"And the defendant further says that from about the 8th day of February 1885 to and until the 20th of February 1885 plaintiff refused to perform any of the parts set down for him to sing, or to attend rehearsals, or to obey calls as they were sent to him, and generally conducted himself in a brutal and insubordinate manner. That on the 20th of February at said City of Chicago this defendant with great difficulty persuaded him to act and sing in the part of 'Arturo' in the Opera of _I Puritani_, but before said last named day, he had been regularly and formally notified and called to the rehearsals of the Opera of _Mignon_, and to rehearse, and sing the part of 'Guglielmo,' and he refused so to do, and tore up the calls, or notices sent to him therefor, and threw them in the face of defendant's messenger. The said Ravelli was announced to the public to sing the _rôle_ of said 'Guglielmo' in said opera of _Mignon_ in all advertisements and notices for the 19th day of February A.D. 1885, but wholly refused and neglected so to do, and also neglected and refused to appear and sing in the _rôle_ of 'Don José' in _Carmen_, announced in bills and advertised for February 20th, 1885. "That after this defendant had as aforesaid persuaded said Luigi Ravelli to sing in the part of _I Puritani_, he continued to sing until the 13th March, at which time this defendant was with his Company at the City of Denver, in the Territory of Colorado, at which time and place he again without reason or excuse neglected and refused to sing in a public concert advertised and given in said City by this defendant. "That thereafter and until the 6th of April 1885 said Ravelli was insubordinate, disrespectful, and self-willed in all his relations with this defendant, and falsely pretended to be unable to sing with the exception of two occasions, and on each of such occasions, without permission of this defendant, and without notice, he wilfully omitted the various principal airs and songs in the presence of the public who had paid to hear him sing the same, thereby causing this defendant great annoyance and loss by reason of the disappointment of the public, and the ill-will of the public towards this defendant caused thereby. That during the past four weeks during which this defendant has been with his said Company in the City and County of San Francisco the said Ravelli has repeatedly wilfully broken his contract, disappointed the public and greatly injured this defendant in his enterprise in business. He has sung only twice during all said period, and on his first appearance wilfully and maliciously omitted to sing a principal part of the music set down for him to sing, thereby disappointing the public, interrupting and injuring the representation and inflicting great injury and loss on this defendant.