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Your orator would respectfully represent unto your honor by this his amendment to the original bill that the said Joseph F. Haines at the time of making the deed herein before mentioned that the said Joseph F. Haines was not seized in fee simple of the South East quarter of Section thirteen in Township twenty four North of Range four West of the third principle meridian. but that at the time the said Joseph F Haines made said deed hereintofore mentioned to secure the repayment of the money and interest herein before mentioned he the said Joseph F Haines was seized in fee simple of the one piece of land herein before mentioned To wit the South half of the East half of the North West quarter of Section thirty in Township twenty four North of Range four West of the third principle meridian and was also seized in fee simple for the South East quarter of Section thirteen in Township twenty four North of Range five west of the third principle meridian. your orator would further represent that at the time of making said Deed of Mortgage it was intended to be made on or for the South half of the East half of the North West quarter of Section thirty in Township twenty four North of range four west of the third principle meridian and the South East Quarter of Section thirteen in Township twenty four North of Range five West of the third principle meridian. that Benjamin J. Prettyman wrote said deed of mortgage and then knew, and at every, and all times since has known, such to have been the intention of the parties to said deed of mortgage your orator also charges that he did not discover said mistake until after this rendition of the decree herein your orator would further represent that on or about the twentieth day of January on thousand eight hundred and fifty two the said Benjamin S. Prettyman purchased of the said Joseph F. Haines and the said Joseph F Haines by deed of the date 0002 last above mentioned conveyed to the said Benjamin S Prettyman the land intended to have been described in said deed of mortgage To wit the South half of the East half of the North West quarter of Section thirty in Township twenty four North of range four west of the third principle meridian and the South East quarter of Section thirteen in Township twenty four North of Range five west of the third principle meridian, And in consideration in part for the said land so conveyed by the said Joseph F Hines to the said Benjamin S Prettyman he the said Benjamin S Prettyman assumed the payment of the said mortgage deed which was intended by all parties concerned to have been for or on the same land conveyed by the said Joseph F Haines to the said Benjamin S Prettyman. Your orator represents as before that neither the sum of five thousand dollars nor the interest thereon nor any part of either has been paid. He therefore prays that the said parties defendant to the original Bill may be compelled on their corporate oaths to answer all and singular the premises in theist bill. that an account may be taken of what is due your petitioner upon said mortgage deed. that the premises intended to be included in said mortgage deed may be sold under a decree of this court and the proceeds applied to the satisfaction of your Petitioners debt. And that your Honor, will grant such other and further relief as the nature of the case may require William B Parker Subscribed and sworn to upon me this 7 May AD 1854 JA James Clk

James Harriott complainants Solicitors LD Hamilton

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L. D. Hamilton vs J.F. Haines and subpoenas Amended Bill

Filed May AD 1854 J A James clk