Audubon County journal. (Exira, Iowa) 1884-1993, 1912-09-12

scription thereof as lot 2 of the
northwest quarter of the northwest
quarter of section ten township sew
enty eight, range thirty-fiye; that
subsequent thereto, about the year
1896, the said John P. Frost died
Iintestate, 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
Hesitate, 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 PhilMpsen, 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 John 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
pective spouses, and of the unknown
heirs, next of kin, legatees, deyi-
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 and under you,
the said defendants or through and
Iunder the said John P. Frost, John
Frost and Lydia A. Frost, his wife,
by reason of your relationship with
them, OF 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 un-
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 Bowdish and Ira Bowdish,
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 them, or
any other unknown claimant of all
or any part of the property in this
notice described, the'- names and
places oe residea. e are 10 the s..
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 in actual
visible, open, distinct notorious con-
tinuous, hostile adverse possession,
Iof oil of tho Drar,;eoe hora;, doc
cribed, commencing under claim OF
ownership and color Of title, for
> more than ten years last past. That
the matters and things as herein
E set out. create cloud upon plain
tiff's title to said premises.
! Wherefor Plaintiffs pray that their
I title and estate in and to the said
e northeast quarter of the northeast
: 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 seventy-eigh
range thirty-fiye, thence north 20
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, OF
under you, and by through and I'M
der John P. Frost, John Frost and
Lydia A. Frost, his wife, or either
: of them, be barred and forever
! estopped from claiming or having
g any right or title to said property
y adverse to the plaintiffs, and that
: the title thereto be quoted in the
: plaintiffs, and the cloud on theil
l title thereto removed