The Lexington intelligencer. [volume] (Lexington, Mo.) 1901-1949, 1920-12-31

~FFN"io Ny MS Will OF record
Door page in the pro- S
'ate once for Lafayette County. Mis-
ourl; that Susan Jordan was the con
ldential agent and adviser of the Main
IN and attended to all Of her bnsi-
less affairs; that on the 5th dav of
November, 1913, through the false
fraudulent representations of said {
sarah Jordan and Elizabeth Susan
January, plaintiff was persuaded and
nduced to execute, in form a pre-
.ended deed Of record in book 223 Mt
page 633, Recorders Office for Lafav-
cite County, Missouri, ~purporting to
convey unto the said Elizabeth Susan
January all Of the aforesaid described
real estate for the false and pretended
consideration of $1.00 and other good
and valuable considerations that said
deed was delivered to Chas. Lyons and
was to be held and retained by him
until the death Of the Plaintiff and the
death Of her sister, at which time it
was to be delivered to the said Eliz-
abeth Susan January, provided she
had complied with the terms Of the
contract and agreement with plaintiff
and her sister, Sarah Jordan; that
the said Elizabeth Susan January and
Sarah Jordan combined and conspired
at and before the time they procured
the execution Of said deed in form to
convey to the said Elizabeth Susan
January the aforesaid described real
estate, to obtain same without any con-
sideration whatever, and that in pur-
suance Of such combination, c%onspira-
cy, collision and fraudulent purpose,
and by the exercise of undue influence
over the mind of the plaintiff, they
deceived her as to the purport and
contents Of said instrument and there
by fraudulently procured her to ex-
ecute the same by taking advantage
Of her faith, trust and confidence
which she reposed in the said Eliza
beth Susan January and her sister, Sa-
rah Jordan; that afterwards, in fur
therance of their said conspiracy and
fraudulent combination and collusive
scheme, and for the purpose Of car
rying out the same, the said Sarah Jor-
dan and Elizabeth Susan January, on
the 10Th day of November, 1919
through false and fraudulent state.
ment and representation, did Obtain
possession of said pretended deed anC
thereafter, contrary to their said a
greement not to use the same, and IL
fu~rtherance of their said conspiracy
fraudulent combination and collusiv'
scheme, and in carrying out the sam,
. in part without the knowledge or con
sent Of the plaintiff, place said pre-
, tended deed Of record and had tn
same recorded in book 223 at pag
!, 633, Recorders office for Lafayett
, county, Missouri. That said pretend
!. ed deed states that
an conside alton Of the sum {
J One Dollar ($1.0O) and other goo
and valuable considerations to ne
!, 4 bv the said party of the secon
: part, the receipt Of which is herel
: acknowledged" plaintiff sold az
' conveyed the aforesaid described re-
= estate to the aforesid Elizabeth y
: san January, when in truth and Ia
! NO consideration was ever paid by u
\ said Elizabeth Susan January to 50
! nlaintiff for said real estate, and IN
= aid Elizabeth Susan January new
\ performed the services agreed al
! never complied with her agreeme
: and that deed is therefore witho
: consideration and void. That SO
Elizabeth Susan January died on
y about the 22nd day Of Decemb'
u 10t5. and left at the time OF her dea
q as her only children and heirs at Ia
i rmison Grizzle and Ollie Reed, Il
= merly Ollie Grizzle; and that deter
= ants are non-residents OF tne ou
If Missouri, or have %absconded or {
y tented themselves from their US
- Mace of abode in this State. Pa
q fif states that defendants claim SO
. title. interest. or estate IN and 70 8
y real estate adverse TO this estate
!" title of this plaintiff.
n plaintiff further states that she
r. heen in the open, adverse, notorio
hostile and lawful possession Oh
aforesaid described real estate, e
us since the 9TH day Of November Il
20 orf prior thereto, claiming I
N thereon and paying taxes on saiG
m estate. and that plaintiff has ela
al I;tle TO said real estate for inc
,tn thirty 1907 years or more anu
\; been in the open ano auNSisS al,
ION of said real estate during al
ue said time; The mrs
eth nIaint;ff prays the Court to
md oscertain and determine the es'
1ed lie and interest Of the plainSE II
for Attendants. respectfully, in and 70
OF uoaI estate. to define and adJnage
eed ~ indgment and decree the tltle'
liz and interest Of the parties
Ior- oroIlv in and to the aforesaid deSS
ent cd real estate, and plaintlh plsS
ded Court TO hear and finally oeseIl
and onv and all rights, claims Il
the a lien and demands w~hatsoeve
to IN narties or any Of them, tGaS
ised ~ pr affecting said real estatv'
Ian that the court will aware u y,
ore complete relief, whether I'd a
that ,;table, to the parties herein anu
iev- 70 tbem. according to the staVut'
With on.h cases made and provided, an mo
ere sa;d deed Of record in book ~
-oid, Sa,u sss' Recorders office for "
rea- pptte County, Missouri, be cane
nta- sot aside and declared VOID anG
said me title to said real estate D pos ~
isan Cle ~ Of defendants and Vestt
Jan e eq1ab,tif' and for all such o &O
left Pla, Sar general relief as to the
iison nav seem Just and proper. ora
lnts; mad YOU and each OF you arg
d OF ther notified that unless ny s next
Re- appear at this court at sle S !
inty hereof, to be begun and nOI1 "Yir