Mexico Missouri message. (Mexico, Audrain County, Mo.) 1899-1918, 1904-08-11
Order of Publication in
Vacation.

STATE of MISSOURI In the Circuit Court
Frank L. Crosby, Plaintiff
Mary +. Pierce, widow of Charles w.
Pierce, deceased, the Unknown Heirs of
Charles w. Pierce, deceased, and all 9TH
crs having an interest in the subject mat
ter OF this petition whether by descent
from the heirs OF said Charles w. Pierce
or as assigns of Charles w. Pierce or of
his heirs, Defendants
Now on this August 9th, 1904, comes
plaintiff by attorney, and files petition
with the Clerk of this Court, in vacation,
duly verified by ailidayit of plaintiff,
stating among other things, that Charles
w. Pierce, now deceased, was on August
18th, 1881, the owner in fee simple OF the
following described tracts of land in Au-
drain County, Missouri, to-wit: The
southeast fourth OF the southeast quarter
the north half of the southeast quarter,
and all that part of the south half of the
northeast quarter lying south Of the Chi
cago and Alton Railway, all in section 8,
township 81, range z, and that on said
date one Richard s. Todd, for and in con-
slderatlon OF the sum Of sl455.OO, purchas-
ed all Of the said lands from the said
Charles w. Pierce; that on August 1s,
1881, the said Charles w. Pierce and his
wife, Mary f. Pierce, one of the defend
ants herein, In consideration OF the sum
OF Sl4j5.OO, in hand paid Charles w.
hNru ai nd In Of
the said contract Of purchase attempted
aud intended to convey by general war
rsnty deed TO said Richard =. TODD, all Of
said lands, but that the deed made, and
the description OF said land therein was
ERRONEOUS, and does not In fact describe
the said land intended TO be conveyed,
| describing it as the southeast fourth OF
the east quarter, the north half of the
Southeast quarter, and all of the south
half Of the northeast quarter lying south
Of the Chicago & Alton Railway, all in
section s, township 81, range Z, Audrain
County, Mo-" That plaintiff is, in fact,
now the Tightful owner, of the following
portion Of said land first herein described,
viz; The East halt Of the Southeast
quarter aud all that part Of the East half
Of the Northeast quarter which lies south
Of the Chicago & Alton Railway, by a
succession of conveyances from said
Richard s. Todd, who obtained title
thereto through Charles w. Pierce and
wife as aforesaid, and he has succeeded
TO the aforesaid rights of the said Todd as
purchaser and assignee thereof; that the
said Charles w. Pierce Is dead, but as TO
whether his said wife, the said Mary T..
/ Pierce, Is dead he has no knowledge and
| for which reason she Is made party de-
PENDANT TO this suit lfshe is living she
is nonresident Of the State OF Mis-
souri, so that ordinary process OF law can
not be served on her, and her interest in
thu subject matter Of this petition, and
how derived, SO far as plaintiffs knowl-
edge extends, is AS the widow OF the said
Charles w. Pierce, deceased, such being
the Interest as she may have by virtue Of
the marital relation that existed between
her and her husband. Plaintiff further
states that he verify believes there are
other persons Interested IN the subject
matter OF this petition whose names he
cannot insert herein because they arc un-
knowa to him; that said unknown parties
are the heirs al law Uf Charles W. Pierce,
dcreased, and all persons, II any, having
an interest In the subject matter OF this
petition AS heirs Of the said unknown
heirs OF tho said Charles w Pierce, de-
ceased, aud all persons, Il any, having an
interest in the subject matter Of thls pc
tItlon as grantees o. the said Charles W..
Pierce, deceased, OF as grantees OF the
heirs Of said Charles W. rlereei that the