The Hayti herald., 1916-02-24

cure the purchase price thereof, and
that later said John s. Stoddard con.
veyed said land to this plaintiff by
warranty deed and plaintiff salts.
fled the record cf the deed of trust
aforementioned, but that plaintifl
lost said deed SO made by the said
John s. Stoddard conveying said
land to plaintiff, so that the same
does not now appear of record; that
Richard Belson claimed an interest
in said land as an heir of the said
Robert Bel5on, and as and under
such claim In his lifetime conveyed
said land in trust by his trust deed
to John A. Cunningham, trustee for
the Peoples Bank, anu that said
John A. Cunningham sold said land
by trustees deed TO John j. Williams
and that the said John j. Williams
claims title BY and through said
trustees deed. that the said Lee
Hunte. claims title in and to said
land by virtue Of deed executed
TO him by one Joseph Sanders.
| Plaintiff further states that John
Weed was the original purchaser Oi
| the land described as Lots one and
two OF the southeast fractional quar-
ter OF said section six. townships
nineteen, ncrth nf range thirteen.
east. from the United States, he
having entered said land on the i2ill
! LAY Of September. iSiS. from the
| United states OF America. and that
Presley Phillips was the original pur.
chaser for the land described as l.o.
three Cf said section six TOWNSHIP
nineteen, north Of range thirteen
cast. from the United States Of
| America
Plaintiff further states that the
records do not afIirmativelv show by
/ the public records of Pem's"ot coun-
~. Missouri. that the said John
F! Wood ever parted with Tho ii IT, "a
av"rM tia ,hN scid John Woods de-
parted this lie leaving a., his sole
! and only heir at law, Robert A.
! Hatcher. and that the said Robert
!. Hatcher and his wife. by their
,'"rran'y deed. conveyed said lots
o"o and iwo. to Presley Phillips. but
by mistake described said land as
the west half of the east bulf OF Tie
southeast quarter of said section six
aud that William Sanders nyeyed
nv trust deed said land to Presley
Phillips, in the year of 1858; that
jC' Il &. Phillips. Charles A. Davis
aud BETTE Davis, his wife. Bette
Phillips. Shapley G. Phillips, NJ. f..
Phillips. Mary Il. Phillips, Constance
z. Hinton. formerly Constance r.
Phillips. wife Of John S. Phillips.
and Sam A. Phillips claim title to
said land in their lifetime as the sole
end only heirs at law of the said
Presley Phillips, and that the said
SAM a. Phillips is nonresident OF
the state of Missouri. so that the or
d'rary process of law cannot be serv-
cd rnon him in this state.
rlaintiff further charges and ayers
that ne has long since, bv mesne con-
vr"rnces acquired all the right and
i:tercGt cf the said Presley Phillips.
iN and to lots one, two ana three of
tho southeast fractional quarter of
said section six as aforesaid ;that
the interests the said Mrs. Elizabeth
A. Skies and Frank NJ. Skies were
derived by virtue Of a certain deed
of trust conveying said land to the
sold Frank NJ. Skies as trustee of
the said Mrs. Elizabeth A. Skies, but
plaintiff says that said deed of trust
was duly paid eff and is now merely
a cloud upon the title Of plaintiff,
and that the claim of Joseph Hud-
gins in his lifetime, in and to said
land was by virtue of warranty
deed dated the 2Sth day of April,
1887, duly executed by S. A. Phil
lips and Mary E., Phillips, his wife.
conveying part of said land to him.
the said Joseph Hudgins. but plain
tiff says he has, by mesne convey
ances. acquired all the right, title
and interest of the Joseph Hudgins
in and to said land: that the defen-
dant, Lee Hunter, claims title in and
to said land by and through certain
quit claim deed executed by Annie
husband. Charles b. Shoemaker and
Charles Kier Davis. all of whicl,
said deed are of record in the Re-
corders Office in Pemiscot county.
Missouri.
Plaintiff further states that by vir-
tue of long continued possession of
said land by plaintiff and his gran
tors and those under whom he claims
title, and by reason of the facts that
no Cne nor any of the defendants or
any one under whom they might or
could claim title to said land, have |
been in possession OF said land dur !
ing more than thirty one years las; |
past, and that no one nor any of the !
nor any one for them |
nor any one under whom they might
claim or could so claim, has paid any |
taxes on said land, or any part there
of, during more than said period of |
thirty-one years, the title to said |
land has vested in plaintiff. who has
and by and through those
under whom he claims title, in the
actual, open, exclusive and continu-
Dus possession of said land and every
part thereof, during the period of
thirty years last past, claiming said
land in fee simple, under warranty
leeds, duly recorded in the deed rec
Drds of said Pemiscot county. Mis-
souri,.
Plaintiff further states that he is
unable to describe more fully or par
.icularly ~either the interests Of