The White Pine news. [volume] (Treasure City, Nev.) 1868-1906, 1902-04-10
COMPLAINT
Mary A. Bonner, Plaintiff.

/
l vs..
VIM. A. Watson, Annie NJ Watson,
Ernest o. Baker. John Doe and
| Richard Roe. Defendants.
| The plaintiff herein named, complaining
| OF the defendants herein named for cause OF
action slleges:
I. That heretofore and on to wit: April 10,
| 1899, at Cherry Creek. in said county of White
| Pine, the plaintiff and the defendants, VIM.
| A. Watson and Ernest o. Baker, entered in to
| verbal agreement, in and by the terms and
provisions of which the plaintiff agreed to
furnish and supply the said defendants with
| food and lodging for aud during period Of
sixty days from and after said April TO- 1899
and the satd defendants in consideration
| thereof agreed to prospect for mineral and to
locate such OF said lshd as appeared TO them
| said defendants. to contain minerals. as min
| Ing claims in the names OF said defendants
and the plaintiff, and that all claims located
| by said defendants or either OF them during
said period were to be owned jointly by the
plaintiff and said defendants. each owning
| one-third interest in each of any claim located
| by the said defendants or either of them dur
| ing said period.
II. That In accordance with and pursuant
| TO the said agreement the plaintiff did furnish
L
| lodging from said April 10, 1899, until long
after April 30. 1899, and on her part fully com
piled with the said agreement in all respects
Ill That in accordance with aud pursuant
| TO the said agreement the said defendants
| VIM. A. Watson and Ernest o. Baker, during
said period prospected of the vacant and un-
explored land in said county in search of min
erals and located certain mining claims Jointly
| In the names Of themselves and the plaintiff.
w. That on. to-wit; April 10, 1899 and after
| the said agreement had been made and entered
| into as aforesaid, and while the said agree
ment was in full force and effect and while
| the plaintif was complying In all respects
| with the same, the said defendants, VIM A.
watson and Ernest o. Daker, located certain
mining claim situate in Gold Canyon Mining
District, in said county OF white Pine, known
| and called the Joanna" that a notice OF
location OF said claim was on July 81, 1889, filed
| for record In the once Of the Recorder OF said
white Pine county and recorded in Book of
| Mining Location Records on pages 577 and 57S
/ thereof; that said location notices contain q
more sccurate description OF said mining
claim aud is referred to for greater certainty
and the same Ia hereby made part OF the com
plant
v. That the said defendants, VIM. A. Wat
son and Ernest o. Baker fraudulently con-
spired and agreed TO and with the defendant
| Annie N. Watson to cheat and defraud the
plaintiff out Of her one-third interest in and to
| said mining claim: and that pursuant to and
In fuTthsrapce Of said fraudulent agreement,
and not otherwise. the said defendants, VIM.
/ A. Watson and Ernest o. Baker and Annie NJ.
watson caused the said Joanna" mining
claim TO be located in the sole name of the
defendant Annie NJ, Watson, who was in said
location notice thereof described and referred
TO as Mrs. W. A. Watson, and who was at the
date OF the location Of said claim, and is now,
the wife OF the defendant VIM. A. Watson; that
the said mining claim was located under and
pursuant to the said agreement so made and
entered into by and between the plaintiff and
| said defendants, VIM. A. Watson and Ernest
o, Baker ss Aforesaid, and that this plaintiff
was and Is entitled to and the owner of an
equal, undivided one third interest therein.
| VI. That pursuant to and in iurtherance OF
the said unlawful and fraudulent agreement,
between the said VIM, A. Watson, Ernest o,
Baker and Annie N. watson to cheat and de-
| frsudthe plaintiff out Of her interest In and to
said mining claim, the said Annie NJ. Watson
| did wrongfully pretend and assert to be
| the sole owner OF the said Joanna" mining
claim and has pretended to lease the same to
| the defendants John Doe and Richard Roe
| whose other and true names are unknown, and
| has received large sums of money as rents
| and royalties therefrom since the date Of said
| location as aforesaid, and is now receiving
large sums OF money az rentals or royalties
| therefrom.
| VII. That the plaintiff is entitled to a one
third portion of all sums OF money received by
either the said Annie NJ. Watson, VIM. A. Wat
son or Ernest o. Baker as rentals or royalties
| from said mining claim.
wherefore the plaintiff prays judgment
against the defendants; that she be declared
to be the owner OF aud entitled to an equal un-
divided one.third interest of. In and to the
said Joanna" mining claim; that an account
ing be had with the defendants Annie NJ, Wat.
son, VIM. A. Watson and Ernest O, Baker, as
to all sums OF money received by them or eth
! er OF them as rentals or royalties from said
mining claim since the date OF the location
thereof as herein alleged, and that the plain
tiff recovera one third portion thereof that
receiver be appointed TO take charge OF the
said mining claim aud TO receive all rentals
| and royalties arising therefrom and disburse
the same as the Court may direct that the
plaintiff may have such other and different
relief In the premises as equity may require.
Edward McGurrin and D. s. Truman OF Salt
Lake City are the attorneys for N RS. Bonner.
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