Jefferson jimplecute. (Jefferson, Tex.) 1907-1926, 1912-08-29
CITATION BY PUBLICATION.
THE STATE OF TEXAS |
NA--S-

To the Sheriff or any Constable of
Marion County, Greeting:
You are Hereby Commanded to sum-
mon W. H. Yarbroueh by making
publication Of this Citation once each
week for four successive weeks previ-
Gus to the return day hereof. in some
Newspaper published In your county.
II there be = newspaper published
therein, but IL not, then in some news
paper published in the Fifth Judicial
District; but il there be no newspaper
published in said Judicial District.
then in = newspaper published in the
nearest District to said Fifth Judicial
District, to appear 1t the next regular
term OF the District Court of Marion
county, to be holden q: the Court
House thereof, in Jefferson. on the
End Monday in November A. d. 1872,
the same being the nth day of Novem-
Der A, D. 1912, then and there to ans
veY . petition filed in said Court on
the l9th day OF August A. d. 1912. in
suit, numbered on the docket Of said
borough IL Plaintiff. and w. H. Var
borough 10 Defendant, said petition al
leging. That your petitioner. Pearler
Yarbrouah, who is a resident OF Ma
rion county, Texas, complaining Of w.
u. Marlborough, whose residence is I'M
known, shows to the Court that about
January 1st, 1902, she and Defendant
were lawfully married in Cass County,
Texas, and has lived in Marion County
Texas, since that time up to January,
1908. % man and wife, and without
cause or justification Defendant aban-
donsd her and children and she has
never heard from or seen him since
said date; since Defendant abandoned
Plaintiff she has continued to reside at
her homo and has taken care of her
self and children without any assis-
lance Whatever from Defendant. Plain.
tin alleges from day Of her marriage to
Defendant until the date Of his aban-
donment she WAS faithful and true
wife to him and he had no just cause
for abandonment. Aud a. result of
their marriage they have boy s years
old, by name Willie, and q girl 8 years
old by name OF Minnie; further alleges
that after her marriage to Defendant
they acquired by purchase one hun
dred and ten acres tlU of land in
Cas- and Marion counties, being IA
interest in the James Alley II. r. sur
vsy Of $40 acres, less 50 acres sold off
TO Robt. Mccain, Nov. 30th, 1887. Said
lands are II miles from Jefferson. Tex
a. on dirt road leading from Jefferson
to Pittsburg; being the End fourth,
running from West to East; more
particular description is of record in
Book l., page 1872 Deed Records of
Marion County. Texas. Plaintiff al
lsges that this land was purchased on
credit and she has paid part Of the
purchase money due on said land since
abandonment Of her husband and there
10 some vendor lien notes still unpaid,
further alleges that she has made dill.
gent inquiry to ascertain Defendants
whereabouts, but unable to locate him;
therefore was necessary to obtain Cita-
ton by Publication.
Wherefore, Plaintiff sues and prays
that Citation be issued by publication
to Defendant requiring him to appear
aud answer this petition and on final
hearing that she have Judgment dis
solving the bonds Of matrimony exist
ing between her and Defendant and
abe Be awarded the custody of her two
children and the land above described
- her separate property and for all
costs of this suit.
Herein Fail Not, but have before
said Court, at its aforesaid next regular
term. this writ, with your return there
on. showing how you have executed
the same.
Witness, G. NJ. Jones, Clerk of the
District Court Of Marion County.
Given Under My Hand and the Seal
IS OF said Court, at ONCE in jeff
srson this 10th day of August,
A. D. 1912. G. Nj. JONES'
Clerk District Court Marion County