(g) That your orator may have such other and further relief in the premises as shall be agreeable to equity.

And your orator will ever pray, etc.

Jamies Bignell,

Plaintiff, By Charles E. Soule,

His Attorney. Plaintiff, (c) Answer and Cross-Bill.-(Caption.) The joint and several answers of the above named defendants to the bill of complaint of the above named plaintiff except that the above named defendant, Martin Van Doorn, Jr., does not claim to know anything personally about the transactions between said plaintiff and said defendant Franks, but does know the arrangements between the defendant Franks, and defendant Van Doorn,

Jr., and the cross-bill of James A. Franks asking for affirmative relief.

1. For answer to the allegations in the first paragraph of plaintiff's bill of complaint, these defendants admit that the contract set forth therein is a true copy of the agreement made between defendant Franks and plaintiff Bignell, but deny that that contract was the real contract under which the plaintiff Bignell, and defendant Franks, were operating and did operate.

2. For answer to the allegations in the second paragraph of said bill of complaint, these defendants admit that the said Franks took possession of the land described in the contract in paragraph one and has continued in possession thereof until the spring when defendant Franks sold to defendant Van Doorn, Jr., the property described in said second paragraph of plaintiff's bill, and that Franks sold it for $1,000.00, and admit that said Franks will not be able to give Van Doom a good record title to said premises until the same is conveyed to him by plaintiff Bignell, but both defendants deny that the said Bignell is entitled to have any part of the contract price paid to him because defendant Franks says that plaintiff Bignell is indebted to him under the agreement that they have always done business under, and that plaintiff Bignell owes defendant Franks more than enough to pay all the claimed balance on the contract set forth in paragraph one of this bill of complaint, which will hereafter be stated in subdivision two of this answer and cross-bill.

3. For answer to the allegations in the third paragraph of said bill of complaint, these defendants say that they admit that said Franks paid in full on said contract mentioned in paragraph one of said bill of complaint and performed each and every obligation therein men tioned for him to perform up to and including June 6, 1910, admit that defendant Franks did make claims in reference to said contract, but deny that all of such claims were settled by said contract and deny that such claims were fully settled and satisfied and abandoned by said Franks; admit that the payments mentioned in paragraph three of said bill were made; admit that all payments of principal and interest were promptly paid by Franks, but deny that he abandoned the claims he had made from June 6, 1910, to April 25, 1911, and now claims that plaintiff Bignell owes him more than the amount claimed to be due on the contract set up in paragraph one in said bill of complaint.

4. For answer to the allegations in the fourth paragraph of said bill of complaint, this defendant says that according to the terms of said contract mentioned in paragraph one of said bill of complaint, there would be $250.00 due on the principal and $22.50 interest, April 10, 1918. but says under the terms of agreement actually made and performed between the plaintiff Bignell and the defendant Franks, plaintiff Bignell owes Franks more than the amount claimed to be due on the contract set up in paragraph one of the bill of complaint; neither admit nor deny the statement in said paragraph in reference to payments, and deny that all payments have been forfeited; neither admit nor deny that the entire amount of said contract purchase price is $750.00 and interest at six per cent from October 10, 1917, making a total of $777.13.

5. For answer to the allegations in the fifth paragraph of said bill of complaint, these defendants admit that a letter was written by Lillie, Lillie & Lillie suggesting that plaintiff Bignell and defendant Franks get together and settle matters between them, and suggest that they need no attorneys to do it, and they say that the plaintiff had the best reason in the world to believe that those suggestions were in reference to claims of said Franks, and they deny that any matter between said plaintiff and said Franks has ever been settled and deny that any claims of said Franks have ever been abandoned and deny that any claims of said Franks ever made were given up by Franks under the advice of Mr. Farr, his attorney, and deny that any claims made by Franks were ever abandoned by his steady and regular payments of amount due from the last date to April 10, 1918, when the last refusal was made, and claim that said Franks has always insisted that he has money coming to him from said Bignell, as will hereafter more fully appear.

6. For answer to the allegations in the sixth paragraph of the said bill of complaint, these defendants say that the said Bignell has no right to declare the contract forfeited and hold the land described therein free therefrom nor to have any lien thereon determined to be the amount unpaid thereon. And they deny that there has been any default on said contract and claim that said Bignell knows that under the dealings between him and Franks, that he, Bignell, owes said Franks at the present time, as will more fully and hereafter appear; that they admit that it would be inequitable to claim a forfeiture because the plaintiff knows that said contract has been fully paid and that plaintiff now owes said Franks, and defendant Franks is willing to have the plaintiff's claim determined by the court under all the circumstances between the parties, and admit that the remainder of the land, after deducting the lot sold by defendant Franks to Van Doorn should be first sold, if any, and is worth more than enough, many times over, to pay any pretended claim that plaintiff now makes; that they admit that In equity and justice the plaintiff should convey the whole property mentioned in said contract to defendant Franks, free and clear from any lien whatever, and say that when the plaintiff does actual justice and equity between himself and defendant Franks he will convey the entire property described in the contract to defendant Franks, besides that pay defendant Franks the money, he, plaintiff, has in his hands which now belongs to defendant Franks, and that all defendant Franks desires is that plaintiff shall be compelled "to do absolute and complete equity in the premises."