Scally

In addition to the usual allegations in a complaint to quiet title, the plaintiff alleged that defendant gave him and his wife, Margaret S. Kennedy, a daughter of defendant, the land in controversy, consisting of 160 acres, and that they took possession thereof under the gift and expended in making permanent improvements thereon the sum of $4,000 during the year 1912, $3,000 during 1913, and made valuable improvements in the years 1914 and 1915. The prayer is for a judgment decreeing “that plaintiff is the owner in fee,simple absolute, possessed and entitled to the possession of the undivided three-fourths of the real property above described; that the gift of the said quarter section of land described in said complaint by the said defendant Mary A. Scally to plaintiff and to his wife, Margaret S. Kennedy, is good and valid and a complete, executed gift; and that the defendant [plaintiff?] is entitled to the decree of this court quieting his title to said undivided three-fourths of said quarter section of land”; that defendant has no estate, right, title, or interest therein; that she be enjoined from asserting any claim thereto; and “that plaintiff have such other and further…