The Rich Hill tribune. (Rich Hill, Mo.) 1903-1911, 1909-01-14

1909 In vacation NoVembof o0th' ,
1908. u
w. 4. Hough. Plaintiff, /
vs..
Martin Younger and the unknown
heirs and d~evlsers OF Martin Younger.
deccnsed, and al persons claiming
by through or under the said Martin
Younger. deceased, and all persons
claiming by, through Or under the
heirs and devices OF the said Martin
Younger, deeeasel, Defendants.
Now az this day c0mes the Plaint-
m, herein. by his Attorneys,
Templeton h Hales,
In vacation, before the undersigned.
n. ID. Embree, Clerk OF the Circuit
Court within and for said county Of
Bates and ales his petition verified
by his affidavit, alleging, among
other things that defendants, the
heirs and devIsces Of Martin Younger,
deceased, and any and all persons
claiming by, through or under the
heirs and devisees Of the said Martin
Younger. deceased, are all unknown
to this plaintiR and for that reason
he IL unable to give or state the
name or nance or place or places oil
residence, OF the unknown heirs and
dsv.sees II the said Martin Younger,
deceased, or Of those claiming by,
through or under him: nor 10 this
plaintiff able to state or give the
name or names, or place or places oil
residence, Of any person or persons
claiming by, through or under the
heirs and devisees of the said Martin
Younger, deceased; that plaintiff Is
informed and believes that none OF
the parties hereinbeiore named as
parties defendants are residents OF
state oiMisaouri, and for that reason
none OF The said parties defendant
can personally be served with pro-
cess within said state OF Missouri,
whereupon. It 10 ordered 10y the
Clerk ia vacation thatsald defendants
be notified by Publication that
plaintiff has commenced a suit a.
galnst them I'm THE Court, the object
, and general nature ui which Is that
/; the plaiAtid alleges, Rvers end verify
believes that the defendants. Martin
, Younger, and the unknown heirs
, aud uevisees Of the said Martin
YongeF, deceased. and those claiming
- aAa.-.k - Uu..aaa him M f1aaFn
clHim. to be interested
, la the subie o matter q
|. this suit, viz. the lands hereinafter
. fully deserted and set out. but that
, he, the plBlntin IL unable 70 describe
c the said interest orinterests, or from
, whence such interest or interests an
derived, except that sHch Interest OF
interests, whatever it or they mas
be. would have been derived by In
heritanee, devise or purchase, by.
! through or under thu respective
parties defendants above named
That for cause OF action plaintiff
AYERS and alleges that be Is the own
eE In Zee simple OF the following
named and described real estate sit
uate, lying and being in Bates
CoHnty, Missouri, to-wit:
Tho south east quarter OF the north
west quarter and the north east
quarter OF the north west quarter
all ia section eight Cs), of township
forty t40), OF range thirty two tSsl
that no, plaintiff. Is In possession o.
said lands, and that he and thoss
under whom he claims have been II
the open, notorious, adverse, con
tipuous and peaeeable possession o
all the said lands for more than tea
yeaFs before the fling Of this hii
said petition. Plaintiff further al
leges and aver that he verify believes
that the parties defendants have OF
claim o. have or hold, some Interest
ia the lands above described, but, n'
aforesaid. the dcfiuate nature aus
character OF such interest IL 10 thu
plaintih unknown and cannot hereiI
be set out iurthur than az allow
statedi but b n such Interest What
ever II may be. Ia adverse and prc
udieial TO the plaintiff. Wherefor
the paliEtih prays thu court ~ try
ascertain and determine the estate
title and interest OF the plaintin anC
defendants herein respectively Ia ant