Q Q
FLOYD CIRCUIT COURT
THE BANK JOSEPHINE, PLAINTIFF.
VS: ANSWER AND CROSS PETITION
or DEFEMJAEIT , ED HILL, against
DEFENDANT, JOE WHITAKER.
JOE WHITAKER, ET AL., DEFENDANTS.
Comes Defendant, Ed H111, and for answer
herein, and for cross-petition against his co-dcfendant,
' ch Whitaker, and says, it is true, and he herewith alleges,
that on the 22nd day of October, 1951, S. C. Allen, and Dc-
fcndant, Joe Whitaker, as joint makers, made, executed,
signed and delivered to this answering Defendant, and Plain-
tiff in Cross Petition, a certain promissory note in which
and by which the said 8. G. Allen and Joe Whitaker, promised 3
and agreed, to pay to the order of Plaintiff in Cross Petition,
Ed Hill,thc sum of One Hundred (3100.00) Dollars, four months
after the data thereof, at The Bank Josephine, ?restonsburg,
Kentucky: that thereafter, and before the maturity of said note
the same was endorsed by Plaintiff in cross Petition, and there-
after and before the maturity of said note, the name was i
discounted by and to the Plaintiff, The Bank Josephine, Preatonc-
burg, Kentucky. 5
Plaintiff in cross Petition, Ed H111, says i
further that said note became due and payable at the Place 1
where payable, four months from the date thereof, to-wit: [
February 22, 1932; that acid note is Just, past due and cntire- .
,