12. Plaintiffs further state that after learning of the deceit and the fraud committed upon them by the said Anthony Michalski, they did, on June 23rd and July 10th, A. D. 1917, tender to the said Anthony Michalski the sum of two hundred ninety ($290.00) dollars together with the assignment of the farm property and bill of sale above described and requested the said Anthony Michalski then and there to return to them the said land contract and assignment thereof of their own property, but the said Anthony Michalski refused to do so and still refuses to do so, and has started summary proceedings against plaintiffs before one Michael Kluczynski, Justice of the Peace, of Hamtramck township to obtain possession of their said property and threatens to obtain judgment against plaintiffs and evict them from their said homestead, and plaintiffs fear he will do so unless retrained by an order and injunction of this court from proceeding with the said lawsuit before the justice of the peace and unless the said justice of the peace be restrained from hearing and determining the said lawsuit, until the further order of the court, and that the said Anthony Michalski be further restrained from starting any other proceedings to obtain the possession of said property or from actually taking possession of the said property until the further order of this court, and from selling, assigning, transferring or disposing of the said equity in the said land contract.

13. Plaintiffs further state that they always have been ready and willing and are now ready and willing to return to the said Anthony Michalski all moneys, property and property rights received from him in this said transaction, and hereby make an offer and tender to the said Anthony Michalski of the said sum of two hundred ninety ($290.00) dollars, with interest, together with the bill of sale for the personal property and the assignment of the contract for the farm property.

In consideration thereof these plaintiffs pray:

I. That the said Anthony Michalski, the defendant herein, may without oath, his answer on oath being waived, full, true, direct and perfect answer make to all and singular the matters herein stated and charged.

II. That the said assignment from the plaintiffs to said defendant, may be vacated and set aside and decreed to be null and void, as against these plaintiffs, and that the said assignment conveys no right, title or interest in the said land or any part thereof to the said defendant Anthony Michalski.

III. That the said Anthony Michalski may be decreed to release to these plaintiffs all right, title and interest which he claims, or appears to have in the said land by color of the said assignment or otherwise.

IV. And that the said Anthony Michalski may be decreed to have no right, title or interest whatever in or to the said land or any part thereof, and that these plaintiffs may have leave to cause such decree to be recorded in the office of the Register of Deeds for Wayne County.

V. That the said Anthony Michalski may be restrained by an injunction of this court from taking any legal steps to obtain the possession of the premises herein involved, or from selling, assigning or disposing of the said property, or from disposing the plaintiffs of the said property.

VI. And that these plaintiffs may have such further or other relief in the premises as shall be agreeable to equity and good conscience.

Teofil Banski,

Apolonia Banski.

Arthur A. Koscinski,

Attorney for plaintiffs.

State of Michigan, ss County of Wayne.

On this 13th day of July, A. D. 1917, before me, a notary public, in and for said county, personally appeared Teofil Banski and Apolonia Banski, the plaintiffs above named, and severally made oath that they have heard read the foregoing bill of complaint by them subscribed and know the contents thereof and that the same is true of their own knowledge, except as to the matters which are therein stated to be on information and belief and as to those matters they believe it to be true.

Leonard F. Kowalski,

Notary Public, Wayne County, Michigan. My commission expires Oct. 15, 1919. Exhibits "A," "B" and "C" of plaintiff:

Exhibit "A"

Hemtremck, Mich.

Deth June 18-1817

Des is Degremet between Anthony Michalski and T. Banski and is waw, A. Banski Farm. Known as the west half, of, the east half, of the northwest quarter of, Section Four (4) in Town Four (4) North of Range

Fifteen en contoinoy Forty acres more or lest in Permit of Witness.

Anthony Michalski.

Adam Buczynski.

Exhibit "B"

In consideration of one ($1.00) dollar to us in hand paid by Anthony Michalski, hereby grant, sell and convey to him all our right, claim and interest in and to the within contract and in to the premises therein described, with all benefits to be derived therefrom, and said Anthony Michalski, in consideration of the premises hereby assumes and agrees to perform and carry out all parts of said contract (not already performed) within provided to be performed by the party of the second part thereto. Dated June 19, 1917.

Teofil Banski, (Seal)

In presence of Apolonia Banski. (Seal)

Jacon Gaffke,

W. Rybicki.

State of Michigan, County of Wayne, ss.

On this nineteenth day of June, one thousand nine hundred and seventeen, before me, a notary public in and for said county, personally appeared Teofil Banski and Apolonia, his wife, known to me to be the persons who executed the foregoing assignment of contract and acknowledged the same to be their free act and deed.

Jacob Gaffke, Notary Public, Wayne County, Mich. My commission expires Oct. 22, 1919.

Exhibit "C"

This Contract, made the fourth day of March, one thousand nine hundred and fourteen.

Between John Karp, Township of Casco, St. Clair County, Michigan, of the first part, and Andy Peklo, of the City of Detroit, Wayne County, Mich., of the second part, Witnesseth, as follows: