State of Pennsylvania, } Pike County,          } SS.

HIRAM HARPER} vs.                  }In Chancery.

CHARLES LAKE. } To the Honorable the Judge of the Circuit Court of Pike County,25 in the State of Pennsylvania, in Chancery sitting:

Your orator, Hiram Harper, respectfully shows unto your Honor that on or about the fourth day of
50 October, in the year of our Lord one thousand nine hundred and five, Charles Lake became and was indebted to your orator in the sum
75 of one thousand dollars, and being so indebted, in consideration thereof the said Hiram Harper, on the day and year aforesaid, made and executed under
100 his hand a certain note or writing obligatory for the sum of one thousand dollars.

Your orator further shows unto your Honor that the said Charles
125 Lake, on the eighth day of October, in the year of our Lord one thousand nine hundred, and five, to secure the payment of the
150 principal and interest mentioned in said note, made and executed under his hand and seal, and delivered to the said Hiram Harper a mortgage conditioned
175 for the payment of the sum of one thousand dollars and interest mentioned in said

To the Honorable the Judge of the Circuit Court of Pike County,25 in the State of Pennsylvania, in Chancery sitting:

Your orator, Hiram Harper, respectfully shows unto your Honor that on or about the fourth day of
50 October, in the year of our Lord one thousand nine hundred and five, Charles Lake became and was indebted to your orator in the sum
75 of one thousand dollars, and being so indebted, in consideration thereof the said Hiram Harper, on the day and year aforesaid, made and executed under
100 his hand a certain note or writing obligatory for the sum of one thousand dollars.

Your orator further shows unto your Honor that the said Charles
125 Lake, on the eighth day of October, in the year of our Lord one thousand nine hundred, and five, to secure the payment of the
150 principal and interest mentioned in said note, made and executed under his hand and seal, and delivered to the said Hiram Harper a mortgage conditioned
175 for the payment of the sum of one thousand dollars and interest mentioned in said note, according to the conditions of said note, by which
200 said mortgage the said mortgagor mortgaged to the said Hiram Harper, in fee, certain lands and real estate, situated in the County of Pike and
225 State of Pennsylvania, and described in said mortgage as follows, to wit:

The east half of Lot Ten (10), in Block Eight (8), in School
250 Section Addition to the City of Philadelphia:

Which said mortgage was duly acknowledged, and afterwards recorded as a mortgage, in the office of the Recorder
275 of Pike County in said State, on the fifteenth day of October, in the year of our Lord one thousand nine hundred and five, at
300 ten o'clock in the forenoon of said last-mentioned day, in Book 2345 of Mortgages, at page 123,325 as by said mortgage and the certificate of acknowledgment and recording endorsed thereon, and ready to be produced in court, and to which your orator
350 prays leave to refer, will more fully appear.

And your orator believes and states that the sum of six hundred dollars, with interest from the
375 fourth day of April, in the year of our Lord one thousand nine hundred and six, remains due and unpaid to your orator on said
400 note and mortgage, and that no proceedings at law have been had to recover the debt secured by the said note and mortgage, or any
425 part thereof.

And your orator further states and believes that the said premises described in the said mortgage are meager and scant security for the
450 said sum of six hundred dollars and interest mentioned in said note and said mortgage and now due your orator.

Your orator further shows unto
475 your Honor and states upon information and belief that one Emma Allen has or claims to have some interest in the said mortgaged premises or
500 some part thereof, as purchaser, mortgagee or otherwise, which interest, if any, has accrued subsequent to the lien of the said mortgage of your orator,525 and is subject thereto.

Your orator therefore asks the aid of this court in the premises, and that the above named Charles Lake, the defendant
550 in this suit, may appear before the Judge of the Circuit Court, in the court of Chancery, and answer this, your orator's bill, according to
575 the rules and practice of said court, without oath, answer on oath being hereby waived, and that the usual decree may be made for the
600 sale of said mortgaged premises aforesaid, and for the payment of the amount due your orator for principal and interest in the said note and
625 mortgage mentioned, and costs of suit, and that the said Charles Lake and all persons claiming under him subsequent to the commencement of this suit,650 and all other persons not parties to this suit, who have any liens, by judgment or decree, upon the mortgaged premises subsequent to the said
675 mortgage of your orator, or any liens or claims thereon by or under any such subsequent judgment or decree, either as purchaser, encumbrances or otherwise,700 may be barred and foreclosed of all equity of redemption in said premises, and that your orator may have such other and further relief as
725 the nature of the case may require and as to this court shall seem agreeable to equity and good conscience.

And may it please your
750 Honor to grant unto your orator the People's writ of summons, issuing: out of and under the seal of this honorable court, to be directed
775 to the said Charles Lake and Emma Allen, therein and thereby commanding them and each of them, on a certain day and under a certain
800 penalty, to be therein inserted, that they personally be ana appear before the Judge of said court at the court room of said court in
825 said County of Pike, then and there to answer all and singular the premises, and to stand to and abide by and perform such order
850 and decree therein as shall seem agreeable to equity and good conscience. And your orator will ever pray, etc.

On this sixth day of February, A. D. one thousand nine hundred and seven, personally appeared before me Hiram Harper, who, being duly sworn, saith
900 that he is the complainant named in the foregoing bill of complaint; that he has read the foregoing bill of complaint and knows the contents
925 thereof, and that the same is true of his own knowledge, except as to the matters and things therein stated upon information and belief, and
950 as to those matters he believes it to be true.

Subscribed and sworn to before me this sixth day of February, A. D. 1907.

Notary Public. (979 words)