Legal Notice

Legal Notice
In the common pleas court of
Coshocton County, Ohio
in the matter of
COMPLAINT TO QUIET TITLE BY OCCUPANCY IN ADVERSE POSSESSION AGAINST OWNER IN TITLE

Calvary Chapel, Inc.
843 Walnut Street
Coshocton, Ohio 43812
Plaintiff
vs
Coshocton Church of the Bible
Covenant, Address Unknown AND
St. Paul’s Anglican Church of Coshocton, aka St. Paul’s Anglican Church, nka
St. Paul’s United Episcopal Church,
Address Unknown
Defendant

Case No. 2018 CI 0229,
FIRST CAUSE OF ACTION
Plaintiff, Calvary Chapel, Inc.; is the owner of the real estate commonly known as 843 Walnut Street, Coshocton, Ohio 43812 and 1242 East Main Street, Coshocton, Ohio 43812, and more ‘particularly described in the deeds, attached hereto as Exhibit “A” and “B”.
The name of the last owner of record title of said real estate in the office of the Recorder of Coshocton County has been the Defendants and their predecessors in title from 1978 and 1975 through today.
The existence of the names of Defendants upon the records of the County Recorder and Auditor constitute clouds upon the title of the Plaintiff.
That both Defendants are unincorporated churches who transferred the above referenced properties without obtaining court approval as required under the Ohio Marketable Title. Act.
Plaintiff and its predecessors in title have been in undisputed, open, notorious, hostile, exclusive, adverse and continuous possession of said tract for a period greater than twenty­-one (21) years.
That Plaintiff and its predecessors in title have used said tracts without let, hindrance or obstruction from the Defendants or anyone else.
That said property has been used by Plaintiff and its predecessors in title without asking leave of the Defendants and without objection therefrom.
Plaintiff is unable to establish ownership of record to the above described real estate, although entitled to such ownership of record, without filing this proceeding.
Plaintiff is without an adequate remedy of law, other than this action, to quiet title and by similar relief in equity.
WHEREFORE, Plaintiff prays that the respective claims of the Defendants to said real estate be quieted against said Plaintiffs claims and be held void and for naught. That the Court find that Plaintiff has established, by adverse possession, ownership of said property and order the same transferred to its name. That the Court order copies of its entry concerning the title to be certified to the Treasurer, Auditor and Recorder of Coshocton County for transfer of ownership upon the tax duplicate, tax list .and for recording in the official records. That the Defendant be enjoined from asserting any claim to said real estate. That Plaintiff be accorded such legal and equitable relief as shall appear necessary and proper.
You are required to answer the Complaint within 28 days after the last publication of this notice which will be published once each week for three successive weeks. The last publication will be made on August 8, 2018 and the 28 days for answer will commence on that date.
In case of your failure to answer or otherwise respond as required by the Ohio Rules of Civil Procedure, judgement by default will be rendered against you for the relief demanded in the complaint.

James R. Skelton, Attorney for Plaintiff
309 Main Street, Coshocton, OH 43812
(Pub: CCB, Jul 25, Aug 1,8, 2018) #2018CI0229

Category: Legal Notices