meaning thereby that the Plaintiff had been guilty of a Criminal offence had abducted girls for immoral purposes that he had been a party to the seduction of girls of tender age and had been a leading instrument in, and had lived on the prostitution of 50 girls and had made a large sum of money by such prostitution and for purposes of gain consorted with procurers and procuresses.

5. On June 15th 1909 the Defendant falsely and maliciously wrote and published and/or caused to be printed and published of and concerning the Plaintiff and of him in his capacity of Assistant Secretary of the Fermanagh County Council in a certain handbill or pamphlet under the heading "The White Slave Trade in Cunning Veils" the following words:

"William Irvine…conspired with…William H. West, (meaning thereby the Plaintiff) Secretary to the County Council, Fermanagh, with Ernest W. List, Debenham, Suffolk, to detort girls…to use for improper purposes across the seas in an irreligious way in the modernised Mormon way…These conspirators utter highly offensive blasphemy, too gross for paper and ink, using indecent, obscene profane words—are vagrants, begging without any visible means of earning an honest livelihood, obtaining money, food, and lodging through false pretences, misrepresentations, fraudulent statements, are outlaws, decoying girls for immorality and Oriental Harems, to wit: a Suffolk girl kidnapped at the age of 19, taken to Modernised Mormon Portuguese Chapel, Durban, South Africa; a Suffolk girl, kidnapped at the age of 22 by Irvine and taken to F. A. Hughes, Harlot-Monger, Maza Towner Co., North Dakota, who narrowly escaped an inferni pit. An Irish girl aged 22 kidnapped by Elliot or his Co-workers, taken to evil seducers at Lang, Ontario, who narrowly escaped a death trap to tell the sad tale. An Enniskillen girl cuddled away by Irvine to 48 Duncan Street, Dunedin, to catch Maori girls. Thirty-six girls taken away from their chapel in Leadbetter Street , Belfast , for Oriental Harems. Fifty girls taken from Crocknacrieve, see the “Irish Weekly Independent,” Augt. 24th, 1907, for Oriental Harems."

meaning thereby that the Plaintiff had been guilty of a criminal offence and had abducted girls for immoral purposes, was a hypoctite and conspirator guilty of blasphemy, and for purposes of gain consorted with procurers and procuresses or women.

In particular the said words were published to the chairman of the Fermanagh County Council being enclosed in a postal packet or envelope posted to him by the Defendant on the 18th September, 1909.

6. On September 8th, 1909 the Defendant falsely and maliciously wrote and published of the Plaintiff and of him in his capacity of Assistant Secretary of the Fermanagh County Council in a reply paid telegram of that date sent by the Defendant to the Secretary of the said County Council and to William West (meaning thereby the Plaintiff) the following words:

"Wire immediately Edward Cooney's address wanted for police to track him to manslaughter or murder and obtaining money housing food and girls for immorality.  Reply paid. Wilson, Cretingham"

meaning thereby that the Plaintiff had been guilty of a criminal offence, and of gross misconduct in the discharge of his dutires as Assistant Secretary of the Fermanagh County Council by concealing or harbouring a criminal. 

7. On September 16th 1909 the Defendant falsely and maliciously wrote and published of the Plaintiff and of him in his capacity of Assistant Secretary of the Fermanagh County Council in a telegram of that date sent by the Defendant to the Secretary County Council Enniskillen the following words:

"Please request William H. West (meaning thereby the Plaintiff) wire me present whereabouts William Irvine Modernised Mormon who nets my girls a large sum in dollars for use of police Westmoreland County New Brunswick. Wilson, Cretingham"

meaning thereby that the Plaintiff had been guilty of a criminal offence, and of concealing and harbouring a criminal who was wanted by the police, and that the Plaintiff was an improper person to be employed in the capacity of Assistant Secretary to the said County Council.

8. On July 22nd 1910 the Defendant falsely and maliciously wrote and published of and concerning the Plaintiff in a telegram of that date addressed and sent to W. R. Cooney, Enniskillen, the following words:

"Advise Edward seek protection with the police with John" (meaning thereby the Plaintiff) and William West and George Walker, Crocknacrieve far better than threats of mothers of seduced daughters with vengeance and choice of 'Tar and Feathers' cat of nine tails."

meaning thereby that the Plaintiff had been guilty of a criminal offence and had seduced women and girls and was a grossly immoral person.

9.  In or about July 1910 the Defendant falsely and maliciously wrote printed and published or caused to be printed and published of and concerning the Plaintiff in a certain pamphlet under the heading "Treason and Plot. A.D. 1910," the following words :

"To Ministers and Congregations and Absentees ...I pray you put the question to the powers that be and to the police 'Will you institute new powers to deal with the White Slave Traffic'…Go Mr. W. H. West (meaning thereby the Plaintiff) (who 1 will send a copy of this to) Secretary of County Council Fermanagh (and let not this advice be like casting pearls before Swine) to thoroughly unearth this underground work in money and girls in countless thousands…”

meaning thereby that the Plaintiff was a criminal, was an aider and abettor in the prostitution of women and girls, was a hypocrite and an immoral person, and was concealing and harbouring criminals from justice.

10. On or about August 3rd 1910 the Defendant falsely and maliciously wrote printed and published or caused to be printed and published of and concerning the Plaintiff in a certain pamphlet under the heading "Treason and Plot A.D. 1910" the following words:

"50 GIRLS ENTRAPPED
Band of Women Criminals Caught.
Tullyhogue Dungannon, Co. Tyrone, Ireland,
May 8th, 1909.

 “A series of mysterious seductions has recently occupied the attention of the Press in various districts, including Ballina Mallard, near Enniskillen, in Ireland, the destination of several girls having been discovered under circumstances which pointed unmistakeably to foul play.

“There was no definite clue to work upon until a detective was employed, acting on certain suspicions, disguised as one of the fraternity, attended upon the kidnappers: Alice Pipe; Annie Smith; May Carroll; Emma Gill; J. Hughes; McClung and Company, Unlimited, in their Chapel in Leadbetter Street, Belfast, who was at once struck by highly offensive blasphemy emanating from these women during the temporary stay which was with difficulty concealed, but hearing sudden conversations behind the scenes, glanced around and saw the very girl, of tender age, of surprising good looks, who had been decoyed, that was sought for previously in vain. The detective dodged these seducers and obtained other detectives, who, on searching, found that other 50 girls had been entrapped.

 “A quantity of doggerel literature was found on them, and shortly after three of this woman tribe were arrested, who, according to their statements, constituted a band of robbers under the leadership or patronage of J. West (meaning thereby the Plaintiff), W. H. West...Most of these are enormously strong and masculine-looking, and have terrorized girls, silly as young geese, harmless as doves, into their traps during the last 17 years, who, of course, were unaware of the misdoings behind the scenes.

 “So far, these 50 seductions and others also have been traced to the gang, who netted by them a large sum of dollars.”

Meaning thereby that the Plaintiff was a criminal, was an aider and abetter in the prostitution of women and girls, was a hypocrite and an immoral person, was concealing and harbouring criminals from justice, resided in and kept a disorderly house, had been a leading instrument in the procuring of 50 girls for immoral purposes, that he had thereby obtained a large sum of money and for purposes of gain consorted with procurers and procuress of women.

11. In consequence of the premises the Plaintiff has been and is greatly injured in his credit and reputation and has suffered much annoyance, and has been brought into public scandal, hatred and contempt.

The Plaintiff claims damages.

GEORGE F. KINGHAM

DELIVERED this 2nd day of March, 1911, by Herbert Z. Deane, of 265 Strand, in the County of London, the Plaintiff’s Solicitor.