Jefferson jimplecute. (Jefferson, Tex.) 1907-1926, 1912-09-05
CITATION BY PUBLICATION.
THE STATE OF TEXAS |
Cnnnfx of Marion.

County Of Marion.
To the Sheriff or any Constable Of
Marion County, Greeting:
You are Hereby Commanded to sum-
mon W. H. Yarbrough 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.
If there be . newspaper published
therein, but II not, then in some news
paper published in the Fifth Judicial
district; but If there be no newspaper
published in said judicial District,
then in = newspaper published in the
nearest District to said Fifth Judicial
District, to appear at the next regular
term of the Dietrict Court Of Marion
county, to he holden at the Court
House thereof, in Jefferson. on the
End Monday in November A. d. 1912,
tho same being the nth day of Novem-
Der A, d. 1912, then and there to ans
wer . petition filed in said Court on
the 10th day Of August A. d. 1912. in q
suit. numbered on the docket OF said
Court No. 8007, wherein Pearler Var
borough is Plaintiff, and w. H. Var
borough is Defendant, said petition al
leging. That your petitioner, Pearler
Yarbrough, who is resident of Ma
rion county, Texas, complaining of w.
II. Marlborough, whose residence is I'M
known, shows to the Court that about
January LIST, 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, as man and wife, and without
cause or justification Defendant aban-
doned her and children and she has
never heard from or seen him since
said date; since Defe ndant abandoned
Plaintiff she has con tinued to reside at
her home and has taken care Of her
self and children without any assis-
lance whatever from Defendant. Plain
tiff 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. And as result of
their marriage they have boy 8 years
old, by name Willie, and girl years
old by name of Minnie; further alleges
that after her marriage to Defendant
they acquired by purchase one hum
bred and ten acres ul0) of land in
Cnss and Marion counties, being IA
interest in the James Alley II. r. sur
vey of GAO acres, less 30 acres sold off
to Robt. Mccain, Nov. 30th. 1887. Said
lands are II miles from Jefferson. Tex
as 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 1882 Deed Records of
Marion County. Texas. Plaintiff al
leges 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
Is 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
and answer this petition and on tina
hearing that she have judgment dis
solving the bonds of matrimony exist
ing between her and Defendant an6
she be awarded the custody Of her tive
children and the land above described
as her separate property and for al
costs of this suit.
Herein Fail Not, but have befor,
said Court, at its aforesaid next regula
term. this writ, with your return there
on. showing how you have execute,
the same.
Witness, q. NJ. Jones. Clerk Of tn,
District Court of Marion County.
Given Under Ny Hand and the Sea
OF said Court. at office in jeff
. srson this 18th day of August
A. D. 1912. G. NJ. JONES,
Clerk District Court Marion County