Audubon County journal. (Exira, Iowa) 1884-1993, 1913-01-30
either of you, or in some other
ma manner TO the. laintifssAAknowns.;
fasl ax4aihid further caimin and alleging

4
that about the year 1859, George
Cox Jr. became the owner of the
east half of the southwest quarter
OF section eight. township IS, range
"a, by purchase from one Robert
M Hubbard and wife, and that sub
sequent thereto the said George
Cox .Jr died intestate, leaving sur
viving him, as his only sheir-at-law,
his mother, Maria Cox; that sub
sequert thereto, about the year
1867, the said Maria Cox died in
testate, leaving surviving her anon.
other heirs, Mary G. Collins, and
the defendants Fanny Brodrick and
Henry H. Cox; that about the
year 1879, the said Mary c. Col
Inns obtained a deed from H. H.
Cox and wife, of certain Interests
OF the said H. H. Cox, in the land
formerly owned by the said George
Cox Jr., and that subsequent there
to, about the year 1889, the said
Mary c. Collins died interstate, lea
wing surviving her, as her only
heirs-at-law, the defendants, Annie
M. Craig and S. l.. Craig, her hus-
band, Mary E. Collins, Lewis Col
i Inns, Sue P. Collins, Val 1. Collins
and Richard H. Collins; that plain
| tiff is informed and believes that
you, the said defendants, make
some claim adverse to plaintiff, to
| the premises herein described,
based and founded upon the pur-
chase by said George Cox, Jr., of
the said east half of the southwest
quarter of section eight, township
7S, range 81. 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
you, the defendants, Annie NJ 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 G. 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
respective spouses, and of the
unknown heirs, next of kin, lega-
tees, devisees, grantees and
assig nees 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 defendants
or through and under the said
George Cox, Jr., Maria Cox, Alfred
Cox and Mary c. Collins, by reason
of their relationship with you or
them, or in some other manner to
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 halt of the
southeast quarter of the south
east quarter of section seven, az
in township IS, range 81, is t.
Ftrhis plaintiff unknown
And further alleging !ha1 The
claims of each and all Of you, the
defendants herein named and de
lsignated. are unfounded and arr
not valid in law nor equity. Tha
each and all of the defendant
. herein named, are non-residents o
this state, and that if there ar
any unknown heirs, next of kin
Iegatees, devisees grantees O
assignees of any of said defend
ants or of George Cox Jr
/. Maria Cox, Alfred Cox an
Mary c. Collins, or eithe
through or under them, or an
other unknown claimant of G
or any part of the property herei
described, their names and place
of residence are to this plainti1
unknown, although he has sougl
diligently toalearnA the same; tn;
the plaintiff and those under whol
:. he claims title, have been in a
= tual, visible,open distinct, notoriou
continuous, hostile adverse pc
session of all of the prem
: ses herein described, conmencir
:. under claim of ownership and COLI
:. of title, for more than ten yea
last past, towit: since about IL
year 1876; that the matters al
things as herein set out, crea