FORM NO. 53.

COMPLAINT AGAINST DEFENDANT FOR ERECTING AND MAINTAINING A SLAUGHTER HOUSE.

8

[Name of Court.]

Plaintiff complains and alleges:

I.

That the plaintiff is, and at the times hereinafter mentioned was, and ever since has been, possessed of a lot of land situate in the county of

in block No.

in this state, known as lot No.

in the city of

; and he had and has a dwelling house thereon which he inhabited during said times, and now inhabits with his family;

II.

That defendant was during said times possessed of land described as [describe the land] in the immediate vicinity of the said lot and house of plaintiff :

III.

That the defendant, in the month of [state also the year] and while plaintiff and his family inhabited said dwelling house on said lot of plaintiff, erected and he maintains on said land of the defendant, a slaughter house and cattle pens and hog pens in which he kept and keeps cattle and hogs, and he has slaughtered and he slaughters cattle and hogs in said slaughter house, and he, by said acts causes noxious and offensive smells which taint and corrupt the atmosphere so as to render said dwelling house and premises of plaintiff unfit for habitation;

IV.

That by reason of said offensive smells, and such tainting and corrupting of the atmosphere, the plaintiff, [and his wife and two of his children,] has [or have.] become ill, and plaintiff has necessarily expended, and has become liable for the payment of large sums of money in endeavoring to be cured, [and to have them cured,] and by said acts of defendant plaintiff has sustained injury to his damage, dollars.

WHEREFORE plaintiff demands judgment that said slaughter house and cattle and hog pens be abated; and that the defendant be enjoined from further maintaining them; and that plain

tiff have and recover from defendant plaintiff's costs of this action.

dollars, and the

G H,

Attorney for Plaintiff.

FORM NO. 54.

COMPLAINT AGAINST A DEFENDANT FOR OBSTRUCTING A WAY TO PLAINTIFF'S PROPERTY.

[Name of Court.]

Plaintiff complains and alleges:

I.

That plaintiff, at the times hereinafter mentioned was and he is possessed of real estate, situate in the county of in this state, described as: [describe the property.] and he owned and owns a way thereto and therefrom over the adjoining land, which adjoining land during said times was and is owned by the defendant, which way was and is from and to a public highway, and to pass and repass freely at all times thereon with his family and employees and others, with horses, cattle, carts, wagons and other personal property, and which way is described as: [describe the way.]

II.

That the defendant, on the day of, and at other times thereafter, and before this action, obstructed said way of plaintiff by building a fence across it; [or state what the obstruction was] and defendant has ever since maintained said fence [or obstruction] without the consent of plaintiff; whereby the plaintiff has been for a long time, and is, prevented from enjoying said way, to his damage, dollars;

WHEREFORE plaintiff demands judgment that said obstruction be abated; and that defendant be enjoined from erecting or maintaining any obstruction upon or across said way; and that plaintiff have and recover from the defendant lars, and plaintiff's costs of suit; and for such other or further relief as the equity of the case may warrant.

-dol

GH,

Attorney for Plaintiff.

FORM NO. 55.

COMPLAINT AGAINST A DEFENDANT CORPORATION FOR OBSTRUCTING A PUBLIC HIGHWAY.

[Name of Court.]

Plaintiff complains and alleges:

I.

That the defendant during the times hereinafter mentioned was and it is a corporation organized under the laws of this state;

II.

day of

and ever since has in block

That plaintiff was on the been the owner of, and in possession of lot No. No.in the city of

in this state; and said lot dur

street, a

ing all of said time fronted, and it fronts on public highway in said city, and which, before the grievances hereinafter complained of, afforded unobstructed means of ingress to and egress from said lot;

III.

That said defendant has never had said street condemned for its use; and it constructed upon and along said street and in front of said lot of plaintiff, on or about the month of — high embankments, and placed thereon wooden ties, and steel and iron rails, and ran thereon, its locomotives and trains of cars, and has ever since said month of maintained upon and along said public highway said embankments and said wooden ties, and said rails thereon, and has run and runs its locomotives and trains of cars thereon, and thereby interferes materially with the ingress to and egress from said lot of plaintiff, and has thereby diminished the value of plaintiff's said lot in the sum of dollars to plaintiff's dam

WHEREFORE plaintiff demands judgment against defendant for the sum of dollars, and plaintiff's costs of this action, dollars be paid to defendant

and that unless said sum of

within

days after judgment in this action, said obstructions be abated, and the defendant be enjoined from further maintaining the same, or any obstructions upon and along said

street.

G H,

Attorney for Plaintiff.

duly given and made against the defendant C D in the [state the name of court,] in this state, for the sum of dollars; and said judgment was on the

day of

entered and docketed in the office of the clerk of said court.

II.

That at the time said judgment was so entered and docketed said C D, the person against whom said judgment was rendered, entered and docketed, was the owner in fee simple of a tract of land situate in said county of in this state, and which was bounded and described as [describe the land] and which land was not then and has not been since exempt from execution;

III.

That on the day of an execution was issued out of said court to enforce said judgment, and the same was delivered to the sheriff of said county of, under and by virtue of which, said sheriff levied on said land and advertised and sold the same to plaintiff, who paid the purchase price therefor, and said sheriff executed and delivered to plaintiff a certificate of such sale; and subsequently, and on the day of and before this action, said sheriff, by reason of such judgment, execution, levy and sale, executed and delivered to plaintiff a deed of said tract of land, pursuant to such judgment, execution. and sale;

IV.

That intermediate such sale, and the delivery of said deed, the defendant C D was in possession of said tract of land; and while so in possession, and without the consent of plaintiff, the defendant cut down and removed from said land trees which were growing thereon, and removed fences, which were on said land, and which constituted a part of the realty;

and thereby he diminished the value of said tract of land in the sum of dollars, to plaintiff's damage - dollars.

for

WHEREFORE plaintiff demands judgment against defendant dollars; and the plaintiff's costs in this action.

at the county of

Plaintiff complains and alleges: That on the day of in this state, defendant violently assaulted plaintiff and beat him severely, and tore his clothes; and the plaintiff was by such beating made ill and lame, and was disabled from attending to his business for days, and was compelled to pay dollars in endeavoring to be cured; and plaintiff has been ever since said beating, and for a long time will be, by reason thereof, lame; and plaintiff has sustained injuries by said acts of the defendant, to his damage - dollars.

for

WHEREFORE plaintiff demands judgment against defendant dollars, and plaintiff's costs in this action.

this state, the defendant maliciously intending to injure plaintiff in his good name and reputation, appeared before

a