The Birmingham age-herald., 1912-12-18

l
 ment. lacked $9O of paying for her inter est in said lands described In ENhiple | A hereto, which she thought was De- ing deeded to her, and she demands strict | proof of the said Matthews as to wneth- CT or not said note had any valid con | alteration and as to whether or not ne practiced a fraud on her in procurHls he. signature to the same and if 1t IS fouhd ! that there was a valid consideration TOT said note your oratrix is ready Wiiiihs E, | and able to pay said Matthews the salu amount due on said note, together witn | such interest as may have accrued the.e- on. and submits herself to the 1urisdlc- ton of this court to make all the oruets . | and decrees that may be necessary lo reeuire the payment to the salo Maj thews of any sum or sums that may po | found to be due on said note, together with any and all other sums that may be found to be due by your oratrix To the said K. N. Matthews, or statement of account between your oratrix ana the said K N Matthews charging your oratrix with every just claim that tue said K N. Matthews may have against her. and creditng her with each ana every item that may be found to be due her from the said K. N. Matthews. Value of Lands
 I'll, Your oratrlx further states charges and ayers, that said shelby county lands, described in Exhibit A hereto are worth eight or ten thousand dollars. and your oratrlx's one-half inter est in the same, to which she is justly and eaultably entitled, Is worth not less than four or five thousand dollars, and to permit the said K. N. Matthews to held the same and pay to your oratrix Seas amounts to letting him and permit ting him to defraud your oratrix oi moro than three thousand dollars
 .12. The premises considered, your oratrix prays the court that the said k N. Matthews be made a party respond ent to this, bill of complaint, and that the usual process issue out of your Honor s court making him said party respondent, and that on final hearing, your Honor will state an account between the said K. N. Matthews and your oratrix charging the said K. N. Matthews with the rents and profits from said lands described in Exhibit A hereto, for the years 1902, 1903 to 1912, both inclusive, and creditlng him with the taxes paid on said lands and all the permanent im-
  charging him with any other moneys in his possession, and any and all amounts due your oratrix from the said IA. N. Matthews and crediting him with any and all amounts that may be found due him from your oratrix; and that on said final hearing your Honor will declare and decree by the judgment of your Hon ors court that the said K. N Matthews practiced fraud on your oratrix in the preparation of said deeds, and in the pro ourement of the conveyances to him in- stead of your oratrix of one-half Ill., te-est of the said lands described in Ex- hiblt A hereto, and that in equity ana good conscience that your oratrix IS en- titled to a one-half interest in said lands described in exhibit A hereto, and that the said K N. Matthews holds title to said one-half interest in said lands as in trust for your oratrix and that in equi- ty and under the law he is not entitled to the same, and that the said K. N. Matthews be required to convey to your oratrx an undivided one-half interest in the lands described in Exhibit "A' here to, making your oratriX quit clam deed conveying to her all of his right, title and interest in said lands described in Exhibit A hereto, and the said in- terest in said lands which he holds title to by virtue of said conveyance, and that he be required to execute with proper &C., lxnowledgments a conveyance to your oratrix to said one-half interest in said lands, and that, if, for any reason the said conveyance is not made by the said K N. Matthews to your oratrlx, that your oratrx, by appr opriate orders ana dccrees, require the register of this court to convey to your Oratrlx all the right, title and interest of the said K. N. Mat thews in and to the said lands described in Exhibit A hereto. and a title to the said one-half interest, which the said K. N. Matthews holds to said lands, under and by virtue of said deed of convey ance, copy of which is Exhibit "A" hereto.
 And if your Oratrlx is mistaken in the relief prayed. then she prays for such other, further and additional re- lief as may seem to your Honor most proper, and as in duty bound she will ever pray.
 "RIDDY & ELLIS,
 Solicitors for Complainant
 Note: The respondent Is required to answer each and every paragraph of the foregoing bill of complaint, from l to F. both inclusive, and each and every ale gation therein, but answer under oath is expressly waived.
 RIDDLE & ELLIS.
 "Solicitors for Complainant"