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(e) That the State of Wisconsin and all state and municipal officers and agents therein may be decreed to surrender to the State of Michigan, its officers and agents, full and complete possession of all said disputed territory, and may be enjoined from further, in any way or manner, exercising jurisdiction thereof or thereover, and

(f) That this complainant may have such other and such further relief in the premises as may be equitable and as to the court shall seem proper:

May it please the Court to grant to this complainant the most gracious writ of subpoena, to the said State of Wisconsin, and to the Honorable John J. Blaine, the now Governor thereof, and to the Honorable Herman L. Ekern, Attorney General of said State of Wisconsin, commanding them and each of them to be and appear in this Honorable Court on a day to be therein named, and to abide the orders and Judgment of the Court.

ALVAH L. SAWYER,
Menominee, Michigan,
Special Counsel.

STATE OF MICHIGAN,
By ANDREW B. DOUGHERTY,
Attorney General.

Explanation of Exhibits Referred to in, and Attached to Bill

of Complaint.

Exhibit A is a part of a map entitled:

"Map of the Territory of Wisconsin, by David H. Burr, Draughtsman to the House of Rep's-U. S.1836, to accompany the Hon. Z. Casey's report." This map purports to have been made at the time that the Michigan statehood bill was under consideration, and it shows the Montreal River in a single channel, with a lake at its head and a lake at the head of each, the Ontonagon, the Chippewa, the Wisconsin, and the Menominee Rivers, and an interior lake with no outlet but which was afterwards found to be at the head of the Wisconsin River, and is now called Lac Vieux Desert. This whole group of lakes is labelled on the map, "Les Lac Vieux Desert," thus meaning the Lakes of the Desert, and a heavy dark line is traced along the course of the Montreal River to the lake at its head, thence through the group of lakes south of the lake we now call "Lac Vieux Desert," to the lake at the head of the Menominee, which we now call the Brule Lake.

Exhibit B is a copy of a map attached to Captain Cram's first report of his attempted survey of the boundary in 1841, and is Map No. 1 of that report. It is entitled:

"From a map of the entire territories of Wisconsin and Iowa, published by order of the Legislative Assembly of Wiskonsan, 1838."

It is the map referred to by Captain Cram in his report as being a copy of, or similar to a map had by the Judiciary Committee of the Senate when considering the boundary question in 1834, showing the Menominee and Montreal Rivers as both rising in Lac Vieux Desert and forming a nearly direct boundary line from Lake Michigan to Green Bay. Along the proposed boundary is printed, "Boundary between Michigan and Wiskonsan."

Exhibit C is Map No. 2 in Cram's report of his first survey, drawn by him, in so far as the Montreal River is concerned, from information he had received, but not from actual observation, and greatly misrepresenting the course of the Montreal River and showing it as rising in a swamp, with no lake at its head.

Exhibit D is Map No. 6 in Cram's second report, being, according to his report, a combination of several maps referred to therein, but which do not accompany the report, which shows the Montreal River with but one substantial channel and his markings of the head thereof where it forks into what he calls the Balsam and the Pine Rivers. This map shows various streams entering the river from the west, but no stream that can be said to fairly represent the West Branch, as it appears by government surveys and is shown on Exhibit E. It also shows the Menominee River, with its principal branch, the Brule, heading in Lake Brule, and Lac Vieux Desert between Lake Brule and the head of the Montreal River.

Exhibit E is a diagram prepared to exhibit the points and the area of the disputed territory.

Michigan claims the Montreal section of the boundary should start at letter "A," following up the river channel to Island Lake, represented by letter "C," and then to the head of the Brule River at the outlet of the Brule Lakę, represented by letter "D."

Wisconsin claims the boundary should run from "A” through "B," which shows the forks of the Montreal, to "F," the point of Cram's monument, and then through "E," that being Lac Vieux Desert, to "D."

This map also illustrates substantially the disputed area in Green Bay.

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