14. That on the same day that said first quit-claim deed was recorded several other like quit-claim deeds from said Meister to said Lefton were made, none of them bearing any revenue stamps, of various properties in regard to which this plaintiff believes said Meister was in like default. And that at other times still other like deeds were made by him and recorded, in all of which this plaintiff believes and has good reason to believe, said Meister attempted to evade his just obligations. And in particular with regard to the two quit-claim deeds herein complained of this plaintiff believes that they were the result of a deliberate and cunning attempt on the part of said Meister to defraud it by perverting the laws in force with regard to men in the United States service, to his own advantage, he being at the time a single man, but at no time in such service for some reason or another.

15. This plaintiff has no definite knowledge as to whether said Lefton participated in said fraud, but that from all the circumstances believes either he knew nothing of said deeds or participated in the same. That it believes and has good reason to believe, that said Lefton never paid any actual consideration for said lots, nor had any actual interest therein, but either suffered his name to be thus used as a vehicle of fraud, or was in ignorance of the transaction. That said land contracts each provided that the interest of the vendee could not be transferred without the written consent of the vendor. That such consent was never given nor asked by or of this plaintiff. That if in fact said Lefton took any active part in said transaction, he had notice of this restriction, and acted at his peril in accepting any conveyance from said Meister. That said Lefton has never by himself nor anyone acting in his behalf, asserted any right, title or interest in or to said lots by virtue of said deeds, but on the contrary, as this plaintiff is informed and believes, said Meister now claims to have whatever interest said Lefton might have had, and is attempting to mulct this plaintiff with such claims. That said Meister has approached others with said old contracts, trying to unload the same upon them to his own profit and at the expense, annoyance and vexation of this plaintiff.

16. That this plaintiff, being at the time in ignorance of said deeds and the cloud on its title thereby, sold said lots to another party on April 24th, 1919, whose interest would also be affected by said deeds and whom plaintiff feels bound to protect.

17. That said deeds constitute a cloud upon the title of this plaintiff to said lots, and being without adequate remedy except in equity, therefore prays:

18. (a) That each of said defendants may be held to answer under oath as to the facts and circumstances stated in this bill and that each disclose what, if any, right, title or interest he claims at present in or to said lots and in particular that said Lefton discovered to this court what part he actually played in said transaction.

(b) That the said quit-claim deeds above mentioned may be declared fraudulent, null and void of any effect whatsoever as against the title of this plaintiff and that the same be delivered up to be cancelled.

(c) That said defendants, Saul H. Meister and Julius Lefton, be decreed to have no right, title or interest in or to said lots either by virtue of said land contracts or said deeds.

(d) That the cloud placed upon the title of this plaintiff be removed and the decree in this cause may be registered with the Register of Deeds in the County of Wayne and shall stand in effect as cancellation of both of said deeds and as a bar against anyone asserting any right, title or claim in or to said lots.

(e) That each of said defendants be restrained and enjoined from asserting or representing that they or anyone claiming under them have any right, title or interest in or to said lots, and further from placing any further cloud upon this plaintiff's title thereto.

(f) That this plaintiff may have such other and further relief as shall be agreeable to equity.

SECURITY INVESTMENT COMPANY,

(Signed) By Daniel R. Foley,

Its Attorney.

State of Michigan, County of Wayne, ss.

Daniel R. Foley being duly sworn deposes and says, that he is the attorney for the above named plaintiff and makes this affidavit in its behalf, being duly authorized so to do, that he further makes the same for the reason that said plaintiff is not a resident of Wayne County and further that he has a better acquaintance with the facts and circumstances set forth in this bill than any one of the officers of said plaintiff; that he has read the above bill of complaint by him subscribed and knows the contents thereof and that the same is true and to his own knowledge except as to matters therein alleged on information and belief and as to these matters he believes it to be true.

(Signed) Daniel R. Foley.

Subscribed and sworn to before me this 8th day of September, A. D. 1918.

Eugene A. Walling. Notary Public, Wayne County, Michigan. My commission expires March 13th, 1920.

Daniel R. Foley,

Attorney for Plaintiff, 1626 Penobscot Bldg., Detroit, Mich.

State of Michigan County of Wayne,

SS.

(c) Exhibit "2," the Contract Relied Upon.-This contract, made this 19th day of October in the year One thousand nine hundred and fifteen between Moore & Veale Real Estate Corporation, Inc., in Michigan, of the City of Detroit, Wayne County, Michigan, parties of the first part and Thomas B. Townsend party of the second part.

Witnesseth: The parties of the first part, in consideration of the payments to be made and the agreements to be performed by the party of the second part as hereinafter set forth, agree to sell and convey to the said party of the second part, the following described land, situated in the Village of Ecorse, Wayne County, Michigan, to-wit: Lot No. Seventeen (17) of the Moore & Veale's Ecorse Subdivision of the south part of lot two (2) of the Jonas Goodell Estate Sub., P. C. Two Hundred Twenty-Six (226) Village of Ecorse, Wayne County, Michigan.