Brownsville herald. [volume] (Brownsville, Tex.) 1910-current, 1916-02-08
Citation BY Publication.

- taA VA
To the Sheriff or any Constable If Cameron
County. Greeting:
OH are hereby commanded t. snmmon
samuel NJ. Fegtley. IN making publication If
this citation once in such week fnr four sue
cessive weeks previous Ia the return date
here"i. ~ some newspaper published in Your
c,'unty; II there b." a newspaper published
therein. but If not. then in any newspaper pub
lished in the 18th Judicial district: bur If there
br no newspaper published IA said judicial dis
trlct- then In come newspaper published in the
nearest district IL the said 18th Judicial dis
trict. to appear AZ the next regular term If the
District court Sf Cameron cnuny. To be- holden
NJ the court house thereof IN Brownsville. ON
the second Monday in March. 4. H. 1916. the
same being the 18th day II March. \. II. 1916.
then and there To- answer a petition filed in
said court on the 18th day II October. 1915.
in a suit numbered on the docket ~ said court.
M. 99f2, wherein United Land and Irrigation
company is plaintiff and SaInnel NJ. Fegtley il
defendant. and the supplemental petition filed
on the 18th day If January. 1916. said original
petition alleging that the plaintiff is a corpora
tlon duly incorporated. and duly organized and
existing under the laws Of the State Of Texas.
and said supplemental petition alleging that the
place ~ residence ~ said Samuel NJ Fegtley.
is unknown ro plaintiff.
Said original petition for cauSc If action
alleges that on October i'll. 1910. the defend
ant, Samuel NJ. Fcgtley. executed and delivered
to Eugene &. Shireman. eleven t1ll ~pronissory
vendors lien notes. numbered from one IL to
eleven t1lp inclusive. all date Of October IL.
1910. said note number one t1l becoming du.
and payable on or before six CO. months after
It's date, and being for the sum If thirty I'VE
and 10-1OO ($35I0l dollars: notes numbered
tive CD. three 81. four ca. five t5i. six TO-.
seven "a, eight tSD. nine 90. ten ,1Ol and
eleven u1). each for the sum Of one hundred
and seventeen tSf1T.0ol dollars. respectively.
due on or bcfor" six o.. twelve t12l, eigh-
teen t1S), twenty-four (2il. thirty go
thirty six f36l. fnrty-two ti.l. forty-cight
t4sb. fifty -four tJIl and sixty 900 months
from their date. all 81 said notes hearing in
tcrest at the rate If six Is, per cent per an
mum from date until maturity. interest pay
able annually and providing for ten tlol per
cent interest after maturity and for ten tlol
per cent additional as attorneys fees. in ease
the same are placed in the hancs of an attor-
ney for collection.
Plaintiff alleges that said notes were given
for part Of the purchase price for lots number
three OBJ. and four tib IN block one hundred
and eleven I'D. containing fifteen and ninety
two hundredths tlJ.92l acres OF land out Of
the Espiritu Santo Grant. in Cameron county.
Teyas.as subdivided by f. :. Hunt. u aL. by
plat duly recorded in the county clerks office
Of Cameron county, Texas. in Plat Book No.
l. pages ~ and ~.
Plaintiff further alleges that notes number
on. Cl and number two CO have been paid.
and that NIL of said notes have been declared
due and tn" same have been placed in the hands
IF its attorney for collection. and that II has
contracted and agreed with Amos Rich. - pay
him the ten t1Ol per cent provided III sand
notes, rs attorneys fees.
Plaintiff further alleges that on November
t'ts 49,
able consideration. transferred SAID notes To
Grover G. Singer. by an instrument III writing
of that date. duly recorded in the Deed Records
Of Cameron county. Texas. in Vol. n. pages
H.; ct seq. and that on November 2.nd. 1915.
Grover q. Singer, for 4 valuable consideration.
transferred and assigned said notes To the
United Land and Irrigation company. hy an
instrument in writing. recorded in Volume 80.
pages so ~ seq. of the Deed Records Of
Cameron County. Texas. and that the plaintiff
il now the legal owner and holder If said notes.
and that said defendant promised and agreed
tn pay To- plaintiff the amount of money
specified i'm sand notes.
Plaintiff further alleges that in connection
with the deed transferring said land To- the said
defendant. Samuel NJ. Fegtley. that there was
assigned to the said Samuel VI. Fcgtley fifteen
15) shares Of the capital stock of the Indiana
Cooperative Canal company. and that said
deed reserved a lien upon said land. and upon
said stock. for the payment of said notes.
Plaintiff prays for Judgment for the full
amount Of its debt. principal. interest and Mt
turney's fees. for the foreclosure of its lien
against said land. and against said stock. and
for an order Of sale. writ ~ possession. costs
If court, and for general and special relief.
Herein fail not. but have before said court
1T its aforesaid next regular term. tins writ
with your return thereon. showing how you
have executed the same.
Given under my hand and the seal If the
said court ut office in Brownsville. this the 18th
day Of January. 1916.
tScali IDIIS NOW Al-Skl.
Clerk. District Court. Cameron County. Texas.