Limitation Act, and the Intestate Act, any attempt to recover real estate from the Crown or individuals after a lapse of twelve years, which may be extended to thirty under certain circumstances, and personal property after a lapse of twenty years after the time at which the right to bring an action or suit for the recovery thereof shall have first accrued to the person making the claim, however valid the claim to the property may have been originally, is certain to end in fail

ure.

Holland is another country where it is supposed by many Americans that vast estates, from the value of twelve million dollars down, have been lying unclaimed for the last two hundred years, and that nothing is necessary but to demand them at some probate office. For the last seventeen years the American legation at the Hague has notified claimants, either directly or through the Department of State, that there are no probate courts in Holland, and that wills are generally deposited in the care of the notary who draws them up. He makes a duplicate copy, and enters the title and subject matter under a number in his register, which is examined and verified by the registrar once a month. It is evident, where names, dates, and localities are lacking, as is generally the case in the communications of claimants, that, after the lapse of one or two generations, estates can be found only, if at all, by extensive advertising. In 1852 the Dutch Parliament established a state commission for the settlement of claims on the estates of deceased persons, as well as those against the government. This commission gave notice that all claims to property then in their hands must be sent in within five years and six months, after which time such estates would escheat to the state. The great estate sought for in Holland is that of a General Metzgar, who died about two hundred years ago, leaving, as is currently supposed, some twelve millions of dollars. One of the

claimants admitted to our minister at the Hague that if ordinary interest were added to the principal of this claim all the European governments together would be unable to pay it, but that she was willing to wait for the interest. Being discouraged by her reception at the legation, she presented her claim - which had been beguilingly drawn up by a French attorney in the shape of a large pamphlet in person to the king, at the door of his palace. In due time she received a reply from the finance minister that the whole matter had been several times examined by the courts, and decided adversely to the claimants. In most of the Dutch claims the family name alone of the testator is given, but neither the name, the place of death, nor the location of the estate is supplied to assist in tracking it. No official notice of unclaimed Dutch estates is ever inserted in foreign newspapers, and therefore the lists of unclaimed estates published by agents are not from official sources, as asserted by them.

Our embassy in Paris does not give the names of any claimants of estates, but says that the number of inquiries is large, and that in no case has the existence of the supposed estate or of the unclaimed fortune been verified. The legislation of France is such as to dispose effectually, and without appeal, of all claims, even if inherently just and founded on an actual and known heritage, which were not presented and proven within the period prescribed by the French statute of limitations. Under French law, the liquidation of estates is ordinarily in the hands of a notary, and in searching for an estate the usual method is to address a circular letter to every notary in the city and department where the estate is likely to be, giving the name and date of death of the original owner. When there is no landed estate, the heirs-at-law can divide the property among themselves without legal proceedings. If nobody claims an estate,

the state takes it in trust, and the Department of Justice inserts notices of the fact in the official journal. The period of proscription as regards unclaimed estates is thirty years from the date of decease, after which all claims are barred, unless some irregularity in the liquidation can be proven.

In Germany there is likewise a statute of limitations, and there too not a case is known to our embassy where the existence of an unclaimed estate has been verified. As a rule, the data furnished by claimants are insufficient to substantiate any claim, or to identify the locality of a single estate, even when the statute of limitations does not apply to great periods of time elapsing since the testator's death. One great drawback for the claimants is the absence of all probate machinery, and the fact that estates are usually divided amicably among the heirs without resort to any court, transfers of landed estate being made on the land register of the locality, in the presence of the grantor and grantee. Wills have to be deposited in a court during the lifetime of the testator, except in the Rhine provinces, where a will entirely holographic is valid. Wills are opened by the court for interested parties when they produce a certificate of death, or at any rate six weeks after the testator's known death. After fifty-six years have elapsed since deposit of the will without information of the testator's death, the supposed heirs are summoned by advertisement to appear. If in six months no one comes forward, the will is opened, to ascertain whether charitable institutions are mentioned in it. If this be the case, such beneficiaries are called upon to prove the death of the testator. The will is then closed again. When the fact of death is established, the will is opened once more, and published. A certificate of heirship is issued by the court on adequate proof. If the proof is inadequate, or no heirs come forward, a further notice of three months is given

in the official gazette; and should this receive no response, the state regards the property as derelict, and takes possession of it. Even then, if a rightful heir appears within thirty years, his title is acknowledged under certain restrictions. Continued possession by the state for these thirty years gives a valid title, if not disputed in the mean time, in which case it is temporarily in the custody of a special official. As there are several hundred courts thus holding estates, it is essential that claimants should ascertain accurately which court holds the estate in trust. As far as can be learned by the embassy, after careful inquiry, there is not at present any large estate that for more than thirty years has been awaiting distribution, and every effort to discover alleged unclaimed estates has been fruitless. The consuls have permission to investigate claims to estates when their official duties permit, and if remuneration for their services be guaranteed.

The above gives the history of unclaimed estates in Europe; there are no large or important ones; and yet, in spite of the wide circulation of the facts by our Department of State, and by our embassies and legations abroad, for the past fifty years, and of the detection, conviction, and punishment of several claim agents, the imposture, as it offers such large returns, still goes on, and as many moths as ever singe themselves in the flame of alluring advertisements and circulars of unscrupulous agents.

One of the most daring and successful of these swindlers was William Lord Moore, of 5 Ingersol Road, London, England, with a connection in New York styled the European Claims Agency, E. Ross, Manager. Moore's real name was Howard, and as his trial is the first one of the kind that has occurred in this country, it may be interesting to know the history of the man, and his system of procedure as developed at his trial. That this is the only instance of one of

this class of swindlers being brought to bay and convicted in this country is not owing to there being no other persons equally guilty, but to the fact that in frauds of this kind, extending as they do all over the United States, and relating to estates situated in foreign countries, it is difficult for any one victim to bring a suit, or for the numerous dupes to combine against the swindlers. It was not until the numerous complaints to the police in New York and other cities, and to our embassy in London, against Howard, obliged the United States government to take some steps for the protection of its citizens that anything was done to check these systematic frauds. In May, 1892, letters inquiring about Moore in London and Howard in the United States having poured in to the embassy, Mr. Lincoln, our minister at that time, wrote to the British Postmaster-General, calling his attention to Moore's correspondence, and suggesting that the British post-office should stop the delivery to Moore of letters coming from the United States, and return to the writers any valuable inclosures found therein. Otherwise it seemed impossible to put a stop to the scheme in England, as the persons imposed upon in the United States were not of a class that could afford a journey to England to give the necessary testimony in an ordinary criminal prosecution. The Postmaster-General, in reply, regretted that he could not meet the minister's wishes in regard to the detention of Moore's letters, as he did not consider the facts in the case sufficient to warrant him in intercepting letters, but suggested that if it seemed necessary for the protection of its citizens, the American government should detain at New York registered letters addressed to Moore in England. He would send to the legation, however, any letters of inquiry in regard to Moore which might come from the United States. Mr. Lincoln at once wrote to the Department of State at Washington, inclos

ing the correspondence, and stating that, with the assistance of the London police, he had found Moore, who had confessed his swindles, and promised to discontinue them, but that letters were being constantly received at the legation which indicated that the business was being still successfully carried on, in spite of warn'ings sent out to America through the Associated Press. Mr. Lincoln also called the Secretary's attention to the act of Congress of September 19, 1890, allowing the Postmaster-General, on sufficient evidence of fraud, to stop registered letters and return them to the writers. This correspondence was printed by the Department of State as a circular to be sent in answer to letters of inquiry from victims, and the prosecution of Howard shows that Mr. Lincoln's suggestions were adopted.

At the time of his arrest, in 1893, at Jackson, Tennessee, George Frederic Burgoyne Howard had been known for some years as a preacher and prominent member of the Central Fairview Associ ation of the Baptist Church, whence he derived the prefix "Rev." or "Dr." He also edited a religious periodical in New York, entitled The Fairview Advocate, previously The True Baptist, in which he advertised the fraudulent foreign-estate scheme of which he was convicted. But he appears first to have come into prominence by a suit for fifty thousand dollars damages brought by him against well-known citizens and newspapers of the city of Jackson and the State of Tennessee for defamation of character. This suit, lasting for months, during which his history was traced through more than one of the States and to Europe, resulted in a verdict of one cent damages for the plaintiff. The doctor had then, and still has, a host of faithful friends, convinced of his honesty and innocence. After the termination of the damage suit, which practically amounted to a defeat, he returned to his pastoral duties for a while, and then, in 1890, moved

to New York, nominally to practice law; returning to Jackson from time to time to pay up the expenses of his lawsuit. In New York he opened an office at 227 Grand Street, under the name of E. Ross, as a' European claims agent. Here he succeeded in deceiving hundreds of simple-minded persons and in avoiding legal proceedings. When officers went to arrest him, he had left for foreign parts. In 1891 he appeared at 5 Ingersol Road, Shepherds Bush, London, as William Lord Moore, and continued his dishonest career by correspondence with persons in the United States, in much the same manner as the abovementioned Jacquess in his Townley estate fraud, but does not seem to have confined his deceptions to any particular estate. The American embassy in London having, with the aid of the police, found Howard, alias Ross, alias Moore, and obliged him to confess his guilt, he returned to New York, and recommenced, or rather continued, operations under the name of Joseph Ledger, "American agent for the Supreme Court of Chancery, London; " going so far as to furnish mock documents and false seals purporting to emanate from the High Court of Chancery. Then, when he found it was becoming too dangerous for him in New York, he returned to Jackson, Tennessee, called himself the president of the Gulf and Tennessee Railroad, a purely imaginary corporation, and announced that he made a specialty of collecting claims in all parts of the United States and Europe, and that he visited Europe once a year for that purpose.

After a

while complaints and evidences of Howard's fraudulent practices poured in to the postal and police authorities so abundantly that a warrant was issued for his arrest, and his office was searched and his desk broken open for incriminating documents. Howard had fled from Jack son when the warrant was issued, but was arrested by telegram in Chicago. By satisfactory explanations he managed

to effect his release, and left for Canada. But the government offered a considerable reward for his capture, and soon he returned to Jackson, gave himself up, and was placed under heavy bonds. A true bill was found against him by the grand jury, and his trial was begun in the federal court in Jackson on the 4th of November, 1893, he having the privilege of conducting his own defense with the aid of other counsel. There were eight indictments against him, which, after much argument and opposition on the part of his counsel, Mr. L. T. M. Canada, were ordered by the court to be recorded for trial under one heading as a consolidated case. A plea in abatement, on the ground of irregular proceedings on the part of the attorney-general, was then argued for a whole day, and decided by the jury in favor of the government.

The defendant took part in his own defense, and is described as presenting his usual nonchalant appearance, and as even being eloquent. He compared the attorney-general to "a sleuth-hound from whom there was no escape, whether upon the rugged mountain side, in the valley beneath, or upon the bosom of the ocean," and himself to "a pursued man and a victim, who would, however, be protected, from having found the thread of gold, the truth, that would serve him." After the verdict, the attorney-general asked to have Howard sentenced, but the court decided to let the trial go on, and a new jury was impaneled. The attorney-general stated in his argument that Howard's scheme was, by making people believe that they were heirs to vast estates in Europe, to lead them to pay him small sums of money for expenses incurred in getting the information. Thousands of his letters had been sent out for the purpose of opening up a correspondence with credulous persons. He proposed to show that letters had been sent from New York by E. Ross and Joseph Ledger, and from London by William Lord Moore, all of whom were one and the same Dr.

G. B. Howard. Subsequently to the operations of Moore in London and Ledger in New York, postal cards were sent out by Howard, as the president of the Gulf and Tennessee Railroad in Jackson, to the same persons addressed from the other agencies. Upon Dr. Howard's office being searched, letters and accounts were found, already prepared and only awaiting his signature, for the amounts collected from his correspondents, and a number of clerks were busy sending out circulars to his dupes. Numbers of witnesses from all parts of the United States were called, who testified to the receipt of letters from Moore, Ross, Ledger, and Howard, asking for remittances, to be used in looking up estates. Postmen from New York testified to the identity of Howard, Ross, and Ledger, to whom they had delivered letters in New York at an average rate of two hundred a day, and also to the fact that Howard had opened a Dominion employment bureau in New York, under the name of G. W. Harris. He was fully identified as having been in New York under all these different names, by lodging-house keep ers, elevator men, and others. The London police inspector who, at the request of the American legation, had found Moore in London came over to testify to his identity with the defendant. This officer stated that there was no Supreme Court of Chancery or tax assessor, as appeared on Howard's fraudulent certificates. Experts in chirography testified to the handwriting of the letters from Moore, Howard, Ross, and Ledger being one and the same. Strange to say, the trial resulted in a disagreement of the jury, which was therefore discharged, and a new one was impaneled.

On the 6th of December the case was tried all over again. The government now had the additional advantage of the testimony of Mr. New, who had been consul-general at London when Howard was there, and of Mr. Lincoln, who was minister at the same time, as well as of Mr.

Hodson, the messenger of the legation, who had interviewed Howard in London in company with the police inspector. The inspector's identity and statements were fully vouched for, and the cross-examination of Hodson by the doctor was very damaging to the defendant. Mr. Hodson testified that in the archives of the legation was the deposition of one Julian Howlett that the defendant, Howard, was his son, and that his name was Frederick Howlett, thus adding one more to his numerous aliases. The defendant made a sorry argument in his own behalf, almost entirely of a sentimental, and even of a blasphemous tone when he compared his treatment to that of his Lord and Master. The attorney-general easily shattered the slight attempt that Howard had made to disprove his identity with Moore, Ross, and Ledger, which was what the first jury had disagreed on, and also the flimsy fabric of the Gulf and Tennessee Railroad, which no one but the doctor himself had ever heard of. The judge, in his charge to the jury, simplified the case very much by telling them that it was immaterial how many aliases or how many places of business the defendant had, it being sufficient to prove his fraudulent intentions and acts in one only. On the first ballot, the jury found a unanimous verdict of guilty, and the court, after having overruled the motion for a new trial, and refuted the arguments against a continuous sentence, passed sentence of fine and imprisonment on each of the eight counts; making in all nine years and one month imprisonment and twelve hundred dollars fine, besides the costs of the suit, amounting to about twenty-three thousand dollars, which were taxed to the defendant. Howard's name was stricken from the rolls as a practicing attorney in the district court and the circuit federal court. Four of the witnesses for the defense were then arrested for perjury, and sent to jail to await their trial before the grand jury.

So ended this tedious case, in which