Manchester Democrat. [volume] (Manchester, Iowa) 1875-1930, 1901-11-06
Original Notice.
In the District Court Of Io,oa in ana
for Dez01Ca2e CO2t1lty,

In the District Court of IoUa in and
for Delaware County.
CHARLES FERGUSON. )Decem Der Term
ALEX. FERGUSON. ct al Original Notice.
To ALEXANDER FERGUSON. MRS. ALEXANDER
LEE,ARNoLD LEE,MRs.ARNoLDL LEE, WILLIAM
SITES, MRS. WILLIAM SITES, BENJAMIN BITES,
MRS. BENJAMIN SITES, ROSS SITES, MRS. ROSS
SITES. HENRY c. OSBORNE, MRS. HENRY 9.
OSBORNE, PETER CARTER MRS. PETER CAR
TER, ED CARTER. MRS. ED CARTER. JOHN CAR
TER, MRS. JOHN CARTER. DAVID CARTER.
GEORGE ARBEGUsT. ARyENA ARBEGUsT,
WILLIAM LEE, MRS. WILLIAM LEE, GEORGE
W. ANDREWS. Mrs; GEORGE w. ANDREWS,
LINs FERGUSON the Unknown Heirs of JOHN
LEE, the Unknown Heirs Of MARY LEE,
the Unknown claimants Of the east
southwest or. Xxi. of the southeast Xxi Of
s ssss sz tSMas 81 hs 1 III qGs ahs
that there s now on file In the office Of the Clerk
plaintiff. In which among other things he aieg-
es. thai he fs the absolute owner In fee Of the
east half thl Of the southeast Or Xxi, and the
section eleven tii1. township nlnety 1901, North
of range six [G]. west Of the 9Th P. M. and Of
every part and parcel thereof.
That he derives his title to said premises by
purchase from John Lee, Mary Lee. Collins
Ferguson, and George and Hannah Hebron and
by long continued possession and occupancy as
That deed made by John and Mary Lee, con-
yeying the south thirty-two acres of the south
east quarter of southeast quarter Of said section
eleven. to this plaintif does notappear of record
In the Recorders office Of said Delaware county,
and bas been lost and cannot now be found.
That the deeds executed by Nathaniel Hemp
PENDANT, George w. Andrews, for part of said
premises are null and void, and conveyed no
right, title or interest therein to either Of said
That the deed made by said John and Mary Lee
conveying eight acres Isl on the north side Of the
southeast quarter X Of southeast quarter[A l.
does not appear Of record in the recorders ' Of.
flee of said Delaware county and is lost and
cannot now be found.
ed. and the defendants, John Lee. James Lee,
and Arnold Lee are sons of said John and Mary
Lee, that the defendants William Sites, Beuja-
min Sites, Ross Sites, Henry G. Osborne, Peter
Carter, Ed Carter, George Carter, David Garter.
George Arbegust and William Lee are grand
sons Of said John and Mary Lee, and said Ar.
II there are other heirs Of said John and Mary
Lee now living their names and place OF resi-.
dence are unknown to the plaintiff. although.
he has caused dlligent search. and inquiry to be
made to ascertain same.
That he has caused diligent search and in
quiry to be made to ascertain whether the de-
tendants, Alexander Ferguson, Mrs. Alexander
Ferguson, Mrs. James Lee, William Lee, Mrs.
William Lee. or Mrs. Elisha Roe, or either Of
them are now living. and that the place Of resi-
dpnce or whereabouts of said defendants or
either of them, or the heirs of either of them,
are unknown to plaintiff and he cannot more
particularly describe said unknown defendants,
or the unknown claimants to said real estate.
than as stated In said petition.
That If the defendants, or any of them have
any right, title, interest In said real estate or
any part thereof, 1t is as heirs of said John and
Mary Lee or said Collins Ferguson.
That the plaintiff, and those under whom he
claims title to said real estate. now Is. and for
more than ten years last past has been In the
continued, undisturbed, actual, open, adverse,
exclusive, visible and notorious possession OF
thereof. under claim OF right or color Of title.
And the plaintiff asks that his title to said real
estate and every part thereof, be established
and confirmed against the adverse claims of the
defendants and each of them. their heirs and
assigns, and the unknown heirs of said Collins
Ferguson. and Maryland John Lee. and all un-
known claimants to said premises, and that
they, and each of them, and all persons claiming
by, through, or under them, or any of them be
barred and forever estopped from having or
claiming any right or interest In said premls es
or any part thereof, and that plaintiffs title to
all Of said real estate be quieted In him. aud for
such other and further relief as may be deemed
equitable In the premises.
And that unless you appear thereto and de-
fend on or before noon of the second day of the
next term of the District Court to be begun and
holden at Manchester. said Delaware county on
Monday the 10th day Of December, 1901. default
will be entered against you and Judgment and
dapran pndarad G