The Lexington intelligencer. [volume] (Lexington, Mo.) 1901-1949, 1921-01-28


Now this day comes the plaintiff, by ,
her attorney, and files her petition al ]
leging among other things that the
defendants, Emison Grizzle and Ollie
Reed are Mon-residents Of the State .
Of Missouri, or have absconded or abb
sented themselves IRON their usual
place Of abode in this State, where
upon it is ordered by the Clerk of
said Court in vacation, as follows: {
To the said Emison Grizzle and Oh
lie Reed, Defendants: You and each
Of you are hereby notified that the
plaintiff, Susan Williams Major, has
commenced a suit against you in this
court by filing her petition containing
two counts, the object and general ma
ture Of the first count of the plain
tiff's petition is to set aside and can
eel a deed executed by plaintiff on
November 5th, 1918, purporting to
convey unto Elizabeth Susan January
the following described real estate
situate and being in Lafayette
County, Missouri, to-wit:
All Of Lots three (3l, four ~,
five (5), and six (6) in Block thirty
five (35) Of the First Addition to the
City of Lexington, Missouri, except
eighty-seven $50 feet and four (4)
inches off the North ends Of said lots,
for the pretended consideration of
One Dollar ($1.O0) and other good
and valuable considerations, which
deed is of record in book 223 at page
633 Recorders Office for Lafayette
County, Missouri, and to which ref
erence is hereto made, and that the
said deed be declared to be a cloud
non plaintiffs title to the real estate
above mentioned and that the same
be set aside and declared void and for
naught held, and that the title to
said lots be Invested out OF the de-
PENDANTS and vested in the plaintiff,
and that the Court remove such cloud
from plaintiffs title and for all such
other and further general relief as
pertaineth to equity and good con-
science, on the ground that said pre-
tended deed was obtained from plain
tiff by the said Sarah Jordan and F.
lizabeth Susan January on Novem-
Der s., 1913, through false and fraud
ulent representations Of said Sarah
Jordon and Elizabeth Susan January,
and is without consideration and there
fore void; that Sarah Jordan was the
confidential agent and adviser of the
plaintiff. and that relying upon false
and fraudulent representations of said
Sarah Jordan and Elizabeth Susan
January, hat said deed was not to
be delivered nor recorded, plaintiff ex-
ecuted and acknowledged in form a
pretended deed of record in book 223
at page 633, Recorders Office for La
fayette County, Missouri, purporting
to convey unto the said Elizabeth SUI
san January all Of lots 8, 4, 5 and 6
in Block IS, First Addition to the
City of Lexington, Missouri, except
an feet A inches off the North end OF
said lots. for the false and pretended
consideration Of $1.00 and other good
and valuable considerations, and witt
the assurance that said deed was moi
10 be delivered to the said Elizabeth
Susan january nor recorded until at.
ter the death of the plaintiff and he
sister. at which time it was to be de
livered to the said Elizabeth SusaI
January provided she had compiled
with the terms Of the contract ant
agreement with the plaintiff and he
sister, Sarah Jordoh; that said Sa
rah Jordan and Elizabeth Susan Jan
uary colluded together, combined ant
conspired at and before the time the.
procured the execution Of said dee
An form to convey to said Elizabet
Susan January the aforesaid describ
ca real estate, to obtain the sam
without consideration and that l
of such combination, cor
spiracy, collision and fraudulent pun
nose. and by undue influence over tn
mind of said plaintiff, they deceive
her as to the purport and content
Of said instrument and thereby PR
cured her to execute the same by tai
ing advantage Of the faith and cor
hdence she reposed in her said siste
Sarah Jordan. and the said Ehzabet
Susan January; that in furtheran'
81 said conspiracy, fraudulent comb
nation and collusive scheme and II
the D of carrying out the sam
he said Sarah Jordan and Elizabei
Susan January, through false al
fraudulent representations, obtaln'
fossession Of said pretended Iced I
the purpose of placing the same
record, and that afterwards said de-
was placed of record by the said Eli
nheth Susan January and Sarah Jo
dan without the knowledge or conse
of the plaintiff. That said pretend
deed was without consideration, a.
that no money was ever paid by t
said Elizabeth Susan January
plaintiff, and no consideration pass
Aetween the said Elizabeth Susan ia
Nam to this plaintiff, for the afol
aid described real estate, and II
me said Elizabeth Susan January M
er complied with her agreement w
nlaintif and that said deed is the
iose without consideration and yo
and was obtained from plaintiff by n
sal Of false and fraudulent represen'
toms made to plaintiff by the s.
sarah Jordan and Elizabeth Sus
january that said Elizabeth Susan j
nary died December %, 1915, and ]
As der only heirs and children Ennis
Eiiazle and Ollie Reed, dCfendan
And plaintiff asks that said deed
record in book 223 at page 633,
t6fder's Office for Lafayette Cour
Missouri, be declared to be a ell
nron plaintiffs title and be set as
SID cancelled and the title. dives
tt 'of the defendants and vested
plaintiff.
You and each Of YOU are futher