Also one-half of other piece of land described as follows: Beginning at a point lying on the northeasterly side line of highway one chain and eighty links southerly from the intersection of said northeasterly side line of highway with the south line of the Village of Byron aforesaid; thence running north eighty-eight and one-fourth degrees, east three chains and five links to the northeast corner of a lot of land, formerly deeded by Dennis and Kelsey to O. Phelps, on the 29th day of March, A. D. 1848; thence north to the south line of a lot deeded by said Dennis and Kelsey to M. W. Kelsey; thence westerly along the south line of said last mentioned lot to the northeasterly line of the highway; thence southerly along the northeasterly line of highway to the place of beginning. Also one-half of the other piece of land described as follows: Beginning at a point lying on the northeasterly side line of the Pontiac and Grand River Road, three chains and thirty-three lengths southerly of the intersections of said line of road with the south line of the Village of Byron aforesaid, running thence north eighty-eight degrees and fifteen seconds, east, two chains and ninety-one links to the northeast corner of a certain lot formerly deeded by Dennis and Kelsey to Ziza Goff, on the 29th day of March, A. D. 1848; thence running northeasterly to the southeast corner of the Phelps lot, heretofore mentioned; thence westerly along the south line of said Phelps lot three chains and eleven links to the northeasterly side line of highway; thence southerly along the easterly line of said highway to the place of beginning.

5. Your orator further represents that thereafter the said Allen Sheldon departed this life testate. By the terms of his will recorded upon the 21st day of August, 1905, in miscellaneous records of the register of deeds office, of Shiawassee County, in Liber F, upon page 559, the said Allen Sheldon devised all of the lands above described, in fact, all of his real estate in Michigan, to Henry D. Sheldon. At that time of his death, the said Allen Sheldon was the owner of the premises first above described, together with all water rights in connection with the operation of the mill upon said premises, and by the said devise under the terms of the said will, the said Henry B. Sheldon became the owner of all the said premises and power rights upon, to-wit, the 1st day of May, 1912. The said Henry B. Sheldon, together with his wife conveyed the premises first above described unto your orator by a warranty deed of that date. said deed being recorded upon the 14th day of May, 1912, in the office of the register of deeds of Shiawassee County, in Liber 96 of Deeds, upon page 190, and also upon, to-wit, the 8th day of May, 1912, by his quit-claim deed of that date conveyed unto your orator the water power rights in connection with said premises, said quit-claim deed being recorded upon the 13th day of May, 1912, in the office of the register of deeds, of Shiawassee County, in Liber 132 of Deeds, upon page 616.

6. Your orator further represents that one Samuel W. Dexter, to your orator unknown, claimed at one time certain rights in said premises first above described, by reasons of the sale of said land for taxes for the tax of 1832, said Samuel W. Dexter acquiring whatever rights he had in said premises by reason of a quit-claim deed bearing date June 8, 1840, and recorded upon the 19th day of June, 1840, in Liber E, of Deeds, upon page 117. That said conveyance to the said Samuel W. Dexter was without effect for the reason that said taxes of 1832 were no legal lien upon said premises, and that said tax deed was absolutely void, and further that the grantees by virtue of said tax deed have lost whatever rights they may have acquired in said premises by the adverse possession of the grantors of your orator in the regular chain of title.

7. Your orator further represents that certain parties who are now owners of land adjacent to the premises first above described are claiming certain rights in and to certain portions of the premises first above described, now belonging to your orator; that the names of said parties are as follows: Herman Meier and Carrie Meier, his wife, Ernest Kel-sey and Mary Kelsey, Emma Spangenberger, Frank Alden and Ada Alden, Perry Hadsell, Helen Hadsell, Township of Burns, Shiawassee County, Michigan; Fred S. Ruggles and Effie Ruggles, George Downing and Emma Downing, William Betterly and Cora Betterly, Frank E. Tower and Mamie Tower, John N. Ripley and Vinnie Ripley, Edgar Caulkins and Kiva Caul-kins, Robert Coats, Thomas McGee, Elsie McGee, Lucy Kirkendol, Henry Faul, Charles Fritz and Henrietta Fritz, and William Harper and Bertha Harper and Frances Campbell. That these parties and none of them have any right of any description in the premises above described, but their assertion of right and interest in the premises first above described is an open assertion against the title of your orator in said premises and constitutes a cloud upon the right and interest of your orator therein, and should be quieted by a decree of this court.

8. Your orator further represents that attached hereto is a map and diagram of the premises involved, said map, being marked Exhibit A and made a part of this bill of complaint.

9. Your orator further represents for a period of fifty years preceding this date the grantors of your orator have had a right-of-way and easement along the southerly side of land owned by Charles Fritz and Henrietta Fritz and extending around the easterly and northeasterly side of said land to the dam above referred to, used in connection with the operation of said mill; that said right-of-way is 10 feet in width and extends from the easterly side of the Pontiac and Grand River Road, so-called, easterly around said land to the dam aforesaid, a distance of eighteen rods from the center of said road. That this right-of-way and easement was and is a necessary appurtenance to said dam and is the only method of ingress and egress to said dam for keeping same in repair. That said easement and right-of-way as appurtenant to the land described is paragraph one of this bill of complaint has been conveyed to the successive grantors of your orator down to your orator, and that your orator is still the owner of said easement. However, said Charles Fritz and Henrietta Fritz are disputing the right of your orator to use said easement and right-of-way, insisting that your orator has no title in and to said property.