Aberdeen herald. [volume] (Aberdeen, Chehalis County, W.T.) 1886-1917, 1892-06-09

state, had soundings and SURVEYS made
in the river in front of the lands de-
scribed, and have caused maps to he
drawn of said shores and waters and have
authorized their engineer to lay off GER
tain pretended and apparently valid har-
Dor lines along the said shores and for
the purpose of injuring the complainant
and preventing 1t from seeking redress in
the court OF law, are making said SURVEYS
and maps secretly and will not inform
the complainant of their exact location
on the ground, but the complainant verify
believes and charges that the commits
sion are laying off said apparent harbor
lines by making out one line as the har-
Dor line proper and another line from
fifty to three hundred fee! distant from
the harbor line proper, embracing a
large strip of land between said lines
extending all around, in front of and
partly upon compliments lands, which
strip the commissioners are claiming as
the absolute property OF the state of
Washington, to be forever reserved from
sale by said state and to be leased to pri-
vate individuals for the erection and
maintenance of wharves or to be occu-
pied by the state by wharves erected by
it. The inner line OF the two lines above
described, is laid out in many places
across the lands of the complainant, and
far inside of the line of ordinary high
tide, and that in laying out such line the
defendants wrongfully ignored the rights
OF the complainant, to the accretions
which have formed in front of such land
and have pretended to recognize no line
as the boundary of the compliments
land except the meander line Of the orig
inal United States survey, which at
many places is far inside Of the ordinary
high water mark and is wholly upon the
lands Of the complainant. That in lay
ing out such inner line the defendants
have in some places located the same at
a distance of from one to several hun
daed feet beyond the high water marks
and on the shore and have upon their
plats wrongfully indicated such area be-
tween the inner harbor line and the orig
nal meander line as property to be sold
to private individuals and that they are
by these acts wrongfully asserting the
right Of the state to the compliments
land in the following particulars:
First, that large portion of the COM
plainant's lands are claimed to belong alb
solutely to the state of Washington and
an adverse title thereto is asserted.
Second: By the same means they are
asserting the right Of the state to deprive
the complainant Of its right to purchase
the soil of the shore in front of its land.
Third: They are asserting the right of
the state to appropriate to its own use,
without compensation, all the lands OF
the complainant lying between the orig
inal meander line and the present line of
ordinary high tide.
Fourth: They are wrongfully asserting
the right of the state to take away and
utterly destroy the uses of the complain
ants lands for purposes of trade and COM
merce, by selling portion of the land in
front of it's premises to private parties
granting to said lessees or purchasers the
exclusive possession of said shores and
waters and by the same means are as
sorting the right Of the state to destroy
the uses of the complainant's property for
purposes OF commerce without compen-
sation by cutting off its right to access to
said navigable waters from the lands OF
the complainant.
Fifth: By the same means they are
wrongfully asserting the right to deprive
the complainant of its rights to future &C
cretions to its lands without compensa-
ton.
Sixth: The defendants are asserting the
right of the state to take possession Of,
and destroy or sell to private individuals
the said wharves, piers and other inn
proveinents which have been erected by
the complainant and to take the same
without compensation.
The harbor strip to which the defend
ants are asserting title includes all the
docks and wharves together with the
store and warehouse.
The commission are threatening to and
will, unless restrained by order of the
court, make their claim matter of pub