The Waxahachie daily light. [volume] (Waxahachie, Tex.) 1894-current, 1914-05-09


land conveyed and described in
deed from John F. Campbell and
wife, Martha A. Campbell. to F. s.
Williams, dated March 10, 1919, fiji
ed for record March 8, 1914, in the
office Of the county clerk of said
Ellis county. That plaintiff claims
and deraigns title to said AZ Il
acre tract through a regular and
consecutive chain of title from the
sovereignty of the soil That said
Daniel Rogers, John +. Campbell.
and John K. Campbell, purchased
SAID Us IL acre tract from said T.
j. Quinn, and on or about August
u, 1881, had and made a partition
thereof between themselves, ii por-
ton Of said 12S Il acre tract not
n controversy herein, being allotted
and set apart to said Daniel Roger,
another portion thereon not in con-
troversy herein was allotted to said
John r. Campbell and the remain
ing portion thereof, being the same
land in controversy herein was al
lotted to said John +. Campbell,
through and under whom plaintiff
deraigns and claims title. That
said three parties, joined by their
wives for the purpose of effecting
and cyidencing said partition exc
cuted deeds to each other, execut-
ed to each other deeds to the
lands so allotted and partitioned,
and said John X. Campbell and
Daniel Rogers and their wives exc
cuted and delivered to said John
+. Campbell a deed to said A. II
acres in controversy, but the field
notes to same imperfectly describe
the lands SO intended to be convey
ed, thereby creating a cloud on
deed was insufficient, yet said YER
bal partition between said Daniel
Rogers. John X. Campbell, and
John F. Campbell, WAS good as a
verbal partition, and Invested all
title and claim thereto to said land
out of said Daniel Rogers and John
Il. Campbell. That said John F.
Campbell took immediate posses
sion Of said land so allotted to him.
and said partition had been ac-
guessed in by all parties to said
partition, and that neither OF sad
defendants or any parties claiming
under them have since asserted or
claimed any right, title, or inter
est in said z Il acre tract.
That In addition to his title TO
said land shown by consecutive
chain of title as above set forth,
plaintiff AYERS that he has good and
perfect title thereto by reasons OF
the statutes of ten, five, and three
years limitation, alleging that he
and those under whom he claims
and deraigns title, and through
said John F. Campbell, have been IN
actual exclusive, visible, open,
peaceable and notorious possession
continuously, for more than ten
years prior to the filing oil this
suit and any cause of action arising
to defendants for the recovery OF
said land, and also such possession
for more than five years prior to
filing of this suit. and any such
cause OF action arising to delend-
ants under IA deed duly registered,
and in addition thereto such pos
session for more than three years
nrior TO the filing of this suit and
any cause of action arising to de-
PENDANTS for the recovery OF SAID
land. for more than three years,
plaintiff claiming under regular
chain or transfer from the SOW
erejgnty of the soil, and under title
or color Of title, Plaintiff prayS
that said defendants be cited by
publication, for the time and N
the manner as required by law 10
appear and answer sad petition
that an attorney or attof-
news be appointed by tAe
court to represent said defend-
ants (unless they should appear and
answer herein. and that plalntltt
have Judgment removing any ana all
clouds from his title and that all
right claim title and interest OF oc-
PENDANTS and each of them or pre-
tended right claim, right or Inter
est in them be Invested out oil thehi'
and each of them and be vested III
plaintiff, and for further and other
relief. general and special, in law
! ar IN equity to which plaintiff may
be Justly entitled.
Herein fail not, but have before
said court. at its aforesaid next reg
ular term, this writ, with your !e
turn thereon, showing how you nave