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In the Circuit Court of the United States of America,

IN AND FOR THE SOUTHERN DISTRICT OF NEW YORK.

SECOND CIRCUIT.

-IN EQUITY.

CHRISTOPHER C. CAMPBELL,

COMPLAINANT, AND ASSIGNEE IN TRUST,

VERSUS

THE MAYOR, ALDERMEN, AND COMMONALTY OF
THE CITY OF NEW YORK,

DEFENDANTS.

PLEADINGS AND PROOFS.

LOCKWOOD & POST, Solicitors for Complainant,

No. 140 NASSAU STREET (Morse Building), NEW YORK.

FOR THE COMPLAINANT.

MARCUS P. NORTON, of Counsel for Complainant,

TROY, N.Y.

GEORGE H. WILLIAMS, of Senior Counsel for Complainant,

WASHINGTON, D.C.

BENJAMIN F. BUTLER, also of Senior Counsel for Complainant,

BOSTON, MASS.

FOR THE DEFENDANTS.

WILLIAM C. WHITNEY, Counsel for the Corporation,
Solicitor for Defendants,

NEW YORK.

BETTS, ATTERBURY, & BETTS, AND

FREDERIC H. BETTS,

Of Counsel for Defendants,

NEW YORK.

BOSTON:

FRANKLIN PRESS: RAND, AVERY, & CO.

1881.

V73753 Eng 978.81.3

In the Circuit Court of the United States of America,

IN AND FOR THE SOUTHERN DISTRICT OF NEW YORK.

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THE MAYOR, ALDERMEN, AND COMMONALTY OF THE
CITY OF NEW YORK,

Defendants.

Address.

1 Introductory.

2

Bill of Complaint.

To the Honorable the Judges of the Circuit
Court of the United States, in and for the
Southern District of New York:

CHRISTOPHER C. CAMPBELL, of East Chatham, in the town of Chatham, county of Columbia, and State of New York, and a citizen of the said State, and also a citizen of the United States of America, brings this his bill into this Honorable Court against the Mayor, Aldermen, and Commonalty of the City of New York, a municipal corporation in the Southern District of New York aforesaid, duly organized under and pursuant to the laws of the State of New York, as hereinafter will more fully and at large appear.

Citizenship of
James Knibbs.

And thereupon your Orator complains and says: that heretofore and prior to the twenty-fourth day of May, A.D. 1864, one James Knibbs, who, at that time and for a long time previous

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