Mexico weekly ledger., 1905-04-27
County of Audrain,
In the Circuit Court, June Term, 1905
Wabash Railroad Company. Plaintiff
VS..
John Fl. Lane, John w. Musgrave, and
the Unknown Heirs, Devisees and
Grantees or Assigns of W. IL.
Goodrich, deceased. -. Defendants

Goodrich, deceased. -. Defendants
Now on this day, April LIST, 1905,
comes Plaintiff and tiles with 2
CLERK OF this Court, In vacation, bis
peuition duly verified by atiidavlt,
| wherein the Plaintiff states that 1t Is
a c~orporation, organized and existing
under and by virtue OF the laws OF tne
State OF Missouri, and as such corpor,
alton has power 10 Il aud be SUED
and TO exercise the power and rignt OF
eminent domain. -
That Plaintiff In pursuance OF the
laws OF Missouri and OF Its charter IS
| engaged In owning and operating a
| railroad from 50. Louis, missouri,
westward through the County OF Aud.
rain to Kansas City, Missouri, and al
Mexico In said Audrain County IN
furtherance Of its business as such
| railroad corporation, its public basi-
ness requires that 1t shall have further
and other and additional grounds for
depot, stock yards, with side tracks.
switches, turnouts, convenient and
useful for the prosecuting OF It's ousl'
ness.
1t further states that 1t needs and
seeks to acquire for public use a ior
the purpose aforesaid a parcel or tract
OF land situated In the City OF Mexico
and County OF Audrain and described
as follows, to-wit. All that Tract or
parcel of land situate east OF Morris
Street In the said City of Mexico ana
bounded on the north by the righf0f-
way OF the Wabash Railroad, and on
the south by the south branch Of the
Louisiana s. Missouri River Railroad,
which last named railroad Is operated
and occupied by the Chicago " Alton
Railway Company, and being all that
part OF Lot seven ~ Of Block eleven
.tID and all those parts Of Block four
(4l. Block five t5) and Block three 81
of Morris Addition to the City OF
Mexico lying east OF said Morris street
and between the. rightofways Of the
two said faffr6ads last named, and In
Guiding the streets and alleys as indl-
Gated upon the plat OF said motifs
Addition along said tract OF land
aforesaid, save and except the follow
ing portion Of Block three ~ begin at
a point on the east line Of said Morris
street In the center OF the rightofway
of the Louisiana & Missouri River
Railroad; thence north fifty feet for
a point Of beginning; thence north
fifty-eight feet and four inches; thence
north seyenty-six degrees and forty-hVe
minutes east two hundred and forty
six feet and six inches; thence south
thirty.five feet and six inches; thence
on and along the north line Of the
rightofway OF said last named railroad
to the point Of beginning.
That the said w. II. Goodrich in
his life time to-wit: September It'll,
1898, by general warranty deed record
ed In Book SO, page 36S Of the Record
er's office Of Audrain County, Mis-
souri,, became the owner Of said lands
herein sought to be condemned.
And that thereafter, tO-wit: In or
about the year 1900 the said W. II.
Goodrich departed this life, and until
his death appeared to be the record
owner OF said lands.
That the said w. IL. Goodrich left
surviving him heirs at law, but they
are unknown to this Plaintiff, its
agents, officers or attorneys. And that
the said W. II. Goodrich, either in his
life time, by his last will duly exc
cuted by him, devised said land to
some person or persons unknown to
this Plaintiff, or In his life time grant
ed or assigned said lands to some per-
son or persons unknown 10 this Plain
tiff, or at the death OF the said w. II.
Goodrich the said lands we're Inherit
o1 fropo him hu hfo hairs ut auy Whiph
said heirs are unknown TO this Plain
tiff and Plaintiff alleges that the little
TO said lands Is either In said unknown
devlsees, heirs, grantees or assigns OF
the said W.. ii, Goodrich, deceased,
and said Plaintiff declares Its belief
that said title is In n or the other
OF the said three unknown classes OF
person or persons, but Plaintiff has no
knowledge or information and is ig-
norant as to whether the said title be
in the one or the other Of the said un-
known parties. Plaintiff further
states that 1t and the owners Of said
tract Of land who are n0n-residents OF
the State of Missouri cannot agree
upon the proper compensation to be
paid for said land or any interest
therein which Plaintiff seeks to ac-
Quire, although Plaintiff has used
every endeavOr TO learn and ascertain
who be the true owners OF said lands,
and that the names neither of the un-
known heirs, devisees, grantees, or as
signs OF said w. II. Goodrich can be
inserted herein for none are known to
this Plaintiff.
Your petitioner therefore prays for
the appointment by the said Court, or
by the Judge thereof in vacation, Of
three diSinterested freeholders as COM
misSioners,o or OF a jury to ascertain and
assess the damages which the said
owners Of said tract Of land may Sus-
tain as the Just compensation to
which they may be entitled in conse-
quence OF the appropriation and use
OF said lands by the said Plaintiff for
the purposes aforesaid.
Plaintiff further prays for an Order
of Publication notifying said I'M
known owners whoever they maybe OF
the time, place and hearing OF this
petition by the said Court or by the
Judge thereof In vacation.
1t is now therefore ordered by the
Clerk Of the Audrain County Circuit
Court, In vacation, that publication
be made herein notifying the I'M
known heirs, devisees and grantees or
assigns OF W. II. Goodrich, deceased,
that the Wabash Railroad Company
has begun proceedings against them
In the Circuit Court of Audraln Coun.
ty, Missouri, the object and general
nature Of which is for condemnation
and appropriation for public use by
said Wabash Railroad Company, Of
the land herein and above described,
and praying for the appointment of
Commissioners or a Jury 10 ascertain
and asenee tho dannnnoa uLLInh -