Complaint,Petition: Tonka Girl, LLC vs. Town of Dennis Board of Assessors et al

On September 14, 2021 a Complaint,Petition was filed involving a dispute between Tonka Girl, Llc, and Dennis Conservation Land Trust, Lebel, Douglas W., Macgregor, J. Bruce, Our, Christopher W., Town Line, Llc, Town Of Dennis Board Of Assessors, for Equitable Remedies in the District Court of Barnstable County.

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SEP 14 2021
COMMONWEALTH OF MASSACHUSETT! Fi |
SUPERIOR COURT DEPARTMENT OF THE TRIAL|GOURT. / 2 NG

Barnstable, ss.
‘No. 2172 CV 3 U/
TONKA GIRL LLC,
Plaintiff

Vv.

TOWN OF DENNIS BOARD OF ASSESSORS,
TOWN LINE LLC, and DENNIS CONSERVATION
LAND TRUST,
Defendants

COMPLAINT FOR DECLARATORY RELIEF AND MANDAMUS

Introduction and Synopsis of the Case. Plaintiff is the owner of a parcel of vacant land
in the Town of Dennis, located about 700 feet southerly of the Mid-Cape Highway (Route 6).
The parcel contains slightly more than six (6) acres and is bounded on the east by the original
Harwich-Dennis town line. (The Legislature redefined the boundary line between the Towns of
Dennis and Harwich in 1945 and again in 1947). The 6-acre lot was once part of a much larger
parcel. The larger, 11-1/2-acre parcel is first identified in an 1806 deed, which deed was lost in
the fire in 1827, but was re-recorded after the fire.
The 11-1/2-acre parcel was purchased by E. Felderhof in 1894. Mr. Felderhof died
(intestate) in Florida in 1896 still owning the parcel. The Feldethof estate was probated in
Florida, but the Massachusetts real estate was not part of that proceeding. Probate proceedings
were not instituted in Massachusetts until 2018.
In 1971, the Town of Dennis took by eminent domain the southerly portion of the
Felderhof parcel, leaving only six acres in private ownership.
By dectee issued in September 2019; the Barnstable Probate and Family Court
authorizing the personal representative of the estate to sell the Felderhof lot at auction. The

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decree identified the parcel according to the description in the 1894 deed. This, of course, was
the parcel owned by Mr. Felderhof at the time of his death.
The auction was held on October 16, 2019. There were two bidders: the plaintiff and the
defendant, Town Line LLC. Both bidders were aware of the 1971 land taking and knew that
they were purchasing only what was left after the taking. Plaintiff was the high bidder at
$265,000. Plaintiff obtained and recorded its deed at the Barnstable Registry of Deeds on
November 13, 2019. Following customary procedure, the Register of Deeds forwarded a copy of
the recorded deed to the defendant, Dennis Board of Assessors.
Plaintiff subsequently had a full field survey of the Felderhof lot performed by a
registered professional land surveyor. The surveyor was able to locate several of the original
bounds, and through measurements in the deed, was able to accurately define the perimeter of
the lot. The surveyor then prepared a plan of the Felderhof lot in accordance with the standards
governing the survey of land. The plan showed the Felderhof lot as containing 6.035 acres
Plaintiff recorded the perimeter plan at the Registry of Deeds on March 13, 2020. Again,
following customary procedure, the Register of Deeds forwarded a copy of the recorded plan to
the Dennis Board of Assessors.
Plaintiff has been in exclusive possession of the Felderhof lot since November 13, 2019
Plaintiff has communicated with the Dennis Board of Assessors on numerous occasions since
that date, requesting that the Felderhof lot be assessed to the plaintiff.
In Count I of the complaint, plaintiff seeks relief in the nature of mandamus. Despite the
very clear nature of plaintiff's title‘and the equally clear boundaries of the 6.035-acre property,
the Board of Assessors refuses to assess the Felderhof lot to the plaintiff and refuses to provide
the plaintiff with the reason(s) for its refusal. Plaintiff, therefore, petitions this Court to order the
Board of Assessors to perform the clear-cut duty imposed by G.L. c. 59, § 11, i-e., to assess the
taxes on real property to the person or entity that appears as the owner of record as of January
first of each year.
The Board of Assessors has in the past assessed portions of the Felderhof lot to the
defendants, Town Line LLC and the Dennis Conservation Land Trust. Plaintiff has provided
title information to the Board of Assessors and its counsel which shows that those entities hold
title to parcels of land located elsewhere in the Town of Dennis. The Board has not indicated
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whether it has rejected the title information provided by the plaintiff, and if so, why.
The Board may respond to this complaint by stating that, even after almost two years, it is
unable to determine the true owner of the Felderhof lot. For this reason, plaintiff has named
Town Line LLC and the Dennis Conservation Land Trust as additional defendants. In Count II,
plaintiff seeks a declaratory judgment that neither of those entities is the owner of any portion of
the Felderhof lot, thereby eliminating any basis for the Board of Assessors to assess the
Felderhof lot to anyone other than the plaintiff.

‘The Parties .

1 The plaintiff, Tonka Girl LLC, is a Massachusetts Limited Liability Company
which was created on June 4, 2015. Plaintiff’s address is 15 Denwich Road, Harwich, MA
02645. Michael C. Escher is the manager of the LLC.
2 The defendant, Town of Dennis Board of Assessors, is a municipal body charged
with implementing G.L. c. 59, § 11 (assessment of taxes on real estate). Defendant’s address is
685 Route 134, South Dennis, MA 02660.
3 The defendant, Town Line LLC, is a Massachusetts: Limited Liability Company
which was created on January 13, 2016. Defendant’s address is 24 Great Western Road,
Harwich, MA 02645. Cristopher W. Our is one of four managers of the LLC.
4. The defendant, Dennis Conservation Land Trust (f/k/a Dennis Conservation
Trust), was created by a Declaration of Trust-dated February 27, 1988 and recorded in the
Barnstable Registry of Deeds in Book 6212, Page 96. Defendant’s mailing address is P.O. Box
67, East Dennis, MA 02641. Carole W. Bell is one of the founding members and trustees of the
Land Trust.

Material Facts Common to all Counts
5 Plaintiff's record title to the 6.035-acre “Felderhof lot”, and the defendants’ lack
of title to any portion of said lot, is based on the following facts.

Felderhof Lot (Record Title in Tonka Girl LLC)
6 On October 10, 1806, Smith Rogers of Dennis conveyed to Freeman Rogers of
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Dennis a parcel of woodland in Dennis containing eleven (11) acres more or less (1806 deed”).
This was a “warranty deed,” i.e., the deed contains full covenants of warranty as to the grantor’s
title. The 1806 deed was originally recorded in Book 69, Page 195. This book, and all others
but one, were destroyed in the fire at the Barnstable Registry of Deeds on October 27, 1827. The
deed was re-recorded in Dennis Book 1, Page 446. (Re-recorded deeds are found in the “Town
Books”).
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The description in the 1806 deed calls for the Dennis-Harwich town line as the
monument on the east. The is bounded northerly by Jonathan Bassett’s swamp; westerly by land
of Isaiah Nickerson; southerly by land of Samuel Chase.
8 The description in the 1806 deed, when considered in the light of titles to abutting
properties called for in the deed, provides a good starting point for purposes of both title and
location of the 11-1/2 acre parcel. Other information at the Registry of Deeds establishes the
location of the parcel as lying easterly of what was once known as “James Bassett’s Pond” and is
currently known as Eagle Pond. The land between the pond and the 11-1/2 acre parcel was
owned by Eleaser and Isaiah Nickerson; the land to the north of the 11-1/2acre parcel was owned
by Jonathan Bassett, and later by James Bassett; the land to the southeast of the 11-1/2 acre
parcel was owned by Samuel Chase.
9 Freeman Rogers died testate on July 19, 1892. His estate is probated in
Barnstable County as Case No. 10784. The inventory contains several parcels of real estate,
including the “Bassett’s Pond Lot.” The will-of Freeman Rogers contains:no devise of real
estate, but instead directs the executor to sell all real estate. Charles G. Baker was appointed
executor of the estate.
10. By deed dated September 4, 1894, the executor sold the Bassett’s Pond Lot to E.
Felderhof of Dennis following a public auction held on February 7, 1893. The deed is recorded
in Book 212, Page 542. (No first name appears in the deed; only the initial). The deed calls for
bounds and measurements that are quite precise. A copy of the Felderhof deed is appendedto
this complaint as “Exhibit A.”
11. E..Felderhof did not convey the Bassett’s Pond Lot to anyone prior to his death.
E. Felderhof died intestate on June 9, 1896. His estate is probated in the county of his residence,
DeSoto County, Florida, as Case No. 170. A search of Florida records produced no death
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certificate. (At the time, Florida did not require that death certificates be filed in any state,
county or municipal registry). The papers in the probate estate indicate that the decedent had no
known heirs. The Florida probate did not, and could not, include the Massachusetts real estate.
12. Pursuant to Article 34 of the 1971 Dennis annual town meeting, the Selectmen of
that town took by eminent domain 96.68 acres of land in South Dennis. The entire taking was
against “Owners Unknown.” The Order of Taking is recorded in Book 1504, Page 442. A
taking plan is recorded in Plan Book 244, Page 38. Although it was not known at the time of the
taking, the southerly portion of the Bassett’s Pond Lot was within the taking. The Bassett’s
Pond Lot was reduced in size by approximately 45%, leaving record title to approximately six
(6) acres in the Estate of E. Felderhof. (Henceforth in this complaint, the 6-acre “remainder”
parcel will be referred to as the “Felderhof lot”).
13. In 1945, the Massachusetts Legislature re-defined the boundary between the
Towns of Dennis and Harwich. (Chapter 599 of the Acts of 1945). Two years later, the
Legislature redefined a segment of the boundary line. (Chapter 372 of the Acts of 1947). Asa
result of this legislation, the town line was moved slightly to the east of its original location.
14. The alteration of the town boundary did not affect the boundaries of the Felderhof
lot. The easterly boundary line of the Felderhof lot remained at the location of the old town line.
The boundaries of parcels in Harwich which bordered the former town line also remained the
same, although the most westerly portion of those parcels was now in Dennis.
15. On June 17, 2015, the plaintiff purchased a parcel of land located predominantly
in Harwich from the Estate of Joseph W. Jones. This parcel was bounded on the west by the old
town line. The abutter on the southwest (on the Dennis side of the old town line) is identified in
the chain of title as Freeman Rogers.
16. After purchasing the above-mentioned parcel, plaintiff engaged an attorney to
conduct a title search of abutting parcels, and thereupon acquired the title information regarding
the Felderhof lot and other parcels in the vicinity.
17. Plaintiff obtained certified copies of the Florida probate and then reached out to
one of the public administrators in Barnstable County, Attorney Stuart W. Rapp. Plaintiff
provided the certified copies of the Florida probate and all its title information to the public
administrator and requested that he commence probate of the Felderhof estate in Barnstable
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County and obtain a license to sell the Felderhof lot at public auction.
18. On May 2, 2018, Attorney Rapp, acting in his capacity as public administrator,
commenced ancillary proceedings in Barnstable County by filing a petition for formal probate of
the decedent’s estate. The case was docketed as BA18P0669EA in Barnstable Probate and
Family Court. A decree and order of formal probate entered on July 25, 2018. Stuart W. Rapp
was appointed personal representative of the estate.
19. In order to.confirm the location and dimensions of the Felderhof lot prior to any
sale, Attorney Rapp retained the services of a professional land surveyor, Down Cape
Engineering, Inc.
20. On March 4, 2019, Down Cape Engineering, Inc. prepared a sketch plan for the
Estate ofE. Felderhof. (Exhibit B).
21. The plan prepared by Down Cape Engineering, Inc. shows the entire 11-1/2 acre
parcel that was conveyed to E. Feldethof by the executor of the estate of Freeman Rogers in
1894. The plan shows the southerly portion of that parcel which was taken by the Town of
Dennis in 1971. The plan shows the remainder parcel (i.e., the portion referred to herein as the
“Felderhof lot”).
22. The plan prepared by Down Cape Engineering, Inc. also shows that the easterly
portion of the Felderhof lot is claimed by one John M. Connors, and the westerly portion is being
assessed to the Dennis Conservation Trust.
~ 23. - On September 23, 2019, the Barnstable Probate and Family Court issued a
judgment and decree on the personal representative’s petition for sale of real estate. The court
authorized the personal representative to sell the parcel of land described in the 1894 deed into E.
Felderhof, this being the parcel that was owned by Felderhof at the time of his death. The sale
was ordered at private auction
‘on terms set forth in a previous order dated September 11, 2019.
(Exhibit C).
24. ” The auction was held on October 16, 2019. The only bidder other than the
plaintiff was the defendant, Town Line LLC. Plaintiff was the high bidder at $265,000. On
November 13, 2019, the personal representative executed and delivered a deed conveying the
Felderhof lot to the plaintiff. Plaintiff recorded the deed the same day in Book 32463, Page 220.
(Exhibit D).
25 Plaintiff then retained a professional land surveyor, East-Southeast, LLC, to
conduct a full field survey of the parcel described in the fiduciary deed, which included the
portion taken by the Town of Dennis in 1971, and the remainder portion, i.e., the Felderhof lot.
The survey plan was recorded in the Barnstable Registry of Deeds in Plan Book 684, Page 100
on March 13, 2020. (A reduced copy of the plan is appended hereto as Exhibit E).
26. Following customary practice, the Register of Deeds forwarded copies of the
plaintiffs deed and survey plan to the Dennis Board of Assessors.
27 Plaintiff was the sole owner of record of the Felderhof lot as of January 1, 2020
Plaintiff was the sole owner of record of the Felderhof lot as of January 1, 2021. Plaintiff
continues to be the sole owner of the Felderhof lot.
28 The Dennis Board of Assessors, however, refused to assess the Felderhof lot to
the plaintiff.

Plaintiff's Futile Efforts with the Board of Assessors
29 Beginning on or about January 8, 2020, plaintiff has communicated in writing on
numerous occasions with the Dennis Board of Assessors, the staff at the Assessing Dept., and
with Attorney Vicki Marsh at KP Law, the attorney that has handled this matter for the assessing
department. Attached hereto as Exhibits F, G and H are three of the letters which plaintiff's
counsel has sent to the Board of Assessors (exclusive of attachments).
30 No member of the Board of Assessors, nor anyone on the staff at the Assessing
Dept., nor anyone at KP Law, has responded to any of these letters.
31 The Board of Assessors refuses to assess the Felderhof lot to the plaintiff and
tefuses to provide any reason for its decision.

James Wixon Parcel (Paper Title Held by Town Line LLC)
32. By deed dated March 3, 1849 recorded in Book 44, Page 460, Alexander
Nickerson conveyed a parcel of land in Dennis containing fifive (5) acres more or less to James
Wixon (“James Wixon parcel”).
33 The James Wixon parcel abuts the town line with Harwich; however, the parcel is
located on the northerly side of the Mid-Cape Highway (Route 6). This is supported by an
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instrument of taking and plan prepared for Cape & Vineyard Electric Company in 1957. The
Order of Taking is recorded in Book 994, Page 413. The plan is recorded in Plan Book 139,
Page 47 (Sheet 3). The James Wixon parcel is identified in said instrument and plan as Parcel
19. (Exhibit I).
34. By deed recorded on August 30, 1961 in Book 1126, Page 424, Zebina C. Small
conveyed the James Wixon parcel to R. V. Robsham. (Exhibit J). (Zebina C. Small had
obtained various parcels of land from the heirs of James Wixon in 1926).
35. Following the death of R. V. Robsham, title to the James Wixon parcel passed to
his widow, Helene E. Robsham. Following her death, the Estate of Helene E. Robsham had a
plan prepared of the James Wixon parcel by R.J. O’Hearn, Inc. The plan is recorded in Plan
Book 420, Page 2 (“O’Hearn plan”).
36. The O’Hearn firm erroneously placed the James Wixon parcel on the southerly
side of the Mid-Cape Highway. (Exhibit K).
37. None of the abutters named in the deed into James Wixon match any of the
abutters called for in the 1806 deed from Smith Rogers to Freeman Rogers or the 1894 deed
from the estate of Freeman Rogers to E. Felderhof.
38. By quitclaim deed dated November 1, 2001 recorded in Book 14412, Page 2,
Beverly H. Robsham purported to convey the James Wixon parcel to John M. Connors, Jr. The
deed, however, describes the parcel according to the O’Heam plan.
39, - Neither-R. V. Robsham, Helene E. Robsham,or Beverly H. Robsham ever owned
the parcel of land shown on the O’Hearn plan. As a result, the grantee, John M. Connors, Jr.
obtained no interest in the parcel shown on the O’Hearn plan.
40. By deed dated May 28, 2019 recorded in Book 32049, Page 16, John M. Connors,
Jr. conveyed “all [his] right title and interest” in the parcel of land shown on the O’Hearn plan to
Town Line LLC. This deed contains no covenants whatsoever, and is.nothing more than a
release deed. (Exhibit L).
Al. Because John M. Connors, Jr. held no interest in the parcel of land shown ‘on the
O’Hearn plan, Town Line LLC acquired no interest in that parcel from Mr. Connors. Town Line
LLC has no other source of title.
42. The Dennis Board of Assessors continue to assess the parcel of land shown on the
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O’Hearn plan to Town Line LLC despite the fact that Town Line LLC holds no interest in that
parcel whatsoever.

Josephine Morgan Parcel (Paper Title Held by Dennis Conservation Land Trust)
43. By deed dated November 8, 1918 recorded in Book 367, Page 17, Herbert A.
Ryder conveyed to Josephine L. Morgan a parcel of land containing 1-3/4 acres more or less.
(Exhibit M). None of the abutters named in the deed into Josephine L. Morgan match any of the
abutters called for in the 1806 deed into Freeman Rogers or the 1894 deed into E. Felderhof.
44 By deed dated August 20, 2002 recorded in Book 15602, Page 72, Kathryn M.
Morgan conveyed to Jodie M. Barbour (f/k/a as Josephine F. Morgan) her one-half interest in
five parcels of land. (The parties appear to be the children of Josephine L. Morgan). The five
parcels together contained about four (4) acres. The third parcel in that deed is described as
containing 35 rods more or less, being a portion of the parcel described in Book 367, Page 17.
(Exhibit N). None of the abutters named in the deed into Jodie M. Barbour match any of the
abutters called for in the 1806 deed into Freeman Rogers or the 1894 deed into E. Felderhof.
45, By deed dated September 19, 2012 recorded in Book 26710, Page 112, Jodie M
Barbour gifted the parcel containing 35 rods to the Dennis Conservation Trust n/k/a the Dennis
Conservation Land Trust. (Exhibit O).
46. There is nothing in the records at the Barnstable Registry of Deeds that supports
the Dennis Board of Assessors” decision to locate the 35 rod parcel within the Felderhof lot as
the Assessors have done.

COUNT I - Mandamus Against the Dennis Board of Assessors
47. Plaintiff repeats and re-alleges the facts set forth in the preceding paragraphs.
48. By statute, real estate taxes shall be assessed by the city or town in which the land
lies to the person or entity appearing of record in the records of the county registry of deeds and
registry of probate as the owner on January Ist of each year. G.L. c. 59, § 11.
49. A board of assessors is charged with constructive knowledge of the records on file
with the county registry of deeds and registry of probate. In fact, as a matter of long-standing
9
practice, the Register of Deeds forwards all recorded deeds and plans to the assessors of the town
in which the land lies.
50 A board of assessors must use reasonable diligence to determine the owner of
record on January Ist of each year from these sources.
51 The defendant Board of Assessors is under a clear-cut duty to assess the Felderhof
lot to the plaintiff as the owner of record on January 1, 2020 and January 1, 2021. This is not a
matter of discretion.
52 The defendant Board of Assessors has repeatedly failed and refused to carry out
the legal duty imposed on it by G.L. c. 59, § 11
33. Plaintiff is entitled to an order of mandamus because (1) the Board’s duty is clear
cut; and (2) the plaintiff lacks any other adequate and effective remedy.

COUNT II — Declaratory Relief Against All Defendant:
34 Plaintiff repeats and re-alleges the facts set forth in the preceding paragraphs.
55 An actual controversy exists between the plaintiffs and the defendants regarding
the ownership, location and assessment of the Felderhof lot
56. An actual controversy exists between the plaintiffs and the defendants regarding
the location and assessment of the James Wixon and Josephine Morgan parcels
37 Declaratory judgment is an appropriate remedy to settle questions of property
rights. ‘The procedure set forth in G.L. c. 231A may be used to-secure determinations of right,
duty, status or other legal relations under deeds
38. Plaintiff has exhausted all means of administrative relief, and any further attempt
to obtain relief from the Board of Assessors would be futile.
59 Plaintiff has joined in this action all parties considered necessary for a full and
complete adjudication of the issues raised herein.
60. Plaintiff is entitled to a judgment declaring that (1) the plaintiff is the true and
sole owner of the Felderhof lot; and (2) the location and dimensions of the Felderhof lot are as
depicted on Plan Book 684, Page 100.

WHERFORE, plaintiff requests that the court enter judgment declaring that the plaintiff
10
is the true and sole owner of the Felderhof lot, and issue an order of mandamus directing the
Dennis Board of Assessors to assess the Felderhof lot to the plaintiff forthwith, and for such
other and further relief as is just and proper under the circumstances.

Plaintiff,

Peter S. Farber (BBO#544182)
P.O. Box 768
No. Chatham, MA 02650
(508).945-1200
peter.farber@comcast.net ;
Dated: September 14, 2021

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Case Info

Judge

Thomas J. Perrino Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

September 14, 2021

Case Filing Date

September 14, 2021

County

Parties

Daigle, Esq., Peter M Attorney for the Defendant
Dennis Conservation Land Trust Defendant
Farber, Esq., Peter S Attorney for the Plaintiff
Jackson, Esq., Travis C Attorney for the Defendant
Kwesell, Esq., Amy Elizabeth Attorney for the Defendant
Lebel, Douglas W. Defendant
MacGregor, J. Bruce Defendant
Our, Christopher W. Defendant
Stein, Esq., Robin Attorney for the Defendant
Tonka Girl, LLC Plaintiff
Town Line, LLC Defendant
Town of Dennis Board of Assessors Defendant
Michael Princi Attorney
David Rubin Attorney
Stuart Weitz Attorney

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