IN THE DISTRICT COURT IN AND FOR MCCURTAIN COUNTY

STATE OF OKLAHOMA

LUCIOUS CLARENCE CONWAY, JR. )

PLAINTIFF )
)
)
)
vs. ) Case No. _______________________
)
SAGACITY, INC., DAN LITTLE, indiv- )
idually and as incorporator, OTEKA )
LITTE, individually and as incorporator, )
BETTY MOORE, ALBERT STEWARD, )
ERMA MOODY, LUCILLE MOORE )
WILSON, MARTHA J. MOORE )
BLANCHE, CLEO MOORE, JR., )
OZZIE MAE, SMITH, JAMES H. )
JOHNSON, MAE H. JOHNSON, )
LILLIAN FORD, ALICE FAYE )
WARNER, CJ MOORE, MABEL )
GRAVES, OPHELIA WHALEY, )
FRANK NOLEN, JR., THEIR ASSIGNS )
OR SUCCESSORS IF LIVING; IF )
DECEASED, HIS OR HER HEIRS AND )
UNKNOWN HEIRS, AND ALL )
UNKNOWN CLAIMANTS OF )
INTEREST IN THE PREMISES )
ADVERSE TO PLAINTFF, )
DEFENDANTS. )

COMPLAINT TO QUIET TITLE TO REAL PROPERTY

FIRST CAUSE OF ACTION
COMES NOW LUCIOUS CLARENCE CONWAY, JR., PLAINTIFF, Pro Se and for his first
cause of action against the Defendants asserts and states as follows:
(1) That LUCIOUS CLARENCE CONWAY, JR., Plaintiff, is the owner of the following
described real estate, to wit: Real Property in the City of Eagletown, County of McCurtain, State of
Oklahoma, described as S ½ of S ½ of the SE ¼ and the S ½ of the N ½ of the S ½ of the SE ¼ –
Section 28, Township 6 South, Range 26 East, Containing 15 acres more or less. (Homestead Property).
Real property in the City of Eagletown, County of McCurtain, State of Oklahoma, described as South
two hundred and sixty feet (260 ft.) of the N ½ of the SE ¼ of the SE ¼ – Section 28, Township 6
South, Range 26 East, containing 8 acres more or less. This property is commonly known as HC 76
Box 54, Eagletown, Oklahoma (improved with single family dwelling/Homestead Property), by virtue
of Quit Claim Deed dated October 15, 2009, in Book 0822, Page 492 of the Register of Deeds in and
for McCurtain County, Oklahoma, January 5, 2010. See Exhibit A. Further, the Plaintiff is the owner of
the property by prescription and have acquired this land in excess of 15 years as required in 60 O.S.
Section 333 and 12 O.S. Section 93.
(2) That Plaintiff has possession of the property as described in paragraph one in this
complaint and did so by actual, open, hostile, continuous, and exclusive possession and in excess of the
15 years as required in 60 Oklahoma Statutes Section 333 and 12 Oklahoma Statutes Section 93.
(3) That Sagacity, Inc, Betty Moore, Albert Steward, Erma Moody, Lucille Moore Wilson,
Martha J. Moore Blanche, Cleo Moore, Jr., Ozzie Mae Smith, James H. Johnson, Mae H. Johnson,
Lillian Ford, Alice Faye Warner, CJ Moore, Mabel Graves, Ophelia Whaley, Frank Nolen, Jr., Their
Assigns or Successors if living; if deceased, his or her heirs and unknown heirs, and all unknown
claimants of interest in the premises adverse to Plaintiff, Defendants, are persons who claim or appears
to have some interest in, right or title, or lien upon the following described real estate or part thereof:
Real Property in the City of Eagletown, County of McCurtain, State of Oklahoma, described as S ½ of
S ½ of the SE ¼ and the S ½ of the N ½ of the S ½ of the SE ¼ – Section 28, Township 6 South,
Range 26 East, Containing 15 acres more or less. (Homestead Property). Real property in the City of
Eagletown, County ofMcCurtain, State of Oklahoma, described as South two hundred and sixty feet
(260 ft.) of the N ½ of the SE ¼ of the SE ¼ – Section 28, Township 6 South, Range 26 East,
containing 8 acres more or less. This property is commonly known as HC 76 Box 54, Eagletown,
Oklahoma (improved with single family dwelling/Homestead Property). The Plaintiff, by virtue of
tacking, has paid the property taxes for described property.
(4) That the Plaintiff has made due search and inquiry to ascertain whether each of the
individual Defendants herein above is living or dead, and if living, his or her place of business or
residence, and, if deceased, the names and places of residence of his or her heirs, but such information
is unknown or uncertain and cannot be ascertained by them. Plaintiff is credibly informed and believe,
and upon such information and belief assert, that each of such persons, if living, makes, or if deceased,
during his or her lifetime made; or if deceased, his or her unknown heirs now make, the claim asserted
in paragraph 2 hereof; and that such Defendants are made parties Defendant herein by name, if living;
if deceased, their unknown heirs, under the name and style as set forth in the title of this case, and that
constructive service of process only can be obtained upon them.
(4) That the claim of said Defendants to an ownership, interest in, right of title to, or lien
upon said real estate constitutes a cloud upon the title or interest of the Plaintiff.
 WHEREFORE, the Plaintiff prays judgment quieting and establishing their title to said real
estate against the Defendants and enjoining them and each of them forever from setting up or asserting
any interest in, right or title to, or lien upon said premises or any portion thereof. That Plaintiff further
prays that he be permitted to have service by publication upon all of the Defendants upon whom
personal service cannot be obtained, and for such other relief as may be just an equitable.

Respectfully submitted:
By: _______________________________
Lucious Clarence Conway, Jr. Pro Se
HC 76 Box 54
Eagletown, Oklahoma 74734
(580) 835-2358

AFFIDAVIT AND VERIFICATION

STATE OF OKLAHOMA )
) ss.
COUNTY OF MCCURTAIN )

Lucious Clarence Conway, Jr., being first duly sworn, upon oat, depose and state:

My name is Lucious Clarence Conway, Jr. I am the Plaintiff in the above captioned case. I have

read over, know and understand the contents of the foregoing Complaint, the statements therein are true
of my own knowledge, except those statements that are made upon information and belief, and as to
those, we believe them to be true.

___________________________________
Lucious Clarence Conway, Jr.

SUBSCRIBED AND SWORN to before me this ____ day of _________________, 2010 by

Lucious Clarence Conway, Jr.

____________________________________
Notary Public

SEAL My Commission Expires on the ____ of ___________________, ___________