In the District Court of the 12th Judicial District of the State of California, in and for the City and County of San Francisco

The California Star Oil Works Company
Plaintiff

Vs.

R.S. Baker, E.F. Beale, F.B. Taylor and John Doe
Defendants


Filed March 20, 1878


AMENDMENT TO THE SECOND AMENDED COMPLAINT

The California Star Oil Works Company, the above named plaintiff, by leave of the Court, in this behalf first had, makes this its amendment to the second amended complaint herein, as of page 19, line 7, of said complaint and alleges:

That, at all the times of the execution, delivery and assignments of the agreement hereinabove set forth, the plaintiff, and each and all its officers and agents and, as plaintiff is informed and believes, and so states the fact to be, the said Denton were wholly ignorant and had no notice whatsoever of the rights, interests or claims of the said Francisco P., or of the said Juan Forster, or of the said Pio Pico, or of the said Doe, or of any person or persons claiming, or holding, by, through, or under them, of, in or to any of the above described premises, or in, under or by virtue of said agreement; but that as plaintiff is informed and believes, and so states the fact to be, the said Baker and Beale have always well known and had actual notice of all the rights, interests and claims of the said Francisco P., and of the said Juan Forster, and of the said Pio Pico, and of the said Doe, and of all persons claiming, or holding through or under them; and that the said Beale and Baker failed and neglected, at and prior to the times of the execution, delivery and assignments of said agreement, to inform plaintiff, or any of its officers or agents, of said rights, interests or claims, or in any way to communicate the same to it or them, and that the said Denton made and entered into, and the said plaintiff procured to be assigned to it the said agreement, believing, in perfect good faith, that the said Beale and Baker, together with the said Lyon and Leaming, were the sole owners of and were in, and were entitled to, the exclusive possession of the premises described in said agreement.

That acting upon said belief the plaintiff entered into and took possession of the premises in said agreement described, and expended large sums of money in improving and developing the same.

C. R. Greathouse
Attorney for Plaintiff
Duly verified by Joseph S. Taylor, Secretary of Plaintiff

Filed April 27, 1878