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Filing # 79306345 E-Filed 10/15/2018 09:42:09 AM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
MIAMI-DADE COUNTY, FLORIDA
CIRCUIT COURT
CHRISTOPHER MANSON,
Plaintiff, Case No. 17-027479 CA 23
Vv.
CHARLES M. STIWALT, HIS HEIRS AND ALL
PERSONS CLAIMING ANY LEGAL
OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN,
OR INTEREST IN THE PROPERTY DESCRIBED
IN THE COMPLAINT ADVERSE TO PLAINTIFF'S
TITLE, OR ANY CLOUD ON
PLAINTIFF'S TITLE THERETO,
Defendants.
/
MOTION FOR SUMMARY JUDGMENT
Plaintiff, CHRISTOPHER MANSON, by and through the undersigned
counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure,
respectfully moves this Court to enter summary judgment on his behalf and against
Defendants in the above-styled cause because the record in this case conclusively
shows that there is no genuine issue of material fact and Plaintiff is entitled to
Summary Judgment as a matter of law. In support of this Motion, Plaintiff relies on
the interrogatories, pleadings, and affidavits filed with, or to be filed with, the Court,
and Plaintiff states as follows:
UNDISPUTED FACTS1. Plaintiff, CHRISTOPHER MANSON, is the owner by adverse
possession, with color of title, of real property located in Miami-Dade County,
Florida and more specifically described as:
Lot 7, Block 5, NORTH SILVER CREST ADDITION,
according to the Plat thereof, recorded in the Plat Book 17, Page
38, of the Public Records of Miami-Dade County, Florida.
Parcel Identification Number: 30-2135-020-1020
See attached Exhibit 1, Affidavit of Christopher Manson, p. 1-2.
2. For a full seven-year period, Plaintiff has been in possession of all real
property described above by actual, open, hostile, continuous, and exclusive
possession, and the property has been usually cultivated and improved and Plaintiff
has used the property for his own use. See attached Exhibit 1, Affidavit of
Christopher Manson, p. 1-2.
3. Plaintiffs possession has been actual, open, hostile, continuous, and
exclusive since December 22, 2006, in excess of the seven (7) year period set forth
in Florida Statutes 95.16 (2017). See attached Exhibit 1, Affidavit of Christopher
Manson, p. 2.
4. Plaintiff has been in possession of the above real property as described
in a warrant deed issued on or about December 22, 2006 and recorded in Book
25265, Pages 4844-4845, of the Public Records of Miami-Dade County, Florida.See attached Exhibit 2, Warranty Deed to Christopher Manson. Plaintiff is an
arms-length bona fide purchaser of the property. See attached Exhibit 1, p. 2.
5. Plaintiff has been in continuous possession during the seven-year
period, adverse to Defendants and to all other persons. See attached Exhibit 1,
Affidavit of Christopher Manson, p. 2.
6. Plaintiff has paid all taxes and assessments that have been levied or
assessed against the real property described above during a seven-year period
beginning in 2006. See attached Exhibit 1, Affidavit of Christopher Manson, p.
2.
ADVERSE POSSESSION WITH COLOR OF TITLE
7. Section 95.16, Florida Statutes, provides as follows:
95.16 Real property actions; adverse possession under color of
title —
(1) When the occupant, or those under whom the occupant claims,
entered into possession of real property under a claim of title exclusive
of any other right, founding the claim on a written instrument as being
a conveyance of the property, or on a decree or judgment, and has for 7
years been in continued possession of the property included in the
instrument, decree, or judgment, the property is held adversely. If the
property is divided into lots, the possession of one lot shall not be
deemed a possession of any other lot of the same tract. Adverse
possession commencing after December 31, 1945, shall not be deemed
adverse possession under color of title until the instrument upon which
the claim of title is founded is recorded in the office of the clerk of the
circuit court of the county where the property is located.
(2) For the purpose of this section, property is deemed possessed in
any of the following cases:
(a) When it has been usually cultivated or improved.(b) When it has been protected by a substantial enclosure. All land
protected by the enclosure must be included within the description of
the property in the written instrument, judgment, or decree. If only a
portion of the land protected by the enclosure is included within the
description of the property in the written instrument, judgment, or
decree, only that portion is deemed possessed.
(c) When, although not enclosed, it has been used for the supply of
fuel or fencing timber for husbandry or for the ordinary use of the
occupant.
(d) When a known lot or single farm has been partly improved, the
part that has not been cleared or enclosed according to the usual custom
of the county is to be considered as occupied for the same length of time
as the part improved or cultivated.
8. Plaintiff satisfies all requires of section 95.16 in that he possesses a
written instrument conveying title to the real property located in Miami-Dade
County, Florida and more specifically described as:
Lot 7, Block 5, NORTH SILVER CREST ADDITION,
according to the Plat thereof, recorded in the Plat Book 17, Page
38, of the Public Records of Miami-Dade County, Florida.
Parcel Identification Number: 30-2135-020-1020
See attached Exhibit 2, Warranty Deed to Christopher Manson.
9. Additionally, for a full seven-year period, Plaintiff has been in
possession of the real property included in the instrument by actual, open, hostile,
continuous, and exclusive possession, and the property has been usually cultivated
and improved and Plaintiff has used the property for his own use.10. Defendant, CHARLES M. STIWALT, and his unknown heirs have
been served through constructive service, which was completed on or about July 6,
2018. See attached Exhibit 3, Proof of Publication.
11. On or about June 8, 2018, this Court entered an Order Appointing
Guardian ad Litem to represent the unknown heirs and descendants of Charles M.
Stiwalt, who is deceased.
12. On or about July 9, 2018, the Guardian ad Litem, David Aischuler,
Esq., filed a GAL Report, Answer, and Affirmative Defenses. See attached Exhibit
4, GAL Report, Answer, and Affirmative Defenses. In the GAL Report, Attorney
Aischuler notes that on March 7, 1964, Charles M. Stiwalt executed a quit claim
deed conveying the subject property to J.H. Keathley. See attached Exhibit 5,
March 7, 1964 Quit Claim Deed between Stiwalt and Keathley. Mr. Aischuler
then suggests that the unknown heirs and descendants of J.H. Keathley may have an
interest in the property. See Exhibit 4, at 5.
13. Inthe GAL Report, Mr. Aischuler also notes that four years after his
death, Charles M. Stiwalt purportedly executed a quit claim deed conveying the
subject property to Vincent McKnight. See attached Exhibit 6, Quit Claim Deed
between Stiwalt and McKnight. Vincent McKnight is the person who later
transferred the property to Plaintiff Christopher Manson. Mr. Aischuler argues that
the quit claim deed between Stiwalt and McKnight was fraudulent.14. In the Answer, Mr. Aischuler admits all matters of record and asserts
that he is without knowledge and therefore denies all other allegations in the
Complaint.
15. As to affirmative defenses, Mr. Aischuler asserts that Plaintiff cannot
quiet title in his name “without amending the Complaint or otherwise adding the
UNKNOWN HEIRS AND DESCENDANTS OF J.H. KEATHLY, DECEASED, as
a party defendant.” See attached Exhibit 4, GAL Report, Answer, and
Affirmative Defenses, p. 5.
16. The issues raised in the Answer and Affirmative Defense do not bar
summary judgment here.
17. Mr. Aischuler has overlooked that, on or about April 13, 1964, J.H.
Keathley issued a Warranty Deed to Charles M. Stiwalt, which is recorded as Book
4116, Page 233, of the Public Records of Miami-Dade County, Florida. See
attached Exhibit 7, April 13, 1964 Warranty Deed between J.H. Keathley and
Charles M. Stiwalt. Thus, any interest that JH. Keathley obtained through the
March 7, 1964, quit claim deed from Charles M. Stiwalt was conveyed back to Mr.
Stiwalt through the April 13, 1964, warranty deed. For this reason, the unknown
heirs of J.H. Keathley have no interest in the subject property.
18. Additionally, in December 2006, Plaintiff Christopher Manson
purchased the property from Vincent McKnight in an arms-length transaction.Plaintiff Manson believed that Mr. McKnight legitimately owned the property, and
he had no reason to doubt the validity of Mr. McKnight’s ownership. See attached
Exhibit 1, p. 2. Plaintiff paid a fair market price of $60,000 for the property, and
the property was sold through a normal real estate closing. See attached Exhibit 8,
Closing Statement and Check. A deed transferring the property to Plaintiff
Manson was recorded in the public records. See attached Exhibit 2, Warranty
Deed to Christopher Manson.
19. Under Florida law, Plaintiff Christopher Manson qualified as a bona
fide purchaser, and since his deed was recorded, he can assert rights to the property
against the true owner, even without considering the issue of adverse possession.
See Hull v. Maryland Casualty Co., 79 So.2d 517 (Fla. 1955) (holding that the true
owner is estopped to assert his title against bona fide purchasers who rely upon the
record and are without notice of the interest of the true owner); Demosthenes v.
Girard, 955 So.2d 1189, 1192 (Fla. 3d DCA 2007) (noting that to be a bona fide
purchaser, three conditions must be satisfied: the purchaser must have (1) acquired
the legal title to the property in question, (2) paid value therefore, and (3) been
innocent of knowledge of the equity against the property at the time when
consideration was paid and title acquired).
20. However, even if Plaintiff Christopher Manson had been aware of the
fraud, which was not the case, such knowledge would not invalidate his claim foradverse possession. Plaintiff Manson’s deed placed all persons on notice of his
interest in the property, and for a period of seven years, Plaintiff Manson paid the
property taxes and complied with all other requirements of section 95.16.
Accordingly, Plaintiff Manson took the property by adverse possession, and he is
entitled to a judgment in his favor determining that he is the legal owner of the
subject property.
WHEREFORE Plaintiff, CHRISTOPHER MANSON, respectfully requests
that this Court enter summary judgment in his favor and determine that he is the
legal owner of the subject property and grant such further relief as this Court deems
just and proper.
Submitted this 15th day of October, 2018.
/s/Henry G. Gyden
Henry G. Gyden, Esq.
Florida Bar No.: 158127
GYDEN LAW GROUP, P.A.
1228 East 7" Ave.
Suite 200
Tampa, Florida 33605
Telephone: (813) 493-4181
Facsimile: (813) 337-0244 FAX
hgyden@gydenlaw.com
Attorney for PlaintiffCERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 15th day of October, 2018, the foregoing
was served through the Florida e-portal to the following:
David Alschuler, Esq.
David Alschuler, P.A.
6538 Collins Avenue, Suite #166
Miami Beach, FL 33141
Email: eservealschuler@aol. com
alschulerlaw@aol.com
/s/ Henry G. Gyden
Henry G. Gyden, Esq.
Florida Bar No.: 0158127
Gyden Law Group
1228 East 7 Ave
Suite 200
Tampa, FL 33605
Telephone: (813) 493-4181
Facsimile: (813) 337-0244
heyden@evdenlaw.comIN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
MIAMI-DADE COUNTY, FLORIDA
CIRCUIT COURT
CHRISTOPHER MANSON,
Plaintiff, Case No. 17-CA-027479
v.
CHARLES M. STIWALT, HIS HEIRS AND ALL
PERSONS CLAIMING ANY LEGAL
OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN,
OR INTEREST IN THE PROPERTY DESCRIBED
IN THE COMPLAINT ADVERSE TO PLAINTIFF'S
TITLE, OR ANY CLOUD ON
PLAINTIFF'S TITLE THERETO,
Defendants.
AFFIDAVIT OF CHRISTOPHER MANSON
STATE OF FLORIDA
COUNTY OF MIAMEL-DADE
I, CHRISTOPHER MANSON, being first duly sworn, states as follows:
i. Jam over the age of 18 and am qualified to make statements contained in this
declaration.
2. lam familiar with and have personal knowledge of the facts and circumstances
involved herein.
3. iam the record owner of real property located in Miami-Dade County, Florida and
more specifically described as:
Lot 7, Block 5, NORTH SILVER CREST ADDITION, according to
the Plat thereof, recorded in the Plat Book 17, Page 38, of the Public
Records of Miami-Dade County, Florida.
Parcel Identification Number: 30-2135-020-1020
Page | of 3
EXHIBIT 1(hereinafter, “the Property”).
4. For a full seven-year period, I have been in possession of all real property described
in paragraph 3 of this Affidavit by actual, open, hostile, continuous, and exclusive possession, and
the Property has been usually cultivated and improved and I have used the Property for my own
use,
5, My possession of the Property has been actual, open, hostile, continuous, and
exclusive since December 22, 2006, in excess of the seven (7) year period set forth in Florida
Statutes 95.16 (2017).
6. Additionally, [have been in possession of the real property described in paragraph
3 of this Affidavit through a warranty deed issued on or about December 22, 2006 as recorded in
Book 25265, Pages. 4844-4845, of the Public Records of Miami-Dade County, Florida. See
attached as Exhibit A.
7. At the time I purchased the Property in December 2006, I was unaware of the death
of Charles M. Stiwalt and unaware of any impropriety regarding Vincent McKnight’s ownership
of the Property.
8. L purchased the Property from Vincent McKnight at its fair market value as a bona
fide purchaser acting in good faith.
9. Thave paid all taxes and assessments that have been levied or assessed against the
real property described in paragraph 3 of this Affidavit during the seven-year period.
10. Prior to Mr. Stiwalt’s death, the Property at issue was transferred from J.H.
Keathley to Charles M. Stiwalt through a warranty deed on April 13, 1964. which is recorded in
Miami-Dade Public Records Book 4116, Page 233. A copy of the Deed is attached hereto as
Exhibit B.
Page 2 of 3
EXHIBIT 1ii. Thus, J.H. Kealey has no claim to the Property, and he is not a necessary party to
this action.
FURTHER AFFIANT SAYETH NAUGHT. « 4 , ;
Ailche-w
CHRISTOPH
R MANSON
Before me on this Se" tay of August, 2018, appeared CHRISTOPHER MANSON, who
is personally known to me or produced pg) Sg ~ 00-8 /~ pl © identification, and
being first duly sworn, acknowledged that the foregoing information is true and correct.
TRANEICE JILES
ommission # FF 994993 |
y Commission Expl
My Commission Expires:
Page 3 of 3
EXHIBIT 16/9/2017 Miami-Dade Official Records - Print Document
DAMEN RHUL DUO AUTO EU UUES EE ALA
CEN 2OG07RO0S2682
i OR Bk 25265 Pas 4844 ~ 48457 (2pas)
. RECORDED 01/10/2007 11211348
. DEED DOC TAX 369.00
HARVEY RUVIN? CLERK OF COURT
HIAMI-DADE COUNTY, FLORTOA
Prey id ret
Torres & Vadillo, LLP
11402 NW 41st Street Suite #202
Miami, FL 33178
305-485-9700
File Number: MAN-TG-06-871
Will Call No.: 0
{Space Above This Line For Recording Data],
Warranty Deed
This Warranty Deed made this 22nd day of December, 2006 between Vincent McKnight, a single man whose post
office address is 6915 NW Sth Court , Miami, FL 33150, grantor, and Christopher Manson, a single man. whose post
office address is 435 NW 124th Street, Miami, FL 33168, grantee:
(Whenever used herein the terms “grantor” and "grantee" include all the parties to this instrument and the heirs, lege) representatives, and assigns of
individuals, and the successors and assigns of corporations, trusts and trustees)
Witnesseth, that said grantor, for and in consideration of the sum of TEN AND NO/100 DOLLARS ($10.00) and other
good and valuable considerations to said grantor in hand paid by said grantee, the receipt whereof is hereby acknowledged,
has granted, bargained, and sold to the said grantee, and grantee's heirs and assigns forever, the following described land,
situate, lying and being in Miami-Dade County, Florida to-wit:
Lot 7, Block 5, NORTH SILVER CREST ADDITION, according to the Plat thereof, recorded in Plat
Book 17, Page 38, of the Public Records of ‘Miami-Dade County, Florida,
Parcel Identification Number: 30-2135-020-1020
Together with all the tenements, hereditaments and appurtenances thereto belonging or in anywise appertaining,
To Have and to Hold, the same in fee simple forever.
And the grantor hereby covenants with said grantee that the grantor is lawfully seized of said land in fee simple; that the
grantor has good right and lawfal authority to sell and convey said land; that the grantor hereby fully warrants the title to said
land and will defend the same against the lawful claims of all persons whomsoever; and that said land is free of all
encumbrances, except taxes accruing subsequent to December 31, 2006.
In Witness Whereof, grantor has hereunto set grantor’s hand and seal the day and year first above written.
Signed, sealed and delivered in our presence:
Venent™, Ate ‘ (Seal)
Vincent McKnight
DoubteTimes bY
Book25265/Page4844 CFN#20070032682 Page 1 of 2
BIT 2
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https:/Avww2.miami-dadeclerk.com/officialrecords/PrintDocument.aspx?QS=Yao UfOzxryOzpGitQITBn3y7 VIUZbE P8Nj4WafylK7R Extle E8ulL3rSdks... 1/26/9/2017 Miami-Dade Official Records - Print Document
OR BK 25265
Cast pace” PS #245
State of Florida
County of Miami-Dade
The foregoing instrument was acknowledged before me thisl/L-da 7
; LL say of » Foy vi i
who [__] is personally known or [X] has produced a driver's license as identifigation, Incent MEK igh,
anny
[Notary Seal] Notary Public wan
Printed Name: a {t
My Commission Expires: ozo
Warranty Deed - Page 2 Doubletimee
Book25265/Page4845 CFN#20070032682 Page 2 of 2
BIT 2
https:/Avww2.miami-dadeclerk.com/officialrecords/PrintDocument.aspx?QS=Yao UfOzxryOzpGitQITBn3y7 VIUZbE P8Nj4WafyIK7RQ%2bYY E8ulL3rSdks... 2/2MIAMI DAILY BUSINESS REVIEW
Published Daily except Saturday, Sunday anc
Legal Hotdays
eerie
&
ten #18 UL -9 ANNO: 18
STATE OF FLORIDA ChERE
COUNTY OF BAMI-DADE:
Before the undersigned authority personally appeared
JOHANA OLIVA, whe on cath says that he or she is the
LEGAL CLERK Legal Notices of the Miami Daily Business
Review kia Miarii Review, a daily (except Saturday.
Sunday and Legal Holideys) newspaper, published at Miami =
in Miesni-Dede County, Floride, that the attached copy of -
advertiserent, being a Legal Advertisement of Notice in the
matter of
ATCAORTATE
NOTICE OF ACTION - CONSTRUCTIVE SERVICE
CHRIGTGPHER MANSON, Be
VS. CHARLES M. STAVALT, ETAL. JH LEGAL OF EL
: ene Len Oe Wrepeer
in the CIRCUIT Court, : € PROHESTY DESCREED
was published in said newspaper in the issues of : nm COMPLAINT: AEIVERSE
OR} PLAINEPRS THE C8 Any:
OS/16/2618 CHIESI2018 07/02/2018 07/09/2018 ea BLAINTIEES TILE
Afient further says that the said Mier! Daily Business
Review is a newspaper published at Miami, i
© Gounty, Florida end thet the seid newwspa
hereiofore been continuously published in said Miami-Dade
County, Florida each day (except Saturday, Sunday and
Legal Holidays) and es been entered as second class mak
metier at the post office mM Miami in said Mismi-Dade County,
Florida, for 3 period of one year next preceding the frst
pubvication of the aitacted copy of advertisement; end affiant |
further says that he or she has neither pald nor promised ary
person, fim or corporation any discount rebate, commission
or refund for the purpose of securing this advertisement for
publication in the said sewspapes
JOHANA Ou pdfsonaty Kriown to me.
MARIAL MESA
Notary Public State of Florida
Sy connasen' Expias Ma 4, 2020
Bonded through National Notary Agsa
pouty.
Geen, GSE
EXHIBIT 3IN THE CIRCUIT COURT
OF THE 17°77 JUDICIAL GIRCUIT
IN AND FOR MIAML-DADE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 17-27478 CA 23
JUDGE ARECES
CHRISTOPHER MANSON,
Plaintiff,
v8.
CHARLES M. STIWALT,
HIS HEIRS ...: etal,
Defendanis.
_——!
GAL REPORT, ANSWER AND AFFIRMATIVE DEFENSE
COMES NOW the undersigned Guardian Ad Litem, duly appointed by this
Honorable Court to attempt to identify and locate and, if unsuccessful, to protect the
interests of the Defendant(s), UNKNOWN HEIRS AND DESCENDANTS OF CHARLES
M. STIWALT, DECEASED, and respectfully files this GAL Report, Answer and Affirmative
Defense as follows:
GAL Report
4. This cage involves an action essentially to quiet title by adverse possession
fo now vacant land more particularly described as:
Lot 7, Biock 5, NORTH SILVER CREST ADDITION,
according to the Plat thereof, recorded in Plat Book 17,
Page 38, of the Public Records of Miami-Dade
County, Florida.
1 EXHIBIT 4AIKIA Folio Number. 30-2135-020-1020
AJKIA 1150 N.W. 104 Street, Miami, FL 33750
(though property is now vacant land)
2. According to Miami-Dade Property Records, on April 30, 1958, WILLIAM E.
SUTTON, JR. AND JOE ANN SUTTON, HIS WIFE, executed a Warranty Deed
conveying the subject real property fo CHARLES M. STWWALT AND GEORGE M.
HARRINGTON, BOTH SINGLE MEN.
3. fi is unknown what happened to GEORGE M. HARRINGTON but is
presumed that he died.
4. Then, according to Miami-Dade Property Records, on March 7, 1964,
CHARLES M. STIWALT, A SINGLE MAN, executed a Quit Claim Deed conveying the
subject real property to J. H. KEATHLEY. This Deed was recorded in Miami-Dade Public
Records Book 4116, Page 230. A copy of this Deed is attached hereto.
8. it should be noted that the aforementioned 1964 Quit Claim Deed is not
mentioned in the Complaint. As a direct and proximate result of the aforementioned 1264
Quit Claim Deed, it appears that the UNKNOWN HEIRS AND DESCENDANTS OF J. HL
KEATHLEY, DECEASED, also have or may claim to have some right, title, interest or
claim in and to the subject real property and should be added as party defendants.
8. in any event, CHARLES M. STIWALT died on or about October 21, 2002.
A copy of the Death Certificate is attached hereto.
7, Then, according to Miami-Dade Property Records, on duly 24, 2006, four
(4) years after his death, CHARLES M. STIWALT, A SINGLE MAN, purportedly executed
a Quit Claim Deed conveying the subject real property to VINCENT MCKNIGHT, A
SINGLE MAN. A copy of this posthurnous Quit Claim Deed is attached hereto.
2 EXHIBIT 4Obviously, this Quit Claim Deed was fraudulent and a number of crimes were committed
including, but not limited to, Forgery, Uttering a Forged instrument and Grand Theft.
8. Shortly thereafter, five (5) months later, on December 22, 2008, VINCENT
MCKNIGHT, A SINGLE MAN, executed a Warranty Deed conveying the subject real
property to CHRISTOPHER MANSON, A SINGLE MAN. Whether CHRISTOPHER
MANSON was part of the criminal activity or merely an innocent, bona fide purchaser is
unknown,
3. Thus according to Miami-Dade Property Records, CHRISTOPHER
MANSON now owns the subject vacant land which has a present market value of
$42,572.00.
40. CHRISTOPHER MANSON has now filed this lawsuit to quiet tlle to the
subject real property in his name by adverse possession which requires that the
possessor show that the possession was exclusive, adverse, continuous, open and
notorious or actual and visible for the entire prescriptive period, under a claim of right to
the property, The owner must have knowledge of the adverse claim, ar it must be so open
and notorious that he will be presumed to have notice of the claim.
41. According to the Complaint, the UNKNOWN HEIRS AND DESCENDANTS
OF CHARLES M. STIWALT, DECEASED, have or may claim to have some right, title,
interest or claim in and to the subject real property.
42. Miami-Dade Probate Clerk of Court Records do not reflect the opening of a
formal ESTATE OF CHARLES M. STIWALT, DECEASED.
43, Undersigned counsel obtained a copy of the Death Certificate from the
State of Florida Bureau of Vital Statistics which indicates that CHARLES MARION
3 EXHIBIT 4STIWALT was a selKemployed handyman who was never married at the time of his
death. The Death Certificate names ED STIWALT as the Informant of the information
contained therein. interestingly, the Death Certificate indicates that the decedent was
residing at the subject real property at the time of his death. The Death Certificate also
indicates cremation by 1.C.S, Cremation Society, Inc. as method of disposition.
44. Undersigned counsel conducted intemet research which indicates that ED
STIWALT died on or about September 11, 2005.
45. Undersigned counsel contacted ICS Cremation Society, Inc., which advised
that it maintains its recards only far five (5) years per Florida law and that it has shredded
any records it may have had in regards to any relatives of CHARLES M. STIWALT.
46. Undersigned counsel conducted internet research that revealed the names
and last known addresses of some possible family members.
47. On June 18, 2018, undersigned counsel mailed letters fo the HEIRS at six
(8) possibie addresses in Georgia, South Carolina and North Carolina. As of the date of
this GAL Report, none of the letters have been retumed to undersigned counsel.
48. _Undersigned counsel received a response only from SHERRY SMITH who
is the ex-wife of ED STIWALT. She did not know the relationship between CHARLES M.
STIWALT and ED STIWALT, did not know if CHARLES M. STIWALT had any children or
siblings and believed that ED STIWALT had a sister but did not know her name.
Answer
4. All matters of public recard are admitted,
he
EXHIBIT 42 The undersigned Guardian Ad Litem is without knowledge as to all other
allegations set forth in the Plaintiffs Complaint and therefore denies all other such
allegations and demands that the Plaintiff supply strict proof in support of ail essential
elements of its claim(s).
Affirmative Defense
4. The Plaintif cannot quiet tite in his name to the subject real property by
adverse possession without amending the Complaint or otherwise adding the
UNKNOWN HEIRS AND DESCENDANTS OF J. H. KEATHLY, DECEASED, as a party
defendant.
CERTIFICATE OF SERVICE
LEROY
| HEREBY CERTIFY that the foregoing GAL Report, Answer and Affirmative
Defense was filed with the Clerk of the Court via the Florida Courts eF iting Portal and
that a copy thereof was served via email upon Guyden Law Group, PAL at
DAVID ALSCHULER, PA,
6538 Collins Avenue #166
Miami Beach, FL.33144
Telephone: (305) 864-1301
Telefax: (305) 864-1324
Primary Emaik eser
Secondary Ema
Huler@.
wiaocl oom
By: ist David Aischuler, Esquire
DAVID ALSCHULER, ESQUIRE
Florida Bar No. 561286
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RECORDED 69715/2006 14:35:51
DEED HOC TAX 0.60
HARVEY RUVIH, CLERK OF COURT
HEAMI-DADE COUNTY? FLORIDA
QUITCLAIM DEED
THIS QUITCLAIM DEED, executed this 21 day of July 2006 ( year )
By first party, Grantor, Charles M. Stiwalt, a single man
whose post office address is P.O, Box .681284 Miami, Florida 33168
to second party, Grantee, Vincent McKnight, a single man
whose post office address ig. 1150 N.W. 104 Street Miami, Florida 33150
. 3
WITNESSETH, That the said first party, for good consideration and for the sum of
fen Dollars ( $10.00 ) paid by the said second party, the receipt whereof
is hereby acknowledged, does hereby remise, release and quitclaim unto the said
second party forever, all the right, title, interest and claim which the said first party has
in and to the following described parcel of land, and improvements and appurtenances
thereof in the County of
Dade , State of Florida to wit:
Lot 7, Block 5, NORTH SILVER CREST
ADDITION, according to the Plat there -
of recorded in Plat Book 17, at Page
38, of the Public Records of Dade County, *
Florida; together with the improvements
thereon and the contents therein.
, EUR 2
Book24914/Page714 CFN#20060993001 age | o}. OR BK 24914 3
. LAST PAGE PS O71s
IN WITNESS WHEREOF, the suid first party has signed and senled these presenta the dayaid year first
above written Signed, sealed snd delivered in presenve of
Poreteta, (corr Charter Wb Livable
Signature of Wimess Signature of First Party
Price Korn Charles M. Stiwalt
Prat Name of Witness: Print Name of First Party
eed ip Lg f Signature of First Party
_fuweble LtHerohes
Print Name of Witness Print Name of First Party
State of Florida
County of Dade
on 7 {24/2006 before me, Notary Public of Florida state
appeared Charl
personally known to me {or proved to me on the basis of aatisfactory avidence) to be the person(s) whose name(s)
isface subscribed to the wishin instrument and acknowledged to mo that he/she/they exeouted the same in
histher/their authorined capacity{ies), and that by his/hex/their signature(a) on the instrument the person{s), of the
entity upon bebalf of which the person(s) acted, executed the instrument,
WETNEBS my hand and official
Charles M. Stiwalt
Name of Preparer
P.O. BOX 681286 MESMT FE $3768
Addresa of Preparer
Pollo: g 35-
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EXHIBIT 6
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EXHIBIT 8HUD U.S. Departmen of Housing
A. Setviement Statement and Urban Development OMB No. 2502-6285
S. Type of Loan
OU1FHA O) 2. FmHA © 3.Conv, Uning | & Bile Number 7. Loan Number 8. Morty, ins. Gace Num.
Oa VA. © 5. Conv. ins. ANTG-06-874 >
©, NOTE: This fom is furnished to give you a siatement of actual settlement opsis. Amourits paid to and by the saitiement agent are shown. Hern
Marked "{p.c.0.}" were paid outside the. closing, they are shown here for informational Sumoses and ere not Included Ir the totals,
5. NAME OF BORROWER: — Christopher Manson, a single man
Address of Borrewor: 435 NW 124th Street, Miami, Florida 38498
&, NAME OF SELLER: Vincent McKnight, a single men
Asidress of Selter: 8915 NW 3th Court, Miami, Florida 93150 Ti: iy
E. NAME OF LENDER:
Address of Lender:
G. PROPERTY LOCATION: 1150 NW 104 Street, Miami, Florida 33150
H. SETTLEMENT AGENT: Torres & Vadiiio, LLP TIN: 04-3753
Place of Settlement: 13402 NW 44st Street, Suite #202, Miami, Florida 33178 Phone: 305-485-0700
1. SETTLEMENT DATE: 122206 DISBURSEMENT DATE: 12/22/08
2. Coninact sales
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Preview
Filing # 79306345 E-Filed 10/15/2018 09:42:09 AM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT MIAMI-DADE COUNTY, FLORIDA CIRCUIT COURT CHRISTOPHER MANSON, Plaintiff, Case No. 17-027479 CA 23 Vv. CHARLES M. STIWALT, HIS HEIRS AND ALL PERSONS CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN, OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF'S TITLE, OR ANY CLOUD ON PLAINTIFF'S TITLE THERETO, Defendants. / MOTION FOR SUMMARY JUDGMENT Plaintiff, CHRISTOPHER MANSON, by and through the undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, respectfully moves this Court to enter summary judgment on his behalf and against Defendants in the above-styled cause because the record in this case conclusively shows that there is no genuine issue of material fact and Plaintiff is entitled to Summary Judgment as a matter of law. In support of this Motion, Plaintiff relies on the interrogatories, pleadings, and affidavits filed with, or to be filed with, the Court, and Plaintiff states as follows: UNDISPUTED FACTS1. Plaintiff, CHRISTOPHER MANSON, is the owner by adverse possession, with color of title, of real property located in Miami-Dade County, Florida and more specifically described as: Lot 7, Block 5, NORTH SILVER CREST ADDITION, according to the Plat thereof, recorded in the Plat Book 17, Page 38, of the Public Records of Miami-Dade County, Florida. Parcel Identification Number: 30-2135-020-1020 See attached Exhibit 1, Affidavit of Christopher Manson, p. 1-2. 2. For a full seven-year period, Plaintiff has been in possession of all real property described above by actual, open, hostile, continuous, and exclusive possession, and the property has been usually cultivated and improved and Plaintiff has used the property for his own use. See attached Exhibit 1, Affidavit of Christopher Manson, p. 1-2. 3. Plaintiffs possession has been actual, open, hostile, continuous, and exclusive since December 22, 2006, in excess of the seven (7) year period set forth in Florida Statutes 95.16 (2017). See attached Exhibit 1, Affidavit of Christopher Manson, p. 2. 4. Plaintiff has been in possession of the above real property as described in a warrant deed issued on or about December 22, 2006 and recorded in Book 25265, Pages 4844-4845, of the Public Records of Miami-Dade County, Florida.See attached Exhibit 2, Warranty Deed to Christopher Manson. Plaintiff is an arms-length bona fide purchaser of the property. See attached Exhibit 1, p. 2. 5. Plaintiff has been in continuous possession during the seven-year period, adverse to Defendants and to all other persons. See attached Exhibit 1, Affidavit of Christopher Manson, p. 2. 6. Plaintiff has paid all taxes and assessments that have been levied or assessed against the real property described above during a seven-year period beginning in 2006. See attached Exhibit 1, Affidavit of Christopher Manson, p. 2. ADVERSE POSSESSION WITH COLOR OF TITLE 7. Section 95.16, Florida Statutes, provides as follows: 95.16 Real property actions; adverse possession under color of title — (1) When the occupant, or those under whom the occupant claims, entered into possession of real property under a claim of title exclusive of any other right, founding the claim on a written instrument as being a conveyance of the property, or on a decree or judgment, and has for 7 years been in continued possession of the property included in the instrument, decree, or judgment, the property is held adversely. If the property is divided into lots, the possession of one lot shall not be deemed a possession of any other lot of the same tract. Adverse possession commencing after December 31, 1945, shall not be deemed adverse possession under color of title until the instrument upon which the claim of title is founded is recorded in the office of the clerk of the circuit court of the county where the property is located. (2) For the purpose of this section, property is deemed possessed in any of the following cases: (a) When it has been usually cultivated or improved.(b) When it has been protected by a substantial enclosure. All land protected by the enclosure must be included within the description of the property in the written instrument, judgment, or decree. If only a portion of the land protected by the enclosure is included within the description of the property in the written instrument, judgment, or decree, only that portion is deemed possessed. (c) When, although not enclosed, it has been used for the supply of fuel or fencing timber for husbandry or for the ordinary use of the occupant. (d) When a known lot or single farm has been partly improved, the part that has not been cleared or enclosed according to the usual custom of the county is to be considered as occupied for the same length of time as the part improved or cultivated. 8. Plaintiff satisfies all requires of section 95.16 in that he possesses a written instrument conveying title to the real property located in Miami-Dade County, Florida and more specifically described as: Lot 7, Block 5, NORTH SILVER CREST ADDITION, according to the Plat thereof, recorded in the Plat Book 17, Page 38, of the Public Records of Miami-Dade County, Florida. Parcel Identification Number: 30-2135-020-1020 See attached Exhibit 2, Warranty Deed to Christopher Manson. 9. Additionally, for a full seven-year period, Plaintiff has been in possession of the real property included in the instrument by actual, open, hostile, continuous, and exclusive possession, and the property has been usually cultivated and improved and Plaintiff has used the property for his own use.10. Defendant, CHARLES M. STIWALT, and his unknown heirs have been served through constructive service, which was completed on or about July 6, 2018. See attached Exhibit 3, Proof of Publication. 11. On or about June 8, 2018, this Court entered an Order Appointing Guardian ad Litem to represent the unknown heirs and descendants of Charles M. Stiwalt, who is deceased. 12. On or about July 9, 2018, the Guardian ad Litem, David Aischuler, Esq., filed a GAL Report, Answer, and Affirmative Defenses. See attached Exhibit 4, GAL Report, Answer, and Affirmative Defenses. In the GAL Report, Attorney Aischuler notes that on March 7, 1964, Charles M. Stiwalt executed a quit claim deed conveying the subject property to J.H. Keathley. See attached Exhibit 5, March 7, 1964 Quit Claim Deed between Stiwalt and Keathley. Mr. Aischuler then suggests that the unknown heirs and descendants of J.H. Keathley may have an interest in the property. See Exhibit 4, at 5. 13. Inthe GAL Report, Mr. Aischuler also notes that four years after his death, Charles M. Stiwalt purportedly executed a quit claim deed conveying the subject property to Vincent McKnight. See attached Exhibit 6, Quit Claim Deed between Stiwalt and McKnight. Vincent McKnight is the person who later transferred the property to Plaintiff Christopher Manson. Mr. Aischuler argues that the quit claim deed between Stiwalt and McKnight was fraudulent.14. In the Answer, Mr. Aischuler admits all matters of record and asserts that he is without knowledge and therefore denies all other allegations in the Complaint. 15. As to affirmative defenses, Mr. Aischuler asserts that Plaintiff cannot quiet title in his name “without amending the Complaint or otherwise adding the UNKNOWN HEIRS AND DESCENDANTS OF J.H. KEATHLY, DECEASED, as a party defendant.” See attached Exhibit 4, GAL Report, Answer, and Affirmative Defenses, p. 5. 16. The issues raised in the Answer and Affirmative Defense do not bar summary judgment here. 17. Mr. Aischuler has overlooked that, on or about April 13, 1964, J.H. Keathley issued a Warranty Deed to Charles M. Stiwalt, which is recorded as Book 4116, Page 233, of the Public Records of Miami-Dade County, Florida. See attached Exhibit 7, April 13, 1964 Warranty Deed between J.H. Keathley and Charles M. Stiwalt. Thus, any interest that JH. Keathley obtained through the March 7, 1964, quit claim deed from Charles M. Stiwalt was conveyed back to Mr. Stiwalt through the April 13, 1964, warranty deed. For this reason, the unknown heirs of J.H. Keathley have no interest in the subject property. 18. Additionally, in December 2006, Plaintiff Christopher Manson purchased the property from Vincent McKnight in an arms-length transaction.Plaintiff Manson believed that Mr. McKnight legitimately owned the property, and he had no reason to doubt the validity of Mr. McKnight’s ownership. See attached Exhibit 1, p. 2. Plaintiff paid a fair market price of $60,000 for the property, and the property was sold through a normal real estate closing. See attached Exhibit 8, Closing Statement and Check. A deed transferring the property to Plaintiff Manson was recorded in the public records. See attached Exhibit 2, Warranty Deed to Christopher Manson. 19. Under Florida law, Plaintiff Christopher Manson qualified as a bona fide purchaser, and since his deed was recorded, he can assert rights to the property against the true owner, even without considering the issue of adverse possession. See Hull v. Maryland Casualty Co., 79 So.2d 517 (Fla. 1955) (holding that the true owner is estopped to assert his title against bona fide purchasers who rely upon the record and are without notice of the interest of the true owner); Demosthenes v. Girard, 955 So.2d 1189, 1192 (Fla. 3d DCA 2007) (noting that to be a bona fide purchaser, three conditions must be satisfied: the purchaser must have (1) acquired the legal title to the property in question, (2) paid value therefore, and (3) been innocent of knowledge of the equity against the property at the time when consideration was paid and title acquired). 20. However, even if Plaintiff Christopher Manson had been aware of the fraud, which was not the case, such knowledge would not invalidate his claim foradverse possession. Plaintiff Manson’s deed placed all persons on notice of his interest in the property, and for a period of seven years, Plaintiff Manson paid the property taxes and complied with all other requirements of section 95.16. Accordingly, Plaintiff Manson took the property by adverse possession, and he is entitled to a judgment in his favor determining that he is the legal owner of the subject property. WHEREFORE Plaintiff, CHRISTOPHER MANSON, respectfully requests that this Court enter summary judgment in his favor and determine that he is the legal owner of the subject property and grant such further relief as this Court deems just and proper. Submitted this 15th day of October, 2018. /s/Henry G. Gyden Henry G. Gyden, Esq. Florida Bar No.: 158127 GYDEN LAW GROUP, P.A. 1228 East 7" Ave. Suite 200 Tampa, Florida 33605 Telephone: (813) 493-4181 Facsimile: (813) 337-0244 FAX hgyden@gydenlaw.com Attorney for PlaintiffCERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 15th day of October, 2018, the foregoing was served through the Florida e-portal to the following: David Alschuler, Esq. David Alschuler, P.A. 6538 Collins Avenue, Suite #166 Miami Beach, FL 33141 Email: eservealschuler@aol. com alschulerlaw@aol.com /s/ Henry G. Gyden Henry G. Gyden, Esq. Florida Bar No.: 0158127 Gyden Law Group 1228 East 7 Ave Suite 200 Tampa, FL 33605 Telephone: (813) 493-4181 Facsimile: (813) 337-0244 heyden@evdenlaw.comIN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT MIAMI-DADE COUNTY, FLORIDA CIRCUIT COURT CHRISTOPHER MANSON, Plaintiff, Case No. 17-CA-027479 v. CHARLES M. STIWALT, HIS HEIRS AND ALL PERSONS CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN, OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF'S TITLE, OR ANY CLOUD ON PLAINTIFF'S TITLE THERETO, Defendants. AFFIDAVIT OF CHRISTOPHER MANSON STATE OF FLORIDA COUNTY OF MIAMEL-DADE I, CHRISTOPHER MANSON, being first duly sworn, states as follows: i. Jam over the age of 18 and am qualified to make statements contained in this declaration. 2. lam familiar with and have personal knowledge of the facts and circumstances involved herein. 3. iam the record owner of real property located in Miami-Dade County, Florida and more specifically described as: Lot 7, Block 5, NORTH SILVER CREST ADDITION, according to the Plat thereof, recorded in the Plat Book 17, Page 38, of the Public Records of Miami-Dade County, Florida. Parcel Identification Number: 30-2135-020-1020 Page | of 3 EXHIBIT 1(hereinafter, “the Property”). 4. For a full seven-year period, I have been in possession of all real property described in paragraph 3 of this Affidavit by actual, open, hostile, continuous, and exclusive possession, and the Property has been usually cultivated and improved and I have used the Property for my own use, 5, My possession of the Property has been actual, open, hostile, continuous, and exclusive since December 22, 2006, in excess of the seven (7) year period set forth in Florida Statutes 95.16 (2017). 6. Additionally, [have been in possession of the real property described in paragraph 3 of this Affidavit through a warranty deed issued on or about December 22, 2006 as recorded in Book 25265, Pages. 4844-4845, of the Public Records of Miami-Dade County, Florida. See attached as Exhibit A. 7. At the time I purchased the Property in December 2006, I was unaware of the death of Charles M. Stiwalt and unaware of any impropriety regarding Vincent McKnight’s ownership of the Property. 8. L purchased the Property from Vincent McKnight at its fair market value as a bona fide purchaser acting in good faith. 9. Thave paid all taxes and assessments that have been levied or assessed against the real property described in paragraph 3 of this Affidavit during the seven-year period. 10. Prior to Mr. Stiwalt’s death, the Property at issue was transferred from J.H. Keathley to Charles M. Stiwalt through a warranty deed on April 13, 1964. which is recorded in Miami-Dade Public Records Book 4116, Page 233. A copy of the Deed is attached hereto as Exhibit B. Page 2 of 3 EXHIBIT 1ii. Thus, J.H. Kealey has no claim to the Property, and he is not a necessary party to this action. FURTHER AFFIANT SAYETH NAUGHT. « 4 , ; Ailche-w CHRISTOPH R MANSON Before me on this Se" tay of August, 2018, appeared CHRISTOPHER MANSON, who is personally known to me or produced pg) Sg ~ 00-8 /~ pl © identification, and being first duly sworn, acknowledged that the foregoing information is true and correct. TRANEICE JILES ommission # FF 994993 | y Commission Expl My Commission Expires: Page 3 of 3 EXHIBIT 16/9/2017 Miami-Dade Official Records - Print Document DAMEN RHUL DUO AUTO EU UUES EE ALA CEN 2OG07RO0S2682 i OR Bk 25265 Pas 4844 ~ 48457 (2pas) . RECORDED 01/10/2007 11211348 . DEED DOC TAX 369.00 HARVEY RUVIN? CLERK OF COURT HIAMI-DADE COUNTY, FLORTOA Prey id ret Torres & Vadillo, LLP 11402 NW 41st Street Suite #202 Miami, FL 33178 305-485-9700 File Number: MAN-TG-06-871 Will Call No.: 0 {Space Above This Line For Recording Data], Warranty Deed This Warranty Deed made this 22nd day of December, 2006 between Vincent McKnight, a single man whose post office address is 6915 NW Sth Court , Miami, FL 33150, grantor, and Christopher Manson, a single man. whose post office address is 435 NW 124th Street, Miami, FL 33168, grantee: (Whenever used herein the terms “grantor” and "grantee" include all the parties to this instrument and the heirs, lege) representatives, and assigns of individuals, and the successors and assigns of corporations, trusts and trustees) Witnesseth, that said grantor, for and in consideration of the sum of TEN AND NO/100 DOLLARS ($10.00) and other good and valuable considerations to said grantor in hand paid by said grantee, the receipt whereof is hereby acknowledged, has granted, bargained, and sold to the said grantee, and grantee's heirs and assigns forever, the following described land, situate, lying and being in Miami-Dade County, Florida to-wit: Lot 7, Block 5, NORTH SILVER CREST ADDITION, according to the Plat thereof, recorded in Plat Book 17, Page 38, of the Public Records of ‘Miami-Dade County, Florida, Parcel Identification Number: 30-2135-020-1020 Together with all the tenements, hereditaments and appurtenances thereto belonging or in anywise appertaining, To Have and to Hold, the same in fee simple forever. And the grantor hereby covenants with said grantee that the grantor is lawfully seized of said land in fee simple; that the grantor has good right and lawfal authority to sell and convey said land; that the grantor hereby fully warrants the title to said land and will defend the same against the lawful claims of all persons whomsoever; and that said land is free of all encumbrances, except taxes accruing subsequent to December 31, 2006. In Witness Whereof, grantor has hereunto set grantor’s hand and seal the day and year first above written. Signed, sealed and delivered in our presence: Venent™, Ate ‘ (Seal) Vincent McKnight DoubteTimes bY Book25265/Page4844 CFN#20070032682 Page 1 of 2 BIT 2 . ao j EXH https:/Avww2.miami-dadeclerk.com/officialrecords/PrintDocument.aspx?QS=Yao UfOzxryOzpGitQITBn3y7 VIUZbE P8Nj4WafylK7R Extle E8ulL3rSdks... 1/26/9/2017 Miami-Dade Official Records - Print Document OR BK 25265 Cast pace” PS #245 State of Florida County of Miami-Dade The foregoing instrument was acknowledged before me thisl/L-da 7 ; LL say of » Foy vi i who [__] is personally known or [X] has produced a driver's license as identifigation, Incent MEK igh, anny [Notary Seal] Notary Public wan Printed Name: a {t My Commission Expires: ozo Warranty Deed - Page 2 Doubletimee Book25265/Page4845 CFN#20070032682 Page 2 of 2 BIT 2 https:/Avww2.miami-dadeclerk.com/officialrecords/PrintDocument.aspx?QS=Yao UfOzxryOzpGitQITBn3y7 VIUZbE P8Nj4WafyIK7RQ%2bYY E8ulL3rSdks... 2/2MIAMI DAILY BUSINESS REVIEW Published Daily except Saturday, Sunday anc Legal Hotdays eerie & ten #18 UL -9 ANNO: 18 STATE OF FLORIDA ChERE COUNTY OF BAMI-DADE: Before the undersigned authority personally appeared JOHANA OLIVA, whe on cath says that he or she is the LEGAL CLERK Legal Notices of the Miami Daily Business Review kia Miarii Review, a daily (except Saturday. Sunday and Legal Holideys) newspaper, published at Miami = in Miesni-Dede County, Floride, that the attached copy of - advertiserent, being a Legal Advertisement of Notice in the matter of ATCAORTATE NOTICE OF ACTION - CONSTRUCTIVE SERVICE CHRIGTGPHER MANSON, Be VS. CHARLES M. STAVALT, ETAL. JH LEGAL OF EL : ene Len Oe Wrepeer in the CIRCUIT Court, : € PROHESTY DESCREED was published in said newspaper in the issues of : nm COMPLAINT: AEIVERSE OR} PLAINEPRS THE C8 Any: OS/16/2618 CHIESI2018 07/02/2018 07/09/2018 ea BLAINTIEES TILE Afient further says that the said Mier! Daily Business Review is a newspaper published at Miami, i © Gounty, Florida end thet the seid newwspa hereiofore been continuously published in said Miami-Dade County, Florida each day (except Saturday, Sunday and Legal Holidays) and es been entered as second class mak metier at the post office mM Miami in said Mismi-Dade County, Florida, for 3 period of one year next preceding the frst pubvication of the aitacted copy of advertisement; end affiant | further says that he or she has neither pald nor promised ary person, fim or corporation any discount rebate, commission or refund for the purpose of securing this advertisement for publication in the said sewspapes JOHANA Ou pdfsonaty Kriown to me. MARIAL MESA Notary Public State of Florida Sy connasen' Expias Ma 4, 2020 Bonded through National Notary Agsa pouty. Geen, GSE EXHIBIT 3IN THE CIRCUIT COURT OF THE 17°77 JUDICIAL GIRCUIT IN AND FOR MIAML-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 17-27478 CA 23 JUDGE ARECES CHRISTOPHER MANSON, Plaintiff, v8. CHARLES M. STIWALT, HIS HEIRS ...: etal, Defendanis. _——! GAL REPORT, ANSWER AND AFFIRMATIVE DEFENSE COMES NOW the undersigned Guardian Ad Litem, duly appointed by this Honorable Court to attempt to identify and locate and, if unsuccessful, to protect the interests of the Defendant(s), UNKNOWN HEIRS AND DESCENDANTS OF CHARLES M. STIWALT, DECEASED, and respectfully files this GAL Report, Answer and Affirmative Defense as follows: GAL Report 4. This cage involves an action essentially to quiet title by adverse possession fo now vacant land more particularly described as: Lot 7, Biock 5, NORTH SILVER CREST ADDITION, according to the Plat thereof, recorded in Plat Book 17, Page 38, of the Public Records of Miami-Dade County, Florida. 1 EXHIBIT 4AIKIA Folio Number. 30-2135-020-1020 AJKIA 1150 N.W. 104 Street, Miami, FL 33750 (though property is now vacant land) 2. According to Miami-Dade Property Records, on April 30, 1958, WILLIAM E. SUTTON, JR. AND JOE ANN SUTTON, HIS WIFE, executed a Warranty Deed conveying the subject real property fo CHARLES M. STWWALT AND GEORGE M. HARRINGTON, BOTH SINGLE MEN. 3. fi is unknown what happened to GEORGE M. HARRINGTON but is presumed that he died. 4. Then, according to Miami-Dade Property Records, on March 7, 1964, CHARLES M. STIWALT, A SINGLE MAN, executed a Quit Claim Deed conveying the subject real property to J. H. KEATHLEY. This Deed was recorded in Miami-Dade Public Records Book 4116, Page 230. A copy of this Deed is attached hereto. 8. it should be noted that the aforementioned 1964 Quit Claim Deed is not mentioned in the Complaint. As a direct and proximate result of the aforementioned 1264 Quit Claim Deed, it appears that the UNKNOWN HEIRS AND DESCENDANTS OF J. HL KEATHLEY, DECEASED, also have or may claim to have some right, title, interest or claim in and to the subject real property and should be added as party defendants. 8. in any event, CHARLES M. STIWALT died on or about October 21, 2002. A copy of the Death Certificate is attached hereto. 7, Then, according to Miami-Dade Property Records, on duly 24, 2006, four (4) years after his death, CHARLES M. STIWALT, A SINGLE MAN, purportedly executed a Quit Claim Deed conveying the subject real property to VINCENT MCKNIGHT, A SINGLE MAN. A copy of this posthurnous Quit Claim Deed is attached hereto. 2 EXHIBIT 4Obviously, this Quit Claim Deed was fraudulent and a number of crimes were committed including, but not limited to, Forgery, Uttering a Forged instrument and Grand Theft. 8. Shortly thereafter, five (5) months later, on December 22, 2008, VINCENT MCKNIGHT, A SINGLE MAN, executed a Warranty Deed conveying the subject real property to CHRISTOPHER MANSON, A SINGLE MAN. Whether CHRISTOPHER MANSON was part of the criminal activity or merely an innocent, bona fide purchaser is unknown, 3. Thus according to Miami-Dade Property Records, CHRISTOPHER MANSON now owns the subject vacant land which has a present market value of $42,572.00. 40. CHRISTOPHER MANSON has now filed this lawsuit to quiet tlle to the subject real property in his name by adverse possession which requires that the possessor show that the possession was exclusive, adverse, continuous, open and notorious or actual and visible for the entire prescriptive period, under a claim of right to the property, The owner must have knowledge of the adverse claim, ar it must be so open and notorious that he will be presumed to have notice of the claim. 41. According to the Complaint, the UNKNOWN HEIRS AND DESCENDANTS OF CHARLES M. STIWALT, DECEASED, have or may claim to have some right, title, interest or claim in and to the subject real property. 42. Miami-Dade Probate Clerk of Court Records do not reflect the opening of a formal ESTATE OF CHARLES M. STIWALT, DECEASED. 43, Undersigned counsel obtained a copy of the Death Certificate from the State of Florida Bureau of Vital Statistics which indicates that CHARLES MARION 3 EXHIBIT 4STIWALT was a selKemployed handyman who was never married at the time of his death. The Death Certificate names ED STIWALT as the Informant of the information contained therein. interestingly, the Death Certificate indicates that the decedent was residing at the subject real property at the time of his death. The Death Certificate also indicates cremation by 1.C.S, Cremation Society, Inc. as method of disposition. 44. Undersigned counsel conducted intemet research which indicates that ED STIWALT died on or about September 11, 2005. 45. Undersigned counsel contacted ICS Cremation Society, Inc., which advised that it maintains its recards only far five (5) years per Florida law and that it has shredded any records it may have had in regards to any relatives of CHARLES M. STIWALT. 46. Undersigned counsel conducted internet research that revealed the names and last known addresses of some possible family members. 47. On June 18, 2018, undersigned counsel mailed letters fo the HEIRS at six (8) possibie addresses in Georgia, South Carolina and North Carolina. As of the date of this GAL Report, none of the letters have been retumed to undersigned counsel. 48. _Undersigned counsel received a response only from SHERRY SMITH who is the ex-wife of ED STIWALT. She did not know the relationship between CHARLES M. STIWALT and ED STIWALT, did not know if CHARLES M. STIWALT had any children or siblings and believed that ED STIWALT had a sister but did not know her name. Answer 4. All matters of public recard are admitted, he EXHIBIT 42 The undersigned Guardian Ad Litem is without knowledge as to all other allegations set forth in the Plaintiffs Complaint and therefore denies all other such allegations and demands that the Plaintiff supply strict proof in support of ail essential elements of its claim(s). Affirmative Defense 4. The Plaintif cannot quiet tite in his name to the subject real property by adverse possession without amending the Complaint or otherwise adding the UNKNOWN HEIRS AND DESCENDANTS OF J. H. KEATHLY, DECEASED, as a party defendant. CERTIFICATE OF SERVICE LEROY | HEREBY CERTIFY that the foregoing GAL Report, Answer and Affirmative Defense was filed with the Clerk of the Court via the Florida Courts eF iting Portal and that a copy thereof was served via email upon Guyden Law Group, PAL at DAVID ALSCHULER, PA, 6538 Collins Avenue #166 Miami Beach, FL.33144 Telephone: (305) 864-1301 Telefax: (305) 864-1324 Primary Emaik eser Secondary Ema Huler@. wiaocl oom By: ist David Aischuler, Esquire DAVID ALSCHULER, ESQUIRE Florida Bar No. 561286 5 EXHIBIT 4: : glopiaa: | ere. ath fis, pot sd ORC RBATBLEY Uys @ Shep GR Pee . Gade and Sierdnf~ Florida af she. fired part, Joe and fx consis USES SSEY NE hae fon atl pers ; CONSITERAPIONS-——-anate, TSR DOLLARS & OTHER GOOD ARE vais aun of PER J pHi aéeonid part, the récdippt whee: Annih geod be the fw 8. venti otegen peste’, pelisear gat gi siond,gart sd Lovins anit signs sesiscenel shies af the Sie pore BB see ts gm praronh 2 sdquare, bing and be NW, aceordiny garded in Fiat’ Book "17, at Page - ithe Public Records, of Dade. Pioridar Eayether..wite the Ju nes. thereon and- the eantents\y Ja olf wind sisigquler’ she seppurteniins ehicwsitse | se gia, Hele. interest Ene vlaien whaseoestr cof thse Ronofit'agd beboaf.nf de T HAPE ASB TO BO: eoaging ce ta Gayiciae sppe iaining, ond all she. osteds ake fires pare sith, ja Tass ae egidby, 8b ie, arilyr groper use. stidipart ¥ of the second gach, DAS Lo geetie and aaaighs forever ssid part ¥ “Gy Wiheynes IHRARDE, The wiih prt ys + aint send:-Binte at Biorida anit Sage JB Borelsy, edits. thos vn vie dey privanatiy appentitd agtby pad take ackninwtedgmente, . CHAR IBITSCEFN 2ZOCSROFS3001 OR Bk 24914 Pas O714 ~ 7157 (pas) RECORDED 69715/2006 14:35:51 DEED HOC TAX 0.60 HARVEY RUVIH, CLERK OF COURT HEAMI-DADE COUNTY? FLORIDA QUITCLAIM DEED THIS QUITCLAIM DEED, executed this 21 day of July 2006 ( year ) By first party, Grantor, Charles M. Stiwalt, a single man whose post office address is P.O, Box .681284 Miami, Florida 33168 to second party, Grantee, Vincent McKnight, a single man whose post office address ig. 1150 N.W. 104 Street Miami, Florida 33150 . 3 WITNESSETH, That the said first party, for good consideration and for the sum of fen Dollars ( $10.00 ) paid by the said second party, the receipt whereof is hereby acknowledged, does hereby remise, release and quitclaim unto the said second party forever, all the right, title, interest and claim which the said first party has in and to the following described parcel of land, and improvements and appurtenances thereof in the County of Dade , State of Florida to wit: Lot 7, Block 5, NORTH SILVER CREST ADDITION, according to the Plat there - of recorded in Plat Book 17, at Page 38, of the Public Records of Dade County, * Florida; together with the improvements thereon and the contents therein. , EUR 2 Book24914/Page714 CFN#20060993001 age | o}. OR BK 24914 3 . LAST PAGE PS O71s IN WITNESS WHEREOF, the suid first party has signed and senled these presenta the dayaid year first above written Signed, sealed snd delivered in presenve of Poreteta, (corr Charter Wb Livable Signature of Wimess Signature of First Party Price Korn Charles M. Stiwalt Prat Name of Witness: Print Name of First Party eed ip Lg f Signature of First Party _fuweble LtHerohes Print Name of Witness Print Name of First Party State of Florida County of Dade on 7 {24/2006 before me, Notary Public of Florida state appeared Charl personally known to me {or proved to me on the basis of aatisfactory avidence) to be the person(s) whose name(s) isface subscribed to the wishin instrument and acknowledged to mo that he/she/they exeouted the same in histher/their authorined capacity{ies), and that by his/hex/their signature(a) on the instrument the person{s), of the entity upon bebalf of which the person(s) acted, executed the instrument, WETNEBS my hand and official Charles M. Stiwalt Name of Preparer P.O. BOX 681286 MESMT FE $3768 Addresa of Preparer Pollo: g 35- ~10Zo EXHIBIT 6 Book24914/Page715 CFN#20060993001 Page 2 of 2euiniesieen, That thé said’ patties: «ut the first partite and enone: syd) Of PEN ‘DOLLARS “& OTHER -GOGD. AND. VALUABLE CONSIDERATIO: th fie part ¥ of the, ieceml’ parts the in hand paid b have ranted, bargained and sald t9 RUSS heiss and assigns, jorerer, the folloteingd oun of. “Dade State “Zot _7.-Block: S¢ NORTH, STIVER “CREST. cordiag to t Fiat there Stele 6f Horide, Covaty. of Bade, + This instrument was lend for eecord tl te SLOT: WA, ML Kenthtey. 3 Soecedp cenit : rsonally. app. “e sad ntinisier, oaths. and tak eheatedem ents oa = G Wines my aiid ‘Gounty of Dade" of -FROM rMaer > ESCOTO-CASTIELLE.P, AL a SSIES, PS 4B/I3 08 T8980 HO2OF 47/19 BS. Capea of Mavaing ae amen — Bid Liban Saaingetent oo CRB Re, LES. &. Rpsat ews . Cit on OL ES Reotw Une) RP nombr Teen mee 8 Hang. fee, Gan Rn, Cte hea ened C4 MA, OB come tra, bs (&. MOTE: THis fern la Rentahas fe give sew & Biatumert of echatl saibement costs, itidipiichick.. noted gO Meta Ge entails th ceping. Rony ata aime mire tr inbesetONe! ADORE AN we 6 ORO th ee oki DLHARE RF GRREOAER: — Chteintir Satan, a ig man Rearesee of Bie fo MANE GF BERL, Naina SRenight «eg mam, Asternee of Gallee: Te © RARE OF LENDER BRE SF Reperse: @ FROSRAWY LODeTI: «TES eH! 184 diesel, Mal, Rene $2150. 8 RETROMENY SET: Torres Bhai, LLP Tiobareeses Fleas af Settten ‘TAS RW Set Sirens, Sump RARE teal. once aate Phare HRS RtD 1 SETTLRREAT Sere. BREE ORIBLRBREEUT RATA: ORIG Ean vara (ave lamomeret IO, Hoieasrant og Ya has ioe 7305) ee ead gee ep i sgh? Sheree ONE SH Hates, is @nG 5 See RY a pater! ts nfenesnive ase I hate * Smsehtean Seva 2 rsdn 98s inne a aa WINE Rees gai Oe an ‘Sietir fanbrsedionase abate ee fet RTA seas Sa Fam $896, ee 9: Rashnga 8 Sanco Rasy, py gain, ite Sroka: Se ethae i SESE Re Bea MoE Poe ATS, Bors Siz RnGiONeneita D eam $OaRY Sane dese Doabtefionas EXHIBIT 8COTE-CRST LELLG: FB FRM HD. 2 SRERSAISS a us. # 2, sass 2 ee BEB reece — ee ee Sent 4ere pos sedan DORIA, B25 Bee. £2 “pe 4883 80.227 were aia bore prea Pure Rarities EXHIBIT 8 zone 120 S5RM PECashier's Check . 5295581 WTA 372AB 0.2005 Brkddneia, NA Su ° ears ee se =< RRS e Resse HECORER 22, anes wine Bn BRGRSUTULE ROL BHO eRe Ere aTeEHRR wxEC Resnitter Pucckased By} $ 1361691. 0908 Fay S12 [ed TAGGED SLC MRPORED MIMENY C6 BLLLHRS 488) OB CeNTSe To The Orie HRS § HBO, ELD. as aon . _ Te Neots ado al Signarere Customer Copy Retain For Your Records aN VOID AFTER 90 DAYS G0ses 02062 EXHIBIT. EXHIBIT 8HUD U.S. Departmen of Housing A. Setviement Statement and Urban Development OMB No. 2502-6285 S. Type of Loan OU1FHA O) 2. FmHA © 3.Conv, Uning | & Bile Number 7. Loan Number 8. Morty, ins. Gace Num. Oa VA. © 5. Conv. ins. ANTG-06-874 > ©, NOTE: This fom is furnished to give you a siatement of actual settlement opsis. Amourits paid to and by the saitiement agent are shown. Hern Marked "{p.c.0.}" were paid outside the. closing, they are shown here for informational Sumoses and ere not Included Ir the totals, 5. NAME OF BORROWER: — Christopher Manson, a single man Address of Borrewor: 435 NW 124th Street, Miami, Florida 38498 &, NAME OF SELLER: Vincent McKnight, a single men Asidress of Selter: 8915 NW 3th Court, Miami, Florida 93150 Ti: iy E. NAME OF LENDER: Address of Lender: G. PROPERTY LOCATION: 1150 NW 104 Street, Miami, Florida 33150 H. SETTLEMENT AGENT: Torres & Vadiiio, LLP TIN: 04-3753 Place of Settlement: 13402 NW 44st Street, Suite #202, Miami, Florida 33178 Phone: 305-485-0700 1. SETTLEMENT DATE: 122206 DISBURSEMENT DATE: 12/22/08 2. Coninact sales 102. Personal pe 485. Seiement 86,005.00} 407. Contract saies 402. Personal 4,855.00] 403, 404, 405, 405. Cityfiown taxes 66,006.00) io borrower {Line 1400} 405. 108. Ciytown & ES 487. County Taxes from 2/2 | 407. County Taxes from 12/82/08 te 12/3/06 47.89) 8. Assessmecis _ 308, Assaysrnents , Waste from 12/22/06 to ORGD/OT i 409. Waste from 34i. ats. Sit. 4352, A386, Ount due from borrows) Posi Or eamest money a0t, incipal amcant of new icants} 502, Settlement charges to ssiter ding 34003 87,386.05) ting Inan{s} taken eubject fo rae} DUS. Existing icanis} taken sublact to Principal amount of secand [50¢, Payolf of first morieage loan 595. Payolf of second mortgage [aan S08, Deposits held by seller 2 i 507. Pancipal amt of rrarigage held by seller i G fase. Priasipai amt of mortgage held by seiter yitown taxes Daunty Taxes | 514, County Taxes Assessments S12, Assessments 801. Gross amount due to sefter 80,588.05 fine 420} = EXHIBIT 8 362. Less amount paid byMor the borrower S03. Less total reductions in amount due en! i {47,388.085) fine 220} } tine 8203 isoccbie B85. sneer Geis Be, FOF, Remand becrenee Sk Bene Hea, ea. 3OS4, Hecasee foie. Merepegs 88. Be 196, Soe PES. 3085, Arson 1 Prod ees. ee, eRe. ao. 3588, Bethea oF Tie patieat oe Sie Hoy Tee Fea, Ts inciaaree $506. 3 $28%. ey age, hove: 388 335. Eee Radome 88. $48, Pet: a. Wee Pea se be Tiatng Bertin GLP £35, 08 Sess, Best S205 eee one OE ¥ 53S Gee ee 4285, ae Avista UF saemnnnennee Ba REO SIE EXHIBIT 8