....five....years thereafter, which said judgment and sentence still remains in full force and effect, and not in any wise reversed, vacated or set aside, as by a certified copy of the record of said judgment and sentence, ready to be produced in Court, will more fully appear. IN TENDER CONSIDERATION WHEREOF, And forasmuch as your ....oratrix....cannot have adequate relief in the premises, except in a court of equity, where matters of this nature are properly cognizable and relievable. TO THE END, THEREFORE, That the said defendant may, if....he.... can, show why your....oratrix....should not have the relief herein prayed, and that....he....may full, true, direct and perfect answer make (but not under oath, answer under oath being hereby expressly waived) to all and singular the matters and things herein stated and charged. AND That the said....Henry Perkins...., defendant, ... his....servants, agents, attorneys, and solicitors, may each and all of them be enjoined and restrained from incumbering, charging, selling, or otherwise disposing of, or from attempting to incumber, charge, sell, or otherwise dispose of any of the real or personal estate of the said....Henry Perkins....until the further order of this Court; AND That the said....Henry Perkins....may be ordered to pay such sum as this Court shall deem reasonable and just for the support of your ....oratrix....and....her child....during the pendency of this proceeding; and a further sum for....her....costs and solicitor's fees in the prosecution of this case; AND That upon a final hearing of this cause, the said....Henry Perkins....may be ordered, directed and decreed, to pay to your....oratrix.... such further sum, in the nature of alimony, for the support and maintenance of....herself....and....child...., as to this Court shall seem reasonable and just; AND That the bonds of matrimony existing between your...oratrix........ and the said....Henry Perkins...., defendant, may be thenceforth and forever dissolved and annulled; and that all duties, rights, claims and obligations, accruing to either of the said parties by reason of said marriage, shall thenceforth and forever cease and be determined; and that the said parties be severally at liberty to marry again in like manner, as if they had never been married; AND That your....oratrix....may have the sole care, custody, and education of the said....child....; AND That your....oratrix....may have such further or other relief in the premises as to Your....Honor....shall seem meet, according to equity and good conscience; MAY IT PLEASE Your....Honor.... To grant unto your....oratrix.... the people's writ of injunction issuing out of and under the seal of this Honorable Court, to be directed to the said defendant, ....Henry Perkins...., and to....his....servants, agents, attorneys, and solicitors, therein and thereby commanding and strictly enjoining them, and each of them, from incumbering, charging, selling, or otherwise disposing of, or from attempting to incumber, charge, sell, or otherwise dispose of any of the real or personal estate of the said defendant, ....Henry Perkins...., until the further order of the Court, AND MAY IT PLEASE Your....Honor.... To grant unto your ....oratrix....the writ of summons in chancery issuing out of and under the seal of this Honorable Court, to be directed to the said defendant, ....Henry Perkins...., therein and thereby commanding....him...., by a certain day, and under a certain penalty, to be therein inserted, that ....he....personally be and appear before this Honorable Court, then and there to stand to, abide and perform such order, direction and decree therein as to Your....Honor....shall seem meet, according to equity and good conscience. AND Your....Oratrix...., As in duty bound, will ever pray, etc. ...WILLIAM LONG.... ALICE MANN PERKINS.... ....Solicitor....for....Complainant.... ....Alice Mann Perkins...., being duly sworn, says that....she....is the Complainant whose name is subscribed to the foregoing Bill of Complaint; that....she....has heard the above Bill of Complaint read, and knows the contents thereof; that the said Bill of Complaint is true of....her....own knowledge, except as to the matters and things therein stated to be upon information and belief, and as to those matters and things....she.... believes it to be true. ALICE MANN PERKINS.... NOTE. Should be acknowledged before authorized official. See No. 17. Naturally, only such of the above grounds as exist should be included, and other statutory grounds may be substituted, if any such there are. Not all the relief here prayed for need be included. Sometimes the wife does not request alimony, and it is seldom asked where the husband is suing the wife. Paragraphs as to property owned by defendant may in such cases be omitted. In the....Circuit....Court of....Cook.... County. ....Albert Bennett, Complainant.... V. ....Charles Bell, >In....Chancery.... Gen. No....1716.... To the Honorable....Judges....of the. ...Circuit....Court of the County in the State of.....Illinois. Defendant... of.....Cook. Sitting.... XIV-44 ..... 689 in.....Chancery Your....orator, Albert Bennett...., of the County of....Cook....and State of....Illinois...., respectfully....represents....unto the Court, that on the....third....day of....June....A. D....1910, Charles Bell... of the County of. ...Cook....and State of....Illinois...., being indebted to your....orator....in the sum of....Two Thousand ($2,000.00).... Dollars, made and delivered to your....orator his....certain.... promissory note.... of that date, and thereby promised to pay to your....orator, four years.......... after date, the said sum of....Two Thousand ($2,000.00)....Dollars, with interest at the rate of....six....per cent per annum, as will more fully appear by the said....note...., ready to be produced in Court, and by the copy of the same herewith filed and marked "Exhibit A,” and made part of this, your....orator's...., bill of complaint. Your....orator....further....represents....unto the Court, that to secure the payment of the principal sum and interest above mentioned, the said....Charles Bell and Helen Bell, his wife...., on the....third....day of....June....A. D....1910...., by....their....deed of that date, conveyed to your....orator...., in fee simple, the following described parcel of land, with its appurtenances, situated in the said County of....Cook...., to wit: Lot....Three (3)... Block....Five (5), Henry's Addition.......... Subject, however, to a condition ... to the....Village....of....Wilmette.... of defeasance upon the payment of the principal sum and interest aforesaid, according to the tenor and effect of the said....promissory note....; which said deed was, on the....fifth....day of....June....A. D....1910. ..., duly acknowledged and afterward on the....first....day of. .August.... A. D....1910...., filed for record in the....Recorder's....Office of the County of....Cook....aforesaid, as by the said deed and its accompanying certificates of acknowledgment and recording, ready to be produced in Court, and by a copy thereof herewith filed and marked "Exhibit B," and made a part of this bill, will more fully appear. Your....orator....further....represents....unto the Court, that the said ....Charles Bell has....not yet paid the principal sum of....Two Thousand ($2,000.00)..... Dollars or such interest thereon, or any part thereof, although the same long since became due; by means whereof the said mortgaged property has become forfeited, subject, notwithstanding, to redemption in equity by the said....Charles Bell, his....heirs and assigns. Forasmuch, therefore, as your....orator is....without remedy in the premises, except in a Court of Equity, and to the end that the said....Charles Bell and Helen Bell...., who....are....made....parties....defendant to this bill, may be required to make full and direct answer to the same; but not under oath, the answer under oath being hereby waived; that an action may be taken in this behalf, by or under the direction of the Court; that the said....defendant, Charles Bell...., may be decreed to pay your ....orator....whatever sum shall appear to be due to....him....upon the taking of such action, together with the costs of this proceeding, by a sure day to be fixed by the Court; that in default of such payment the said mortgaged premises may be sold, as the Court may direct, to satisfy such debt and costs; that in case of such sale and of a failure to redeem therefrom pursuant to the suit, the....defendants...., and all persons acquiring through or under.... them...., after the commencement of this suit, may be forever barred and foreclosed of all right or equity of redemption of the said mortgaged property; and that your....orator....may have such other and further relief in the premises as equity may require, and to the Court shall seem meet. MAY IT PLEASE the Court to grant the writ of summons in chancery directed to the sheriff of the said County of....Cook...., commanding him that he summon the said....defendants, Charles Bell and Helen Bell...., to appear before the said Court, on the first day of the term thereof to be held at the Court House in Chicago, in the County of....Cook....aforesaid, and then and there to answer this bill, etc. HENRY JONES. ....Solicitor....for....Complainant.... NOTE. Copies of the note and mortgage should be added as Exhibits A and B. 128. Bill of Interpleader. (For heading, follow No. 126 or 127.) Your....orator, Aaron Bradford...., of the County of....Cook....and State of....Illinois...., respectfully....represents....to Your....Honors.... that on the....third....day of....January....A. D....1912...., at....Chicago, Illinois...., your....orator....purchased of....one Charles Denis...., of.....Chicago, Illinois, one.....of the defendants hereinafter named, .two horses...., for which....he....promised to pay the said....Charles Denis....the sum of....Three Hundred ($300.00).... Dollars, and gave .....his notes.....therefor, payable to the said.....Charles Denis six months....after date; that at the time of such purchase the said....Charles Denis.....represented, and still.....insists....., that.....he was.....the ....owner....of said property, and had good right to sell the same to your....orator....and to accept the said....notes....therefor. ..... And your....orator....further....represents....that afterward, on the ...first....day of....February, one Edward Fanning...., of....Chicago, a defendant....hereinafter named, made known and claimed, and still....insists and claims...., that....he...., the said....Edward Fanning was....at the time of said sale the real....owner....of said property, and that the said....Charles Denis was....not the....owner....thereof as....he....pretended to your....orator... but....was....merely the ...agent....for the said....Edward Fanning....in making the said sale to your....orator....; and that the said....Charles Denis....had no authority to take such said....notes....in....his....own....name....; and that the said sum of....Three Hundred ($300.00)....Dollars was due and payable to....him.... the said....Edward Fanning.. and not to the said....Charles Denis....; and then and there notified your....orator...., in writing, not to pay the amount of said purchase money to the said ....Charles Denis.... ..... Your....orator... . further....represents....that the said....Edward Fanning has....commenced an action at law against your....orator. in the....County....Court in the County of........Cook.........., to recover the purchase money due on said property, and that the said....Charles Denis is....now threatening to bring suit against your....orator....on the said ...promissory notes.... Your....orator. ... further....represents.... that....he has....always been willing to pay the amount of such purchase money to such person or persons as should be lawfully entitled to receive the same, and to whom ....he....could pay the same in safety; and....he....hereby....offers.... to bring the same into Court, as the Court shall direct. And your....orator....further....represents....that....he does....not in any respect collude with....either....of the said named defendants, nor ....has he....exhibited this, ....his....bill of interpleader, at the request of....either....of the defendants, but merely of....his....own free will, to avoid being molested and harassed touching the matters contained herein. FORASMUCH, THEREFORE, As your....orator is....without remedy in the premises, except in a Court of Equity; and to the end that the said ....Charles Denis and Edward Fanning... who are made parties defendant to this bill, may be required to make full and direct answers to the same; and that the defendants may severally set forth to which of them the said sum of....Three Hundred ($300.00).... Dollars does of right belong, and if payable, and how in particular they make out their claim thereto; and that the defendants may interplead and settle and adjust their said demands between themselves; your....orator....being willing and desirous and agreeing, that the said sum may be paid to the....one....of them to which the same shall, in the judgment of the Court, appear of right to belong; and that your....orator....may be at liberty to bring and pay the said sum of....Three Hundred ($300.00).... Dollars in this Honorable Court, which your....orator...hereby....offers....to do, for the benefit of such defendant as shall appear to be entitled thereto and subject to the further order of the Court; and that the....defendant, Edward Fanning...., may be restrained by the injunction of this Court from proceeding against your....orator....in the said action at law before referred to, and that ....both....defendants may be restrained from commencing an action or actions against your....orator....for the recovery of said sum of....Three Hundred ($300.00)....Dollars or touching any matters or things aforesaid; and that the said....Charles Denis....may be decreed to deliver the said ...promissory notes....to your....orator....to be cancelled; and that your....orator....may have such other and further relief in the premises as equity may require and as to your Honors shall seem meet. (Conclude with prayer for process as in No. 127.) that....he has....ex ....Aaron Bradford....on oath....states. hibited....his....bill of interpleader against the defendants,....Charles Denis and Edward Fanning...., named in the foregoing bill, without any |