The Lexington intelligencer. [volume] (Lexington, Mo.) 1901-1949, 1916-12-22
John Sullivan and Timothy Sullivan,
Plaintiffs.

hODeII T.. L. JdlhopAf q NhAA~ I
The unknown consorts, heirs, devil
sees. alienees, or immediate, mesne
or remote, voluntary OF involuntary
grantees, of Isaiah Smelser deceased,
The unknown consorts, heirs, devil
sees. ~alienees. or immediate, mesne or
remote voluntary OF involuntary
grantees Of Nancy Smelser, deceaseds
and the unknown consorts, heirs, devil
sees, alienees, or immediate, mesne,
or remote, voluntary or involuntary
grantees Of Susan Jane Hall, deceas-
ed, Defendants
Now at this day come the PlalntIIs,
by their attorney, Thomas A Walk
er. and file their petition, duly verified
by the affidavit Of Thomas A Walker,
their attorney and agent, alleging
among other things, that the places
of residence of all the defendants,
other than the defendant, Robert Z.
/. jackson, r Unknown to the Plain
tifs and said unknown defendants can
not be served with the ordinary pro-
cess of law as required by the stat
.utes, Plaintiffs petition alleging and
being in words and figures as follows:
Plaintiffs state the places of
residence of all the defendants other
than the defendant Robert e.. Il.
Jackson, are unknown to the plain
tifs, and that said unknown defend
ants al not be served with the or
binary process of law as required by
the Statutes. =.
And Plaintiffs for their cause of
action state that they are the own
ers and in possession of and claim
title to the following described real
estate situated in Lafayette County,
Missouri, to wit:
The Northeast quarter of the south
east quarter, and the southwest quar-
ter Of the North east quarter, all in
section seventeen, township forty
nine, Range Twenty four
Plaintiffs state that there are or
that they verify believe there are
persons interested in or who claim to
be interested in the subject matter
Of this petition, whose names plain
tihs can not insert herein, because
they are wholly unknown to them, and
whom they can not further describe
than as being the unknown consorts,
heirs, devisees, a~lienees, or immediate,
mesne or remote, voluntary or IN
voluntary grantees, of Isaiah Smelser,
deceased, and of Nancy Smelser de-
ceased and of Susan Jane Hall de-
ceased, respectively.
That said unknown parties derive
their title or claim to derive their IT,
tie or claims as c%onsorts, heirs, devil
sees, ~alienees or immediate, mesne or
remote, voluntary or involuntary
grantees, of the said Isaiah Smelser,
deceased, and of the said Nancy
Smelser, deceased and of the said
Susan Jane Hall, deceased, respect
lively.
That the interests of the defend
ants herein, as far as plaintiffs are
able to ascertain and know are de-
rived from and made apparent by
the following facts and defects in the
record title Of said Real estate.
Plaintiffs state that in the year
1843 one John Smelser was the own
err of said real estate and died in
said year without ever having con-
veyed the same of record, that N the
death of the said John Smelser he
left as his only heirs at law, Nancy
Smelser, his widow, who has since
died, Isaiah Smelser, John R
Smelser, Benjamin Smelser, Rebecca
A. Smelser, who afterwards inter
married with one William A. Sam
pie, Susan Jane Hall who after
wards intermarried with one Luke
Hall, and Mary f.. Smelser, who af,
forwards intermarried with one Will
lam Hickman, his children, to whom
said real estate descended each being
vested with an undivided one sixth in.
terest in said real estate subject to thu
Dover interest of the widow. Blu
it does not appear from the recort
that the said Isaiah Smelser ever con
veyed his interest in said Real es
/, tate. That on the 18th day of Aug
/, ust 1853 the said Susan Jane Hal
and Luke Hall, her husband, by thei
deed Of that date attempted to con
: yer her interest in said Real estat
/ to Nancy Smelser, that said dee
/ was recorded in the Recorders ofic
r for Lafayette County, Missouri 0
/ the 10th day Of November 1853 i
Book ''Y" at Page GO and whethe
4 she did in fact convey her interei
= Plaintiffs are unable to say, but if 81
did not, then her interest has nevC
e been conveyed to any one, but if sal
deed conveyed the interest Of sa.
Susan Jane Hall in said real esta'
e to said Nancy Smelser, then it do
i not appear Of record that said NanC
d Smelser ever conveyed said interes
= That the said Nancy Smelser di,
T. in the year 1894 and left as her on
ID heirs at law, her son Benjamin
It Smelser, and her daughter Mary
d Hickman and other persons who
h names are unknown to these plai
tiffs. That said Benjamin F. Smells
te has conveyed all his interest in so
4 Real estate to these plaintiffs, TIL
n Mary e. Hickman died in the ye
v, 1916 leaving as her only heirs,
IN law, VIM. f. Hickman, John Hickm
le and Addie Hit her children, a
Of Edna Ramey, Ruby Logsdon, a
u William Browning, children of
st deceased daughter, Susan Brownil
to and defendant Robert Z, L, Jacks
ne a Minor, and a child of Nell Brow
4 ing jackson, deceased, who was
child OF Susan Browning dsceas
a all Of whom have conveyed their
ng terest to plaintiffs except the s.
err, Robert E. l.. jackson, who is a
nor.
SIS Plaintiffs state that they and tn
elk, under whom they claim have b
if in the open, notorious, exclusive, c
aid tinuous, adverse, quiet and pea
81 / .lI, v.Arrlrrt,r &c nnfI In.I