San Patricio County News (Sinton, Tex.), Vol. 2, No. 51, Ed. 1 Thursday, February 2, 1911 Page: 4 of 6
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ment to San Patricio County News, Thursday February 2. 1911
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mi ipii,
■ ' *• ? - ■ *■
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rnbefi
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id unknown wife of
; S. Creigler if living, and
^e unknown heirs of tin
S. Creigler, if living, and if
the unknown heirs of the said
>wn wife of the said W. S.
ligler, and the unknown heirs and
|L representatives of the said un-
Swn heirs of the said unknown
Wife of the said W. S. Creigler;
: n And John C. Pooley, if living, and
if dead, the unknown heirs of the
Aald John C. Pooley, and their un-
known heirs and legal representa-
tives; and the unknown wife of the
said John C. Pooley, if living, and if
dead, the unknown heirs of the said
unknown wife of the said John C.
Pooley, and ihef unknown heirs and
legal representatives of the said un
vid H. Taylor;
1 if dead, the unknown heirs and legal | those whose estat^Plaintiff has have i the 3rd Monday in March, A. D. 1911J Also, because rln
renresentatives of the unknown wife I had continuous, umnterruuted. neace-! the same beine the 20th dav of *i____ —a.k/fsSSI
And Frank C. Tayk>r, if living, and representatives of the unknown wife j had continuous, uninterrupted, peace- | the same being the 20th day of of them, and those whose e
dead the unknown heirs and legal of said Walter Neil; able, exclusive, adverse and actual! March, A. D. 1911, then and there plaintiffs and Phi™
If dead, the unknown heirs and legal
representatives of the said Frank C.
Taylor; f
of said Walter Neil; j able, exclusive, adverse and actual: March, A. D. 1911, then and there Plaintiffs and each
And W. ’Li. Culgar, if living, and if possession of all the lands described j to answer the petition filed in sard have had continuous uninterrupted—.
dead, the unknown heirs and legal above, using and enjoying the same, ; Court on the 26th day of January, peaceable, exclusive, adverse and t&fflH
And Sarah C. Taylor, if living, and (representatives of the said W. L. Cul- under actual enclosure, for a period A. D. 1911, in suit numbered on the tual possession of all the lahliCvl^F
if dead, the unknown heirs and le- gar; and the unknown wife of the of thirty years next prior to the in- Docket of said Court Xo. 1429, scribed above/ using and enjoying^!
gal representatives of the said Sarah said W, L. Culgar, if living,;, and if stitution of this suit. ; wherein C. C. Smith e&p W. P. the same under actual enclosure* foiE^li
C. Taylor, defendants, by making a 1 dead, the unknown heirs and legal That Plaintiff says that all of the Hughes are Plaintiffs, and More- a period of thirty-five years next
publication of this citation once in representatives of the unknown wife matters, occurrences and transactions head Wright, if living, and if* the prior to the institution of this
each'we^k for eight successive weeks , of said W. L: Culgar; ; out of which any possible claim on said Morehead Wright be dead, then Plaintiffs, and each of them say thm
previous to the return day hereof in And G. F. C. Bulcholder, if living,! the part of the Defendants, or any of unknown heirs of the said Morehead all the matters, occurrences* aaff S
some newspaper published in your and if dead, the unknown heirs and the Defendants, could arise, arose, oc-! Wright, and their unknown heirs and transactions, but of which any dos-X 1
county, to be and appear at the next legal representatives of the said G. F. jcurred and transpired more than thir-j legal representatives; and the un- ^ible claim on the part of the Dc ^ /U
regular term of the District Court of C. Bulcholder; and the unknown wife ty years prior to the institution of known wife of the said Morehead fendants or any of the Defendants
San Patricio County, Texas, to be of the said G. F. C. Bulcholder, if i this suit, and consequently all causes j Wright, if living, and if the said ; could arise, occurred and transpired
holden at the Court House thereof, living, and if dead, the unknown heirs of action, if any, existing in the De- ! unknown wife of the said Morehead more than thirty-five years prior to
in Sinton, Texas, on the third Mon- and legal representatives of the said fendants, or any of the Defendants J Wright be dead, the unknown heirs the institution of this “suit, and con-
day in March, A. D. 1911; the same unknown wife of the said G. F. C.
being the 20th day of March, 1911, Bulcholder; |
then and there to answer the petition And the partnership firm of Pool-
known heirs of the said unknown filed in said Court on the 25th day ey-Xeal & Company, and the unknown
Wife of the said John G. Pooley ; i January. A. D. 1911. in suit num- members of the firm of Pooley-Xeal
J 'And the. partnership firm of Crig- bered on the Docket of said Court, & Company, if living, and if dead, the
dar. Batchelder & Comparty, and the i No. 1127, wherein George H. Paul is ! unknown heirs and legal representa-
are barred by the provisions of the j and legal representatives of the said sequently all causes of action if any
Five and Ten Years’ Statutes of Lim- unknown wife of the said Morehead existing in the Defendants ’or any-
itations of the State of Texas, because | Wright, are Defendants, said petition of the Defendants, are barred by the
arising more than Five or Ten years j alleging as follows: provisions of the Five and Ten Years’
respectively, prior to the institution i That Plaintiffs both reside in San Statutes of Limitation of the State
of this suit, and by virtue of Art. Patricio County, Texas; that all of of Texas, because arising more than
3347 of the Revised Statutes of Tex- the Defendants indicated above by five and ten years respectively
m
m
:-y~£
unknown members of said firm, if Plaintiff, and Benjamin Dale, if liv- tives of the unknown members of the as, all rights, titles, estates, claims or j the prefix unknown are in fact un-j prior to the institution of this suit*
• . m. m . • m ■% «i i ______ 1 >1 CT O n . 1 if t Vi rv on i ,1 TY r.n -‘it n 4%, TV „ 1 » 1. .. f i vrn /-v-P D 1 O Cl _________ _____ ___ i d cv vti niiJn n f TY f a ti rl n ’i to nv n vi i- i-vP ! 71 O Wt H f ll D P1 J! 1T1 t 1 f f Q ; Tt PQ Ti B At" a J V, ..I _ _ _ _ * Cj'a a a r n W « . ^
iving. and if dead, the unknown ing, and if the said Ben ’a min Dale be ; firm of Pooley-Xeal & Company; and
ft'eirs and legal representatives of the uead. toe uhm- wn he •. of the said the unknown wives of the unknown
■ Said unknown members of said firm; Benjamin Dale,'and 'h r unknown members of said firm, if living, and
and the unknown wives of the said j heirs and legal representatives; and if dead, the unknown heirs and legal
unknown members of said firm, if the unknown wife of the said Ben-
living, and if dead, the unknown Janiin Dale, if living, and if the said of the unknown members of said
hbirS and legal representatives of ! unknown wife of the said Benjamin | firm;
the unknown wives of the unknown Ba*e be dead, the unknown heirs of And Andrew B. ^James, if living,
members of said firm of Criglar, the ,sa'd unknown wife of the said aud if dead, the unknown heirs and
Batchelder & Company;
Benjamin Dale, and the unknown legal representatives of the said An-
8#
w.
And George F. Batchelder (also heirs and leSal representatives of the drew B- James; and the unknown
spelled Batcheldor), if living, and if unknown wife of the said Benjamin wife of the said Andrew B. James, if
dead, the unknown heirs and legal Ua5e:, r j living, and if dead, the unknown heirs
representatives of the Baid George And George \\ . Haygood, if living, j and legal representatives of the un-
F. Batchelder, (or George F. Batch- and if the said George W. Haygood known wife of the said Andrew B.
eldor >; ba^dead, then the unknown heirs of j James;
And Joseph Ollinger and Sarah the sald George W. Haygood, and [ And Mrs. Louisa James, if living,
Batchelder Ollinger, husband ana their unknown heirs and legal repre-' and B dead, the unknown heirs and
wife,‘If living, and if dead, the un- sentatives; and the unknown wife of le&a.l representatives of the said Mrs.
known .heirs and legal representa- the sa\d George W. Haygood, and if Louisa James;
tives of the said Joseph Ollinger and
of his wife, Sarah Ollinger; and
Sarah Ollingen, if living, and if dead,
her unknown h£irs and legal repre-
ntaiives; and Joseph Ollingen, if
demands of the Defendants, or any of i known to the Plaintiffs, and cannot and by virtue of Art, 3347 of the
the Defendants, have vested in the ; be more accurately named or de-j Revised Statutes of-Texas au rights
Plaintiff, who has full title to said • scribed by Plaintiffs, and the resi- titles, estates, claims or demands of
tract of land, precluding all such j den.ce of each and all of the Defend- the Defendants, or any of the De-
representatives of the unknown wives i claims. ; ants named or indicatedjln this peti- fendants, have vested in the Plain-.' - '
That notwithstanding the truth of tion are likewise unknown to these tiffs, who have full title to their re-
the above averments, Plaintiff says | Plaintiffs. _ ! spective tracts of land above de-
there are certain defects and breaks i That the Plaintiff, C. C. Smith, is i scribed, precluding all such claims,
in the Plaintiff's chain of paper title seized and possessed in fee simple ! But, notwithstanding the truth" of
from the sovereignty of the soil, 1 oc+Qto " 1 ^ • ' - *
’
estate, and in the possession of a the above averments, these Plaintiffs
certain tract of land in San Patricio I say, and each of them say, that there
County, J exas, a part of a survey pat- are certain ^defects and breaks in
fv«. -Set SI'S ■ of kss
Said tract of land so owned and seiz- said defects and>breaks in the chain
o P°ss?ssed by+vthe Piaint?ff. of said paper title give rise to claims
C. C. Snxith having the following ] on the part of Defendants respective-
—.....-.................,-------- ™et®s and bou?ds/AOBQe0sinnmg th? 1which, though invalid, as a matter
preciate the market value of Plain- -N- co^n®r 9; 1403.89 acres of land Gf fact have the effect to cloud the
-:-------... liaJ6UUUi auu lL ------tiff’s property, and injure and em- | ^.™ye,d by' ^r&i1C+1S^ ^ C'1?' Plaintif?s’ title> and each of said
the unknown wife of the said George And A- B- James, Jr., and Aman- harass the Plaintiff in its ownership by deed dated December 11, Plaintiffs’ title to their respective
™ “------- •• ge -----—’ ’• - - -l~* —^ --------..--LX x---,J 1900. of record in the Deed Records tracts of land, and to affect'in a de- %
which said defects and breaks in the
chain of paper title give rise to
claims on the part of the Defendants,
respectively, which, though invalid as
a matter of fact, have the effect to
cloud the Plaintiff’s title to said tract
of land, and to affect in a degree the
marketability of said title, and to de-
% MS i Er0Perty riSht ,0 Sa‘e t of s/n<Patrf(fi(/c’ounty, Texas/in’Vol/
yin^ and if dead, his unknown heirs
ahd legal representatives;
And the partnership firm of^Pool-
ey*Nichol & Company, and the un-
kxurtvn members o!f said firm, if liv-'
ing, and if dead,-the unknown heirs
wife of the said George W. Haygood; !the unknown heirs and legal repre-
>wn heirs of the Said
of the said George W.
gree the marketability of the said
• w
and the unknown heirs of the" sa,id sentatives of such deceased;
ff * * - -
Haygood: v
unknown wif
And George L. Haygood, if living,
And Xathan C. Foiger, if living,
and if dead, the unknown heirs and
Plaintiff says he cannot indicate 1 P’ on thence south 1 title, and to depreciate the market
more fully, for the reason that he degree east, with the east line of said vaiue of Plaintiffs’ nmnartv onH
value of Plaintiffs’ property, and to
the claims and titles which are made
legal representatives of the said Xa- i against Plaintiff.
and if dead, the unknown heirs and than c- Foiger; and the unknown
legal representatives of Geor&e L. ! wife of the said Xathan C. Foiger/ if
Haygood: and the unknown wife Qf i livmg, and if dead, the unknown
ahd legal represeritatives of the mem- '•^le said George L. Haygood, if living, he/rs and legal representatives of the
said unknown wife of the said Xathan
C. Foiger; ' \
And Xathan C. Taylor, if living,
and if dead, the unknown heirs and
legal representatives of the said Xa-
than C. Taylor; and the unknown
_______^ _____ _____ _________ _ wife of the said Xathan C. Taylor, if
<«)r-Nerl & Company, ‘ and the mi- aentatives; and the unknown wife of livinS- and if dead, the unknown heirs
bers Of said firm^ and the unknown
wlve$ of the said ‘unknown members
of said firm; and the unknown heirs
And legal representatives of said un-
known wives of said unknown mem-
of said firm;
and if dead, her unknown heirs and
legal representatives;
And G. F. C. Batchelder, if living,
and if the said G. F.^C. Batchelder
be dead, then the unknown heirs of
the said/ G. F. C. Batchelder and
nd the partnership firm of Pool- their unknown heirs and legal repre
. known members of said firm of Pool- the said G. F. C. Batchelder, and if
If €gf-Nerl & Company/Tf living, and if]s^e t>e dead, then the unknown heirs
id, the unknown heirs and legal and legal representatives of the un-
»k .yPresenfatives of the unknown known wife of the said G. F.’ C.
* J&embers of said firm; and the un-1 Batchelder;
rc|lnown wives of the unknown members t HoAildt^V ' L- Crigler if living, and if
. Hrf said firm if living, and if ddad, the l*™6: thejinknown heirs of the said
unknown heirs pf the unknown wives h/ir an^d their unknown
and legal representatives of the said
unknown wife of said Xathan C. Tav-
lor; *
And David Taylor, if living, and
if dead, the unknown heirs and legal
representatives of the said David Tay-
lor; and the unknown wife of the said
does not know the exact nature of jtiact landr varas to the X. E. | injure and embarass the Plaintiffs in
corner of o0 acres tormerly owned their ownership, and the ownership
by Dubose; thence west wuth the 0f each of said plaintiffs’ property
north line of said Dubose tract to ; and, the right to sale tliereof; that
the western bdry. line of the said Defendants are asserting claims to
Morehead Wright purvey and east- said property, the exact nature of
ern boundary of the John W. Pa up which Plaintiffs do not know, but
survey; thence north, with said line - -
Plaintiff further says there are
certain instruments of record iii~ San
Patricio County and in Bee County,
which, by reason of inaccuracies of
expression and recitals therein, would
,
seem to show that Defendants are of Wrigkt and Paup surveys, to the
maSng cWms to saw M and cloud n°rthern b0UndarS’ ,ine- °f S3id Sur'
Plaintiff’s title.
Plaintiff says that he has indicated
the above claims of the Defendants,
and the said defects in said paper title
for the purpose of complying with
. A
same are unfounded and injurious ta
plaintiffs’ rights and a cloud on
Plaintiffs’ title. That these defect
v;l
orr%?s‘*^sc.ng:
ern boundary to the place of begins of Deftndanttf respectively, arise, are
, . | indicated as follows
There are excepted, however, and : FIRST; That sa
the requirements of the Statutes of jncluded within tb® metes and described in this petition wdre, as
tut; lequuenieuis ui tue awiuies, oi bounds above set out 14 acres of land nrpvioiislv tW
to the indications of the Lwnpd. nnsfipSSPll hv Plain- ?iriously state?’ ^ part ofbbe °.ri^:
’» <
That said tracts of land
Texas, as iu me inuieations ui uie ; AWnpr] Qpiypri and noqqpwprt hv Plain
know claims if 4»y, of the Ue- S W^es
fendants, but this Plaintiff says that are xneted and bounded as follows:
he does not intend thereby simply to j Beginning at a stake in the intersec-
nal survey patented to Morehead
Wright by Patent No. 267, Volume
9, Abstract No.^148, and no convey-
adjudirate and determine in this suit 11ion of the eastern boundary of said ance, ap5eaiTrS ,°.f, re,c/)rd .i1"0111, sai<^
thp snprifir riaims of thP n«rtin,,i«r' Morehead Wright; that the claims V
or Any
I
si#;
the specific claims of the particular ] 1403 89 acres and the southern or ■ * J / / \ne
Defendants, as indicated above, hut ka„aap +v,a rmht and demands of Defendants,
JBknown heirs of the unknown wives ' vv” ,a’ une‘er, and their unknown LDavid Taylor, if living, and if dead" Defendants, as indicated above, but southeastern^houndary of “the right of l*'“the^^e to^hes^P^Stiffs ¥
unknown members oTTaid firm heirs and le^al representatives; and Ithe unknown heirs and legal repre- it is intended and desired not only way of the St. Louis, Brownsville, i known ^ Pontiffs un-
* i J l> A nnlrn/vn-M U.i f- 1!__* m . , k I SODlfl I 1VOC t~\ T f Vl A CO 1 n r» ly a «x a. I f A O 1 11 fl 1 P'T t Q CimVl O 1 TY1 C Vlllf O T 1 ! n T • _ _ *1 i 1 _ ft j IVUU W U.
lund Walter Xerl if livimr and if :<he unknown wife- ^ living, of the, s®n+tativ^ °f the said unknown wife
IBjnTO..VaUeT Neri, it li\ing, and it said w. L. Crigler and if dead, the o1 tbe sar^d David Taylor:
Taylor;
.N& i rwG«7Ssenta'-l ,.Ynd ,HarrH »• Taylor, if living.
-«■ . I tives of the said unknown wife of and if dead- the unknown' heirs and
U“*J^Ln Wif®, said^ Wal- the said w L Crigler. j legal representatives of the said Har-
And W. S. Creigler; if living, and if ’ riet TaJTlor: . \
' - - And David II. Taylor, if living, and
unknown heirs of the said
ol-i ZJ-Jr:?!!:’1
Kpr Nerl, If living, and if dead, the
-JaMttaiQwn heirs of the said unknown
l wife of said Walter Nerl; ’ ( aeaa’ tbe
nd Walter Neil (or NT
and if dead, the unknown heirs heirs and legal represehtatives; and Taylor-
legal representatives of the said the unknown wife of the said W. S. And Ami
i^r Neil; and the unknown wife [ Creigler, if living, and if dead, the ^ j na r rank c. xaylor, if living, and i
unknown heirs of the said unknown
wife of the said W. g. Creigler, and
the unknown hejirs and legal repre- . J „
sentatives of the-said unknown heirs » ^nd,Ba^ab r*"ay^or> if living, and
of the said unknown wife of the said dead’ the unknown heirs and legal
W. S. Creigler;
said Walter Neil, if living, and
l heirs a>nd legal
e unknown wife
the unsown heirs jwad legal
*83ter Neil;
W. L Culgar, if living, and if
the unknown heirs and legal
leotatives of Ifhe said W. L.
, G and fche unknown wife of the
L. Culgar,’if living, and if
the unknown heirs and legal
entatives of the unknown wife
id W. I,. Culgar; ,
id O. F. C. Bulcholder, if living,
If dead, the unknown heirs and
representatives of the said G. F.
Mllcholder: and the unknown
|9f the said G. F. C. Bulcholder,
flng, and If dead, the unknowfi
and legal representatives of the
—
And John C. Pooley, if living,
if dead, the unknown heirs of me
said Jno. C. Pooley, and their un-
known heirs and legal representa-
tives; and the unknown wife of the
said John C. Pooley, if livinj^and if
dead, the unknown heirs of the skid
unknown wife of the said John C.
Pooley, and the unknown heirs and
if dead, the unknown heirs ahd legal ^endants named or indicated above,
demands ^SECON'D: Plaintiffs say that they
or rights whatsoever in and to said sajd 1 403 89 acres 887 varas to the rw6 *ndlca<;ed the above claims of
tract of land existing in the Defend- x.'E. corner of a tract known as \ll \ ntntr ^
ants, named or indicated above, or Dnbose tract- thpnce in a westerly ■ tbeir s.aid PaP®r title for the pur- ,
any of the Defendants named or in- ; direction, following the northern : P°*® 01 o^Se^at
dicated above. boundary of said Dubose tract, to the ’ t“ent^ 1 TT ' 3£
Premises considered. Plaintiff . common boundary of the John W. ; .tb® dfdl^°a f °1
prays: Pann and Morehead Wright surveys- ^aims, ot any of the Defendants.
FIRST: For Citation by publica-‘ thence following the boundary Una i ^ aSudf
°n l:!'°n each and »'• °f <»« De- between said Morehead Wright and ca°t‘e ana defemiLla'tti^S tto.
representatives of the said Frank C
Taylor;
legal
representatives of the said Sarah C.
Taylor are Defendants, said petition
alleging.as follows: ,
That Plaintiff resides in Washing-
ton County, Iowa, and that all of the
Defendants indicated above h>v the
prefix unknown are in fact unknown
to the Plaintiff, and cannot be more
accurately named or described by the
Plaintiff, and the residence of each
as required by the Statutes of Texas,
regulating such Citation against De-
fendants, who are unknown, or whose
residence is unknown to the Plain-
tiff, and as against unknown heirs of
John W. Paup surveys, in a northerly
direction to a stake; the intersection
of said boundary line with the S. E.
. , • ----------. ico railway company; thence in a
such deceased persons, the Plaintiff j northeastern direction, following the
nvoking the jurisdiction of this Court | said southeastern boundary line of
recognized by Art.. 1235, Art. 1236 ! said right of way to the beginning,
and Art. 123 8, inclusive, of the Re- That Plaintiff, W. P. Hughes, is
vised Statutes of this State, as well as ! seized and possessed in fee simple es-
the jurisdiction conferred by Chapter tate, and is in the possession of a
'22, Art. 1504a, and Art. I504f in-! certain tract of land in San Patricio
elusive, of the Revised Statute’s of' County, Texas, a part of the original
Pexas- ' survey patented to Morehead Wright
specific claims of th© particular De-
fendants, as indicated above, but it ia
intended and d< MR ~
legal representatives of the said un- and a11 of the Defendant^nanUd’1 af *n^EC°XD: A,Thaf „upon hearing Of ! by Patent No. 267, .Volume 9, Ab-
known heirs of jthe said unknown wife' tadicate^n this petition are likewise mertC^ISe’t- aintlS^ have his judg-infract 148. Sakl tract of land so
of the said John C. Poolev- |,lnUAnmxv, , lkewlse | ment divesting out of Defendants, owned and seiz,ed and possessed h^-
licholder; \
id tbe partnership firm of Pool- j b'7ng:- and dead, the
Gff Hn^TriA+plain* i of De^endants, all rio-ht, /aid Plaintiff, W. P. .Hughes, being
Company, and the , , _____
l unknown - members of said firm, if defendants herein.
of frl.*- mem! 1 «Ue. interest, estate, claim
B5SS.-W,,I the *a,d °- F- I lari Batchelder ¥c5mp7n7 intHhc' hereof 'SS” S' ( mahd TnTad’ ^““d S' ofuSSI U^Tot W t^lniS 1 'aSinVt unkaownY-eirs
Wcholder: x lmatoowB-.ni.mw......... ■* x ms’ af.ree.ld. and ht££.«*i«£, • "tato, thTtoteS^.^“SI!
the same in this Plaintiff whot-hof eastern boundary of said 1403.89 Atffe . k ng.th® ^un?dietl°?-?f this
claims, estates,
rights whatsoever in and to said
tracts of land existing in the Defend-
ants’ named or indicated above, ot.
any of the Defendants’ claims indi-
cated above.
THIRD: Premises considered, lataa
Plaintiffs pray for Citation by publi-
cation upon each and all of the De*-
fendants named or indicated above,
as required by the Statutes of Texas
regulating such citations, against
fendants, who are unknown, or whose
residences are unknown to the Plain-
■ >
firm,
unknown
' ?A. ■ ■ '
£
I That the Plaintiff aIso: th«mofoilowiogitto ..Otero
-•f the firm of Poolej'-Neal & and lagal representatives of the
?any; and the unknown wives kRowh wives of the unknown
, - the
’ , vuuuntis,. iexas, described as follows K luat tne Riamtiff also : . tuuuee louowiiigHue eastern ^hanfer^?
heirs to-wit: One League and Labor of havehls decree precluding all claims boundary of said 1403.89- acres, 887; {5 J4fincluSiveof theRevited st5- N‘
- un-; land ori e-inn in- o-a^„x„,i »... a , On tne nart of ftia — I varas to the X. R. corner of a tract ■ ' ?u 4 r» inc msi v e, Ot tne Revised stat
■/
j land originally granted hv Coahuira °n tc/e ,part of tbe Defendants or,,
mem- and Texas to Benjamin Dale hv -rant any of the Defendants, in and to said knoWR as
it ssrs. ,mi“. °tL°Tof crt*,*r-Batahai-, 1 s-EE «h^rMs:
t*e Dubos°ernterL°t; “thence !
heirs and legal
of the unknown wives of the
wn members of said firm;
Jd Andrew B. -James, if living.
If dead, the unknown'heirs and
il representatives of the said An
* a a , scribed in Title Xo 105 VolAmk 1i not said claims be specifically above northern boundary of said Dubose , ,.y 7,‘77 j/' ,J
representa- j And George F. Batchelder (also Saiib League and Labor of l-m i ‘‘ alleged, and that Plaintiff be auiten ' lract, to the common boundary of n: f 2 ^srnent diverting but of the
ve» of the Veiled Batcheldor 1. ,f livin*. and «! d^i^'w ! <» title .. ...inTin the John tv. Pan,, and the Morehead i
B. James; and the unknown
dead, the unknown heirs and legal lows: Beginrinfi- on ti c a,,/v, 7
representatives of the raid Geotgj of the Papak£?Cr«k It thj v^tl/
R Batcheider (or George F. Batch- j w«t corned of a %Vnt .Veto tea’gue
and I^abor made to RcrhPrt Carlisle
* nv,d,i°Seph °lin^er and Sarah | thence South with the west boundary
ITChcIHor Olllr,... 1_____1____, . of CC-FI At___t:.l “
n °f nin James’ if Batchelder Ollinger, husband and I of said Carlisle grant passing his
n and if dead, the nnltnntcn wife f livino- m ... Ca„h.-----* ________6 ’ YrtbS5in«» nis
varas, a
varas to a
and if dead, the unknown wife, if living, and if dead, the. un- ! Southwest corner at lO.lE)
and legal representatives of Ahe known heirs and legal represents-! stakei thence West ^YOO v-
.own wife ot-the-eald Andrew B. fives of the said Joseph oi Ungerand Utah.! thence North llni) “.‘“as jo a
his vi.e. Sarah Ollinger; -and Sarah ; stake on the south bank of said Pap-
;aid Creek
place of begin-
tates claims nr T " t5.^S’ e.s‘ Ww-T1": TVr U1C "J™U 1 ants, all right, title, interest, claii#
nop/„j„..,7 ’ J demands existing in Wright sutve^s, thence io11owt- Qr demand in and to safd tract of
m
next regular term
[ your return thereon.
rd M«- Louisa James, if living, Olligen, if living, and if dead her' alote Creek; thence down said Creek y*’ahave execated
If dead, tl»^ unknown heirs and unknown heirs and legal renres’enta Wlth Its meaade.rs to place of hevin. . c ^ hS G- D.
°'the sald Mrs-!
anj Di ^be Defend-; :ng the boundary, line between said 1 land aforesaid owned and possessed
M nvc a w t °r uot specifically-j Morehead Wright and John W. Paup by said C. C. Smith in fee simple, and
rot-rtS / d, • surveys, in a northernly direction to affirmatively Vesting the same in said v -
v.1 or -x 1 Blaintl^f farther prays a stake, the intersection of said bofcn- Plaintiff, C. C. Smith, whether or not
J e-aB-'vapdJor general relief. i dary liqe with the southeast %m- ' said right, title, estate, interest, claim
h.fnro -a aA1L AOT. but have you dary line of the right of way of the or demand be specifically above al-
sam court at its aforesaid St. Louis, Brownsville & Mexich rail- leged and described.
this Writ with way; thence, in a northeastern direc- FIFTH: That upon hearing of/'
,n. slfowing how tioii, following the said southeastern this cause Plaintiff, W. P. Hughes'
the same. j boundary line of said right of way, . have his judgment divesting out of
r, McGloin, Clerk of it0 the beginning. s > Defendants^ and each of the Defend--
P e J/!fer,I'.lct Court of San Patricio That Plaintiffs have good and suf- ants, all right, title, interest, estate,
v* * „ , and if dead, his unknown heirs’and That Plaintiff has a good and suf-I . ’ exas’ I ficient paper title of record from the j claim or demand in and to said tract
nd A..B. James; Jr.t and Aman- legal representatives; ; ficient paper title of record from the ; Given under mv hand and «eal of smereignty of tbe soi1’ especially if of land aforesaid, contaiiiing 14
ft. James, If they are living, and And the partnershb firm of Pool i sovereignty of the soil, especially if ! 0JflrCe iu Sintbn this the 25th dav the aPP™I>riate and proper legal pre- ; acres, and affirmatively vesting same
or any of them are dead, then ,ev-Xichol & Comnanv and tL ,, ^ Epe appropriate and proper legal nre- °f January- A- D. 1911. * sunvptions are indulged in favor of; in this Pontiff, W. P. Hughes, ’
pan>, and the un-, ------...----- . .... * (Seal) G T) ,-cimv said to the,r respective tracts fof whether or nfit said right, title, es-
Clprk nici-iAf n \ a etLUiN, land above described, and that Plain- tate, interest, claim or demand be
' rn nit TC°ur ' San Patricio tiffs, and each of them, further have ! specifically above alleged and de-
unt\, Iexas. fuU and complete title, precluding all scribed.
claims of any of the Defendants to
i^lieir respective tracts of land afore-
Sheriff San Patricio rlt?0?1, sai(L Further, by Teason of the stat- all claims on the part of Defendants,
1 t. , Texas, utory operation and effect of the or any of the Defendants, in and to
Statutes of Limitation of the Statd their respective tracts aforesaid,1'
of Texas, applicable to real property, j whether or not said claims be
> %
BSSJSSTtXJr' reVTe-
B*j Nathan C. Foiger, if living, | and legal represiWW-es of the merfi-! scribed aforesaid; and that Plaintiff
>U dead, the unknown heirs and bers t>f said firm; and the unknown furtb€‘r has full and complete title,
I representatives of the said Xa- i wives of the said unknown mem-howc ' Preciuding all claims of aqy oi
land
■ny, and the un- °ijriate ana proper legal pre-
rs of said firm if liv- i ^M.mpti°ns are indulged in favor of
unknown heirs ! all.aaid body, of land de-
- „ . --------, -------said unknown members ' prefcluding a11 claims of any of the
C. Foiger: and the unknown of said firm; and the unknown heirs i Defendants- to said tract Y»f
M the said Nathan C. Foiger, : and legal representatives of said uu-
Hffc; And if dead, the unknown known wives of. said unknown
and legal representatives of the
Unknown wife of the said Na-
C. Foiger;
bers of said firm;
mem-
aforesaid further by reason of the
statutory operation and effect or the
Statutes of Limitation of the State of
A true copy, I certify.
YD
SIXTH: That Plaintiffs, and each
of them, have their decree precluding
all claims on the part of Defendants,
Texas applicable to real property, be- Citation By Publicati
e,-N^rlth| Pc1ortm"pr.n7P 2? tV’ut thS V™ Teats' Statute’of Uml-
W'.fAji
ion being the Five Years’ Statute of Umi: | specifically above alleged, and that
ration, as prescribed by Statutes reg- ! Plaintiffs, and each of them, be quiet-
THF ST4TR me ti-vil- ulating said Five Years’ Statute of ed in their respective titles, as
To the Sheriff ,/‘ . », 'Limitation, and prescribing the re- against all titles estates, claims or
San Patricio Counti- .,<’ns4fl,do of njnrements thereof, and also by the demands existing in Defendants, or
Va., renting: ^statutes regulating the Ten Years’ any of the I>efendAnts, whether or
said firm and the unknown Statutes of ^mVtaUo'n^nd9 prescrS < sumnion Morehead Wright^MHi f° StattU,teS of Li.niitat*on’ and Prescrib- not specifically above alleged.
M-aylor. ir living 'T? ^ ‘ ^ 'i'75 SS'o? U,u"S(o/i7as^U S* Km
Ad Nathan C. Taylor, if' living, j k'nown'members'of said'firni oTpaaT 5a,-0n’ as P^scribed bv Statutes regu-
« the unknown heirs and ey-Nerl & Com anv if Hving and H: Wn"f ^ld F Ve YeaJ®’ Stat,ltes of
representatives of the said Xa- dead, the unknown heirs and w^ Lmutation and prescribing the re-
lC.VTaylor; and the unknown representatives of the unknown mem- Statnto«ntS tber.eof- and also by tk/
vlVto“ltda7450orS7t'm“ib“nrs M"n°,r fnTTi Morehe.8 IVright, if living. I fnRthYr^uWtertto«o"f:".Bd«;4?-
* BBd reprenentatlves of if and if dead, the unkr/w,: »“« .«* SSf/.iiL'K" W tally by virtue of Article 3347. of the ! pray for eaui,
¥3
and legal representatives
unknown wife of said Nathan
Taylor;
And Davl
, the
IBtatlves of the said David Tay
^.aod the unknown wife of the
iPavld Tayier, if living, and if
the
ItAtives
Of the said David Taylor;
, „ , . ------ --------, showing
< ach of them deraigned title, have executed the same,
had, for the past thirty-five
lylor;
s. Creigler, and their mi- 'vl>oin Plaintiff deraisns title have '/aid hnkiioWn wife of the said More- and
known heirs’ and legal representa- had- fcr tbe past thirty years and aead Mlright be dead, the unknown have
tives; and the unknown wife of tiie doun to the present time, continuous, keBs; and legal representatives of the
n; "T!’nterrupted, peaceable, exclusive ' ?a’7 pnicn-ow n wife of the said More- continuous uninterrupted, peaceable. CoontV'" T* xa ^
, . ... .. and Adverse possession of ’’ • e .s*
us-.ng and enjoying rh» same. ot th,s Citat on once in each week said tracts of land, using and en- Given under my hand and seal of
and paying each year as thev accrued ror e,ght Puvcessive weeks previous hiving the same and paving each ’ off5ce in Sinton. this the 26th day of
all taxes due thereon, and claiming1,0 the return dav hereof, in some ’-ear as there accrued all*the taxes January. A. D. 1911.
s''aint* under deeds duly registered newPPaPer published in your Conn- due thereon, and claiming the same
tor said full period of thirty years ■’ B there be*a newspSper jnihlished 'nder deeds duly registered for said
V
M
•m
unknown heirs anrl au" .‘"e ,,l,h“o"-n wue ot the ■ “e mwiu time, continuous. “Xy a,!u 1'^UI ‘mueseniatives of tire years and down to the present time, *M-C9l0jn' CieTkt ?f
ive» of the (aoi \ K I ^Preset.tativcs of said Walter Vn uninterrupted, peaceable, exclusive ; saief^■ unknown wife of- the said More- contimioi-c ..nintaW„,/»L na,v.,i,u the Distract Court- of San Patricio
unKn°wn and the unknown wife of said Wall abd'adverse possession of said bodv of had ^riaht. by making publication excliisW
d Harriet D. Taylor, if living. 'I'drrM, heirs of the - aVd Ini'cn,o!‘n’
IP. the unknown heirs and wife of said Walter \e i
■preaentatlves of the sai<i Hat- And Waltcr Nc11 x. a|, „ „v.
4 . 'ng- and if dead, the unknown heirs
lan (i,
David H. Taylor, if living, and and legal representatives of the said PI or to tbp 'nstBution of this suit G'f‘rfMR. t° apiiear at the n^xt regular full (leriod of thirty-five years prior
WA unknown heirs and le- Walter Neil; and the unknown wife and extending to the time of its Insti- p*m- ntbe district Court of San ; to the institution of this suit and
iSealf. G. D. McGLOIN,
Clerk District Court, San Patricio
County, Texas.
gsentativeS" of the said Da-jOf the said Walter Neil.
"iivi“e- — tuu°n A,s°-«»,«,«and.r
X
V
} r _
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San Patricio County News (Sinton, Tex.), Vol. 2, No. 51, Ed. 1 Thursday, February 2, 1911, newspaper, February 2, 1911; Sinton, Texas. (https://texashistory.unt.edu/ark:/67531/metapth717532/m1/4/: accessed July 10, 2024), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu.; crediting Sinton Public Library.