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1 United States Circuit Court, in Equity. Richmond Safety Gate Company vs. Samuel H. Ashbridge, et al. October Sessions, 1900, No. 44. Plaintiff's Brief 1900

handle is hein.trials/acps0001 and id is 1 raw text is: UNITED STATES CIRCUIT COURT. IN EQUITY. Richmond Safety Gate Company O I October Sessions, 1900 VS. VS No. 44. Samuel H. Ashbridge et al. J PLAINTIFF'S BRIEF. STATEMENT OF THE CASE. The plaintiff is the Richmond Safety Gate Company, a corporation organized under the laws of the State of Indiana. The defendants are executive officials of the city of Phila- delphia. The plaintiff manufactures a certain patented device which is a convenient and safe inclosure to protect the shaftways of freight elevators. It consists of a gate or door to close the opening into such shafts and also a device by which the said gate is raised and lowered automatically by the action of the elevator. The plaintiff has for many years been accustomed to deal freely in this device all over the United States and also in the city of Philadelphia. In December of the year 1899 the defendants, who are certain executive officials of Philadelphia, ordered plaintiff to cease the installation of its device within the limits of said city. In answer to the plain- tiff's protest the defendants stated that one of their number, Robert C. Hill, the Chief of the Bureau of Building Inspection of the city of Philadelphia, had been given authority by an

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