Brownsville herald. [volume] (Brownsville, Tex.) 1910-current, 1913-10-30
Fl STATE OF Y

iou II uSISDr ~ uiiiiiO
J. i. Moberly and James b. Conway
by making publication of this Citation
once in each week FIR four successive
weeks previous to the return day hereof,
in some newspaper published in Your
County, if there be Il newspaper pub
lisled 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 i'm the nearest
District to said 18th Judicial District. to
appear at the next regular term O. the
District Court of Cameron County to be
holden at the c urt House thereof. in
Brownsville. Texas, en- the 18th Monday
after the second Monday in October AID.
1919. the same being The 10th day of No
yember. AID. 1913 then and there to
answer a petition fled in said Court on
the 9th day of October. AID. 1913 in a
suit, numbered OH the docket of said
q urt No. 22iS. wherein r. b. Rentfro is
plaintiff. and j.. L. Moberly, James p.
Conway and j. S. DOdS0n 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. B. Hop
kins Judge # said Court:
Comes now r. 3. Rentfro, who resides
in Cameron County State Of Texas, here
-. r.. -.JIa1 JDyo..X.cc - " -.
being first had and obtained, files this his
First Amended Original Petition in lieu
Of his Original Petition filed herein com
planning Of j. II. Afoherlv whose place
Of residence is t. this Plaintiff unknown.
and James b. Conway whose place
# residence is to this plaintiff unknown
and J. :. pnison who resides in Cameron
County. Texas. hereinafter STYLED lie
PENDANTS. and for cause OF action plaintiff
represents INTO the court rs follows:
T.
That heretofore to-wit IN or ab III the
29th day Of January AID. 1899. defcn-
dant j. #. Moberly executed ana delivered
t. plaintiff his Two promissory vendor
lien notes each for the sum OF Ole Hun
bred and Eighteen GG-l0O ($11%.OGl FOL
lars respectively. each bearing date on
the day and year aforesaid and dine and
nnyable n the 18Th day Of January 4 d.
l9l0 and the Goth day cf January AID,
1911 each respectively and payable to~tAe
order If plaintiff I'll Bruwnsvillc. Texas
ana bearing interest At the rate of six
rcr cent per mum from date nntii p3Id
and stipIlating for ten per rent. Oh rhc
amount Of principal .nd interest then
f.c rs attorneys fees IN ease suit az
hrrught on same or if placed in the hands
0f nm attorney for C ilection, whereby ,ir-
PENDANT became liable anC bound to pay
and promised TO pay plai!tiif the sum'of
money III said notes specified together
with all Interest and attorneys fees due
thereon according to the tenor and effntt
thereof: said notes being given for part
IF purchase price on the following de-
Settled real estate; situated in The CoaiI
~ ii Cameron. in the State OF Texas 10
wit: out Of share - # the FSpiri;I
Grant J. :. DE la CARA original grantee
and being block 20 containing 10 acres
I'M - - dtltS u " DIVth - ittolNlhS
TO j. w. Davis survey map and plat of
the RcntfrO and Male subdivision of the
Media Luna tract as of record on page
Il o. b ok l Map Records of Cameron
County. Texas; that said property was
heretofore to-wit on the Doth day Of Jan
uary, 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. S. bod
son one OF the defendants, has paid to the
plaintiff herein the sum of Two Hundred
($200.00) dcllars which has been duly