xt73bk16mf8w_529 https://exploreuk.uky.edu/dips/xt73bk16mf8w/data/mets.xml https://exploreuk.uky.edu/dips/xt73bk16mf8w/data/51w14.dao.xml unknown 35 Cubic Feet 77 boxes archival material 51w14 English University of Kentucky Copyright has not been assigned to the University of Kentucky. Contact the Special Collections Research Center for information regarding rights and use of this collection. Louisville and Nashville Railroad Company and Lexington and Eastern Railway Company records Railroads -- Appalachian Region -- History. Railroads -- Kentucky -- History. [372b] George Copeland v. Jane Copeland text [372b] George Copeland v. Jane Copeland 2016 https://exploreuk.uky.edu/dips/xt73bk16mf8w/data/51w14/Box_53/Folder_5/2073.pdf section false xt73bk16mf8w_529 xt73bk16mf8w \ .
F£Y*?TT CIRCUIT COUTT.
Recurity front Company, naminittrntor
of Coorgo Copland, dccca ed, Elaintiff.
3T:"~"Wjii""“ffi, ,~’; ’ .1???) {5370"S-E;"-"'I‘TC‘.TQH
V.
0.?- i:'":i“3U=’JKY {BEIGE CCTIITJFY.
Jana Copland, &c., Befonfants.

— ~ — — — ~ ~ — o 0 o - - - — - — - -

The defendant, Kentucky Union Company. donuts
generally to plaintiff's Petition upon the ground that
Brno Fooe not state facts xnf'foiont to constitute any
con o of action against this defendant.

Without waiving its Tomurror aforesaid, the dofcndp
not, Kentucky Union Company, otrtoo that it is a corporation
orontod, organized and oxinting nude? the lows of tho *tato of
”entuohyi with power to contract and be contracted with, to sue

. and he toad, and rith all such other powers on are nocoo wry
or oopronxioto to the purposes of its incovporotion, and that
'\
its principal offioo nnﬁ ﬂlLGO of hueinoco is in the City of
ﬂexington, ingotto County, Kentucky.

Defendant furthor state: that one George Gopland,
formerly tronruror of the Kontuoky Union Company, died intestate
on who 11th day of February, 191$, in Fayette County, Kentucky,
of which County said Copland woo a resident and in which he was
domiciled at the time of his death, and that Subsequently on the

‘ day of 7orch, 1915, the wlmintiff, Security iiuot Company,
was duly opyointod and qualifiod no Adminiotrntor of said ﬂoorge,
Copland under and by virtue of orders of the Fayette County Court.

\\.
~— (1‘:-—

naia Court having jurisdiction in tho promises, and that tho
plaintiff thereupon entered upon its duties as Administrator
of saia estate ané has been over since and is now acting
in said capacity.

Dofondunt further states that at tho time of his
ﬂoath and for many years yrior thoroto, said George Copland
Vtcd hcl' tho nooition of Trenmuror of tho Kentucky Union Oom—
nuny one that in oOnnooti n with maﬁa position nnﬁ the fis-
charge of his duties as such Troocuror, saiﬁ Coplané became
inﬂobtoﬁ to this ocfcn not as horoinaftor more fully explained
anﬁ was So indcbtod at the time of his aoath.

Defendant further states that said George COPlanﬁ
at his death was indootoe to this ﬂofonfnnt in the total sum
of Fourtcon Th usend, Throo Hundroﬂ anﬂ Fifty-eight and twenty-
ei: ono~hun§ro§thn Dollars ((14,358.26), compocoa of the fif—
toon several items hereinafter m ntioneﬁ, together with
intorost thereon from tho rospnotiVC dates on which saiﬁ sover—
cl items become ﬂue, subjoot, however, to certain oroaits.
aggregating Two Thoucuno, ”no Hunfroa ané ?wcnty~sevon end five

> onowhundrodth“ Dollars (33,127.05), which mains the not balrnoo

of grinoipsl duo fr0m said George Conlnnd, or his estate, to
this defendant tho sum of TwolVo Thousana, ﬁne ﬂunﬁroa aha
Thirt¥*ono anﬁ twenty-one ono~hnnﬂrnﬁths “allots ($12,251.91),

' not incluaing interest. Wofoniont states that no part of acid
indobtoanoss on& no tort of tho interest thereon has over boon
xoturnoa or rotcid or accountoﬁ for in any way by tho sciu
George Copland, or any one for him, to this dcfcnﬁnnt, and that
on ouch of the items oonctituting onia total sum of $14,558.26

‘ the Sofonasnt, Kentucky Union Company, is entitled to intoxcst
at tho rate of six per cont {6%) per unnum from tho rospcotiVQ

\ ‘.
V 0:11:05; 11390:: which (1:132: 017’ 5:11:15. 121301113 "1.1003130 «2.11:: 1121321 1351.112.
‘ TI?1:£:‘~111:2:;11 L; 113.: 3210:: start-.1213 1:211:38 1:13:36: 000 1'30 (10:31:31.6.
1151:3353: an}: 11:13 2112201143012 to $2112.13 Soﬁenﬂmﬂ on “2,213 136331 (15:32? 01"
1311321, 1905.31 “£2210 amt: oi" i;‘13.530.00 on {1000113127 of a; certain (1211101:
[217326 or? 3’ 13. 5..-.210. 12331231 23;; 1:32:72. CIT-cog}? {2931121116, (5:13:3303153121‘0‘:
. 'T- 1.1 ‘:rwmm ‘.‘ “ _‘Hw “ we rvrﬁr ?-. “'le .’ "I 'r‘ v" '4“"",“ 71v”-".."31‘H' 4 ‘.‘"
'3’; bile: _I=.{§.=;2,;{3_(3r;‘f U31;2».}jr_ {10:11:}x243d“ ‘.:) :a..w 317(35):, (4.1. will -‘t(»-«_'-.:II»£{/UG—4
.5”: :1:3’5<1:-1511 ‘1‘11zty 27,1;1113‘2112'sxg', £"3‘1i': "'21:". f—EE'SEGGQRCER‘E 31;;1;I1~3x‘2§1‘f; :13". :‘113‘6.
:1:2':-:2:32: out of? 2:210 :f‘trgmaz of 1:31;: TZC’AZIS‘V-‘ify 17115-03”: (30323221111127 3 {3313235319
211123113; 0:? 2,112. 032.033.: 5931“ 2:31;: '5.»-.23r1"2::1:t ’uizcrxzoi’ was; '.:-'13 13210112: 2:31;?
3:31:11 21,32,311 5131:: Was: 1121323.; ‘:1???3‘."£1::‘1‘322ﬁ€)ﬁ 112163. 1121111332.?zorzi a? 512:, '
1321511: “1:21:29 :20 223216211112 3:33 '3211'? 255111: 171.15.: 1131‘: 12:11.2:3‘21’oeé :21‘». 331;? 113.51
“in: 2:21.63 2303:22158011? 'L>":':.;* 323:1 3:112:73; 01...; 311:", 3‘: 21:28:10
1711, 17213’w.:*¢cr 1111021 4:21;; 11:12.32: 0:“? ':'..tfqis 3131433 1:11 333:; 33.51::
312311132302". .‘; 3353139331 'iai Egg-‘51:; I‘ot<::j3;1irlg‘ 33.12.52 flint: of: 53450.00, 01'
2:21;? ”Dart “52133303”, {12117. {3212.13 :.:: 3*:‘211izairzj1201100 of: 13:32:21 11.331115210331206
.. "2:131:10198'3 <2:‘;1:l’“i; 2113‘ 34:21:“: ('.‘. :.1311:;::1:1'_?..{11:16.g £2.11
1731;313:3923: :11“? “521::- T’rmm 2511:1311 Company, ’12:: 13310 031x201? .1:? Georg-‘30
, 7
» 2139123313, "'17.,21121v‘2ﬁnally, 1131:“: 2331:: ’.::1’2233 (1111;211- pay 1:112; 11:? the: 0.21332:
121.1%; (55': the: ‘ 121231225: of $210 222111311 :.:-21;; 1511:1031 {Ecz'trgptmyz $213 making;
0:23“, 321:; (321332: and the ;j.=::w..;m:‘s:t there-3:3 2‘5133 151.2521i'1izﬁ any a (2:131:1-
_ 332,313.11 331111 12:33 11122121. 1:; 1311?:‘13?11111'h:1 =1"; and 12112111323313}. 533:3; 1:21:21: 12215.3
(30:22:26,231 :12; "the "Sim 1111:: not 111:? 33153:: in (1111] 312111 to 33:26.

\ ‘ 0
--4_-
$00130 Copland, and by the agpropriatimn of said sum by maid
George Capland as aforocgid, he became inacbtca to this defame-
ant as for money had and receive? mi it by him in the sum of
3530.00, with interest thcrcan at the rate pf six per cent (6?)
per annum from January 29, 190%, until paid.

Eefcnéant further states that said George Copland be~
came unﬁ wag indebtoa to ﬁlls ﬁcfcnﬁant on the BOﬁh day of
September, 1904, in the sum of 9100.00 on annount of a certain
chock #1921 of said ante xxx drawn by said George Sopland, as
Treasurer of the Kentucky Union Company, to the araer of ﬂourgo
Caplpnﬁ, inaiviﬁuelly, anﬂ the ruhscquenﬁ payment of the check
nut of the fmnﬂm of the Kentucky Unian Coupﬁny; that the making of
rai? check an the payment tharcef was without any considera-
tion ana was whelly unwarranﬁui uni unatﬁhorized; that this
Céfﬁndant at the time was nsb inﬁcbtod in any sum to said
$90330 Copland, anﬁ by the cypropriation of said gum by said
Goorge Copland as aforesaid, ha bacemo indebted to this defenﬁ-
$38 as for money haﬂ and rcceivcﬁ of it by his in the sum of
:]100.00, with interest thnroan at thy rate of six per cent {6”}
yer annum from September 50, 1904, until ﬁaid.

Befcndmnt further states that said George Coplana bc- ‘
cawo and was induhtoﬂ to this acfonﬁunt on the 2nd ﬂay of Feb-
rm ry, 1905, in the sum of $560.00 on account of a certain check
#2102 of said éatcxmmﬂ drawn by said 000350 Copland, as Treas-
urer of the Kcntuaky Union Company, to the order 0f George
Copland, indiviﬁually, and ﬁhe subSQQuCnt payment of the check
out of the funﬁs of the Kentucky Union Company; that the making
of said check ane tho payment thereof was without any consiaer~ «
ution and Wag wholly unwarranﬁeé anﬁ unauthorisoa; thaﬁ ﬁhis
aefondant at the time was noﬁ inﬂohtcd in any sum to said

0 Coarse Copland, and by the appropriation of saiﬂ sum by said
George Copland as aforesaia5 he became inaebteﬁ to this aofendant

‘.. V
--5._

as for money had and received of it by him in the sum of
$500.00, with interact thereon at the rate of xix per cent
(6%) per annum from February 2, 1905, until paid.

ﬁefondant faiths: stoteo that said George Copland be-
came an& was inéobtod to this defendant on the 20th day of
February, 1005, in tho sum of $100.00 on account of a certain
chock $2119 of Said datcxmwmiﬂrmmn by said George Coplanﬂ, as
Troomnrer of the Kentucky Union Company, to the oraer of George
Coplana, inoivﬁaually, nna the subsequent payment of the c eck
out of the tunes of the Kentucky Union Company: that the making
of saié chock enﬂ the payment thoroof was without any cansidcr—
otion an& was wholly nnoarrantcé one unauthoriseﬂ; that this
aofendcnt at the time was not indebteﬁ in any sum to said
George Coplana, onﬁ by? the apgropriation of said sum by said

. >‘Goorgo Coylnnd as aforceuid, he became indebted to this acfcnéent

as for money had and rcecivco of it by him in the sum of
$100.00, with interest thorcon at the rate of six per cent
(6‘) yer annnm from F binary 20, 1:05, until paid.

iefcndant further ctntco that gaiﬁ George Coplanﬁ bo-
cone one was indebted to this defonﬁent on the 0th day of

> Jovombcr, 1906, in the sum of $100.00 on account of a certain

check f2569 of 331G date ami drawn by said George Copland, as
Treasurer of the Kentucky Union Sonyany, to the orﬁer of George
Copland, inﬁivlduolly, onﬂ tho subsequent payment of the chock
out of the funae of the Kentucky Union Company; that the making
of ooiﬁ chock onﬂ the teymont thcr of was without any 0 noiéer—
otion anﬂ.was wholly unwarranted and unauthorized; that this
defonﬂent at the time wen not inaobtcd in any sum to soia
George Coplono, one by the up3ropriation of ouiﬁ sum by saia
George Copland as aforoooiﬂ, he become indobteﬁ to this ﬁcfmndant
as for money hea ena received of it by himin the sum of

--5_-
$100.00, with interest thoroon at the rate of six per cent (6%)
per annum from Eovcmbcr 6, 1006, until paid.

Def naant furthor otatog that said George Copland
became and was indebted to this defendant on the 29th day of
December, 1906, in the sum of $1268.46 on account of a certain
chock #2618 of said Cato drawn by onié George Copland, as
Treasurer of the Kentucky Union Company, to tho ordvr of the
Lexington & Tastorn iailway Compnny, nnﬂ the subsequent payment '
of sniﬁ whack out of the innao of the Kentucky Union Company;
that tho making of Sgid chock an? the payment thorcof was without
any oonsiﬁoration anﬂ was whoily unwarrantea and unauthorized;
that this deionaant at the time was not indebted in any sun
to said Lexington & 7a$tcrn Railway Company ané there was no
obligation whatovoy upon the part of this aofonéant to pay said
ﬂexington & ﬁamtorn Railway Cgmgany said mum of $1268.46, or
any part thereof, and that in consequence of such unauthoriiea
ena.improper éraft by said Coyiana upon the funds of thig
Company and tho subnequcnt payment of said check, or draft, the
said George Copland became inﬁcbtoﬁ to tﬁis defonéant, as afozn-
said, in tho sum of $1368.46, with intorost thereon at the rate
0? nix par cont (6ﬁ) per Unnnm from the 29th day of December,
1906, until paia.Said money was paid by said COpEand presumably in

discharge oﬁ an indebtedness of his own to said Lexington & Eastern

Ry, Co. uofondant further States thnt said George Copland
became and was indebted to thin ﬁofonﬁant on the 20th day of
February, 1907, in tho sum of $5000.00 on account of a certain
chock $064? of said date xnﬁ.drawn by said George Copland. as
Treasurer of the Kentucky Union Comnany, to the order of Goorge
Conlrnﬁ, inﬁividunlly, and tho onbwmquont naynont of the check

. out of the funﬂs of the Kentucky Union Company; that the making

of naiﬁ check an& the payment thornof was without any consider-
ation and was wholly unwarrantoﬁ and unauthorized; that this
defonﬂnnt at the time was not inéohtoa in any Sum to saia

\\. l ‘
--7--
Gooxgo Coplanﬁ, and by: tho appropriation of said sum by maﬁa
George Copland as aforesaid, ho hoonmo indebted to this aofnnd~
out as for money had and received of it by him in the sum of
$3000.00, with intoroot thoroon at tho rato of six per cont (Sf)
per annum from February 20, 1907, until paid.

Defendant further otatos that saia George Copland bo-
onmo and woo inaobtoa to this Gofonﬁant on the 15th day of
Hovomhor, 1907, in tho sum of $100.00 on account of a certain
shook #2858 of said data ﬁgﬁ;§rown by saié George Coplana, as
Treasurer of tho Kentucky Union Company, to the order of $00130
Cohlund, indivi&ually, and the subsequent payment of the check
out of tho fun 3 of tho Kentucky Union Company; that the making of
soia check and the payment thnrcof was without any considera-
tion on& was wholly unsorrsntoﬂ and unauthorized; that this
ﬂofonﬁant at the time was not inaohtcf in any sum to said
George Coglana, and Joy tho agnrooriation of said gun by oaia
George Coplana as ofoxosaiﬁ, he become inﬂobtoa to this defend-
ant on fox mohog had on& roooivoﬂ of it by him in the sum of l

V €100.00,'oith interest thereon at the rate of six per cont (6?)
per annum from Hovomhor 1:, 1907, until haia.

Eefmhaant further states that oaia George Coylanﬁ he~ l
oomo and was inﬁobtoﬁ to thio Gofonaunt on the 50th day of Hovom-
her, 1909, in the sum of $£14.80 on account of a certain chock
f3271 of oaiﬂ oats ﬁxﬁ.drawh by said George Ooplonﬂ, as Treasurer
of tho Kontuoky Union Company, to the order of 550130 Coplana,
inﬂiviﬂually, an& the subsequent ﬂaynont of the check out of
the funas of tho Kentucky Uhion Company; that the making of
oaia chock and tho payment thereof was without any Consideration

‘ aha was wholly unworrantod aha unauthori ed; that thio aefenﬁhnt
, at tho time was not inaohtoﬂ in any sum to saiﬂ Goorgolcoglnnd, '
ﬂﬂﬂ.;by‘th0 appropriation of maid cum by said George Copland
_ as aforesaiﬂ, he become inéohtod to this Gofcnoont as for money

\W.
~~S~~ .
hna ana received of ii by hit in the sum of $214.80, with
intern t thenoon at the rate of mi: per cent {65) per nnnum
from Hovcmbor 50, 1909, uni 1 paid.
ﬁefonﬂant further states that said ﬁcorge Copland
hooano anﬁ was iniobtcd to thir ﬁefondant on the 13th day of
July, 1910, in ﬁho sum of $5000.00 on account of a certain
chock #5411 of said ante Frnwn by said Goozgc Copluna, as Treas- '
urn: of tho Kentucky Union Company, ﬁo ﬁho orécr of ﬁho Lexington
& Tastorn ?ailway Comyany, 32G the subsequent payment of said
check out of the innds of the Koniucky Union Company; ﬁhaﬁ ﬁho
nxﬁdng of saiﬂ chock an? the yaynonﬁ thereof was without axy
consideration ana was wkolly unwarrirtod and nnaaﬁhorized;
’ thoﬁ this defendvnt at the time wag not inﬁobﬁed in any2sum
to said Lexington a Vaxtcrn Failway Campany ané there was no
nhligaﬁion whatever vpon the tart of this defendant to pay ssia
lexingﬁon E Taotorn Railway Company said sum of $5000.00, or
any Qnrt thereof, aha bhxt in connequoncc of much unauthorized
tnﬁ improper ﬂraft by 9330 Goylanﬂ upon the funds of this
Company ﬂnﬁ tho suhsoquont paynnnt of said Check, or draft, ﬁne
snia George Cepland banana inéobﬁod to this ﬁefbnﬁant, as afore-
saﬁa, in the Bum of $5000.00, with intcrout thereon at the
rate of six per ocnﬁ (65) per annum from the lﬁﬁh ﬂay of July,
1910, until pa164 Said money was paid by said Copland presumably in
discharge 0: an indgptcdness of his ogn to gaid L. & E. Railwoy Co.
neionuanu furthor states tnat sold 000336 Coplana no-
' came and was inﬂobtod i0 this defendant on ﬁho math day of
fugust, 1910, in She sum of {1&5.00 on accounﬁ of & contain
chock £545? of oaiﬁ date xmﬁ dyawn by said 000230 Coplanﬁ, as
Troasurcr of the Kentucky Union Company, to the order of George
Coylana, inaividually, an& the suhmowuont naymont of the check .
out of the funds of ﬁne Kcniucky Union Campany; that ﬁhe making of
solo check anG ﬁho payment thereof was udﬁhout any consiaoration

_\ .’—
__9__
anﬂ was wkolly unwarranted and unaﬂihorisea; that this
> dofwnﬁcnt aﬁ the $110 was net indebtcﬂ in any sum to said
Gecrgo Copland, unﬁ by the appropriatinn of said Sun by said
#00350 Ooplunﬂ, as aforbsaid, he bccnmc inﬂebtcﬂ to this dofond~
nut 33 for manny haé ﬁnd rvccchd of it by him in the sum of
$1“5.00, with interest ﬁhcreon at the raﬁa oi six per cent (63)
per annum from ﬁuguﬁt 12,1210, unﬁil paid.
Defon ant further states that said George Copland he-
came and was indebted 39 ﬁhim ﬁcfenﬁamt on Shh nth day of
Octsbor, 1011, in the sum of f1?5.00 on aeoounﬁ Of a certain
check $5693 of saia ante xxﬁ drawn ﬂy gaid George Copland, as
Treasurer of the Konﬁucky'Unicn Ccmysny, ta Etc orﬁer of George
Caplvnﬁ, inﬁiviéually, nnﬂ the Suhchumnt yaymcnt of the check
out of the funau of ﬁhc Kentucky Ehion Canaany; that the making
of gaid check and the payment thereof was without any ewngiaer—
atinn cad was wholly unwsrrantcd anﬁ unauthorixcé; ﬁhat this
ﬁefonﬂunt aﬁ ﬁhp ﬁimc was mat inéehtad in any gun $0 said . .
George Coplsnﬁ, Qh5 by” the apprmpriatiwn of saiﬁ Sun by saia
George Copiand as afozcsaiﬁ, be becamc inéebtoﬁ to this ﬂefand—
ant as for money had anﬂ reenivcﬁ of it by him in the sum of
$135.00, with interest thCTC¥E at the rate of six per cent (65)
per annum from Ocﬁobcr 9, 1911, until paiﬁ.
Defenéant furﬁhmr states thnﬂ saiﬁ George Coplanﬂ bG— '
came ané was inaobtod to this doionﬂaat on the 15th day of fugumt,
191 , in the mum of $1:5.00 on account of a ccrﬁain chock $5925
of maié ﬂatoxmnﬁ arawn by said George Copland, as Treasurer of
ﬁhe Konﬁucky Union COmpany, to the orﬁer of George Capland,
. indiviﬁually, ané the subsequunﬁ waymont of ﬁhe check out of
the funas of the Kentucky Union Gompany; that ﬁhe muﬁjng of said
check and ﬁhc yaymcnﬁ thcroof was without any consideratinn anﬁ
. was wholly unwarranted anﬁ unmuﬁharixod; ﬁhaﬁ this ﬁcfenﬁanﬁ

....lO—a
at the time was not indebted in any sum to said George Copland,
and by ﬁhe appropriation of said sun by said George Coplund
. as aforesaid, he became indented to this defendant as for money
had end received of it by him in the sum of $135.00, with
interest thereon at the rate of six per cent (63) per ennun
from Augu t 15, 1912, until paid.

Defendant further states that said Scorge Copland be-
came an? was indebted to this defendant on the 12th day of
January, 1913, in the rum of $2560.00 on account of a certain
cheek #5995 of said Gatﬁxﬂjﬂ drawn by said George Copland,
as Treasurer of the Kentuek§ Uni n Company, to the order of
George Conlend, individually, and the subsequent payment of
the check out of the funds of the Kentucky Union Connany;
that the making of said check End the payment thereof was without
any consideration snd.wee whoily unwarranted and unauthorized;
that this defendant st the time was not indebted in any sum to
said George Copland, and by 'the unproprietion of said sun by
suid George Cotlund, as aforesaid, he became indebted to this
defendant as for money had and received of it by him in the sum
of $2560.00, with interest thereon at the rate of six per cent
(0”) per unnun from ﬁunuery 11, 1015, until paid.

hefendent states that the total amount of seid slain
(not including interest), to-uit:- $14,358.26, is subject to be
reduced by certain credits set forth in the affidavits and state-
monts herewith filed and maﬁa a part hereof,murkod ”Txhibiti”,
and which said credits aggregate the total sum of $2,127.05;
that after deducting i“Enid total c nﬂits of $2,127.05 from the
total of the above-mentioned fifteen items, there is e not tel—
3330 of 31s,351.21 duo from the estate of George Copland,
deceased, to the Kentucky Union Company not counting or including
uny interest thereon or on tho Several items of which said total

~ is composed.

\‘.
«1.1-— ‘
Eofendent states that the first of the three archive
t 'which the eboVe'tethl of $12,558.26 1S subject is a credit
of $1,814.55, ascertainea ea whewn by the affidavits enG itcnﬂzcﬂ
etetenrnte herewith filed aha maﬁa a part hereof, as of February
11, 1015, the date of the tenth of said George Coplana; that the
nee nd of exiﬁ three creFﬁts eentiete of five items of 550.00
arch, being a part of the current ﬂzlawy ﬁne said 000330 Coplana
fer the menthe of ”my, June, Juli, 'uguet and Crptcmber, 1005,
at the rate of $50.00 per month, uni which said sums aggregate
the tote} of H 50.00, which sh H15 be ereeitea at the rate of
550.00 he: menth for each 0? said menths of Key. June, July.
‘egust ehﬂ 'ept ﬁber in the year 1005; that the third of saié
’ creﬂits iv the sum of 563.50 file he the estate of saiﬁ 300130
Geplaea fer eclrry for ehe~hhlf if the month of February, 1015,
en :he 11th of thigh ment? of neiF year eeiﬁ Cehlend Gied and
ye 0f whtch ante eeié sum e1nuld be croﬁited.
Def nﬁant further states that subject te the foregoing
c edite, the estate 0T Sewage Ceplrhd is justly inﬁebteﬂ to the
Kentucky ﬁnish 00mpahy 31% 3315 Kentucky Unieh Company 13 entitloa
to rocever from said George COW3TEG'S oetete the following sums
with interest, te—wit:—
$450.00, with intercet from Texeh 25, 100?, until paid,
$530.00, with interret from Jan. 20, 1904, until paid,
$100.00, with intero t fror Sept. 30, 1904, until ﬂaiﬁ,
0560.00, vith interest from Tehy. 8, 1905, until paid,
i-E‘s100.eo, with intm'errt fret: ."“C‘ey. 20, 1905, until jjsa‘i,(1,
$100.00, with interest from Rev. 6, 1906, until ﬁaiﬁ,
$1268.46, with interont from The. 29, 1906, until yeid,
21’; 5000.00, with intermat‘ ri‘rom E‘ehiziuexy 20, 190?, until paid,
' Silo-0.00, xitb. interest '.z'from Efevembcr 123, 1907, until said,
$314.80, with intercnt from Uevember 50, 1909, until paiﬁ,

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$5000.00, with interest from Joly 15, 1910, until paid,-

i;f'3.535.00, with 1111;021:er ’T‘I'oz: .iit;;11:i.it 1273, 1310, until void,

2:;-125.00, :z'ith interest from October 9, 1911, until 1mm,

$135.00, with interact from ‘uguut 15, 1912, until paid,

ﬁ2560.00,with intorcvt from anuoxy ll, 1915, uutil 331d,

Befondcnt status that the Several claims Leroio
- mentioned end oocortcd by it worm fully set »ut in a certain
etotomnnt of claim verified or the offidovite of W. 3. 10303011,
FiCCAPrcsiﬂont of tho Kentucky Union CoUDﬂnJ, and 05 Y. T. Vﬂr~
run, an accountant who ozeoinod the boots and accounts of said
Conyuny startl; after tho ’ooth of said George Copland, and that
the several claims no etato? dnﬁ verified more by thio defendant
yrheontoﬁ to the plaintiff, Security ?ruot Company, as idminis-
{317355;}? of (300ng CO:)1_...3'16., (3.31. ‘31:“: mmdey of 7413;311:313, 3.915, :Vncl
oeyment of said claim and of cvch of the several items consti-
tuting the same was thereupon Pomanﬁeﬁ by this defendant vf the
plaintiff, hut such payment wan roiu~od dad no part of Said
claim or of any interest on eaia claim hen ever been caid.
Defendant refers to and woken a part hereof the too said office»
Vito and the several ctoteoontq they to uttahooa which hero boon
‘ hcﬂetoforo filed with this pleading, marked “ixhibit A”.
Dcfondant furthcr states that said George Copland

ﬁt his death loft rurvivfng him him widow, Jone Coplenf, and
his three children, George Coplsnd, ‘. S. Copland and Jennie
Cooldnd; that cook dud all of acid persons are of full 330 and
o;id.Ccoxge Copland, '. G. Copland and Jennie Coplaﬂﬁ are the only
children and heirs at low of said dcocﬂont. Defendant further
atcteo that i. C. Copland, one of tho children of said George
Cooland, deceased, is a non~rcsiéent of the itcte ofiﬁontucky,

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am& an deﬁbnasnﬁ believew in new absent thorviwom; Chaﬁ Said
A. H, Coplmnﬂ roniﬁor in ﬁhc City of Tichmnnﬁ, HCRTiCG Gountg,
Virginia, anﬁ that ﬁiahmnnd, Virginia, in the name of the
plaaa WhJTOin a pogtoffioe is knpt noarcmﬁ to the 31800 where
said i. 3. unplana rcaiéen, or may be found.
Defonﬂanﬁ staﬁes that it has no ﬂafinitc or suffi—

Giant knowledgc of the use Gr di“posiﬁi n made by sgiﬂ ﬁomfge
Coplanﬂ, dceousod, of tho SUVCTRl sums of money for which
0131* is maﬁa naminst hiv by 33:: defendant in this actian,
hut this defendaat has rcasnn to Believe snﬁ charges that

of such use er ﬁiaposition as was actual‘y mace by saia
Covlund oifsaid mancyn, thwt Riv Wifﬁ an? chﬁiuren received
thm full henafiﬁ; that dcfcnﬂunt :3 informoé, believes and
Chﬁrges that 311, 0r 3 great yart of raid sums of money,

warm used by said Gocxgo Coplsnﬂ, ﬁecomscd, in purchaﬁing
articles 0f hsuschrld furniture axﬂ inruishings ana silver

anﬁ SiIVerwaro and 560033 anﬁ honﬂi, which were Copasiteé in
the 110 #311355; 112211 Of 7311 :3 :3"o, Jill-1:”: Cu“{>l::-.11Ca, and. 3113 children,
George Coylzmﬂ, ‘« G. Coylanﬂ an? Jennie Coplanﬁ; :n& this
ﬁcfonﬁani has roam n to belﬁnvo :30 chargrs bhnﬁ all of the
articles and itGMS of yroperty so furnishoé by maﬁa George
Unﬁlgnﬁ, éeceasoﬁ, with annoys rightfully belwnging to ﬁhis
defenaunﬁ, or & largo parﬁ of Such articles, are now in the
panacmsinn anﬁ under the cantrol 0f suié Jane Esplané, George
Coplgnd, 1. C. Copland and Jennie Copluna, ax same one or more
of @hem; that saia property was in the poasersion and unﬂcy the
conﬁrol of said pnrgons at the time of the ﬁcath of George Cop-
lanﬂ, ﬁeoaased, aha unless since ﬁisyeﬁcé of by them, or some one
ar more of them, -is ntill in ﬁhcir posnossion ané under their
cantxol. ,

This defendanﬁ further states that, as appears from the

.....-11}-..
Petition herein, there is a controversy between ﬁho plaintiff,
as personal reprceontztivo of eaiﬁ icovgc Coplanﬁ, and Jane
Coolané, the wiﬂow of raid ﬁnenaont, r sponti:; iho UREOT»

' whip of eeyﬁnin.”urhiturc, house wlﬂ go ﬁg and other property
now in hhr possession, or in the wonscwsion of her childran, or
some ono or more of them, ahﬂ thie defendant novrﬁonies that the
atciaxtcrz-iaizni; film“; as; ".'E‘imhiif)”: * with. the .37oi3i’uion and 3=urporﬁing
to he an inventory of the out in of said Goongo Caplend,dececsea,
is a full, correct OT true invvhtory of all of the pereenal
prayerﬁy belonging to ani left by Said George Goplund ﬁﬁ his
ﬂeath, aha it avorg that all oi‘tho property of every kind I
dororibed in the stucemant file? as TKhihfﬁ B with ﬁhﬂ Elﬂidtiff's
Petition was ﬁhe property of oaiﬁ George Soplend at his death

. rmﬂ.rightfnlly belongs to his ceiptq anﬂ should be taken in
charge by the plainiiff as his Taminisﬁrhtor uni reﬁuveﬁ to
cash to hatisfy the claims of crofitorg of $31G est to,incluaing
tho claims of this Cofendani.
Defenﬁeht av rs ﬁhut ihe hormonal pronorty of Said
George Coyluni, docceged, is probably inuufiicicnt $0 pa: anﬁ
ﬁeﬁiufy She claims agninei his eat to $18 thaﬁ in orﬁer to 3&3
smﬁ oatirfy such Olﬂi-S, ii will he necemeary to sell the real
eat to belonging to oaié C ergo Ceplonﬂ at his aeaﬁh aha
main fully acscrihoﬂ in ﬁho gluintiif's ?otition heroin; that the
@5310 of gaia real estate dooeohdoa at the Coméh of amid_Georﬁe
Coplcnd to his Shreo children HDCVUsnnmed, subject to She morital
rﬁgjjh'bs of tho 1:? mother.
ﬁefanaant Staﬁca that it is essential in the due ﬁxes-
orvotion anﬁ protection oi‘bhc personal proyorﬁy belonging $0
said George Coplana an& new in ﬁhe possesei n of tho surviving
nowhere of his fondly, that said Jane Coplanﬁ, his widow, aha his ~
. Said three children, George Coplahﬁ, i. C. Coplano and Jennie

\ K V .
i_§5__

Coplzmé, be restrainoo gum? 5:21;) Dino d from :Ljpjcﬁrr'mr‘iSting;, (36-11ng

or otherwise Qiepoujng of any of mail ﬁorsnnal groyorty now in

their yoeeoxnion Oi'under their control, Whether some he uhown

in the 'oc‘aiinuut :i’ilozl with the L‘otiﬁf on, Z"1:11”3€€-':d "1731;211:533 13 .I;“,

one purporting to be an offlo'ol inventory of ooiﬁ estate, or

whethtr game be nhoﬁn by the mtstonont £180 filcﬂ witL the

Petition, murkco ”Exhibit 3”, 2r be otherwise ohoxn, 323 to that

eti, this dofonéant echo trot the Court will enter on oroor herein

pen ins thie octi n, enj for $100.00, with interest thereon at Che rate of six per cent

(Gﬁ) For ennum from ﬁcvember l“, 1907, until_peie; also Juogmont
for $314.80, with interest thereon at the rate of six per cont

\\ u .
..—j,f:)—..

(oi) per enuum from ﬂovember 30, 1999, until paii; also judgment
for 35000.00, with intorcst thereon at the rttc of six per Cent
{6”) yer annum from Jul; 13, 1910, trtil said; also juﬂgncnt
for $135.00, with interest thereon at the rate of six per Cent
(63) per ennum from ﬂugust 1;, 1310, until paid; also judgment
for $125.00, with interest thcrcdn ﬁt the rate of six per cent
fail per annum from Dctobor C, 1011, until paid; also jtﬁgncnt
for Qlf5.00,‘with interest tbtrooh at the rate oi?six per cont
(6??) per z,‘:,n.:->,wrs from ingurrt 1:3, l€?l§-:, until 9::1 I}; also jufgi‘nmt
ior £2560.00, with inter st thsrcou at the rate of six per cent
(6?) nor annun from Janutrj ll, lTlS, until said; subject,
however, to the credits a grognﬁirg $2,187.05 mentioned in
the foregoing pleudirg {no {istirctly set forth in the itcrﬁzod
statements embodied in the s fidevits and surmarios hereto
:nhiercd Ekﬂﬂﬁeé “”éﬂzib t ﬁ”: :13” defoud::1t furiiuvr ozuuni that
this its ”newer to the plaintiff's ?ctition may be taken as
a Uross~Potit on against its co—dofwndente, Jane Copland, George
Coylehd, ﬂ. C. Copland and Jennie Cehlund, and that said do-
fendents may be summoned to answer herein ard that e warning
order may be entered against the non—rcsident defendant, A. C.
Coylamd, and this defendast further rruys for an order of
injunction against the aforesaid Jane Copland, George Coplﬁnd,
A, C. Coylund and Jennie Cayl;n6, enjoining and restraining
them from appropriating, selling, or ethcrviso disposing of
any of the woroonal property in their posse eion mentioned in
the foregoing issuer and Cross—Petition, which personal property
belonged to Said George Ccpl ed at his death, and the title and
ownership of which itinOW in dispute, and a claim to which is
made by the Administrator of said George Coylanﬁ, and this do—
fendant further prays that a full investigation may be had '
heroin respecting the estate of said Copland at his death, with
the View of ascertaining definitely just what property he owned

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