Brownsville herald. [volume] (Brownsville, Tex.) 1910-current, 1924-12-06
THE STATE Of x

To the Sheriff or any Constable OF
Cameron County-Greeting:.
You are Hereby Commanded to sum
mon j. T. Moffett, Marry Moffett and
w. H. Woolcock by making publica-
ton Of this Citation once in each
week for -four successive weeks prev
ious to the return day hereof,
in some newspaper published in your
County, to appear at the next regular
term Of the District Court Of Cameron
County, to be holden at the Court
House thereof, in Brownsville, on the
first Monday in January A.. D., 1925 the
same being the 5th day Of January A.
d. 1925, then and there to answer q
petition filed in said Court on the IND.
day Of De sfber A. ID. 1924. in a sult,
numbered IN the docket of said Court
No. COO wherein The James-Dickinson
Farm Mortgage Company is Plaintiff
and J. T. Moffett, Marry Moffett,
q. D. Lovelace and w. H. Woolcock
are Defendants, and said petition
alleging that on or about Septem-
Der %. 1920, W. H. Woolcock con-
viewed to j. T. and Marry Moffett,
certain land situated near Santa Ma
ria, Cameron County, Texas, described
as being a part of q 200 acre subdivl-
sion, generally known as the W. H.
Hurlburt Land and described by metes
and bounds as follows:
Beginning at a point and post for the
s. f. corner of this tract, which point
and post is the intersection OF the cent
er line of a road to the west with the
east line Of said W. II. Hurlburt land
and is One Thousand Two Hundred
Fourteen and Seven Tenths G214.7) feet
North Of and fifty seven and fave
tenth (57.5) feet East of an old Mes
auite post which is the Southwest corn
or of the W. H. Hurlburt land and IS
the Northeast corner of the W. I. Lew
IS Land; thence North with the East
line. of the W.. H. Hurlburt Land one
Thousand Eight Hundred Seventeen ana
Four Tenths C1817.A) feet to a point
and post for the Northeast corner OF
this tract: thence West One Thousand
Seven Hundred Ninety Seven and rive
.Tenths G797.5) feet to a point and post
for the Northwest corner of this tract;
thence South One Thousand Eight Hun
dred Seventeen and Fourt Tcnths
18174) feet to a point and post
for the Southwest corner OF thls tract
which point is in the center me o.
road East and West; thence East WIN
the center line Of said road "a distance
of One Thousand and Seven Hundred
Ninety Seven and Five Tenths tIf9'.o'
feet to the point of beginning, contain
inc Seventy Five (75) acres. more or
less which deed of conveyance from
Woolcock is recorded in Volume 20, az
, nogo 394-385. Deed Records Of Cameron
County, Texas. -
That as part of the puraches prlce
consideration J. T. and Mary Moffett
executed and delivered to WooicocK,
five first vendors lien notes, numbered
| Al TO AS inclusive, dated September -.
1920. each for the principal sum OF
$4,000. bearing interest at SIX per cent
from date until maturity. all past Que
nrincipal and interest bearing interest
at ten per cent; said notes containing
the usual accelerated maturity and at
torney's fees clauses, which said first
vendors lien notes were on September
%. 1920. in due course, before maturity
and without notice, Endorsed transferred
and delivered to this plaintiff and
this plaintiff is now the Legal and equit
able owner and holder 81 sald notes.
That as further consideration for said
land. the defendants, J. t. and MarrV
Noffett. executed and delivered to W.
II. Woolcock. five other second vendors
lien notes, inferior to the first describ-
ed notes. the lien securing same, each
for the principal sum of S85O.OO. dated
September %, 1920. numbered B1 to
RS inclusive. due and payable in one
to five years after date. with interest
at six per cent from date until maturity
oil past due principal and interest bear
ing interest at ten per cent, containing
the usual accelaretd maturity and at
torney's fees clauses, which notes this
nlaintiff is informed ard believes are
row owned and held by the defendant
C. d. Lovelace. by reason whereof. de
fendant Lovelace. is claiming some kind
or character of interest in said land.
Plaintiff ALLEGES, that ~byszreason Of
the fact that it is the owner and hold