SUMMONS STATE OF INDIANA SS COUNTY OF KOSCIUSKO THE ESTATE OF ELSIE I. MODGLIN, Plaintiff vs. THE UNKNOWN BENEFICIARIES OF THE ELSIE I. MODGLIN REVOCABLE LIVING TRUST AND THE UNKNOWN TRUSTEE OF THE ELSIE I. MODGLIN REVOCABLE LIVING TRUST, Defendants IN THE KOSCIUSKO CIRCUIT COURT CAUSE NO. 43C01-1601-PL-11 This summons is to Defendants, the Unknown beneficiaries of the Elsie I. Modglin Revocable living trust and the Unknown trustee of the Elsie I. Modglin Revocable living trust, and to any other person who may be concerned. You are notified that you have been sued in the Kosciusko County Circuit Court, Kosciusko County, Indiana, in the above-entitled action, by the person named above as the Plaintiff. The named Plaintiff is the Estate of Elosie I. Modglin who can be contacted in care of its attorney William R. Wilkinson at 1200 S. Tillotson Overpass, Suite #1, Muncie, Indiana 47304, (765) 288-8980. The nature of this suit against you is to quiet title in favor of the Plaintiff to real property situated in Kosciusko County, Indiana, (hereinafter "real property"), more fully described as follows: A tract of Land 51.50 ft. containing .12 acres and shown on tax records as key #7-53-192 and shown location as NE 14-34-7 located in Kosciusko County, Indiana. SUBJECT TO ANY AND ALL EASEMENTS OF PUBLIC RECORD And A part of the Northeast Quarter of Section 14, Township 34 North, Range 7 East, in Kosciusko County, Indiana, more specifically described as follows: Commencing at the Southeast corner of the Northeast Quarter of Section 14, Township 34 North, Range 7 East; thence West 1405.0 feet along the quarter section line; thence North 31 degrees zero minutes West 660.0 feet thence North 17 degrees zero minutes East 400.0 feet to a stone marking the Northeast corner of Lot 8 in Sunset Beach (amended) said stone being the place of beginning; thence South 77 degrees 48 minutes East 92.0 feet to an iron pin; thence South 29 degrees 18 minutes east 10 feet more or less to the water's edge of a lagoon; thence Southerly on and along the water's edge of said lagoon 10 feet more or less; thence Southeasterly on and along the water's edge of said lagoon 455 feet more or less; thence Southwesterly on and along the water's edge of said lagoon 123 feet more or less to a point on the water's edge of a 40 foot boat channel; thence Northwesterly on and along the water's edge of said boat channel 276 feet more or less; thence Northerly on and along the water's edge of said boat channel 138 feet more or less; thence Northwesterly on and along the water's edge of said boat channel 104 feet more or less to a point on the water's edge which is South 17 degrees zero minutes west 54 feet more or less of the place of beginning; thence North 17 degrees zero minutes East 54 feet more or less to the place of beginning. SUBJECT TO ANY AND ALL EASEMENTS OF PUBLIC RECORD An answer or other response in writing to the complaint must be filed either by you or your attorney within 30 days after the third publication of this summons. If you fail to do so, judgment by default may be rendered against you for the relief demanded by the Plaintiff. If you have a claim for relief against the Plaintiff arising from the same transaction or occurrence, you must assert it in your written answer or response. Dated: January 25, 2016 Ann Torpy, Clerk Kosciusko Circuit Court Attorney for Plaintiff: William R. Wilkinson, ID #2076-48 UAW-GM Legal Services Plan 1200 S. Tillotson Overpass, Ste. 1 Muncie, IN 47304 (765) 288-8980 or (800) 263-6361 2-19, 26, 3-4 hspaxlp
