Further answering said paragraph, plaintiff says that on the day that he learned the farm had been sold to the defendant, Byers, plaintiff had sent an agent out to said premises to repair the roof of the house and barn and make other improvements. Plaintiff denies said farm had grown up to weeds and says that said farm and said crops growing thereon, when the purchase was made, were cared for and harvested by plaintiff.

2. Answering paragraph two, plaintiff admits that six month's interest became due on the contract February 1st, 1919, and says that at that time Hartley E. Hendrick, an attorney of Grand Rapids, Michigan, who was then acting as attorney for plaintiff had funds of plaintiff's in his possession and had been instructed to pay said interest and that plaintiff did not know until after the sale had been made to said Byers that that said interest had not been paid by his said attorney, nor did he know that the 1918 taxes, due in December, had not been paid; and plaintiff denies that the defendant, Louis P. Ohler, demanded the same several times, but he admits that a so-called notice forfeiting said contract, was served upon him after the defendants, Ohler, had made the said sale to the said Byers, whether or not said defendants have a copy of said notice plaintiff does not know, as defendants failed to attach a copy of the same to their cross-bill, as therein alleged.

Further answering said paragraph, plaintiff denies that said sale was made in good faith, but he admits that the said Byers had been in possession for several weeks when this suit was started.

3. Answering paragraph three, plaintiff denies that the said Ohler got out of said farm only what was due him, as plaintiff had an equity of a large amount, to-wit, $3500.00 and upwards, in said property. He denies that it was necessary to make a sale to preserve said property, and charges the truth to be that he seized the slightest pretext possible as a basis for a so-called or alleged forfeiture of said contract; that said defendant might again sell said property for a large amount and to keep and retain the amount paid in by plaintiff and his assignor.

Further answering said paragraph he denies each and every allegation therein contained, excepting that he did state to Mr. Gleason, that his attorney, Mr. Hendrick and his agent, Mr. DeGolia, were endeavoring to sell said property, and had a sale practically consummated at the time plaintiff learned defendants had sold said property to the said Byers.

He admits that he stated to Mr. Gleason that Mr. Hendrick and Mr. DeGolia assured plaintiff he would not lose anything on the purchase, and that he ought to make some money on it. He admits that he stated he would not live on the farm as he is employed as a laborer in a furniture factory in Grand Rapids; that he is a single man well along in years, and that a large part of the savings of a lifetime have been invested in said premises. He denies that he said that he had purchased the place against his better judgment; that he had a guarantee from anyone he would not lose anything on the purchase. He denies that he said he had no use for said farm, but admits that he told Mr. Gleason he would like to get his money out of it.

4. Answering paragraph four, he neither admits nor denies that the notice, Exhibit A, legally terminated his contract, as there is no Exhibit A attached to said cross-bill. Plaintiff, however, denies that any notice legally terminated his contract, and denies that defendants can hold possession of said property; denies that they had a right to sell, buy or deal said property without plaintiff's consent, and for further answer says that the whole transaction is a wilful, deliberate fraud upon the rights of plaintiff, is unjust, unequitable and is but an attempt to legally steal from plaintiff his rights in said property. Further answering, plaintiff reiterates that he made a legal tender of the interest due and was ready to pay any taxes due, had his tender been accepted, and was and now is ready and willing to pay to defendants, or any of them, anything he owes, or anything the court may find plaintiff owes to defendants.

And plaintiff denies that defendants, or any of them, are entitled to to the relief prayed for in their cross-bill of complaint, or to any relief in the premises, and prays that the same may be dismissed with his costs. John M. Dunham, Jeremiah C. Hubbell,

Attorney for plaintiff, Business Address:

(e) The Contract Involved-(Exhibit B).-This contract, made the 29th day of June, in the year of our Lord one thousand nine hundred seventeen, between Louis P. Ohler and Agnes A. Ohler (husband and wife), of Jennison, Ottawa County, Michigan, parties of the first part, and Andrew D. Boomsma and Lucy Boomsma (husband and wife), of Holland, Ottawa County, Michigan, parties of the second part, witnesseth as follows:

First. The said parties of the first part, in consideration of the sum of money hereinafter mentioned to be paid to them by the said parties of the second part, and of the covenants to be performed by the said parties of the second part, as hereinafter expressed, hereby agree to sell to the said parties of the second part, all that certain piece or parcel of land situate in the township of Wyoming, County of Kent, State of Michigan, known and described as follows:

The east half (1/2) of the southwest quarter (J) of section fifteen (15) in township six (6) north, range twelve (12) west, except nine and one-half (9 1/2) acres in width from the west side thereof and except parcel conveyed in deed recorded in liber 399 of deeds, on page 578, with the privileges and appurtenances thereunto belonging.

Second. The said parties of the second part, in consideration of the covenants herein contained on behalf of the said parties of the first part to be performed, agree to purchase of the said parties of the first part, the above described land and to pay for the same to the said parties of the first part, or their legal representatives, the sum of six thousand dollars, lawful money of the United States, in the manner following, that is to say: (on the margin appeared, "Three thousand dollars by transferring a house and several lots in Holland to first parties by second parties, the balance"), one hundred dollars or more each year on August, commencing August 1, 1919. Interest on the whole amount to commence August, 1917. First parties to give second parties a warranty deed of above premises when one thousand dollars has been paid on the principal and take mortgage for the balance, with interest at the rate of six per cent. per annum, payable semi-annually, on the whole sum that shall from time to time remain unpaid; both principal and interest to be paid at Jennison, Michigan, and also, that they will, so long as any part of the principal or interest of the said consideration money remains unpaid, well and faithfully, in due season, in each and every year, pay, or cause to be paid, all taxes and assessments, ordinary and extraordinary, that may for any purpose whatever be levied or assessed on said premises, or on this contract, or the interest in said lands created or represented by this contract, and that they will not commit or suffer any other person to commit, any waste or damage to the said lands or the appurtenance, except for firewood or otherwise for their own use or while clearing of the lauds for cultivation in the ordinary manner.