]
York County		]
South Carolina		]
			] 22-Jan-1879
Personally appeared	]
Martha S Bell		]

Who being first duly sworn says:

I.  That a cause of action exists in favor of the above named 
plaintiff against the above name defendant and others, the 
grounds of which appear by the sworn complaint of the plaintiff 
in this action on file in the office of the Clerk of said Court; 
that in said action the plaintiff took to enjoin and restrain 
the sheriff of York County from selling the real estate of 
James Brian, deceased, under execution for cash, to the prejudice 
of the heirs-at-law, and prays that said real estate may be sold 
under an order from this court under such terms as may be just 
for the purpose of paying the debts of James Brian, deceased, 
according to their legal priorities and for _____ of any residue 
amongst the heirs-at-law of James Brian, deceased, and that the 
creditors of said deceased be called in by publication, and for 
each other relief as may be just and equitable.

II. That Aaron W Brian and Martha J Smith, two of the defendants 
in this action, are necessary parties to the action, the former 
residing at Camden, Ouachita County, Arkansas, and the latter 
residing at Jacksonville, Polaski County, in the state of  Arkansas; 
that Mary J Wray, another defendant and necessary part, resides at 
Kings Mountain, Cleveland County, in the state of North Carolina; 
and that defendant Sally Hall Jeffreys, and other necessary parties 
reside at Hendersonville, Henderson County, in the state of 
North Carolina: each of the aforesaid defendants being heirs-at-law 
of James Brian, deceased, and non-residents of the state of 
South Carolina, and it not being in the power of the sheriff of 
York County to serve either of them personally with the summons and 
complaint in this action.

Sworn to and subscribed before me this 22nd day of January, 1879.

Martha J Bell
Joseph F Wallace