that the said....Fannie Baxter and Helen Baxter, 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 a guardian ad litem may be appointed by the Court for the said infant....defendant....; that the dower of your....oratrix....in the said premises may be assigned and set apart to....her....; and that a division and partition of the residue thereof may be made by and under the direction of this Court, between your....orators, Bradford Baxter and Charles Baxter... .... and the....defendants, Fannie Baxter and Helen Baxter...., according to their respective rights and interests therein, to be judged by the Court; and that in case an assignment of dower, and division and partition in said premises cannot be made without manifest prejudice to the parties interested, that the same may be sold, under the direction of the Court, and the proceeds thereof distributed between the parties, according to their respective interests; and that your....oratrix and orators....may have such other and further relief in the premises as equity may require and to Your....Honors....shall seem meet. (Conclude with prayer for process as in No. 127.) D. (c) (2) Pleadings-Chancery-Notices. 131. Notice of Foreclosure of Mortgage. ....August third....A. D....1914.... To....Charles Bell and Helen Bell... ..... .Mortgagors...., No....323 Linden Avenue, Wilmette, Illinois.... You will take notice that as Agent for....Albert Bennett, I....have this day foreclosed the Mortgage heretofore given by you, dated....June fifth.... A. D....1910...., and recorded on....June fifth....A. D....1910...., on page. .120....book....One....of Records in....Cook....County, on the property in the premises known as....323 Linden Avenue...., and that the sale under said Mortgage will be held at....the Courthouse in the City of Chicago....the....fourth....day of....October....A. D....1914...., at....12....M. HENRY JONES. Agent for....Albert Bennett.... 132. Notice to Owner of Mechanics' Lien for Material and Labor. TO....George B. Swift.... YOU ARE HEREBY NOTIFIED, That....I....have been employed by ....John Harding....to furnish material and labor for the erection of the....cut stone....on the building being erected for you by....Henry Rogers and Company, a corporation.... under....its....contract with you on your property....at the Northwest (N. W.) corner of Dearborn and Harrison Streets.....in the.....City.....of.....Chicago.... County of ....Cook....and State of....Illinois...., and that there....will be....due ....me....on the....twelfth....day of....September....A. D....1914.... therefor the sum of....Five Hundred ($500.00)....Dollars, and that ....I....shall hold the buildings and your interest in the grounds, liable for the amount that is due....me....on account thereof. DATED this....ninth....day of....August...A. D.... .1914.... WILLIAM JONES.... NOTE. See No. 129 and note concerning statutory requirements. D. (c) (3) Pleadings-Chancery-Miscellaneous. 133. Answer. (For heading, see No. 126 or 127.) The answer of.... Charles Denis, defendant... of....Aaron Bradford, complainant.... to the bill of complaint ..says.... .promissory ....This defendant... reserving to....himself....the right of exception to the said bill of complaint for insufficiency thereof in law or in fact, the same as if demurrer thereto had been filed, for answer thereto, that....he was....and still....is the holder....of the. notes....referred to in said bill of complaint; that said....promissory notes were....delivered to....him....in payment for....two horses....as set up in....complainant's.. s....bill of complaint and that at the time of the sale of said....horses....to said....complainant, he, Charles Denis, .the rightful owner of said....horses....and that....they were his....property and the property of no other person. And....this defendant....further answering....prays....that the said....Aaron Bradford....be directed to pay said....Three Hundred ($300.00)....Dollars to ....him....as the....person....rightfully entitled thereto. was.... 134. Order. HENRY WARD..... ....Solicitor....for... .Defendant.... (For heading, see No. 126 or 127.) AND THIS DAY COMES The complainant hereto, by....William Long, her solicitor...., and this cause coming on now to be heard upon the Bill of Complaint filed herein, taken as confessed against the defendant, and the Court, having heard all the evidence adduced herein by the complainant, and the same having been reduced to writing, and a certificate thereof filed herein, and having heard the arguments of Counsel, and being fully advised in the premises, finds said defendant....to be guilty of said allegations in said bill.... IT IS THEREFORE ORDERED, adjudged and decreed by the Court that the complainant be and....she....is hereby divorced from the defendant, and released from the obligations of....her....marriage and restored to all and singular the rights and privileges of an unmarried ....woman, and she is hereby restored to her maiden name Alice Mann.... ENTER: JOHN TUTHILL.......... [SEAL OF COURT] JUDGE. NOTE. This form will naturally vary considerably with the nature of the order to be entered. The People of the State of....Illinois.... To the Sheriff of said County, GREETING: WE COMMAND THAT YOU SUMMON....Charles Bell and Helen Bell...., if....they....shall be found in your County, personally to be and appear before the....Superior....Court of....Cook....County on the first day of the term thereof, to be held at the Court House, in...Chicago..., in said County, on the....first Monday....of....June....A. D....1914...., to answer unto....Albert Bennett....in a certain....original....Bill of Complaint....for Foreclosure of Mortgage....filed in said Court, on the Chancery side thereof. And have you then and there this Writ, with an endorsement thereon in what manner you shall have executed the same. [SEAL OF COURT] WITNESS, ....RICHARD J. McGRATH...., Clerk of our said Court, and the Seal thereof, at ....Chicago...., aforesaid, this....tenth....day of ..May....A. D....1914.... The People of the State of....Illinois.... TO....Henry Sayre....and your Attorneys, Solicitors, Agents and Servants, and to each and every of them, GREETING: WHEREAS, It hath been represented to the Honorable....the Judges........ of the....Circuit....Court of....Cook.... County, in the State aforesaid, on the part of....William Smith, complainant...., in a certain Bill of Complaint, exhibited before said....Judges....and filed in said Court against you, the said....bill charging.. '...., among other things, that you are combining and confederating with others to injure the....complain ant...., touching the matter set forth in said bill, and that your actings and doings in the premises are contrary to equity and good conscience. And Honorable....William McDonald, one of....said....Judges...., having entered an order that a Writ of Injunction issue out of said Court, according to the prayer of said bill: ....We...., therefore in consideration thereof, and of the particular matters in said bill set forth, DO STRICTLY COMMAND YOU, the said....Henry Sayre.... and the persons before mentioned and each and every one of you, that you do absolutely desist and refrain from any action that will in any wise change your interest in or title to the premises at....143 W. Ohio Street...., concerning which certain acts are charged in said bill as contemplated by you, until this Honorable Court, in Chancery sitting, shall make order to the contrary. Hereof fail not, under penalty of what the law directs. To the Sheriff of said County, to execute and return in due form of law. WITNESS, ...JOSEPH E. BIDWILL, JR., . . . . Clerk of said Court, and the Seal thereof, at....Chithis.... third.... [SEAL OF COURT] cago. aforesaid, .May....A. D....1914.... day of In the....Circuit....Court of....Marion.... County, .September.... Term, A.D....1914.... William Ward, Plaintiff.. V. ....John Williams, Defendant... .DEFENDANT'S.. ANSWER: Gen. No....233122... CLERK. First defense. ...Defendant....at the time of selling said....automobile....to....plaintiff....had no reason to believe and did not know that said....automobile was... .not in good condition. Said....defendant denies....that....he....had attempted to repair....said machine....and had ceased....its.. ...use for that reason. Second defense. .Defendant admits....that....he....had not used ....said machine....for a period of....one month....prior to....its.... sale, but....says....that....he....had not used....said machine....on account of the fact that....he....had been ill and had not been able so to ...plaintiff.. ...it....and that this fact was as well known to the as to....him...., the.... ...defendant.. and said....defendant denies.... all the other facts alleged in....plaintiff's....complaint. use... JOHN WILLIAMS.... ....Defendant.... D. (d) (2) Pleadings-Code Complaint. 138. Complaint for Deceit in Sale of Personalty. (For heading, see No. 137.) COMPLAINT. ....William Ward, plaintiff, complains....of....John Williams, defendant...., and....says....: First, that.... defendant...., on the .third....day of....July....A. D....1912...., at....Cedar Rapids...., in the County of....Marion.... in the State of....Iowa...., intending to deceive the said....plaintiff.... and to induce....him....to purchase a.... .Paddington automobile...., the property of this....defendant...., from....him...., the said....defendant....made to....him, the plaintiff...., certain false representations, to wit: that said....automobile was.....in good condition and that.....it.....had been used by said ...defendant....for.... three months....previous and during that time had never been broken and had been found satisfactory by said....defendant.... Second, that in truth and in fact said....automobile was....not in good condition and said....defendant....had been compelled to quit using said....automobile....for a period of........one month....prior to....its.... sale and said....defendant....had had said....automobile....to a certain repair shop in the County of....Marion... State of....Iowa... on ...two or three....different occasions, attempting to get said....automobile....in running condition, but....was....unable to do so. Third, that the....plaintiff...., relying on said false representations, .was....thereby induced to purchase and did purchase said....automo bile.... Fourth, that....defendant....well knew when....he....made the representations aforesaid that they were false. Fifth,—that.... plaintiff ....by....his....reliance on said representations suffered damage to the amount of....One Thousand ($1,000.00).... Dollars. WILLIAM WARD.... Plaintiff.... . In the.... Superior....Court of.. .Lake....County, ...Henry Williams, Plaintiff. ....1913.... V. Gen. No....67123.... ...Elgin, Joliet & Western Ry. Co.,| Defendant....) Plaintiff, Henry Williams, complains....of....Elgin, Joliet & Western Ry. Co., defendant...., and....says....: That on the....fifth.... |