Brownsville herald. [volume] (Brownsville, Tex.) 1910-current, 1924-12-27
Legal Notices

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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 9Th day of January A.
d. 1925, then md there to answer a
petition filed in said Court on the End.
day Of December A. d. 1924. in a suit,
numbered on the docket of said Court
No. SAj4, wherein The James-Dickinson
PArm Mortgage Company is Plaintiff,
and J. T. Moffett, Marry Moffett,
c. d. Lovelace and W. II. Woolcock
are Defendants, and said petition
alleging that on Or about Septem-
Der %, 1920, w. II. Woolcock con
veyed to j.. 7. and Marry Moffett,
certain LAND situated near Santa Ma
ria, Cameron County, Texas, described
as being a part Of a 200 acre subdivi-
sion, generally known as the w. II.
Hurlburt Lane and described by metcs !
and bounds as follows:
Beginning at a point and post for the
S. E. corner of this tract, which point
and post is the intersection of the cent
CT Inc VI a lOdu l lHe WtSl Will bHc
east line of said W. H. Hurlburt land
and is One Thousand Two Hundred
Fourteen and Seven Tenths C1214.7) feet
North of and fifty seven and five
tenth (57.5) feet East Of an old Mes
quite post which is the Southwest corn
CT Of the W. H. Hurlburt land and is
the Northeast corner Of the w. G. Lew
is Land; thence North with the East
line of the w. H. Hurlburt Land One
Thousand Eight Hundred Seventeen and
Four Tenths (1S17.4) feet to a point
and post for the Northeast corner of
this tract; thence West One Thousand
Seven Hundred Ninety Seven and Five
Tenths GI97.5) feet to a point and post
for the Northwest corner of this tract;
thence South One Thousand Eight Hun
bred Seventeen and Fourt Tcnths
(1S114) feet to a point and post
for the Southwest corner Of this tract
which point is in the enter lire Of q
road East and West; thence East with
the center line of said road a distance
Of One Thousand and Seven Hundred
Ninety Seven and Five Tenths 0797.5)
feet to the point of beginning, contain
ing Seventy Five (75) acres. more or
lcSS HiN dccu VI conveyance lIOiI
Woolcock is recorded in Volume 90, at
! page 384-385, Deed Records of Cameron
County, Texas.
That as part Of the puraches price
consideration, J. T. and Mary Moffett
Executed and delivered TO Woolcock,
J five first vendors lien notes, numbered
Al to AS inclusive, dated September p,
1920, each for the principal sum Of
$4,000, bearing interest at six per cent
from date until maturity. all past due
principal 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 Of said notes.
That as further consideration for said
land, the defendants, j. t. and Marry
| Moffett, executed and delivered to W.
: H. WOolcock, five other second vendors
lien notes, inferior to the first describ-
ed notes, the lien securing same. each
for the principal sum of S850.00, dated
September %, 1920, numbered B. to
B-5 inclusive, due and payable in one
to five years after date, with interest
at six per cent from date until maturity
all past Que principal and interest bear
ing interest at ten per cent, containing
the usual accelaretd maturity and at
torney's fees clauses, which notes this
plaintiff is informed and believes, are
now owned and held by the defendant,
c. y. Lovelace, by reason whereof, de-
PENDANT Lovelace, is claiming some kind
or character of interest in said land.
Plaintiff alleges, that by reason of
the fact that it is the owner and hold
er of the first vendors lien notes, that
it holds a superior title to said land,
and that whatever right, title, interest
or equity, the defendants or either or
them may have, is inferior and subsery-
lent 10 the plaintiffs superior title and
vendors lien.
That notes Al 10 A-4 inclusive, are
past due and unpaid. and plaintiff prays
for judgment establishing its debt as
against the defendants, J. T. and Mary
Moffett, and establishing and foreclos-
ing it's vendors lien as against all de-
endantS on the above described land,
and for general and special relief, in
law an in equity, to which it may be
entitled.
Herein Fail Not. but have before sa'
Court, at its aforesaid next regular
term. this writ with your return there
on. showing how you have executed the
same.
Given under my Hand and the Seal
of said Court. at office in Brownsville,
this, the End day of December A. d..
1924.
q. 81
John Seaman
District Court. Cameron County,
A true copy | certify
John Scanlan
Clerk District Court. Cameron Co.,
Texas. Observation-Disclosures T