Petition For Declaratory Judgement and Permanent Injunction.

Allegations Common To All Counts.

Comes now plaintiff Honey’s Restaurant and Pub, L.C. and states:

1. Plaintiff Honey’s Restaurant and Pub, L.C., is a Missouri limited liability company in good standing, operating in Carthage, Jasper County, Missouri.

2. Defendant City of Carthage, Missouri, is a Missouri municipal corporation or body located entirely within Jasper County, Missouri.

3. Plaintiff is duly licensed by the State of Missouri, the County of Jasper, and the City of Carthage to operate a restaurant bar and to dispense liquor by the drink from Monday through Saturday.

4. As the holder of such licenses plaintiff is entitled pursuant to § 311.097, RSMo., having met all other applicable requirements of the law, to obtain a Sunday sales license, save the City of Carthage has ordinances which prohibit such sales, including without limitation, § 3-61 and § 3-64, Carthage Ordinances.

5. As a result of the defendant’s prohibition of Sunday sales, plaintiff has been denied its right to obtain a Sunday sales license from the State of Missouri and suffered losses in sales, and because of state law requirements each Sunday plaintiff has had to remove and put under lock and key all liquor, and render beer taps unusable in order to sell food at considerable time and expense. Furthermore, plaintiff, its officers and employees, are subject to municipal prosecution and loss of its current license if it attempts Sunday liquor sales.

6. The ordinances aforesaid are in conflict with state law and accordingly are null, void, and invalid as prohibiting Sunday sales when the same are upon proper license, authorized.

7. Plaintiff has no adequate recourse at law.

COUNT I

For Count I plaintiff states:

8. Plaintiff incorporates all allegations set forth in paragraphs numbered 1-7 above.

9. Plaintiff requests the Court to declare the law applicable to the facts that the ordinances which deprive plaintiff of privileges accorded by § 311.097, RSMo., are invalid.

WHEREFORE, plaintiff prays for a declaration of law declaring § 3-61, 64 Carthage Ordinances of the defendant invalid, and costs.

COUNT II

For Count II plaintiff states:

10. Plaintiff incorporates all allegations set forth in paragraphs numbered 1-9 above.

11. That unless the Court enters an injunction prohibiting enforcement of said ordinances, plaintiff will suffer immediate and irreparable injury, loss, or damage.

WHEREFORE, plaintiff prays the Court to permanently enjoin the defendant from enforcing or threatening the enforcement of § 3-61, 64 Carthage Ordinances aforesaid, and costs.

Roberts, Fleischaker, Williams,
Wilson & Powell
Attorneys for Plaintiff

I don’t know ‘bout you, but ever now and then the person that writes the "Teens to Tots" column that is published in this paper really gets on my nerves.

In yesterday’s paper the suggestion was to loosen up a little on restrictions placed on kids with tv’s and telephones in their rooms. Not fair to let them have such instruments of destruction and restrict use to only weekends. Oh boo, hoo. Poor things.

If that’s such a problem, I’ve got a sure fix, take ‘em outa the room. Then they won’t have ta feel bad havin’ a tv and not bein’ able to watch it.

I’m guessin’ the kids have figured a way ta hook up head phones and watch the set whenever they want anyway. Set some rules and stick too ‘em, the kid will adjust.

This is some fact, but mostly,

Just Jake Talkin’.

by

Carthage Printing Services

PRIME TIME WITH KIDS

by Donna Erickson

Turn holiday and all-occasion greeting cards into nifty gift boxes. These easy-to-make boxes are ideal for wrapping flat items such as a handkerchief, photo frame, jewelry, collector’s baseball, football or basketball cards, CDs or a ticket to a movie, concert or play.

It’s especially fun for kids to choose cards to suit the personality of the person receiving the gift. For the romantic, pick a card illustrated with roses or a beautiful country scene. Or, look through your old cards to find one with writing on it to fit the occasion, such as "Happy Birthday to a Special Aunt."

The illustration might also provide a clue for guessing the contents of the box. A snowy, wintry scene of the mountains would be a perfect choice if the gift is a lift ticket for a day of skiing!

Here’s how to make a box that is 3/4 inch deep: Cut a standard-style greeting card along its center fold. The front of the card will be the lid of the box. The back of the card will become the bottom of the box. Trim this piece 1/8 inch on all four sides, since you will want the bottom of the box smaller than the lid. If you wish to cover the verse or message on the inside of the card, glue a piece of construction paper on top.

Start with the top of the box. On the back side of the front of the card, measure and draw (with a pencil) four lines the length and width of the card 3/4 inch from the edges. Follow one of the lines at each corner and use scissors to cut a 3/4-inch slit at each corner. Fold the card along the four lines, bending the corners where you have made the slits. Add a drop of household glue to the corner flaps to hold them in place.

Measure, clip, fold and glue the bottom of the box in the same manner. Let glue dry. Trim a piece of tissue paper and place in the box with the gift. Tie with a ribbon and your gift is ready to give.