The Wichita daily eagle. [volume] (Wichita, Kan.) 1890-1906, 1899-06-24
DOODLE
Continued from Vlrs. p.ss,


Of the interior department as aforesaid.
the names OF which clerks are to tn.
plaintiffs unknown. to suppress said az
fidayits, and the information therein con-
tanned, and to thereby reyent a hearing
and investigation of the charges OF fraud
against the entry and final proof Of said
James w. Lynch for sad tract of land.
And plaintiffs further allege that BY the
corrupt conduct Of said James W. Lynch
and has said agent, the said O'Brian
Moore. the information contained in said
afidavits was suppressed and was never
brought to the attention Of the proper Of
fcers of the government of the United
States, whose duty It was to pass upon
the validity OF the final proof of said
James W. Lynch for said tract OF land.
and the question of the proper Issuing of
the patent to him thereon.
And plaintiffs further say that while the
matter of the consideration of the said
false and fraudulent final proof of said
James W. Lynch was pending before the
land bureau Of the interior department
of the United States, the said James w.
Lynch did pay to said J. H. King. receiver
of the United States land ONCE at Perry.
Oklahoma Territory. the sum OF three
hundred dollars, in money. the same being
represented by a bank check for that sum,
which was collected by the said ]. H.
King and the money received by him, and
did also give to the said J. II. King a
certain mare of considerable value, for
the purpose and with the intent of cor
rim he uofl II 70 III,
favorable consideration and take favora-
Bile action to and for the said James ".
Lynch in the matter of his then pending
application to make final proof, and to
assist said defendant. Lynch. in his ef-
fort to fraudulently procure said patent
for said tract Of land, from said plaintiffs
herein.
Plaintiffs further allege that the said
James W. Lynch did on or about and dur
ing the month of December, 1885, and prior
to the time he procured his homestead
entry as aforesaid, enter into fraudulent
and unlawful combination with B. s.
Barnes and John w. Dalton, of the firm
of Barnes & Dalton. of Ponca City, Okla
homa Territory, and David 5. Pryor.
Chester W. Howe and A NJ. Waugh and
names Of whom are to the plaintiffs I'M
known. to acquire title to said described
tract Of land, to-wit: the said southeast
quarter Of section q. in township 26 north,
range 2 east Of the Indian meridian in
Kay county, Oklahoma Territory, for
speculative purposes, and the said COM
bination OF individuals did thereafter aid
and assist the said James w. Lynch in
acquiring title to Sid tract OF land for
speculative purposes, and for the use and
benefit Of all of said parties under said
agreement, in violation of law and In
fraud Of the rights Of plaintiffs herein,
the United States.
And plaintiffs further allege that at or
about the time OF the procurement of the
patent to said tract of and by said James
w. Lynch. as aforesaid, the exact date
being to these plaintiffs, at this time, I'M
known, the said James W. Lynch, said B.
s. Barnes and John w. Dalton. the said
David c. Pryor, Chester w. Howe and
A. NJ. Waugh and other persons to these
plaintiffs unknown. did procure a charter
as a corporation to be issued by the duly
constituted authorities in the state Of
Kansas, in the name of the Ponca City
Land and Improvement company, for the
sole purpose OF acquiring title to. owning.
selling and dispos!ng OF the land COM
prised in said quarter section Of land
above described, and the lots to be plot
ted out OF said quarter section; that said
charter was taken out In the state of
Kansas for the reason that such a corpor-
alton was, Is and ever since has been, in
violation of the laws OF the territory of
Oklahoma.
That said Ponca City Land and I'm
proveent Company did not own at the
time said corporation was organized. nor
has It at any other time, nor was Il
formed for the purpose OF owning, any
land in the state OF Kansas but. as afOre-
said. for the purpose Of owning. controll-
ing and disposing OF said land described
IN the aforesaid patent to said James W.
Lynch, and the incorporators were large
ly, II not exclusively, composed of the
said parties. who, as aforesaid. in DeceSn-