Brownsville herald. [volume] (Brownsville, Tex.) 1910-current, 1929-11-29
c ADVERTISEMENT
lima, deceased; are Defendants. and
said petition alleging


lima, deceased; are Defendants, and
said petition alleging
That plaintiff is lawfully seized
and possessed IN his own proper
right Of Lot Z, Block 100, 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. i'm Volume 8, on page Is
thereof, said lot being rectangular
in shape, enclosed within parallel
lines and being fifty feet go it,
IN width and one hundred and
twenty feet In length u20 IT'D.
III.
That plaintiff is lawfully 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 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.
D. BY virtue OF and under the
statute OF three years limitation
under color OF title by consecutive
chain Of title down to plaintiff
for more than three years before
plaintiffs cause OF action accrued
herein.
G. BY virtue OF and under the
five years statute or limitation
having peaceahle 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 or action accrued herein.
ID. by virtue OF and under the
ten years statute OF limitation,
having peaceful and adverse pos
session thereof, Cultivating, using
and enjoying the sane for more
than ten years beofre plaintiffs
cause Of action accrued herein.
III.
That, although plaintiff has own
ed, held, used, cultivated and en-
Joyed the lot Of land as above al
legged, defendants in various man
ners and nc different times and
IN some instances by virtue or re-
corded instruments have asserted
and claimed rights, titles or In
terestS IN the lot above, all 0i
which asserted claims. and ZACH
and every one OF them are un-
founded. void and Of no force OF
effect whatever. but, although void
such claims have "a tendency tc
actually injure plaintiff, the own
er Of the lot, by throwing a sus-
picion on the title and d~epreciat-
ing the market value thereof, there
by hindering and adversely affect
ing an advantageous disposition
OF the same.
More specifically. this plaintiff
says that the defendants, Soste-
mos Cano de Saenz, in her indi.
vidual capacity and as admins
tratrix aforesaid, and Matte Wood
a widow, Rae Wood WeIder anr
husband. A. @. WeIder, Fl. G
Wood, j. 3. Wood. Southwest Bi
tulithlc Company, "a corporation,
Security State Bank OF San Juan
Texas. a anking corporation. ant
Mrs. Annette Natenson, a widow
are claiming or appear to be claiming
respectively. interest In the allow
lot for they appear to be rec0rl
owners and holc--s Of Judgment
distracted against "A. a.. Browne
but the true fact is that a. "A
Browne. the defendant In each AM
every Of said judgement, IS A. A
Browne, ST.. and the true fact 1
that IA. "A. Browne, Sr., at no tim
ever had any right. title. interest
claim or demand In or TO the abov