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

Molina and the unknown heirs
and legal representatives or Isabel
Molina, deceased; Rafael Molina de
Rivera, sometimes called and be-
Ing Rafael Molina de Reverb, and
the unknown heirs and legal rep
eSentatives Of Rafael Molina de
Rivera. deceased; ManaelR ~ ina
and the r-.known heI-- and legal
representatives Of Manuela Molina
deceased; Isabel Molina de Rem
don. and the unknown heirs and
legal -epre -entatives OF Isabel Mo-
lima de Rendon. deceased; Andrea
B~uenrostro de Mc---la and the un-
known heirs and legal representa-
tives OF Andrea B~uenroStro de Mo-
lima, deceased; are Defendants, and
said petition alleging
I.
That plaintiff "a lawfully seized
and possessed IN his own proper
right Of Lot z. Block $50, in the
city OF Brownsville, fin Cameron
County, Texas. as said lot and
block r mapped and plated and
appear OF record In the Map and
Plat Records OF Cameron County.
Texas. In Volume 5. on mage ~
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 ft.).
II.
That plaintiff Is law--lly seized
and possessed OF the above lot
holding and claiming the same In
fee-simple by a legal and record
title and color OF title; and that
plaintiff Is owner In fee-simple or
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 or 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
VI h|t4QA LCLAuCu LCACl4
3. BY virtue OF and under the
statute OF three years Limitation
under color OF title by consecutive
chain OF title down 70 plaintiff
for more than three years before
plaintiffs cause OF action accrued
herein.
g. BY virtue or 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 q deed and
under deeds duly registered for
more than five years before his
cause Of action accrued herein.
d. BY virtue OF and unce- the
ten years ~sfnt~-- OF limitation.
having peaceful and adverse pos
session thereof. cul14vating. using
and enjoying the same for more
than ten years beJfre plaintiffs
cause Of action accrued herein.
III.
That. although plaintiff has own
ed. held, used, cultivated and en-
ioyed the lot OF land as above al
legged, defendants In various man.
ners and at different times and
in some instances by virtue OF re-
corded instruments have asserted
and claimed rights, titles or in
tcrestS in the lot above. all OF
which asserted claims, and Oh
and every one or them are un-
founded. void and OF no force or
effect whatever, but, although void,
such claims have a tendency To
actually injure plaintiff, the own
or OF the lot, by throwing q sus-
picion on the title and ~depreciat-
ing the market vr'Ie thereof, there
by hindering and adversely affect
ing ar advantageous disposition
Of the same.
More specifically. this plaintiff
says that the defendants, Soste-
mos Cano de Saenz, III her indi-
vidual capacity and as admins
tratrix aforesaid. and Matte Wood.
=. a widow, Rae Wood Welder and
husband, "A. III. Welder, ii. O..
Wood. j. 3. Wood, EJuthwe. BIZ
tulithic Company, a corporation,
Security State Bank Of San Juan,
Texas, a mixing corporation, and
Mrs. Annette Natenson, a widow,
are claiming or appear to be claiming,
respectively, interest in the above
lot for they appear TO be record
owners and hol- s OF judgments
abstrac5ed against A. A. Browne.
but the true fact is that A. A.
Browne. the defendant IN each and
every OF said judgement. Is "a. IA.
Browne, Sr., and the true fact IS
that A. A. Browne, ST., at no time
ever had any right, title, interest,
claim or demand In or to the above
property. The 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 all the remaining
| defendants in this cause may as
sert In or to the lot in question
is BY virtue Of the fact that the
remaining defendants are. each
and all. heirs or related to heirs
Of Manuel Molina. deceased, and
or Of his former wife, Andrea Buen-
rostro de Molina. deceased, who
were prior owners OF this lot. The
family history, however, or these
defendants and their respective
relationships l. not been salts
factorily learned W this plaintiff
after diligerA search, investigation
and inquiry, but, so far as this
plaintiff Is informed and believes.
he has already acquired deeds OF
conveyance from all and singular
the heirs OF Manuel Molina and
his former wife. Andrea Buenros-
tr0 Gle Molina, both deceased.
WHEREFORE, premises c0nsid-
nrna nraus that dnfnn-