Wilbur Wright, Plaintiff vs. Orville Wright, Defendant
Case No. 1,000,004
1. And now comes plaintiff and says that he is a member of
the firm of Wright & W'right, a firm doing a general printing and
press-manufacturing business in the city of Dayton, Ohio. That Orville Wright
the defendant is the other member of said firm.
2. Plaintiff further says that on or about the day of July,
1892 said firm entered into contract with Mathew and Light, printers, to erect
for them a Wright re-re-Wright improved press of new and improved design, for
which services said firm, of which the said plaintiff and said defendant were
equal partners, the sum of $250.00 in cash.
3. Plaintiff further says that about the day of August,
1892, it was mutually agreed by the partners to said firm that Orville Wright
should labor for L. Wright at printing and that Wilbur Wright shouJd continue
the work of constructing said press, but the wages earned by said Orville
Wright were to be the property of the firm afore said.
4. Plaintiff further says that a difference of opinion
having arisen in said firm as to who was doing the least work said defendant
Orville Wright having exhausted his vocabulary, in order, as this plaintiff
firmly believes, to further insult said plaintiff, insisted that said
plaintiff instead of working on the press, should also work in said printing
office, at girls work, although said defendant well knew that the pay for such
work was but small and that said plaintiff being unfamiliar with such work
would be able to accomplish but little.
5. Plaintiff further says that he understood such
proposition by said defendant to be intended as an insult, and he knew, as did
the defendant, that there would be financial loss to the firm thereby,
nevertheless said plaintiff acquiesced in said proposition for the sake of
peace in said firm.
6. Plaintiff further says that he worked in said office for
a number of days and that said defendant collected from L. Wright the
proprietor of said office the sum of $ for the services of said firm of Wright
& Wright aforesaid, for the time both members of the firm worked at
printing and binding.
7. Plaintiff further says that subsequently said partners
in said firm entered into an agreement whereby said plaintiff agreed to assume
all expenses attending the construction of said press and finish said press,
and further pay said defendant the sum of $15 for labor upon said press,
whereupon said plaintiff was to secure entire control of said press and was to
receive all of the. $250.00 which said firm was to receive for said press. It
was also agreed that the money earned by said defendant in the office, while
said plaintiff was at work on the press, was to be retained by said defendant,
the plaintiff receiving pay for his work out of the $250.00 aforesaid. It was
further agreed that in all other matters the partnership should continue as
8. Plaintiff further says that when he demanded his share
of the sum collected by said defendant for the services of the firm while both
members worked in said office and work on the press was suspended, said
defendant refused, although said plan had been opposed by said plaintiff and
had been entered into, merely to afford said defendant an opportunity to
insult said plaintiff and to taunt said plaintiff with the statement that his
own services were being paid for at the rate of two dollars and a half &
day, while only a few cents a day was being collected by said firm aforesaid
for the services of said plaintiff; but said defendant proposed to settle on a
basis of $2.50 per day for his own work and a few cents a day for the work of
9. Plaintiff further says that while, as a member of said
firm, he is willing to stand his share of the expense entailed upon said firm
for the gratification of the pleasure of said defendant alone, nevertheless he
is not willing that said defendant should have all the fun, and said plaintiff
all the expense.
10. Plaintiff further says that he was first insulted, then
cheated, and then accused of having a dishonest and tricky business character
as instanced by his application for his share of the money earned by said
firm, while the work on said press was suspended.
Wherefore said plaintiff prays an order issuing out from
this court directing said defendant to pay said plaintiff one-half of the
money collected by him in behalf of said firm for work in office, while work
on the press was suspended, and further prays an order directing said
defendant to apologize for his insulting conduct, and requesting him to keep
his mouth shut in future lest he should be again guilty of befouling the
spotless and innocent character of others.
Atty - for plaintiff.