The plaintiff complains of the defendant, and says that on the day of 18—, the plaintiff was possessed of a messuage, and was entitled to a way from the said messuage over a close to a public highway and back again, for himself and his servants on foot, and with horses, cattle, carts and carriages, at all times, all in said county; yet the defendant wrongfully obstructed the said way by fencing across the same, whereby the plaintiff was damaged dollars.

Wherefore plaintiff demands judgment for

other proper relief.

dollars, and

T. N., Att'y for Plaintiff.

No. 53.

Against an adjoining occupier for discharging rain from the eaves of a roof upon the plaintiff's land.

The plaintiff complains of the defendant, and says that on the day of 18, at said county, the defendant was possessed of a building abutting on the land of the plaintiff, to wit (here describe), and then and there wrongfully built the eaves of the said building hanging over the plaintiff's land, whereby the rain-water poured on the said land and made it wet and useless, whereby the plaintiff was damaged Wherefore plaintiff demands judgment for other proper relief.

dollars. dollars, and

A. C. G., Att'y for Plaintiff.

No. 54.

Complaint for debauching the plaintiff's wife.

In the

A. B. vs. C. D.

and up to the

Said plaintiff complains of said defendant, and says that prior

day of

18-, said plaintiff and his

wife, B. B., lived together in peace and harmony as husband and wife, and with their children, of whom they had

sons and

daughters, they were in the enjoyment of the highest state of domestic happiness and conjugal felicity. But on the day and year aforesaid, and on divers other days and times between that time and the commencement of this action, the defendant did wrongfully, deceitfully and wickedly seduce, debauch and carnally know said B. B., the said wife of the plaintiff, whereby she abandoned the plaintiff and her children, and the plaintiff has lost her services and has been put to great inconvenience, and has suffered great grief, mortification and anxiety, and has been damaged in the sum of thousand dollars, for which he demands judgment.

K. K., Att'y for Plaintiff.

CHAPTER III.

COMPLAINTS IN EQUITY.

No. 1. For the foreclosure of a mortgage where there are junior incumbrances,

2.

3.

and praying the appointment of a receiver.

For the foreclosure of a mechanic's lien.

For the foreclosure of a mortgage claiming 7 per cent. interest under the law of another state.

4. To foreclose a mortgage and cancel an uncanceled mortgage.

5. For foreclosure of an indemnifying mortgage.

6. To foreclose a chattel mortgage and have a receiver appointed, where successive mortgages were given on the same goods.

7. Against heirs - foreclosure of mortgage of ancestor.

8. For the enforcement of a mechanic's lien upon the interest of a tenant for repairs or machinery.

9. To redeem-additional paragraph.

10. To redeem a mortgage.

11. To quiet title.

12. To quiet title.

15. For specific performance of a contract for a conveyance or lease of real

estate.

16. For specific performance of a parol contract for the sale of real estate taken out of the statute by part performance.

17. For specific performance of parol agreement for exchange of land.

18. For specific performance of a sale of real estate.

19. For specific performance of a contract in favor of the vendor.

20. For specific performance of a contract to convey and quiet title.

21. For specific performance by the lessee of an agreement to execute a lease.

22. To enjoin the negotiation of negotiable instruments.

23. For abatement of a nuisance, with damage, and an injunction against its maintenance.

24. Against a tenant, to enjoin waste with forfeiture and damages.

25. To enjoin a sale of real estate.

26. For an injunction.

27. To enjoin sale by sheriff.

28. For the recovery of the possession of an instrument not negotiable, or past due, and to enforce payment against the payor.

29. For the recovery of money against the husband, and a decree subjecting lands, fraudulently conveyed to the wife, to the payment of the judgment.

No. 30. To revive a judgment of foreclosure and quiet title.

31. To enforce a trust in notes.

32. To enforce a trust in real estate.

33. To enforce a trust in land or money.

34. For the rescission of partnership articles, and dissolution of co-partnership. 35. To set aside a fraudulent conveyance.

36. To reform a deed.

37. Action for dissolution of partnership, etc.

38. Complaint for dissolution of partnership for an injunction and receiver.

39. For a specific performance of a contract of life insurance.

40. By a reversioner or remainderman to quiet title.

41. For the possession of real estate and to quiet title.

No. 1.

For the foreclosure of a mortgage where there are junior incumbrances, and praying the appointment of a receiver.1

In the

STATE OF INDIANA,

-Circuit Court,

County, Term, 18-.

A. B. vs. C. D. and D. D., his wife, E. F., G. H. and I. J.

The plaintiff complains of the defendant, and says that said defendant C. D., on the day of -, 18-, by his note, now overdue, and of which a copy is herewith filed, promised to pay the plaintiff dollars, and to secure which, said C. D. and defendant D. D., his wife, on the same day duly executed, acknowledged and delivered to the plaintiff a mortgage, of which a copy is herewith filed, whereby they mortgaged lot

day of

in

block in the town of -, in said county, then vacant, and thereupon said mortgage was, within forty-five days of its execution, duly recorded in the recorder's office of said county. That afterwards, to wit, on the -, 18-, said defendant E. F. furnished material and built a house on said lot, and duly filed a notice in the recorder's office of said county, within sixty days of the completion of said building, claiming a lien for dollars, and afterwards, to wit, on the 18-, said defendants C. D. and D. D. executed another mortgage on said lot to said G. H., to secure on the same day duly recorded in said recorder's office, and on the next day, to wit, the -, 18-, said defendant I. J. recovered judgment against said defendant C. D., in the

day of

day of

dollars, which was

1 Where a receiver is to be appointed the complaint should be verified.

said circuit court, for dollars. That said note, and both said mortgages, as well as said mechanic's lien and judgment, remain wholly unpaid, whereby the plaintiff has a lien paramount to all said defendants', E. F., G. H. and I. J., upon said lot, and they have liens in the order herein above stated; and plaintiff says that said defendant C. D. is insolvent, and said lot is not worth the amount of the plaintiff's claim.

Wherefore plaintiff demands judgment against defendant C. D. for dollars, and for a foreclosure of the mortgage and sale of the mortgaged premises, and a decree declaring the plaintiff's priority, and a foreclosure of the equity of redemption of all said defendants in said lot, and the appointment of a receiver to take possession of said property pending the suit, and for all proper relief. T. T., Att'y for Plaintiff.

The plaintiff complains of said defendants, and says that said defendant C. D. is the owner in fee of lot

in block

day of

in the town of That prior to the 18-, the plaintiff furnished two hundred thousand bricks and other material for the building of a brick house upon said lot, which were by said E. F. used to build a house on said lot, and said G. H. performed the carpenter work thereon; that said bricks were delivered upon a contract to said first named defendant, for

dollars. That on the day and year last aforesaid, and within sixty days from the completion of said building, the plaintiff filed in writing in the recorder's office of said county, a notice that he would hold a lien for said sum upon said house and lot, of which a copy is herewith filed. That each of said other defendants, in like manner, filed a separate and several notice of his intention to hold a lien for the sum due him, for the work so performed by him upon said house, which several liens were in