xt70zp3vt865_156 https://exploreuk.uky.edu/dips/xt70zp3vt865/data/mets.xml https://exploreuk.uky.edu/dips/xt70zp3vt865/data/63m46.dao.xml unknown 14 Cubic Feet 31 boxes archival material 63m46 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. Harkins Family papers Mineral rights -- Kentucky -- Floyd County -- History. Law reports, digests, etc. -- Kentucky. Mining leases -- Kentucky -- Floyd County -- History. Practice of law -- Kentucky. Bankers -- Kentucky. Banks and banking -- Kentucky -- Prestonsburg. Coal trade -- Kentucky -- Floyd County -- History. Lawyers -- Kentucky. Bank Josephine v. Whitaker, Joe et al text Bank Josephine v. Whitaker, Joe et al 2016 https://exploreuk.uky.edu/dips/xt70zp3vt865/data/63m46/Box_18/Folder_10/0001.pdf 1932 1932 1932 section false xt70zp3vt865_156 xt70zp3vt865 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- .
,

 1y unpaid; that said note is the primary obligation of
Defendant, Joe Whitaker, and that said Defendzmt ought
to pay said note, together with interest thereon frmn
maturity, and the costs of the action in which this Cross-
Petition is filed, as well so the costs of this oroeoopetic-
tion: that said note was protested at mturity, at a cost
to Plaintiff, of $2.06, which mount is reasonable, and
which Defendant, Joe Whitaker promised and agreed to psy,
which is Just, past due and entirely unpaid: that defends nt f
Jae Whitaker should psy said amount with 6% interest thereon, ,
from date said note was protested.
Plaintiff, Ed Hill, in Cross Petition says fur-
ther, that this is an action for the recovery of money due upon
I. written contract, as heroinsbove set out: that he ought, so
he believes, to recover from Defendant, the sun of $102.06,
with interest st the rate of 6% per smmn from Februsry 22,
1932, until paid; thst Defendant, Joe Whitaker ought to pay
said mount, with interest so doreseids that Defendsnt, Joe
Whitaker is insolvent, snd does not have m property in this
State. subject to execution, or not enough thereof to satisfy
the Plsintitf'e demand, and the collection of the demand
will be endangered by daisy in obtsining Judmont or on. return
of no property found.
rhinestone, Defendant, Ed Hill, enters his ‘
sppsdrsnos herein, and solves service of summons and time
provided by low for this cause to stand for trial, and sgrses
that this «use be dookoted and stand for stops st the Septem-
ber, 1932, Term of this Court: he preys Judment our easiest
Defendant, Joe Whitskor, in the sun of $102.06, with 6% interest
thereon from February 22, 1932, until paid; preys thst s General
Order of Attachment issue herein; for his costs herein expended,

 and for all proper and equitable relief.
ED HILL,
BY
W
ST MM OF mmucm,
COUNTY OF FLOYD.............5§CT
Affiant, Edward P. Hill, gays he is agent
and attornqy of Defendant, and Plaintiff in Crooo Petition,
Ed Bill; that the said Ed Hill is now absent from Floyd
County, Kentucky, and has no other officer or agent, known
to affiant, auparior in authority to him; that the stutomnnto
and allegations of the above and foregoing answer and orooa~
petition, are true as he verily believes.
subscribed and sworn to before me by Edward
P. Hill, this the 15th day of August, 1932.
WWW iifilLIE , FE. 5% 5071:“? . KY.