The Hayti herald. (Hayti, Mo.) 1908-1922, 1916-02-17
John S. stoddard gave this plaintiff

uGeu OF Trust on SAID lanu TO Sc
cure the purchase price thereof. and
that later said John =. Stoddard con-
veyed said land to this plaintiff by
warranty deed and plaintiff salts
fed the record Of the deed Of trust
aforementioned, but that plaintiff
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 Belson. and as and under
such claim I'm his lifetime conveyed
said land in trust by his trust deed
to John A. Cunningham. trustee for
tho Peoples Bank. and 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
Hunter 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 Of
the land described as Lots one and
two of the southeast fractional nuar
ter Of said section six. township
nineteen, north OF range thirteen.
east. from the United States. lie
having entered sntl land on the l2tt
day OF Sertc mbrr. 1913. frcm the
ruitcd States Of America, and that
Presley philiiEs WAS the original pur
chaser for the land described rs Lot
three of suid section. six, township
nineteen. nurth Of range thirteen,
cast, from the United :; a:cs CT
America
Plaintiff further states that the
records do not aflirmatively show b"
the public records Of Pems2nt coun-
~. Missouri. that tho said John
Wood ever parted with the title to
50 d land. hut plaintiff charges ANA
avfrs TIA; the said Ichn Woods d..
parted this life leaving as his sole
and only heir at law, Robert A.
Hatcher. and that the said Robert
A. Hatcher and his wife. by their
warranty decd. conveyed said lots
one and two, to Presley Phillips, but
nv mistake described said land as
the ives, half of the east half of tl,
southeast quarter of said section six
and that William Sanders conveyed
bv trust deed said land to Presley
Phillips. in the year of 1888; that
Join S. Phillips, Charles A. Davis
aud Bette Davis. his wife, Bette
Phillips, Shapley G.. Phillips, NJ. L.
Phillips. Mary L. Phillips. Constance
z. Hinton, formerly Constance r.
Phillips. wife # John S. Phillips,
and Sam q. Phillips claim title to
said land in their lifetime as the sole
and only heirs at law OF the said
Presley Phillips, and that the said
Sam A. Phillius is nonresident OF
the state OF Missouri. SO chat the or
binary process of law cannot be serv-
cd upon him in this state.
Plaintiff further charges and AYERS
that he has long since. bv mnsne con-
veyances acquired all the right and
interest Of the said Presley Phillips,
in and to lots one, two and three of
the southeast fractional quarter of
said section six as aforesaid ;that
the interests the said Mrs. Elizabeth
4. Skies and Frank M. Skies were
derived by virtue of certain deed
OF trust conveying said land to the
said Frank NJ. Skies as trustee of
the said Mrs. Elizabeth A. Skies, but
was duly paid If and is now merely
a cloud upon the title Ct 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 r. 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 bv Annie
S. Mott and Dr. Thos. II. Mott, her
husband. Charles b. Shoemaker and
Charles Kier Davis, all of which
said deed are OF record in the Re-
corder's Office In PemiscOt county.
Missouri. Il
Plaintiff further states that by vir-
tue of long continued possession of
said land by plaintiff and his gran
tors and these under whom he claims |
title, and by reason of the facts that /
no che nor any If 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
defendants, nor any enc for them
ncr 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
deeds, duly recorded in the deed rec
ords OF said Pemiscot county, Mis-
souri,.
Plaintiff further states that he is
m hla m lpssribu mono fully mr. mar