Audubon County journal. (Exira, Iowa) 1884-1993, 1913-01-23
either of you. or in some

eftner OF you, or In some other
manner to the plaintiff unknown.
And further claiming and alleging
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
81, by purchase from one Robert
M. Hubbard and wife, and that sub
sequent thereto the said Georges
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
1867, the said Maria Cox died in
testate, leaving surviving her amens
other heirs, Mary c. Collins, and
the defendants Fanny Brodrick and
Henry H. Cox; that about the
year 1879, the said Mary c. Col
Inns obtained deed from II. H.
Cox and wife, of certain interests
OF the said H. H. Cox, in the and
formerly owned by the said George
Cox Jr., and that subsequent there
Ito, about the year 1889, the said
Mary c. Collins died intestate, 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
Inns, Sue p. Collins, Val /. 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
rs, 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
you, the defendants, Annie NJ Craig
and S. L. Craig her husband, Mary
E. Collins, Lewis Co,lins, Sue P
Collins, Val 1. 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
respective 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
ICox, 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 G. Collins, by reason
of their relationship with you OF
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 half of thse
southeast quarter of the south
east quarter of section seven, az
in township 70, range 81, is te
this plaintiff unknown.
Andrfurther alleging thas thf
claims of each and all of YOU, the
defendants herein named and de
lsignated, are unfounded and ara
not valid in law nor equity. Tha,
each and all Of the defendants
. herein named, are non-residents, o,
, this state, and that if there arr
any unknown heirs, next of kin
begatees, devisees grantees o.
Iassignees of any Of said defend
tants or of George Cox Jr.
Maria Cox, Alfred Cox ant
Mary c. Collins, or either
through or under them, or any
other unknow,1 claimant Of 81
or any part of the property hefei1
, described, their names and places
of 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 ac
: tual, visible,open distinct, notorious
continuous, hostile adverse pos
session of all of the premi
: ses herein des ribbed, ccn,m.ncin,
: under claim of ownership and colo
. of title, for more than ten year