State of California
County of Los Angeles

In the County Court of said County

Andrew J. Kraszynski
Plaintiff

Vs.

The Los Angeles Petroleum Refining Company
Defendant

COMPLAINT
The above named plaintiff complains of the Defendant an acting Corporation having its place of business in the city and county of Los Angeles, and for cause of complaint avers:

That heretofore to wit, on the 10th day of April 1874 he, the said plaintiff, was the owner and entitled in the manner hereinafter stated to the possession of a tract or piece of land situated in said county and heretofore forming a part of the Rancho de San Francisco bounded and described as follows:

Beginning at an oak tree about thirty six inches in diameter on the east side of the road in the San Fernando Pass marked with a large cross on its western side and with an “LJ” on its northern side and distant about a half a mile in a northerly direction from station No. 5 of Hancock’s survey of said Rancho running thence north 77 degrees west 24 chains and 65/100 of a chain to a point; thence north 22 degrees 46’ west 21 chains and 28/100 of a chain to a point; thence north 10 degrees 13’ east 54 chains and 48/100 of a chain to station No. 4; thence north 79 degrees 48’ west 24 chains 79 links to a sycamore tree marked No. 4, and the head of a small canon; thence north 38 ˝ degrees east 40 chains to a certain station from which an oak tree marked B.T.S. south 38 ˝ degrees west 7 chains 98 links; thence south 48 degrees 2’ east 53 chains and 18 links to a post marked No. 6; thence north 86 degrees east 6 chains and 4 links to a small sycamore tree marked No. 7; thence south 8 degrees east 10 chains 41 links to a post marked No. 8; thence west 7 chains 77 links to a post in a mound of rocks; thence south 28 degrees 41’ west 28 chains 10 links to a station on a high bluff; thence south 6 ˝ degrees west 40 chains 91 links to the place of beginning – the same containing three hundred and eighty one and 2/3 acres (381 2/3) be the same more or less – it being the same land with the house of plaintiff thereon now known as and called by the name of “Lyons Station.”

That on the said 10th day of April 1874, the defendant was occupying under, and as tenant at will of the said plaintiff, a portion of the land so described consisting of about two acres in a square or rectangular form, situated about fifty yards from the house of the plaintiff known as the “Lyons Station”, upon which the said defendant had by its agents and servants erected [?] and sundry houses, buildings, etc., for the manufacture (as defendant avers) of oil from petroleum.

That on the said 10th day of April, 1874, he, the said plaintiff, gave in one form of law, a notice to said defendant through its duly authorized agents, to quit the said premises so held at the will of said plaintiff, and to surrender to plaintiff the possession of the same, in manner and form recognized by law.

That their and these and for more than thirty days thereafter the said defendant neglected and refused to give and surrender up to plaintiff the possession of said premises as aforesaid, and that it still doth so neglect and refuse so to deliver and surrender up the said possession, but unlawfully withholds and detains the same against him, the said plaintiff, and keeps and detains him, the said plaintiff, from the possession of the same.

Plaintiff further avers that by reason of the premises he has been greatly damaged in the sum as he says of one thousand dollars.

Whereupon plaintiff prays judgment of restituting the said premises and for said damages and costs of suit in this behalf expended.

Mitchell, McConnell & Judge
Attorneys for Plaintiff

Filed May 14, 1874