The Elk Mountain pilot., 1922-04-20
township eleven QD, South of
Range eighty-nlne (e9) West OF
Il II i

that plalntlH is the owner IN Zee
simple of said property; to require
the defendants to set forth the ma
ture of their claims respectively in
said property, and to have adjudicate
all adverse rights, title, claims, de-
mands, interests or estates of said de-
PENDANTS in said property; and to OBJ
tain decree declaring that the
defendants, and each of them, have
no right, title, claim, demand, inter-
est or estate in said property, or any
part thereof; and that the title of
plaintiff is good, valid and perfect
and forever enjoining defendants
from asserting any right, title, claim,
demand, interest or estate in said
property, adverse to plaintiff; and for
plaintiffs costs.
The interests of the unknown heirs,
and the unknown devisees, legatees
and creditors if any, and the unknown
personal representative or represen-
tatives, if any, of the estate of James
w. Skinner, mentioned in paragraph
one ~ of the title are that they
claim to have some right, title or in
terest in and to the property above
described as parcel one ~ by reason
of their being heirs, devisees or lega-
tees, or personal representatives or
creditors of James w. Skinner, if
deceased, who, at one time, owned an
undivided three-eights (M) interest
in the property described as parcel
one (D, but lost the same by Treas
urer's Deed, as fully set forth in Sub
division (a) of paragraph five (5) of
the complaint.
The interests of the unknown heirs,
and the unknown devisees, legatees
and creditors, if any, and the unknown
personal representative or represen-
tatives, if any, of the estates of w. H.
White, C. L. Stewart, j. D. Parsons,
Jr., and j. C. Parsons, respectively,
mentioned in paragraph one (D of
the title, are that they claim to have
some right, title or interest in and to
the property above described as par
eel two (2), by reason of their being
heirs, devisees or legatees, or personal
representatives or crditors of said
w. H. White, C. L. Stewart, ]. D.
Parsons, Jr., and ]. C. Parsons, re-
spectively, if deceased, as fully set
forth in subdivisions (b), (c), (d) and
(h) of paragraph five (5) of the COM
plant, said White, Stewart, and ]. D.
Parsons, Jr., at one time having owned
undivided interests in the property
described as parcel two (2), which
they lost by Treasurers Deeds; and
said j. c. Parsons having owned tax
sale certificates of said property, but
which said certificates are invalid.
The interests of the unknown de-
fendents mentioned in paragraph two
(2) of the title, are that they claim
some right, title or interest in and
to the above prem. IS by reason. of
their being heirs, devisees or legatees
or personal representatives or credi-
tors of Jedidiah Ellis Newcomb, if de-
ceased, who at one time owned an un-
divided one-twelfth Q-12) interest in
said premises, but which was later
disposed of by his assignees for the
benefit of his creditors as fully set
forth in subdivision (e) of paragraph
five (5) of the complaint.
The interests of the unknown de-
PENDANTS, mentioned in paragraph
three (3) of the title, are that they
claim some right, title or interest in
and to the above-described premises,
by reason of their being heirs, devil
sees or legatees or personal represen-
tatives or creditors of Pearl Haley,
May M. Haley, Maude Haley, and the
unknown heirs of Allen Haley, de-
ceased; that said Allen Haley having
died seized of an undivided one
twelfth Q-12) interest in said prem
ises, left a will wherein he devised
said interest to said Pearl Haley, Nav
M. Haley and Maude Haley, and his
executors having later conveyed said
interest as fully set forth in sub-di-
vision ~ of paragraph five (5) of the
complaint
The interests of the unknown de-
PENDANTS mentioned in paragraph
four (4) of the title are that they
claim some right, title or interest in
and to the above-described premises
by reason of their being heirs, devil
sees or legatees, or personal represen-
tatives or creditors of Florence E.
Forsyth Burrows, James A. Forsyth,
Charles T. Forsyth, Henry Reginald
Forsyth and John Stanley Forsyth,
and the unknown heirs of Alexander
Forsyth. deceased, and the unknown
heirs of Sophy f. Forsyth, deceased;
said Alexander Forsyth having died
seized of an undivided 'one-twelfth
Q-12) interest in said premises, leav-
ing a will wherein he devised his
property to his wife, Sophy Elizabeth
Jenkins (Forsyth) during her life
and while SIZE should remain unmar-
ried, and after her death or re-mar-
riage, to their children or decendents
of deceased's children; that said chill
dren conveyed their interests to
Sophy E. Forsyth and she thereafter
died testate. devising all her property
TO said children, from whom title de-
scended to plaintiff, as fully described
in subdivision (g) of paragraph five
(5) of the complaint.
The interests of the unknown de-
PENDANTS mentioned in paragraph six
(6) of the title. are that they COM
posed the last Board of Directors of
The Pacific Coal and Coke Company
which claimed to have some right, tt
tie or interest in said premises above
described by virtue of having been
given a ninety-nine (99) year lease,
the same being dated July 15, 1887,
and recorded in Book 90, page 327 of
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