Leonard Hickox, Isabella Hickox, G. Martin, J. C. Hogeland, , Bernard Eking, Daniel Brown, Reuben H. Loomis, S. M. Wather, J[ohn] C. McIntosh, , Jacob Jones, J. C. Wright, George Beagle David W. Vrooman, J. A. Chadsey, Lewis Tille, James Clark, and Christian Bidaman, claim to have title severally to some part of said tract of land last aforesaid and also to some part of the lands herein before described but to what part any of said defendants claim title your Orators are not informed and cannot state and are wholly uninformed as to the source from which they claim title, and charge that they have no title to the same or any part thereof and that their said claim of title is in fraud of the rights of your Orators as such creditors.
And that in purchasing or obtaining said pretended claims they severally had full notice of the fraudulent conveyance aforesaid.
Your Orators further state that the following Lots and Blocks in the City of are laid out on said last mentioned quarter section and to all of which the above statements and charges in relation to said quarter section apply to wit:—
Blocks 116, 117, Lot No. 2. on Block No. 118, Block No 119 Lots 1, 3 and 4 on Block No. 120, Block 121, Lots nos, 1, 2 and 3, on Block 122, Block 123, Lots Nos. 1, 3 and 4 on Block No. 124, Lot 1 and South half of the North half and 40 ft. wide East end North half of the North half of Lot No. 2, all lot No. 3 on Block No. 125,
The South fourth of lot No. 4 on Block No. 126, Lots 1, 2, and 3 on Block 127, Lots 2, 3 and 4 and West half and S. E 1/4 of L. 1 on Block 138, Lots 2 and 3 and the North East fourth of lot 1, on Block No. 139 Lots 2, 3 and 4, on Block 140, Lot No. 2 and the West one fourth of four on Block 141, Blocks 142, 143, 144, 145, Lots 1, 2 and 3 on Block 146, Lots 3 and 4 and the West half of Lot No. 1 on Block No 147, Lot No. 2 on Block 148, Lots 1 and 2 on Block no. 149, Lot 1 Block 154, Blocks 155, 156, 157, Lots 1, 2 and 4 on Block 158, Blocks 159, 160 and 161.—
Your Orator further states that all the foregoing lots, blocks and tracts of land, are situated North of the base line and West of the 4th. Principal meridian in and within the County of .
Your Orators further state that they are informed and believe that the persons in possession of many of the foregoing tracts of land and town lots have permitted the same to go to sale for taxes and that tax titles have accrued thereon.
And charge that said lands were so permitted to be sold for taxes and tax titles permitted to accrue thereon for the purpose of casting a shadow over said title and of hindering, delaying and defrauding your Orators in the collection of their said [p. 500]