6. That in truth and in fact, the said defendants all knew and have always known, since the assignment of said contract of Abner T. Klees and wife to Walter F. Johnson and wife, what the real intention of the parties was and that these plaintiffs never sold or contracted to sell anything except the easterly 40 feet of said property.

7. Yet, notwithstanding this knowledge on the part of said defendants, they have wrongfully, fraudulently and intentionally taken possession of all of plaintiff's property and claim to be the owners thereof, and said defendants, wrongfully and with intent to cheat and defraud these plaintiffs are detaining and seeking to detain and claiming to own the said westerly 40 feet of said parcel of land.

8. That the contract existing between these plaintiffs and Abner T. Klees and Mabel Klees, as assigned to Walter F. Johnson and wife, defendants herein, and the contract between Walter F. Johnson and wife and Gordon Rogerson and wife, defendants herein, should be corrected, modified, and changed to conform to the real facts and so as to describe the easterly 40 feet of said parcel of land only and the said defendants should be enjoined by an injunction of this court from selling, contracting to sell, keeping or claiming to own the westerly 40 feet of said parcel of land, or from excluding or attempting to exclude these plaintiffs from their full title, occupancy and possession of said westerly 40 feet of said parcel of land.

9. That the value of the land in question is in excess of one hundred dollars and that these plaintiffs are without relief in the premises save in a court of equity.

10. In consideration whereof and to the end therefore, these plaintiffs pray:

(a) That the said Walter F. Johnson and Esther R. Johnson, Gordon Rogerson and Emily Rogerson, defendants herein, may each of them, without oath, their answer upon oath being hereby waived, full, true, direct, and perfect answer make to all and singular the matters herein stated and charged.

(b) That the contract between these plaintiffs and Abner T. Klees and Mabel Klees, his wife, assigned to Walter F. Johnson and Esther R. Johnson, his wife, may be corrected, changed, and modified so as to describe the easterly one-half of the parcel of land therein referred to; said contract being recorded in Liber 312 of deeds, on pages 449 and 450 Oakland County Register of Deeds office.

(c) That the contract or agreement of sale between Walter F. Johnson and Esther R. Johnson, his wife, and Gordon Rogerson and Emily Roger-son, his wife, may be changed, corrected and modified so as to describe the easterly 40 feet of the land described and referred to in the contract mentioned in Subdivision B of the prayer for relief in this bill.

(d) That the said defendants, jointly and severally, may be restrained and enjoined by this court from selling, assigning, transferring, encumbering, leasing, or exercising any rights of ownership over the westerly 40 feet of the lands described in this bill of complaint or from claiming any right, title, or interest therein by virtue of the contract in existence between the plaintiffs in this cause and Abner T. Klees and Mabel Klees, his wife, or by virtue of any contract or sales agreement now in existence between the defendants herein.

(e) That the said defendants, jointly and severally, may be restrained and enjoined from interfering with plaintiff's right of possession, entry and from the exercise of authority and ownership in, to and over the westerly 40 feet of said above described parcel of land.

(f) That these plaintiffs may have such other and further relief in the premises as may be agreeable to equity and good conscience.

And these plaintiffs will every pray.

Frank L. Clark, Hannah Clark. A. L. Moore,

Attorney for plaintiffs,

Pontiac, Michigan. (Verification.)

Amendment to Bill of Complaint.-(Caption.) Now come the plaintiffs, by their attorney Andrew L. Moore, and moves the court to enter an order granting permission to plaintiffs to amend the prayer contained in the bill of complaint on file in said cause by adding thereto the following section:

"Section H. That in the event the court finds that loss or injury would result to Gordon Rogerson and Emily Rogerson, defendants herein, if the contract between plaintiffs and Abner T. Klees and Mabel M. Klees. which contract was assigned to Walter F. Johnson be reformed, and further finds that the said Gordon Rogerson and Emily Rogerson, are Innocent purchasers in good faith of the entire eighty feet of said premises from the said Walter F. Johnson and wife, then in that event, these plaintiffs pray that the court may determine the cash value of the said westerly 40 feet of land and that the said defendants, Walter F. Johnson, and his wife, Esther R. Johnson, may be decreed to pay to these plain tiffs in cash an amount equal to the value of said westerly 40 feet as determined by said court in lieu of having said land contract reformed as herein prayed for, and that these plaintiffs may be decreed to have a lien in the nature of a mortgage upon said easterly 40 feet of the premises described in paragraph two of this bill of complaint to secure the payment thereof and that said sum shall be deemed to be due and payable forthwith; and that in the event of a decree for the cash value of said westerly 40 feet, that plaintiffs be decreed to be entitled to their reasonable costs and charges to be taxed against the said Walter F. Johnson, and Esther R. Johnson."

A. L. Moore « Attorney for plaintiffs

Dated July 9, 1919.

(c) Answer of Walter F. Johnson and Esther R. Johnson.-(Caption.) Walter F. Johnson and Esther R. Johnson, defendants herein, answering the bill of complaint filed in said cause, respectfully show unto said court as follows:

I. These defendants admit the allegations of paragraph one of said bill of complaint.