Audubon County journal. (Exira, Iowa) 1884-1993, 1912-09-19
said premises, but that through in


scription thereof as lot of the
northwest quarter of the northwest
quarter of section ten township sew
enty-eight. range thirty-five; that
subsequent thereto, about the year
1895, the said John P. Frost died
interstate, leaving surviving him, as
his only heirs at law, his widow,
Mary Jane Frost, and his parents,
John Frost and Lydia A. Frost.
That subsequent thereto, about the
year -, the said John Frost and
Lydia A. Frost, his wife, died in
testate, leaving surviving them as
their only heirs at law, their chill
dren, the defendants Mary Mount,
James Frost, Sarah Redell, Aman-
da Bowdish, Martha Dunn, Charles
Frost and Nora Phillipsen, and that
the plaintiffs are informed and be-
lieve that you, the above named de-
PENDANTS, make some claim adverse
to the plaintiffs to said premises,
based and founded upon the con-
,veyance aforesaid from John Frost
and wife, to uo.-da P. Frost and that
such claim is derived through the
said John P. Frost and through
John Frost and Lydia A. Frost, his
wife, as heirs of John P Frost,
by reason OF you being the chill
dren and heirs of the said John
Frost and Lydia A. Frost, his wife,
and that the claims of your res
pectiye spouses, and of the unknown
heirs, next of kin, legatees, devil
sees, grantees and assignees of each
of you, and of John p Frost, John
Frost and Lydia A. Frost his wife,
and all persons claiming by through
or under them, to said premises, are
derived through ard under you,
the said defendants or through and
under the said John P. Frost, John
Frost and Lydia A. Frost, his wife,
by reason of your relationship with
them, or either of them, or in some
other manner to these plaintiffs
unknown. And further alleging
that the claims OF each and all of
you. the defendants herein, are UNI
founded. and not valid in law nor
equity; that the defendants j. T..
Page and - Page, his wife, given.
name unknown, Mary Mount and
Harvey Mount, her husband, James
Frost and Nellie Frost. his wife.
Sarah Redell and Redell, her
husband. given name unknown.
Amanda BoMdish and Ira Rowdish,
her husband. Martha Dunn and
Clinton Dunn, her husband, and
Charles Frost, are non-residents of
this state, and that if there are
any unknown heirs, next of kin, leg
atees, devisees, grantees and as
signees of any OF said defendants,
or of John Frost and Lydia "A. Frost
his wife, or either of them, or of
John P. Frost, or any person claim
ing by. through or under then, or
any other unknown claimant of all
or any part of the property in this
notice described, the"- names and
places ~ reSidei q are 10 these
plaintiffs unknown, although they
have sought diligently to learn the
same. And further alleging that the
plaintiffs and those under whom
they claim title, have been liz actual
wis lot;
tinnous, hostile adverse possession,
of all of the premises herein des-
cribed, commencing under claim of
ownership and color of title, for
more than ten years last past That
the matters and things as herein
set out, create cloud upon plain
tiff's title to said premises.
Wherefor Plaintiffs pray that their
title and estate in and to the said
northeast quarter of the northe east
quarter of section nine, and the
tract of land Described as follows
towit: Commencing at the north
east corner of the southwest quar-
ter of the northwest quarter of sec
ton ten, township seyenty-eigbt,
range thirty-five, thence north 90
rods, thence west 80 rods, thence
south 20 rods, thence east 80 rods
to the place of beginning. all in
township seventy-eight, range thir-
ty-five. Audubon County, Iowa, be
established, against the adverse
claims of each and all of You, the
defendants herein. and that all
persons claiming by, through or
under you, and by through and un-
der John P. Frost, John Frost and
Lydia A. Frost, his wife, OF either
Of them. be barred and forever
estopped from claiming or having
any right or title to said property,
adverse to the plaintiffs, and that
the title thereto be Quoted in the
plaintiffs, and the cloud on their
title thereto removed