Audubon County journal. (Exira, Iowa) 1884-1993, 1913-02-06
either Of you, o. n some other
manner to they 1aintitf sunAncwn:s

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And further claiming and alleging
that about the year 1852. George
Cox il. became the owner of the
east hall OF the southwest quarter
Of section eight, township 70. range
"a, by purchase from one Robert
NJ. Hubbard and wife, and that sub
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
1867, the said Maria Cox died in
testate, leaving surviving her anon,
other heirs, Mary c: Collins, and
the defendants Fanny Brodrick and
Henry II. Cox; that about the
year 1879, the said Mary C. Col
Inns obtained 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 1880, 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 I. 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
70, range "a, and that such claim
is derived by you, the defendants,
Henry H. Cox and Fanny Brodrick,
by reason of i 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 1. Collins and Richard
II. 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
assignees of you, the said defend
ants, and of George Cox Jr., Mary
G. Collins, Maria Cox and Alfred
Cox, and Ell 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 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 half of the
southeast quarter of the south
east quarter of section seven, al
in township IS, range 81, is to
this plaintiff unknown
And further alleging that the
claims of each and all of you, the
defendants herein named and de-
signated, are unfounded and are
not valid in law nor equity. That
each and all of the defendants
herein named, are non-residents of
this state, and that if there are
any unknown heirs, next of kin,
Iegatees, devisees grantees or
assignees of any of said defend
ants or of George Cox Jr.,
Maria Cox, Alfred Cox and
Mary G. Collins, or either
through or under them, or any
other unknown claimant of ell
or any part of the property herein
described, their names and places
of residence are to this plaintiff
unknown. although he has sought
diligently to learn the same; that
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, commanding
under claim of ownership and color
of title, for more than ten years
last past, towit: since about the
year 1876; that the matters and
things as herein set out. create