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

ed real estate; that said real estate
was devised to plaintiff in the year
Of ... by her father, Thomas Will
as appears by his viii Of record
IN book page in the pro-
bate Office for Lafayette County, Mis-
souri,; that Susan Jordan was the con-
fdential agent and adviser Of the plain
tiff and attended to all Of her bust
ness affairs; that on the 9th day 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 Lafay-l
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, conspira-
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 26th day Of November, 1913
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 ir
/ fur%therance of their said conspiracy
!. fraudulent combination and collusivt
/. 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 tn
same recorded in book 223 at pag,
! 693, Recorders Office for Lafayett
, County. Missouri. That said pretend
: ed deed states that
a Elm consideration Of the sum 0
One Dollar ($1.00) and other goo
: and valuable considerations to he
p raid bv the said party of the seconI
: part, the receipt of which is hereb.
& acknowledged" plaintiff sold an
e conveyed the aforesaid described req
t estate to the aforesid Elizabeth Su
( san January, when in truth and fac
4 no consideration was ever paid by tn
4 said Elizabeth Susan January to sal
h plaintiff for said real estate, and tina
t said Elizabeth Susan January neve
h performed the services agreed an
! never complied with her agreemer
r. land that deed is therefore withol
consideration and void. That sal
n Elizabeth Susan January died o n (
ID about the 22nd day of Decembe
d 1915, and left at the time Of her deaf
r. as her only children and heirs at lay
A. Emison Grizzle and Ollie Reed, TO
merly Ollie Grizzle; and that defenI
n ants are non-residents of the Sta
~ of Missouri; or have absconded or a
a scented themselves from their usu
N place of abode in this State. Plat
tiff states that defendants claim son
40 title, interest or estate in and to sa
IN real estate adverse to this estate, al
n title of this plaintiff.
r Plaintiff further states that she h
ha been in the open, adverse, notori0t
Cd hostile and lawful possession of t
he aforesaid described real estate, ev
~ since the 9TH day Of November, 19l
k and prior thereto, claiming til
M thereon and paying taxes on said re
az estate. and that plaintiff has clail
NJ ed title to said real estate for the Ia
90 thirty 1907 years or more and h
hi been in the open and adverse posses
ion Of said real estate during all
ne. said time;
NJ Wherefore, by reason Of the prer
nd SEES, plaintiff prays the Court to t
cd ascertain and determine the esta
title and interest Of the plaintiff a
If defendants, respectfully, in and to ST
.ed real estate, to define and adjudge
H. its Judgment and decree the title,
or tate and interest Of the parties S
orally in and to the aforesaid descT
led ed real estate, and plaintiff prays
md court to hear and finally determ
any and all rights, claims and int
10 ests, lien and demands whatsoever,
the parties or any Of them, conce
ing or affecting said real estate,
20 that the court will award full
ho+ complete relief, whether legal or
uitable, to the parties herein and e
Of them, according to the statutes
We such cases made and provided, and I
n;J said deed of record in book 223
'ae page 633, Recorders Office for Lad
cite County, Missouri, be cancel
Ia set aside and declared void and
the title to said real estate be div
ed out Of defendants and vested
la plaintiff, and for all such other
'Sor further general relief as to the c.
&c. may seem just and proper.