The Lexington intelligencer., 1921-01-21


JAMS, as appears by his will of record
IN book; ;...---:.--. page: In the pro
bate office for Lafayette County, Mis-
souri,; that Susan Jordan was the CON
fidential agent and adviser Of the plain-
tiff and attended to all of her busi-
ness affairs; that on the 9TH day OF
November, 1913, through the false
and fraudulent representations Of sTitS
Sarah Jordan and Elizabeth Se&fl
January, plaintiff was persuade, ijGt
induced to execute, in form pr,
tended deed of record in book 223 at
page 633, Recorders Office for Lafay-
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 S1.00 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, collusion 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 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
! furtherance 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-
Z tended deed of record and had the
same recorded in book 223 at page
/ 633, Recorders office for Lafayette
D County, Missouri. That said pretend
= ed deed states that
a 'ln conside alton of the sum Of
8 One Dollar ($100) and other good
: and valuable considerations to her
2 paid bv the said party Of the second
: part, the receipt of which is hereby
6 acknowledged" plaintiff sold anc
q conveyed the aforesaid described rea'
4 estate to the aforesid Elizabeth Su.
4 san January, when in truth and fact
a no consideration was ever paid by the
4 said Elizabeth Susan January to sai(
h plaintiff for said real estate, and tha
It said Elizabeth Susan January nevel
h performed the services agreed an'
+ never complied with her agreemen
" and that deed is therefore withou
= consideration and void. That salt
n Elizabeth Susan January died on O.
a about the 22nd day of December
a 1915, and left at the time Of her dealt
i. as her only children and heirs at law
4 Emison Grizzle and Ollie Reed, for
4 merly Ollie Grizzle; and that defend
"A ants are non-residents Of the Stat
~ of Missouri, or have absconded or ab
Il sented themselves from their usus
n place of abode in this State. Plain
h. tiff states that defendants claim som
ne title interest or estate in and to sal
IN real estate adverse to this estate, an
n title Of this plaintiff.
= Plaintiff further states that she ha
ne been in the open, adverse, notorious
pd hostile and lawful possession Of tn
te aforesaid described real estate, eve
~ since the 5th day of November, 1911
b and prior thereto, claiming It'll
n thereon and paying taxes on said rel
AZ estate, and that plaintiff has claim
M ed title to said real estate for the las
90 thirty (30) years or more and ha
ii been in the open and adverse possess
or ion Of said real estate during all {
,e said time;
NJ Wherefore, by reason of the prem
nd ses, plaintiff prays the Court to tr
cd ascertain and determine the estat
or tile and interest of the plaintiff ar
Of defendants, respectfully, in and to sa
s 4 real estate, to define and adjudge |
10 its Judgment and decree the title, e
~ tate and interest of the parties Sc
mt orally in and to the aforesaid desert
Iad ed real estate, and plaintiff prays q
NJ court to hear and finally determil
,he any and all rights, claims and inte
to ests, lien and demands whatsoever,
ed the parties or any Of them, concer
IN ing or affecting said real estate, al
% that the court will award full al
.ot complete relief, whether legal or G
M av uitable, to the parties herein and ca
~ Of them, according to the statutes
10 ~ such cases made and provided, and tn
IA said deed of record in book 223
az, 90 page 6S3, Recorders Office for I,afa
~ ette County, Missouri, be cancell
~ ~ set aside and declared void and u
ON ON the title to said real estate be dive
90 30 ed out Of defendants and vested
Iaft & plaintiff, and for all such other a
~ ~ further general relief as to the Coz
,ss may seem just and proper.
' ~ And you and each Of you are +
D. ther notified that unless you be 9
49, ~, appear &C this court at the next te
- hereof. to be begun and holden at