Brownsville herald. [volume] (Brownsville, Tex.) 1910-current, 1929-12-06

Z4
and legal representatives OF Isabel
Molina, deceased; Rafael Molina de
Rivera, sometimes called and be-
ing Rafael Molina &c Reverb, and
the unknown heirs and legal rep
e~sentatives Of Rafael Molina de
Rivera deceased; Manuela ~ ina
and the r--known he.-- and legal
representatives Of Manuela Molina,
deceased: Isabel Molina de Rem
don, and the unknown heirs and
legal repre- -entativeS Of Isabel Mo-
lima de Rendon. deceased; Andrea
BuenroStro Gle Mc--la and the un-
known heirs and legal representa-
tives Of Andrea B~usnroStro de Mo-
lima, deceased; are Defendants, and
said petition alleging
I.
That plaintiff is lawfully seized
and possessed IN his own proper
right Of Lot 7, Block $50. in the
city Of Brownsville, in Cameron
County, Texas, as said lot and
block are mapped and plated and
appear OF record in the Map and
Plat Records of Cameron County.
Texas, III Volume 8, on page l3
thereof, said lot being rectangular
in shape. enclosed within parallel
lines and being fifty feet $50 ft.)
In width and one hundred and
twenty feet IN length u20 IT,.
ii.
That plair.iff Is law--.lly seized
and possessed OF the above lot
holding and claiming the same in
fce-simple by a legal and record
title and color OF title; and that
plaintiff is owner In fee-simple Of
the above lot, holds legal and equi-
table title thereto In peaceable and
adverse possession thereof under
and BY virtue Of the statutes OF
limitation OF this state Of Texas
aS follows:
A. BY virtue Of and under the
statute OF three years limitation,
under title by virtue of regular
chain OF transfer from and under
sovereignty Of the soil for more
than three years before his cause
OF action accrued herein.
q. BY virtue OF and under the
statute Of three years limitation
under color of title by consecutive
chain or title down TO plaintiff
for more than three years before
plaintiffs aus Of action accrued
herein. W
g. BY virtue Of and under the
five years statute Of limitation
having peaceable and adverse pos
session thereof. cultivating, using,
and enjoying the same and pay
ing the taxes thereon, and claim
ing respectively under a deed and
under deeds duly registered for
more than five years before his
cause OF action accrued herein.
ID. BY virtue OF and un6e- the
ten years s+~+--- Of limitation,
having peaceful and adverse pos
session thereof. cul-.Eating, using
and enjoying the same for more
than ten years beofre plaintiffs
cause Of action accrued herein.
III.
That. although plaintiff has own
ed, held. used, cultivated and en-
j0yed the lot OF land as above al
legged, defendants III various man
ners and al different times and
in some instances by virtue OF re-
corded instruments have asserted
and claimed rights, titles or In
terests in the lot above. all of
which asserted claims. and On
and every one OF them are un-
founded. void and Of no force or
effect whatever. but, although void.
such claims have q tendency TO
actually injure plaintiff. the own
er Of the lot, by throwing a sus-
rici0n on the title and depreciat-
ing the market we thereof, there
By hindering and adversely affect
ing al advantageous disposition
OF the same.
More specifically, this plaintiff
says that the defendants. Soste-
mos Cano dc Saenz. In her indi-
yidual capacity and as admins
tratrix aforesaid. and Matte Wood.
la widow, Rae Wood Welder and
husband, al q. Welder, II. G..
Wood, j. .. Wood, Lyuthwe BIZ
tulithic Company, 8 corporation,
Security State Bank OF San Juan.
Texas. a mixing corporation. and
Mrs. Annette Natenson, q widow,
are claiming or appear to be claiming,
respectively, interest in the above
lot for they appear 20 be record
owners and hol- S Of judgments
a5strac.ed against A. "A. Browne,
but the true fact " that "A. IA.
Browne. the defendant In each and
every of said judgement, is a. A.
Browne ST., and The true fact Is
that "A. "a. Browne. Sr.. at no time
eve had any right. title. interest.
claim or demand in u to the above
property. Ihe further fact Is, how
ever. that "A. "A. Browne. Jr. here
tofore acquired title to and there
after conveyed the above property
to plaintiff herein.
The ownership, interest or claim
which each and al the remaining
defendants in this cause may as
sert in or to the lot III question
Is by virtue OF the fact that the
remaining defendants are, each
and all. heirs or related To heirs
az Manuel Molina, deceased, and
or Of his former wife, Andrea Buen-
rostro dc Molina, deceased, who
were prior owners OF this lot. The
family history, however, or these
defendants and their respective
relationships not been salts
factoriIv learned w this plaintiff
after diligen- search, investigation
and inquiry. but, so far as this
plaintiff Is informed and believes,
he has already acquired deeds or
conveyance from all and singular
the heirs OF Manuel Molina and
his former wife. Andrea BuenrOs-
tro de Molina, both deceased.
WHEREFORE, premises consid-
cred. plaintiff prays that defen-
aNm - NAmE - m@mmw 49, 49,