Source: Jackson County Chancery/Circuit Loose Records
Available: Tennessee State Library & Archives and Tennessee Technological University Library
To the Hon W. G. Crowley Chancellor of the 5th Chancery Division of the State of Tennessee presiding at Gainesboro, Jackson County, Tennessee.
The Bill of Complaint of Clinton Jones (*marked out-- and William E. Jones --) citizens of Jackson County, Tennessee
Elizabeth Thaxton and her husband Alexander Thaxton
James W. Meadows
Artimissia Keith and her husband William Keith
Iby Gipson and her husband Tobias Gipson
Margaret Rush and her husband James Rush
Martha Huff and her husband Cullom Huff
Franklin Meadows commonly known as Duke Meadows
Elizabeth Allen and
all citizens of Jackson County, Tennessee and
John Allen and Mariah Allen of the state of Kentucky and are non-residents of the State of Tennessee
Humbly complaining your orators most respectfully represent and show unto your Honor that on the 13th day of December 1873 one Charles Meadows instituted and commenced in the circuit court of Jackson County Tennessee an action of ejectment against one Charles Haile who was at that a tenant of defendant Elizabeth Thaxton occupy the following described tract of land, to recover which said action was brought the tract of land is described as follows to wit lying in the 11th Civil District of Jackson County Tennessee Beginning on Charles Meadows . . . containing fifty acres more or less -- for a more perfect description of said land reference is here made to the certified copy of the verdict and judgment in said ejectment case which herewith filed and which will be herein after referred to and mentioned as Exhibit "A" to this bill--
Your orators state to your Honor that said ejectment cause progressed regularly in said court until the May Term 1877 of said Circuit Court of Jackson County, Tennessee when at said May Term 1877 and on the 29th day of May 1877 said cause was submitted to a Jury of Jackson County, Tennessee when there was a verdict and judgment infavor of the plaintiffs therein that they recover of defendants therein all and every part of said tract of lands above described.
Your orators would further state to your Honor that pending said action in ejectment law Charles Meadows died intestate in Jackson County, Tennessee whereupon a icesefacias(?) was duly and regularly ordered to issue in said cause cause (sic) which was never and duly and legally executed upon and are of said heirs of Charles Meadows deceased to wit the defendants hereto except Elizabeth Thaxton and her husband Alexander Thaxton and Joshua Haile, when said cause was duly and regularly revived in the (?)(?)(?) of said heirs, before final judgment in said cause a copy of the verdict and final judgment in said cause is here with file marked as Exhibit "A" hereto and asked to be made a part of this bill as much so as if herein copied at length in the same words and figures -- but need not be copied --
Your orators charge that after said verdict and judgment in said circuit court in said ejectment cause as aforesaid and long after circuit court had adjourned, to wit on the ___ day of ____ 1877 and while circuit court was in cession at Cookeville Tenn, the minutes of said court not having been signed by his Hon, the circuit judged presiding before he left said court were come to said circuit judge at Cookeville Putnam County Tennessee to be here signed when said defendant Joshua Haile appeared before said court in the absence of all the plaintiff in said ejectment suit an order giving the defendant Elizabeth Thaxton and her husband or to her attorney the defendant Joshua Haile the suits for said tract of land for the year 1877 and also all the rents and arising from said land from the death of said Chas Meadows upto said year 1877, A copy of said order is herewith filed as Exhibit "B" to this bill and is is (sic) asked and ample manner as if herein copied in the same words and (?)(?)(?) -- but need not be copied, said order is contained in the certified copy of said circuit court recon heretofore referred to in this Bill --
Your orators charge that said order was fraudulently procured by said Haile. It was not made in open court, none of the plaintiffs in said cause were present when it was made it was not even made in the county where said was pending but in Putnam County, Tennessee as aforesaid, said order purports to be by consent of the plaintiffs when in fact the plaintiffs nor any of them were present, nor did they or any of them give any consent to said order --
Your orators state that defendants except Haile and Elizabeth Thaxton & her husband are heirs at law of said Chas Meadows deceased except the husbands of the married women, they further state that Elizabeth Allen, Thomas Allen, John Allen, and Mariah Allen are the children of Malissa Allen who was a daughter of said deceased and are minors and have no general guardian.
Your orator Clinton Jones avers and charges that he on the ___ day of ____ 1876 purchased from the said heirs of Tobias Gipson and wife Iby Cullom Huff and wife Martha John Meadows Franklin alias Duke Meadows William Keith and his wife Artemissa and Artemy Harris - for a valuable consideration all and every part of said tract of land belonging to them or their entire right title interest and claim to all and every part of said land. He also purchased from them and each of them all their right title claims and interest in and to each and every part of the rents and profits arising from said lands from the death of Charles Meadows to and including his purchase were made said purchases and conveyances of both the lands and the rents as aforesaid are evidenced by title Bonds made and executed by each of said parties to your orator on the ____ day of ____ 1876, and the purchase money having since been paid by your orator for said interests in said land and rents the respective parties have made to your orator a deed both for said land and the rents, aforesaid, said decd are title bonds are all regular & c and are here filed as exhibit C, D, & C to this Bill but need not be copied.
Your orator Wm E. Jones warns and charges that on the ___ day of ____ 1876 that defendant James Rush and his wife Margaret Rush sold and conveyed unto your orator, for valuable consideration by title bond of that date all their right title interest and claim in and to all and every part of said lands together with all their right title and claim to the rents arising from said land from the death of Charles Meadows to and including the year in which said conveyance was made.
Your orator warns and charges that having paid the purchase money on said land he now has the deed of said James and Margaret Rush comming their entire interest in said lands and rents aforesaid , -- said deed and said title band one herewith filed as Exhibits G & H but need not be copied.
Your orators state to you Honor that said land descended to the defendants hereto except Joshua Haile and Elizabeth Thaxton & her husband Alexander Thaxton in common and that said land has never been divided or partitioned between said heirs of Charles Meadows deceased from whom the same descended.
Your orators aver and charge that they are the respective owners of the interest of said heirs as aforesaid in and to all and every part of the said land and the rents as aforesaid.
Your orators aver & charge that none of the parties plaintiffs in said ejectment suit from whom said conveyance were made to your orators in any under entwined in said cause at Cookeville Putnam County, Tenn giving to defendants Elizabeth Thaxton & her husband or to Joshua Haile their attorney the rents and profits arising from said land for the year 1877 and also all the rents there in orrians(?) from the death of Charles Meadows deceased and even though such consent had been by them given and made the same was a fraud upon the rights of your orators they having already parted with and conveyed to your orators all their right title & interest in and to said lands and every part thereof and the rents arising there from. so you Honor can see that even though said andr(?) was agreed and consented to as it purports to have been the same was without power as authority and was a grass(?) fraud upon your orators rights and was entered without the knowledge or consent of your orators or those from whom they purchased
Your orators aver and charge that under and by virtue of said conveyances they are entitled to the rents and profits arising from said lands for the years 1874-5-6-&7.
Your orators further charge that during the pundency(?) of said ejectment suit in the circuit court defendant Joshua Haile illegally fraudulently and without any authority collected and appropriated the rents arising from said land for the year 1874&5 and is now seeking to collect the rents for the 1877 off of your orator Clinton Jones by suit before and Charles Hopkins a Justice of the Peace of Jackson County Tennessee and has reconvened judgment for the same from which judgment your orator Clinton Jones prayed and obtained an appeal to the next term of the Circuit Court for Jackson County where said appeal said judgment is wholy unjust the rents belonging to your orators as aforesaid.
[There are many more pages to this case. However, there is no additional genealogical information to be obtained from the case.]