Audubon County journal. (Exira, Iowa) 1884-1993, 1913-01-16
t.-rFV ? ~ = 9
either of you, or in some

y a
that about the year 1859, George
Cox Jr. became the owner of the
Least half of the southwest quarter
OF section eight, township IS, range
80, by purchase from one Robert
M Hubbard and wife, and that SUBJ
sequent thereto the said George
Cox Jr. died intestate, leaving sur
viving him, as his only heir-at-law,
his mother, Maria Cox; that sub
sequent thereto, about the year
SCI, the said Maria Cox died in
testate, leaving surviving her amons
other heirs, Mary c. Collins, and
the defendants Fanny Brodrick and
Henry H. Cox; that about the
year 1873, the said Mary c. Col
lins obtained a deed from H. H.
Cox and wife, of certain interests
OF the said H. II. Cox, in the land
formerly owned by the said George
Cox Jr., and that subsequent there
to, about the year 1880, the said
Mary c. Collins died intestate, lea
wing surviving her, as her only
heirs-at-law, the defendants, Annie
NJ. Craig and S. L. Craig, her hus-
band, Mary E. Collins, Lewis Col
films, Sue p. Collins, Val l. Collins
and Richard H. Collins; that plain
tiff is Informed and believes that
dot
some claim adverse to plaintiff, to
the premises herein described,
based and founded upon the pur-
lchase by said George Cox, Jr., of
the said east half of the southwest
quarter of section eight, township
IS, range "a, and that such claim
is derived by you, the defendants,
Henry H. Cox and Fanny Brodrick,
by reason of your being heirs
of Maria Cox, deceased, and by
fyou, the defendants, Annie N Craig
and S. l.. Craig, her husband, Mary
E. Collins, Lewis Collins, Sue p.
Collins, Val I. Collins and Richard
H.Collins through your mother Ma
ry c. Collins. deceased, by reason OF
the said Mary c. Collins being an
heir of Maria Cox, deceased, and
also by reason of the purchase
aforesaid from H. H. Cox and
wife, and that the claims OF your
Prospective spouses, and of the
unknown heirs, next of kin, lega-
tees, devisees, grantees and
assignees of you, the said defend
ants, and of George Cox Jr., Mary
c. Collins, Maria Cox and Alfred
Cox, and all persons claiming by,
through or under you, or them, to
said premises, are derived through
or under you, the SAID defendant:
or through and under the said
George Cox, Jr., Maria Cox, Alfred
Cox and Mary c. Collins, by reason
LOT their relationship with you OF
them, or in some other manner tc
this plaintiff unknown; that the
manner of derivation of the claim
if any, of any other unknown claim
ant of the said southwest quarter
OF section eight the northeast quar-
ter of the southeast quarter and
the east half of the east half of the
ISoutheast quarter of the south.
east quarter of section seven, al
in township rs, range So. is tc
this plaintiff unknown
And further alleging !has the
claims of each and all of you, the
descendants herein named and de
lsignated, are unfounded and ars
not valid in law nor equity. Tha,
each and all of the defendant,
herein named, are non-residents OF
, this state, and that if there arr
any unknown heirs, next of kin
legatees, devisees grantees OF
assignees of any of said defend
ants Or of George Cox Jr.
/ Maria Cox, Alfred Cox ant
Mary C. Collins, or eithe
. through or under them, or an,
ether unknown claimant of 81
or any part of the property herei1
! described. their names and place
9 lot residence are to this plaintiff
unknown, although he has sough
diligently to learn the same; tina
the plaintiff and those under whom
: he claims title, have been in &C
Z tual. visible, open distinct, notorious
continuous, hostile adverse pos
g session of all of the premi
{ ses herein described, commencin,
+ under claim of ownership and colo
I OF title, for more than ten year
4 last past, towit since about tn.