Brownsville herald. [volume] (Brownsville, Tex.) 1910-current, 1929-11-23
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and equitable title thereto " pea
ceable and adverse possession
thereof under and by virtue Of the
statues OF limitation OF this The
state Of Texas as follows:
"a. by virtue or and under the
statute OF three years Limitation
under title BY virtue of regular
chain OF transfer from and undar
sovereignty or the soil for more
than three years before their -ause
or action accrued herein.
r. by virtue OF and under the
statute or three years Limitation
under color OF title by consecutive
cnain OF title down 70 plaintiffs
Tor more than three years before
PLAINTIFFS cause OF action accrued
herein.
@. BY virtue or and under the
i've years static or Limitation.
having peaceble and adverse pos
session thereof. cultivating using.
and enjoying the same and paying
the taxes thereon, and Claiming
respectively under a deed and un-
der deeds duly regis red for more
than five years before their cause
OF action accrued herein.
u. BY virtue OF and under the
ten years statute or limitation
having peaceful and adverse nos
session thereof, cultivatinR. using
and enjoying the same for more
than ten years before plaintiffs
cause of action accrued he in.
III
That, although plaintiffs have
owned, held, used. cultivated ara
enjoyed the lot of land as above
alleged, defendants, in various
manners and at different times
have asserted and calimed rights.
titles or interests in the above
land, all Of which asserted claims
and each and every one or them.
are unfounded, void and Of no
force and effect whatever, but. al
though void, such claims have a
tendency To actually injure lain
Tits, the owners of the above land.
by throwing a suspicion on the
title and depreciaitng the market
value thereof, thereby hinderinr
and adversely affecting an advan-
tageouS disposition Of the same.
That, after diligent search and in
curry. plaintiffs are unable 70 as
certain the nature and extent of
delendants' claim and claims. but
plalnIltfS are OF the belief and 20
state the facts to be that such
claim or claims are by reason III
each and all the defendants be-
ing the original grantee OF de-
S~cendantS, or husbands or wives OF
descendants. or heirs, assigns ~
legal representatives OF descen-
dants. Or heirs on the original
grantee OF the san Pedro de Car
ricl-os' grant OF land in Cam
County, Texas, consisting of three
leagues. being Confirmation Num-
per z Of tine acts OF the Lerisla-
tuIe Of February 10. 1852. as shown
ln Gammel's Law OF Texas. Vol
TINE s. pages gu to 949, except.
however. that R. II. MAYHEM and
lis unknown heirs and leral re-
representatives. are made defendants
because or former ownership By r
~ Mayhem OF d judgmen. against
Ynocente g. REYES. which iudr-
M1nt Is for three hundred ana
flfty-one dollars and sixty cents
tS35l-60l plus interest ana costs
and IS distracted in Volume A
page l35 Abstract or judgment Re-
cords, Cameron County. Texas. but
ls nov long barred by the ten wear
statute Of limitation.
WHEREFORE. premises consid-
cred, plaintiffs pray that defen-
dants be cited to appear and an
swer herein In the manner ana
tlme provided by law; that plain
tiiIs recover Of and from defen-
dants, and or and from each "
them, the title 10 end the pos,ns-
SION Of the above land. and that
they have their writ oil restitution
therefor, II necessary; that thew
particularly have judgment ~ thr
Court 20 remove any and all cloud
from their title I'd the above land
and that they have relief general
ly.
TIE defendants. and each OF
them, will take notice that this
action is brought as well TO trv
title as for damages.
Herein Fail Not. but have he
fore said Court. at us aforesaid
next regular term, this writ with
your return thereon. showing how
you have executed the same.
Given Under Ny Hand and the
seal OF said Court, at office in
brownsville, Texas, this. the 18th
day Of November "A. ID. 1929.
SEAL
JNO. p. SCANLAN. Clerk
Dist. Court, Cameron County.
BY M. y. McTIERNAN.
Deputy.
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