizen and not to a Chinese citizen, The petition alleged that similar false representations were made to the Consul for Portugal to the effect that the premises were sub-let to Portuguese citizen, defendant's servants thus obtaining the visa of the Portuguese Consulate to the warrant bby these false representations.
"Intimidation and Abuse", The petition alleged that at time prior to during, or subsequent.
Text read from the printed page and cleaned; old type leaves the occasional error.