defendant Jabez J. Piggott claims to own and holds in possession.
Also Blocks 113 and 115 which the said defendant Solon Stark, a resident of , claims to own and holds in possession
Also the South one fourth of Lots 3 and 4 in blocks 88, 89, 90;
Block 93; Lots 2 and 3 in Block 100; Lot one in Block 101; Lot 1 in Block 102; Blocks 103, 104, 105 and 106; Lots 3 and 4 in Block 107; N 1/4 of Lot 3 in Block 108; Blocks 111, 112, 114, 128, and 129; Lot 3 in Block 134; Block 136; Lots 1 and 2 in Block 150 and Lot <3> in same Block, except the East 75 feet; Lots 2 and 3 in Block 151and Block 153; which the said defendants , James Clark, Reuben H. Loomis, John Wilkie, , John C. Bidaman, E. Mayor, , , B. Gilbride and John Griffiths claim to own and hold in possession, but what part or which of said lots or Blocks are claimed and held by said defendants respectively is unknown to your orators and they cannot state, but pray that said defendants respectively may in their several answers state and define the limits of their several possessions and claims of title.
Your Orators further show that the said Joseph Smith deceased, was in his lifetime the Trustee of a pretended religious society called the Church of Jesus Christ of Latter Day Saints, and that the defendants above named and described as being in possession of the Lots and Blocks above described of which the said Joseph Smith died seized, respectively claim their pretended titles to said Lots and Blocks as your orators are informed, under certain conveyances executed by the successors of the said Smith in said office of Trustee of said pretended religious society, said successors undertaking to convey said Lots and Blocks of which said Smith died seized, individually, merely by virtue of being his successors in said office and without any authority derived from said Smith;
Your Orators further show and charge that said conveyances are wholly fraudulent and void as against your orators, but they constitute a cloud upon the title to said premises and would prevent said premises from being an adequate price if sold upon an execution issued on the said judgement of your Orators without the aid of this Court.
Your Orators further show that the dates and parties to said conveyances in deta[i]l are unknown to your orators and they cannot describe them more particularly, and they pray that said defendants may be required to state fully in their respective answers in what manner they acquired their respective pretended titles to said lots, and to exhibit to this Court with their answers hereto, the conveyances [p. 494]