Campbell v. Frankem

This action was commenced in the Marion Superior Court. A change of venue was taken to the Hendricks Circuit Court. The complaint contains seven paragraphs. The first is as follows:

That on February 11th, 1874, the defendant, for the consideration of one thousand dollars, agreed to convey to plaintiff certain real estate described as lot No. 11, and lots Nos. 106 and 107, in a certain addition to Indianapolis, subject to certain incumbrances by a mortgage and accrued taxes, which the plaintiff was to pay, as part of the consideration.

“That, before and at the time of said agreement, said…