2. That Gen. C. H. McCarthy, of St. Paul, Minn., was unjustly and deliberately excluded from the Boston convention, and subsequently shamefully persecuted and driven from the order, and that Alexander Sullivan, Michael Boland, and D. C. Feeley are responsible and censurable for that series of reprehensible acts.
3. That delegate from home organization was excluded from the Boston convention, and that the same three defendants are responsible and censurable for that exclusion.
4. That the same defendants issued a deceptive report to the Boston convention, leading the order to believe that its affairs had been examined by independent committees, and that the order was $13,000 in debt; that, in fact, Alexander Sullivan and Michael Boland were on the committee of foreign affairs, and the Treasurer states that there was a balance in the treasury and not a debt.
5. That prior to the Boston convention one hundred and eleven thousand ($111,000) dollars was expended without any direct or indirect benefit to the order, and most of it in a manner that could not in any way have benefited the order, and that the same three defendants are censurable and responsible for this enormous and wasteful expenditure.
6. That this enormous sum was spent without the sanction or knowledge of the home portion of the R. D.
7. That various persons sent abroad were not supplied with sufficient funds, and that the agent of the Triangle is responsible and censurable for that criminal neglect, and not the three defendants.
8. That Michael Boland and the late Secretary of the I. N. B. issued fraudulent transfers, for the purpose of deceiving the order in Philadelphia into believing that the union with the home order had not been broken.
9. That Michael Boland and D. C. Feeley, the former by acts and the latter by assent, are guilty of attempting to pack the Pittsburg convention by, first, excluding the delegate from the Pacific Slope; second, excluding Mr. McLaughlin, delegate from Dakota; third, excluding O'Sullivan and Delaney, rightful delegates from New York; fourth, admitting the Rev. Dr. Betts and John J. Maroney, on bogus credentials from the bogus districts; fifth, admitting Boland and Malone, illegal delegates from New York; sixth, admitting proxies from Iowa, Brooklyn, and Illinois; seventh, sitting as delegates themselves in direct violation of the constitution.
10. That the $80,491, reported to the district convention as having been spent in active work was not spent for any such work, no such work having been done or contemplated during the eleven months within which this large amount was drawn from the treasury. The active work done between the Boston and other district conventions, was paid for out of the surplus held by the agent of the Triangle at the time of the Boston convention, and not out of the $87,491 drawn from the treasury months after such active work had ceased.
11. That Michael Boland and D. C. Feeley, the former by acts and the latter by silence, are responsible for the expenditure of this large amount of money, and censurable for deceiving the district convention as to the purpose for which it was spent.