Nogales international., 1946-01-04
Defendants.
Civil Action No. 3745
SU MI MON S

above named defendants Mary Ellen
Farrell, and the Unknown Heirs of
Ainslie May Barrowdale, deceased,
and the Unknown Owners of an un-
divided portion of Lots Is and Is in
Block A and Lots and 10 in Block
B of Patagonia Townsite, in Santa
Cruz County, State of Arizona:
YOU ARE HEREBY SUMMONED
and required to appear and defend
in the above entitled action in the
above entitled court, within twenty
days, exclusive of the day of service.
after service of this summons upon
you if served within the State of
Arizona, or within thirty days, ex-
elusive of the day of service, if
served without the State Of Arizona,
and you are hereby notified that in
case you fail so to do, Judgment by
default will be rendered against you
for the relief demanded in the COM
plant.
The name and address of plain
tiff's attorney is James v. Robins,
212 Trust Building, Nogales, Arizona.
A brief statement of the nature of
the action, as set forth in plaintiffs
complaint, is as follows: That de-
fendant Mary Ellen Farrell is
minor over the age of fourteen
years; that the names of the un-
known heirs of Ainslie May Bar
rowdale are unknown to plaintiffs
and said unknown heirs are there
fore sued in this action, also, as the
unknown owners of an undivided
portion of Lots 13 and Is in Block
A and Lots and 10 in Block B of
Patagonia Townsite in Santa Cruz
County, Arizona, and that plaintiffs
are informed, believe, and allege
that the unknown owners of said
undivided portion of said land are
all minors under fourteen years of
age and that plaintiffs do not know
any of their names or places of resi-
dence. That plaintiffs are the own
ers in fee simple of an undivided
one hundred one one hundredth
eighth 101 108) interest in said
land and the improvements thereon
and are also the owners of an estate
during the life of Helen Farrell
Jeffcott of an additional one fifty
fourth Q/54) interest in said land.
That defendant Mary Ellen Farrell
is the owner of an undivided one
eighteenth Q/18) interest in said
land subject to said estate of plain
tiffs during the life of Helen Farrell
-Jeffcott. That the unknown heirs
of Ainslie May Barrowdale, deceas-
ed, sued in this action as Unknown
Owners of an undivided portion of
said land, are the owners of an un-
divided one one hundred eighth in
terest in and to said land. That the
estimated value of said land is
$3,00OO0 and that the plaintiffs and
defendants own said land as tenants
in common and are in possession
thereof. That there are no liens
or encumbrances on said land ap-
pearing of record and no persons
other than plaintiffs and defendants
are interested in said land. That
a fair partition of said property
cannot be made without depreciat-
ing the value thereof and that a
sale thereof is more beneficial to
the parties Plaintiffs pray for a
partition of said land or if a fair
and equitable division thereof can
not be made, or cannot be made
without depreciating the value, or
if sale is more beneficial to the
parties, that said land be sold and
the proceeds be divided between the
parties.
GIVEN under my hand and the
seal of the Superior Court of the
State of Arizona in and for the
County of Santa Cruz, this 18th day
Of December, 1945.
DOROTHY TITCOAGB,
Clerk.