Brownsville herald. [volume] (Brownsville, Tex.) 1910-current, 1913-10-23
H A OF X

lou dIc ncTtDN cOIiliuduutu " SufihIho
J. +. Moberly and James B. Conway
by making publication of this Citation
once in each week for four successive
weeks previous to the return day hereof,
in some newspaper published in your
County. if there be a newspaper pub
Iishcd therein. but if not, then in any
newspaper published in the 18th Judicial
District: but if there be no newspaper
published in said Judicial District. then
in a newspaper published in the nearest
District to said 2Sth Judicial DiStricc to
appear at the next regular term of the
District Court Of Cameron County to be
holden at the Curt House thereof. in
Brownsville, Texas. on the 18th Monday
after the second Monday il October. AID.
1913. the same being the 10th day of No
ycmhcr, AID. 1913. then and there to
answer q petition fled in said Court on
the 9th dav of October. AID. 1913 in a
suit, numbered on the docket Of said
Court No. 22iS wherein II. 3. RcntfrO is
plaintiff. and J. f. Moberly, James b.
Conway and j. S. Dodson are defendants
and said petition alleging:
The State Of Texas.
County of Cameron.
No. 224S.
In the District Court Of Cameron Coun-
ty, Texas: To the Honorable w. 3. Hop
kins Judge # said Court:
Comes now II. i. Rentfro. who resides
in Cameron County. State Of Texas. here
matter called Plaintiff. leave OF the court
being first had and obtained, files this his
First Amended Original Petition in lieu
of his Original Petition fled herein com
planning of ]. f. Moberlv whose place
Of residence is t. this plaintiff unknown.
and James 3. Conway whose place
of residence is to this plaintiff unknown,
and j. S. DOdsOn who resides i'll Cameron
County. Texas, hereinafter styled De
PENDANTS. and for cause of action plaintiff
represents unto the court as follows:
That heretofore tO-wit on or about the
29th day of January, AID. 1909, dcfen-
dant j. +. MObcrly executed and delivered
to plaintiff his two promissory vendor
lien notes each for the sum of One Hun
drcd and Eighteen 0G-100 ($11S.06) Dol
lars respectively, each bearing date on
the day and year aforesaid and due and
payable Cn the 29th day of January AID.
1910 and the Doth day Of January AID.
1911 each respectively and payable to the
order of plaintiff in Brownsville, Texas
and hearing interest at the rate of six
NON amt annlrln fpnn, date until maud
and STIMULATING for ten per cent. on The
amount Of principal and interest then
due as attorneys fees i'll case suit IS
brought on same or if placed in the hands
Of an attorney for c Election. whereby de-
PENDANT became liable and bound to pay
and promised to pay plaintiff the sum Of
money in said notes specified together
with all interest ard attorneys fees due
thereon according to the tenor and effect
thereof; said notes being given for part
of purchase price on the following de-
scribcd real estate; situated in the Com
tv of Cameron. in the State of Texas to
Wit: ont of share - # the ESpirltl
Grant j. :. De la Cara original grantee
and being block 20 containing 10 acres
and > II acres out Of Block % according
TO j. W. Davis survey map and plat OF
the Rentfro and Male subdivision of the
Media Luna tract as of record OH page
II Of b ok | Map Records Of Cameron
County. Texas; that said property was
heretofore tO-wit on the Doth day Of Jan
nary, 1909, conveyed by plaintiff to de
PENDANT, by his deed of writing of that
date. in consideration. among other things
of the two notes herein described and
that in said deed Of conveyance a lien
was retained thereon to secure the pay
ment of said notes; that both of said
notes are due and unpaid. and defendant,
though often requested. has failed and re
fused and still fails and refuses to pay
said notes. or any part thereof. but the
same remain still due and unpaid.
That said notes have been placed in the
hands of Graham. Jones. West < Dancy,
attorneys. for Collection and plaintiff has
contracted to pay them the ten per cent.
attorneys fees stipulated herein. the same
being reasonable and the usual and Gus
tomary fee.
That on tO-wit July 18th 1912, and since
the original filing Of this suit j. $. bod
son one of the defendants. has paid to the
plaintiff herein the sum of Two Hundred
4 4O0n nnl Jnnorc u-bicb hoe hnnn Iu1y