The Lexington intelligencer. [volume] (Lexington, Mo.) 1901-1949, 1921-01-14

Jams, as appears by his win of record
IN hook. page. in the pro-
bate Office for Lafayette County. Mis-
souri,; that Susan Jordan wa the con-
hdential agent and adviser of the plain
TN and attended to all Of her bust
ness affairs; that on the 5th dav of
November, 1918, through the false
and fraudulent representations of said
Sarah Jordan and Elizabeth Susan
January, plaintiff was persuaded and
induced to execute, in form a pre-
tended deed of record in book 223 at
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 $l.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, conspira-
cy, collision and fraudulent purpose,
and by the exercise of undue influence
owe 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 26th day of November, 1918
through false and fraudulent state
ment and representation, did obtain
possession of said pretended deed and
thereafter, contrary to their said a.
greement not to use the same, and in
f~urtherance of their said conspiracy,
fraudulent combination and cOllusive
scheme, and in carrying out the same
in part without the knowledge or con-
sent Of the plaintiff, place said pre-
tended deed Of record and had the
same recorded in book 223 at page
633, Recorders Office for Lafayette
County, Missouri. That said pretend
ed deed states that
"ln consideration Of the sum Of
One Dollar ($1.00) and other gooc
and valuable considerations to her
rdld by the said party of the second
part, the receipt Of which is hereby
acknowledged" plaintiff sold anC
conveyed the aforesaid described rea'
estate to the aforesid Elizabeth Su.
a January, when in truth and fac
no consideration was ever paid by thu
said Elizabeth Susan January to salt
! plaintiff for said real estate, and tina
said Elizabeth Susan January nevei
a performed the services agreed AM
never complied with her agreemen
and that deed is therefore withou
consideration and void. That SAT-
Elizabeth Susan January died on o.
about the 22nd day Of December
1918, and left at the time of her dealt
as her only children and heirs at law
Emison Grizzle and Ollie Reed, for
merly Ollie Grizzle; and that defend
ants are ~non-residents of the Stat
! Of Missouri, or have absconded or alb
scented themselves from their usua
place Of abode in this State. Plain
tiff states that defendants claim som
, title, interest or estate in and to sal
, real estate adverse 20 this ectate, an
title of this plaintiff.
Plaintiff further states that she ha
/. been in the open, adverse, notorious
/ hostile and lawful possession Of tn
! aforesaid described real estate, eve
!. since the 9Th day of November, 1915
and prior thereto, claiming It'll
thereon and paying taxes on said res
estate, and that plaintiff has claim
+, ed title to said real estate for the las
. thirty 1901 years or more and ha
: been in the open and adverse possess
r ion Of said real estate during ali Q
said time;
|, Wherefore, by reason of the prem.
1 SEES, plaintiff prays the Court to tr.
i ascertain and determine the estat
: tile and interest of the plaintiff an
Z defendants, respectfully, in and to sal
1 real estate, to define and adjudge b
!. its Judgment and decree the title, e!
tate and interest of the parties sev
= orally in and to the aforesaid descril
i ed real estate, and plaintiff prays II
4 court to hear and finally determir
a any and all rights, claims and int
y ests, lien and demands whatsoever,
4 the parties or any of them, concert
ing or affecting said real estate, ar
that the court win award full ar
q complete relief, whether legal OF e.
uitable, to the parties herein and ea'
h of them, according TO the statutes
such cases made and provided, and tn
i said deed of record in book 223
page 633, Recorders Office for Lafa
cite County, Missouri, be cancelle
set aside and declared void and tn
y the title TO said real estate be dives
= ed out of defendants and vested
plaintiff, and for all such other al
y further general relief as to the Cou
may seem just and proper.
~ And you and each Of you are FL
! Their notified that unless you be a
: appear at this court at the next ter
y, beraof "a he hegun and holden at I