HomeMy WebLinkAboutQuiet TitleJuelanne Dalzell
JEFFERSON COUNTY PROSECUTING ATTORNEY
Courthouse -- P.O. Box 1220
Port Townsend, Washington 98368
Telephone (360) 385-9180 FAX (360) 385-0073
Jill Landes, Deputy Prosecutor
Michael Haas, Deputy Prosecutor
David W. Alvarez, Deputy Prosecutor
Tracey L. Lassus, Deputy Prosecutor
Lianne Perron-Kossow, Victim Witness Advocate
TO:
FROM:
DATE:
RE:
MEMORANDUM
Michelle Farfan, DCD
David Alvarez, Chief Civil DPA
Friday, November 15, 2002
Arnold & Alison Wood
Quiet Title Action
DEPT. OF COMMUNITY DEVELOPMENT
This will confirm that the Woods have successfully quieted title in themselves with
respect to a certain right-of-way adjacent to real property owned by them in Block 21 of the
Irving Park Addition.
The attached documents are copies of the Orders and Stipulations which reflect the
judicial recognition of quiet title in the Woods for that right-of-way.
Please consider this fact when processing the BLA application filed by the Woods.
David Alvarez
November 13, 2002
W.C. HENRY & SUSAN J. ALLEN
Attorneys at Law
2000 Water Street//P,O. Box 576
Port Townsend, WA 98368
(360) 385-2229
FAX (360) 385-2370
chon rypt(~t3,cablespeed,com
,JEI'FEhouN C:OUNIY _
DI~PT. OF g0MMUNITY DEVELOPM[NI
Mr. David Alvarez,
Deputy Prosecuting Attorney
Jefferson. County Prosecutor's Office
PO Box 1220
Port Townsend WA 98368
RE: Arnold and Alison Wood vs. JeffCo et. al.
Quiet Title against private rights of way, Irving Park Addition
Dear Mr. Alvarez:
We have completed the quiet title action against any and all private rights of way on the
vacated streets around Block 21, Irving Park Addition.
For your use when the Woods' permit application comes through again, I am enclosing
copies of all the private judgments quieting title, and a checklist of dates when the various
judgments were entered.
Thank you for your cooperation in this matter.
Sincerely
HENRY & AL~E~E~
W.C. Henry
cc: clients
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SEP 2 T 2002.
IKIV 18 axa
JDFEHSON COUNTY
DEPT. OF COMMUNITY DEVELOPMENT
02 SEP 26 14:
JEFFERSS?i C-"J' ULi T Y
HAR1ANHE '-,-'FALTERS, CLE2K
BY . DEPT. C!_E~k'
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR JEFFERSON COUNTY
ARNOLD C. WOOD and ALISON E. WOOD, )
individually and as husband and wife and a marital )
community, and WOOD SURVEYING, INC., a )
Delaware Corporation, )
Plaintiffs,
JEFFERSON COUNTY, a municipal corporation; and
SUSAN WARE; and MONIKA J. MARRIOTT; and
JAMES W. & SAUNDRA PERKINS; and JOSEPHINE)
M. SWIFT; and GARY W. KRYSTOFIAK; and )
TIMOTHY FURST & PAUL MAGI]); and JAN )
ANDERSON; and GERALD L. HOOD; and GARETH )
J. PtI~LIPS; and TIMOTHY C. PETERMAN and )
JAMES T. WALTZ; and MICttAEL P. REGAN; and )
ELDEN D. and SHARON F. McKENZlE; and KWO )
HWA TSENG and NORMAN GLASSMAN; and )
ALASKA RESOURCES, INC.; and WILLIAM M. )
CAMPBELL IV and CATHERINE F. CAMPBELL; )
and KATHLEEN MARTINELLI; and UNKNOWN )
AND UNNAMED OWNERS OF LOTS IN IRVING )
PARK ADDITION, )
Respondents. )
)
NO. 02-2-00328-1
STIPULATION AND
JUDGMENT QUIETING
TITLE (PARTIAL)
STIPULATION:
Plaintiffs by and through their counsel of record, and Jefferson County by and through the
ST!YULATION AND J-U-DGMENT - 1
W.C. Henry & S.J. Allen
ATTORNEYS. AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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Jefferson County Prosecuting Attorney, do hereby stipulate and agree as follows:
1. Plaintiffs own real property ih Jefferson County legally described as:
Block 21, Irving Park Addition to the City of Port Townsend as per Vol. 1-of Plats, page
42, records of Jefferson County, Washington, together with the East half of vacated Third
Street adjacent thereto, the West half of vacated Second Street thereto, the South half of
vacated Cedar Street lying between the centerlines of Second and Third Streets, and all of
vacated Florence Street lying between the centerlines of Second and Third Streets, which
by operation of law would attach thereto.
2. The Plat of Irving's Park Addition to the City of Port Townsend was recorded May 5,
1888 in Volume 1 of Plats page 42, Jefferson County, Washington. A true and correct copy of
the Plat is attached as Attachment A. An Amendment to the Plat of Irving Park was recorded on
December 26, 1990 in Volume 6 of Plats page 144, a true and correct copy of which is attached
as Attachment B.
3. The East half of platted Th/rd Street, the West halfofplatted Second Street, the South half
of platted Cedar Street lying between the centerlines of Second and Third Streets, and Florence
Street lying between the centerlines of Second and Third Streets, each adjacent to Block 21,
Irving Park Addition, were statutority vacated by Jefferson County Resolutions #52-93 recorded
in Auditor's File Number 361406 in June 1993, and #3-01 recorded in Auditor's File Number
440058 in January, 2001.
4. At no time since the recording of the Plat of Irving Park in 1888 have the portions of
platted streets described above been opened, developed, improved or actually used as a public
right of way, nor have those portions of the platted streets been used by any other private owner
for a way of necessity or easement.
5. At the time'the Plat was filed, and thereafter until 1909, there was in effect a statute of the
STIPULATION AND JUDGMENT - 2
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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laws of the State of Washington, adopted under Sec. 32, Chapter 19, Laws of 1889-1890, which
read as follows:
Any county road, or part thereof, which has heretofore been or may hereafter be
authorized, which remains unopened for public use for the space of five years after the
order is made or authority granted for the opening of same, shall be and the same is hereby
vacated, and the authority for building the same barred by lapse of time.
6. The effect of that statute was to bar any interest of the public in any street right of way,.
shown on a Plat, which had not been developed for a period of five years after the recording of
the Plat, or in the present case by May 5, 1893.
7. By operation of law, any interest which the public may have had in that portion of the
affected streets adjacent to Block 21 was fully vacated on or about May 5, 1893, because the
streets had not been opened.
8. The County agrees that the public has no further interest in the East half of platted Third
Street, the West half of platted Second Street, the South half of platted Cedar Street lying
between the centerlines of Second and Third Streets, and Florence Street lying between the
centerlines of Second and Third Streets, each adjacent to Block 21, Irving Park Addition,
Jefferson County, Washington.
9. The parties agree to entry of the subjoined Order.
H2EN-RY & ALLEN
w.c. Senry, wSs^%6 4
Attorneys for Plaintiffs
JUELANNE DALZELL
David W. A~varez, WS~
Chief Civil Deputy
Attorney for Jefferson County
STIPULATION AND JUDGMENT - 3
W.C. Henry & S.J.'Allen '
ATTORNEYS. AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-222~
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ORDER:
This matter having come on upon the foregoing Stipulation between the parties, and the
Court being fully advised, it is hereby'
ORDERED, ADJUDGED AND DECREED that the public has no further interest in, or
fight to construct a roadway, within the East half of platted Third Street, the West half of platted
Second Street, the South half of platted Cedar Street lying between the centerlines of Second }nd
Third Streets, and Florence Street Iying between the centerlines of Second and Third Streets, each
adjacent to Block 21, Irving Park Addition, Jefferson County, State of Washington, and it is
hereby ORDERED, ADJUDGED AND DECREED that the Plaintiffs and their heirs, successors
and assigns are hereby vested with fee title in and to those portions of the above'vacated streets,
provided that nothing herein shall eliminate or otherwise affect any private easements, if any,
which may be held by persons or entities other than Jefferson County, whether express or implied,
known or not known, to use the fights-of-way designated above.
Entered this ~ day of September, 2002. u z~~ ,~.ssi~~'-'~J~ on~Ter~'
Presented by:
Attorney for Plaintiffs
Approved for entry, presentation waived:
Attorney for Jefferson County
STIPULATION AND JUDGMENT - 4
W.C. Henry & S.J.'Allen
ATTORNEYS. AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
Name Served NOA Answer Default Judgment
Susan Ware vo tom,/m~old will work ~vith 9-4-02 XX 11-8-02
her for agreement
Monika Marriott 9-4-02 Stipulate 10-17-02
Perkins 9-4-02 XX 11-8-02
Swill sold, discussed with buyers for consent 9-4-02 Stipulate 11-8-02
Krystofiak called 9-5, may con~ent 9-4-02 XX 11-8-02
Furst/Magid 9-4-02 XX 11-8-02
Anderson 9-4-02 XX 11-8-02
Hood called 9-18 9-4-02 XX 11-8-02
Phillips 9-4-02 XX 11-8-02
Peterman/Waltzl 9-4-02 XX 11-8-02
Regan 9-4-02 Stipulate. 10-17-02
McKenzie 9-4-02 Stipulate 10-17-02
Tseng/Glassman 9-4-02 XX 11-8-02
Alaska Resources 9-4-02 XX 11-8-02
Campbell 9-4-02 XX 11-8-02
Martinelli 9-4-02 XX 11-8-02
Jefferson County 8-30-02 9-11-02 9-11-02 Stipulate 9-26-02
Unknown/Unnamed Owners 9-4-02 XX 11-8-02
On all but JC, service by publication or mail is calculated from date of mailing of notice, or date of
first publication, 9/4/02.
Wednesday, November 13, 2002
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,~ 8 ant'9
Y~UU~.
JEFFERSON COUNTY CLER -
IN THE SuPERIoR COURT OF THE STATE OF WASHINGTON
IN AND FOR JEFFERSON COUNTY
ARNOLD C. WOOD and ALISON E. WOOD, )
individually and as husband and wife and a marital )
community, and WOOD SURVEYING, INC., a )
Delaware Corporation, )
Plaintiffs,
Vs.
JEFFERSON COUNTY, a municipal corporation; and
SUSAN WARE; and MONIKA J. MARRIOTT; and
JAMES W. & SAUNDRA PERKINS; and JOSEPHINE)
M. SWIFT; and GARY W. KRYSTOFIAK; and )
TIMOTHY FURST & PAUL MAGID; and JAN )
ANDERSON; 'and GERALD L. HOOD; and GARETH )
J. pHIl.LIPS; and TIMOTHY C.-PETERMAN and )
JAMES T. WALTZ; and MICHAEL P. REGAN; and )
ELDEN D. and SHARON F. McKENZIE; and KWO )
HWA TSENG'and NORMAN GLASSMAN; and )
ALASKA RESOURCES, INC.; and WILLIAM M. )
CAMPBELL IV and CATHERINE F. CAMPBELL; )
and KATHI.EEN MARTINELLI; and UNKNOWN )
AND UNNAMED OWNERS OF LOTS IN IRVING )
PARK ADDITION, )
Respondents. )
)
NO. 02-2-00328-1
DEFAULT JUDGMENT
(WARE; pERKINs;
KRYSTOFIAK; FURST
&.MAGI]); ANDERSON;
HOOD; PHILLH'S;
PETERMAN & WALTZ;
TSENG & GLASSMAN;
ALASKA RESOURCES;
CAMPBELL;
MARTINELLI, AND
UNKNOWN LOT
OWNERS)
JUDGMENT SUMMARY
A. Judgment Tt~: Arnold C. Wood and Alison E. Wood, individually and as husband and wife and
DEFAULT JUDGMENT - 1
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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marital community, and Wood Surveying, Inc., a Delaware Corporation,
B. Judgment Against:
· Susan Ware: Lots 1 thru 10, Block 22, Irving Park Addition (APN 963-302-201)
· James W. Perkins and Saundra Perkins: Lots 4 thru 7, and Lots 3 & 8 less the
North Half, Block 20, Irving Park Addition (APN 963-302-002)
· Gary W. Krystofiak: Lot 3 in Block 9, and also Lots 5 thru 9 and Tax 45 (North
half) in Block 9, and also Lot 10 in Block 9, and also Lots 1 & 2 in Block 8, Irving
Park Addition (APN 963-300-902, and APN 963-300-904, and APN 963-300-
905, and APN 963-300-802) .'
· Timothy Furst and Paul Magid: Lots 1 thru 10, Block 10, Irving Park Addition
(APN 963-301-001)
· Jan Anderson: Lots 3, 8 & 9, Block 8, and also Lots 9 & 10, Block 7, and also
Lots 5 & 6, Block 8, and also Lots 4 & 7, Block 8, Irving Park Addition (APN
963-300-804, and APN 963-300-705, and APN 963-300-801, and APN 963-300-
803)
· Gerald L. Hood: Lot 10 & Tax 45 (S. 1/2), Block 8, Irving Park Addition (APN
963-300-810)
· Gareth J. Phillips: Lots 1 & 2, Block 9, and Lots 9 & 10,. Block 10, Irving Park
Addition (APN 963-300-901; APN' 963-300-705)
· Timothy C. Peterman and James T. Waltz: Lots 9 & 10, Block 7, Irving Park
Addition (APN 963-300-701)
· Kwo Wha Tseng & Norman Glassman: Lots 1 thru 10, Block 5, Irving Park
Addition (APN 963-300-501)
· Alaska Resources Inc.: Lots 1 & 2, Block 6, Irving Park Addition (APN 963-300-
601)
· · William M. Campbell IV & Catherine F. Campbell; Lots 3, 4, 7 & 8, Block 6,
Irving Park Addition (APN 963-300-602)
· Kathleen Martinelli: Lots 5 & 6, Block 6, Irving Park Addition (APN 963-300-
603)
· Unknown and Unnamed Owners of Lots in Irving Park Addition to the City of
Port Townsend.
C. Principal judgment amount . $ 00
D. Interest to date of Judgment $ 00
E. Attorney's fees $ 00
F. Costs $ 00
G: Other recovery amount $ 00
H. Principal judgment shall bear interest at 0 % per annum.
I. Attorney's fees, costs and other recoveqt amounts shall bear interest at 0 % per annum.
J. Abbreviated description of any real property Judgment Award:
Quiet title against private fight of way, prescriptive easement or way of necessity over and
across the East half of platted Third Street, the West half of platted Second Street, the
South half of platted Cedar Street lying between the centeflines of Second and Third
Streets, ~nd Florence Street lying between the centerlines of Second and Third Streets,
DEFAULT JUDGMENT - 2
W.C. Henry & SJ. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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each adjacent to Block 21, Irving Park Addition, Jefferson County, Washington. (APN
963~302-101, 963-302-102, 963-302-104, 963-302-105, 963-302-106, 963-302-107,
963-302~108, and 963-302-110).
L. Attorney for Judgment Holder: Henry & Allen
M. Attorney for Judgment Debtor: None
This matter coming on regularly before the Court this day, plaintiffs appearing by their
attorney; and it appearing that Service by Mail was made upon the Defendants Ware, Perkins, -
Krystofiak, Furst, Magid, Anderson, Hood, PhilliPs, Peterman, Waltz, Tseng, Glassman,
Alaska Resources Inc., Campbell and Martinelli, and that Service by Publication was made
upon the Unknown and Unnamed Owners of Lots in Irving Park Addition, as required by
law; that the time for answering by or on behalf of each defendant has expired; that each and all
.the defendants are wholly in default, and the court, having considered the evidence and having
heard and entered its Findings of Fact and Conclusions of Law,
NOW THEREFORE, IT IS HEREBY ORDERED, ADJUDGED AND DECREED
1. That fee simple title in and ~to lands and premises in Jefferson County, Washington
described as:
The East half of platted Third Street, the West half of platted Second Street, the South
half of platted Cedar Street lying between the centerlines of Second and Third Streets, and
Florence Street lying between the centerlines of Second and Third Streets, each adjacent
to Block 21, Irving Park Addition as per Vol. 1 of Plats, page 42, records of Jefferson
County, Washington (APN 963-302-101, 963-302-102, 963-302-104, 963-302-105,
963-302-106, '963-302-1'07, 963-302-108, and 963-302-110)
be and the same is hereby quieted, established, and confirmed in Arnold C. Wood and Alison E.
Wood, individually and as husband and wife and a marital community, and Wood Surveying, Inc.,
a Delaware Corporation, against any and all private rights of way, ways of necessity or
prescriptive easements.
DEFAULT JUDGMENT - 3
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St ! P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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'2. IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that each and all of the
defendants, and all other persons or parties unknown, claiming any right, title, estate, lien, or
interest in or to the said real estate or any portion thereof, and all persons cIaiming under the
defendants, or any of the them, be and they are hereby forever barred from having or asserting any
right, title, estate, lien, or interest in the property or any part thereof adverse tothe plaintiffs.
DATED November ~ 2002
Presented by:
HENRY & ALLEN
Attorney for Plaintiffs
'~iOUA$ J. ~
JUDGE/COURT COMMISSIONER
DEFAULT JUDGMENT - 4
W.C.' Henry & SJ. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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NOV 8 ..... -
JEFFERSON COUNTY CLERK
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR JEFFERSON COUNTY
ARNOLD C. WOOD and ALISON E. WOOD, )
individually and as husband and wife and a marital )
community, and WOOD SURVEYING, INC., a )
Delaware Corporation, )
Plaintiffs,
Vs.
JEFFERSON COUNTY, a municipal corporation; and
SUSAN WARE; and MONIKA J. MARRIOTT; and
JAMES W. & SAUNDRA PERKINS; and JOSEPHINE)
M. SWIFT; and GARY W. KRYSTOFIAK; and )
TI-MOTHY FURST & PAUL MAGI]); and JAN )
ANDERSON; and GERALD L HOOD; and GARETH )
J. PHILLIPS; and TIMOTHY C. PETERMAN and )
JAMES T. WALTZ; and MICHAEL P. REGAN; and )
ELDEN D. and SHARON F. McKENZ[E; and KWO )
HWA TSENG and NORMAN GLASSMAN; and )
ALASKA RESOURCES, INC.; and WILLIAM M. )
CAMPBELL IV and CATHERINE F. CAMPBELL; )
and ~THLEEN MARTINELLI; and UNKNOWN )
AND UNNAMED OWNERS OF LOTS IN HIVING )
PARK ADDITION, )
Respondents. )
)
NO. 02-2-00328-1
JUDGMENT SUMSqARY
(PARTIAL)
(SWIPT)
JUDGMENT SUN,MARY
A. Judgment To: Arnold C. Wood and Alison E. Wood, individually and as husband and wife and
PARTIAL JLrDGM3~NT SUMMARY - 1
W.C. Henry & S.J.'Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385~2229
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a marital community, and Wood Surveying, Inc., a Delaware Corporation,
B. Judgment Against: Josephine Swift and her successors Deron Graham and Leonie Wilson
C. Principal judgment amount $ 00
D. Interest to date of Judgment $ 00
E. Attorney's fees $ 00
F. Costs .~. $ 00
G. Other recovery amount $ 00
H. Principal judgment shall bear interest at 0 % per annum.
I. Attorney's fees, costs and other recovery amounts shall bear interest at 0 % per annum.
J. Abbreviated description of any real property Judgment Award:
Quiet title against private right of way, prescriptive easement or way of necessity over and
across the East half o£ platted Tlrird Street, the West half of platted Second Street, the
South half ofplatted Cedar Street lying between the centerlines of Second and Third
Streets, and Florence Street lying'between the centerlines of Second and Third Streets,
each adjacent to Block 21, Irving Park Addition, Jefferson County, Washington. (APN
963-302-I01, 963-302-102, 963-302-104, 963-302-105, 963-302-106, 963-302-107,
963-302-108, and 963-302-110).
L. Attorney for Judgment Holder: Henry & Allen
M. Attorney for Judgment Debtor: None
DATED: November 4, 2002
HENRY & ALLEN, Attorneys
W. C. Henry, WSBA 4642
Attorney for Plaintiffs
PARTIAL JUDGMENT SUM/v~Y - 2
W.C. Henry & S.J.'Alten
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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IN THE SUPERIOR COURT OF THE STATE
IN AND FOR JEFFERSON COUNTY
ARNOLD C. WOOD and ALISON E. WOOD, )
individually and as husband and wife and a marital )
community, and WOOD SURVEYING, INC., a )
Delaware Corporation, )
Plaintiffs, )
)
Vs. )
)
JEFFERSON COUNTY, a municipal corporation; and )
SUSAN WARE; and MONIICA 3'. MARRIOTT; and ')
JAMES W. & SAUNDRA PERK_~S; and JOSEPHINE)
M. SWIFT; and GARY W. KRYSTOFIAK; and )
TI]VIOTHY FURST & PAUL I~AG][I); and JAN )
ANDERSON; and GERALD L HOOD; and GARETH )
J. PHILLH~S; and TIMOTHY C. PETERMAN and )
JAMES T. WALTZ; and MICHAEL P. REGAN; and )
ELDEN D. and SHARON F. McKENZIE; and KWO )
HWA TSENG and NORMAN GLASSMAN; and )
ALASKA RESOURCES, INC.; and WILLIAM M. ).
CAh'[lPBELL IV and CATHERINE F. CAMPBELL; )
and KATHLEEN MARTINELLI; and UNKNOWN )
AND UNNAMED OWNERS OF LOTS IN IR~,qSNG )
PARK ADDITION, ')
Respondents. )
)
NO. 02-2-00328-1
STI~ULATION AND
JUDGMENT FOR
PLAINTIFF FOR
QUI~T'~LE (PART/AL)
(Swift)
Parties to tiffs action, as witnessed by their signatures, stiPulate to the entry of a judgment
in this action, as set out below:
STIPULATION TO J-UDGM~NT - 1
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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1. Deron Graham and Leonie M. Wilson, successors in title to Josephine M. Swift and the
owners of Lot 4, Block 9, Irving Park Addition to the City of Port Townsend, as per Vol. 1 of
Plats, page 42, records of Jefferson County, Washington. (APN 963-300-903), agree that they
have and claim no private right of way, prescriptive easement or way of necessity over and across
the East half of platted Third Street, the West half of platted Second Street, the South haLf of
platted Cedar Street lying between the centerlines of Second and Third Streets, and Florence
Street lying between the centerlines of Second and Third Streets, each adjacent.to Block 21,
Irving Park Addition, Jefferson County, Washington.
2. Judgment is hereby entered that title is quieted to Plaintiffs ARNOLD C. WOOD and
ALISON E. WOOD, individually and as husband and wife and a marital community, and
WOOD SURVEYING, INC., a Delaware Corporation, against any private rights of way,
prescriptive easements or ways of necessity against Josephine Swift, or Deron Graham and
Leonie M. Wilson, who shah have no further interest in the East half or'fatted Third Street, the
West half of platted Second Street, the South half of platted Cedar Street lying between the
centerlines of Second and Third Streets, and Florence Street lying between the centerlines of
Second and Third Streets, each adjacent to Block 21, Irving Park Addition, Jefferson County,
Washington.
3. Upon entry of this judgment, these defendants are further discharged from this case.
TH(~A,S j. ~qAJHA~
DATED: /,/- J~- d L
Judge/Court Commissioner
Presented by:
W'.C. Henry, WSBA 4642
STIPULATION TO JUDGMENT - 2
W.C. Henry'& S.J.'Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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Attorney for Plaintiffs
Agreed, and judgment may be entered..
without further notice or presentj~on:
Leonie M. Wilson
State of Washington
County of Jefferson
of
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Subscribed and signed before me by Deron Graham and LeoNe M. Wilson this ~day
2002.
t10'[ AP,¥ -'" ?OBLI¢
I1~ C011111~101{ Ill:~t~$
'otary Public-in and fi)a4'he State of
!ast'dngton residing at
ommission expires: /~2
STIPULATION TO JUDGMENT - 3
W.C. HemT & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(3'60) 385-2229
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR JEFFERSON COUNTY
ARNOLD C. WOOD and ALISON E. WOOD,
individually and as husband and wife and a marital
community, and WOOD SURVEYING, INC,, a
Delaware Corporation,
Plaintiffs,
Vs.
JEFFERSON COUNTY, a municipal corporfition; and
SUSAN WARE; and MONIKA J. MARRIOTT; and
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JAMES W. & SAUNDRA PERKINS; and JOSEPHINE)
M. SWIFT; and GARY W. ~--RYSTOFIAK; and )
TIiVlOTHY FURST & PAUL MAGH); and JAN )
ANDERSON; and GERALD L. HOOD; and GARETH )
J. PHIl,LIPS; and TI~IOTHY C. PETERNI_AN and )
JAMES T. WALTZ; and MICHAEL P. REGAN; and )
ELDEN D. and SHARON F. McKENZIE; and KWO )
HWA TSENG and NORMAN GLASSMAN; 'and )
ALASKA RESOURCES, INC.; and WILLIAM M. )
CAMYBELL IV and CATHERENE F. CAMPBELL; )
and KATH_LEEN MARTINELLI; and UNKNOWN )
AND UNNAMED OWNERS OF LOTS IN IRVENG )
PARK ADDITION, )
Respondents. )
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NO. 02-2-00328-i
STIPULATION AND
JUDGMENT FOR
PLAINTIFF FOR
QUIET TITLE (PARTIAL)
(Regan)
Parties to this action, as witnessed by their signatures, stipulate to the entry of a judgment
in this action, as set out below:
ST~ULATION TO JUDGMENT - I
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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1. Michael P, Regan as the owner of Lots 4 & 5, Block 7, Irving Park Addition to the City of'
Port Townsend, as per Vol. 1 of Plats, page 42, records of Jefferson County, Washington. (APN
963-300-702) as the owners of Lots 6, 7 & 8, BIock 7, Irving Park Addition to the City of Port
Townsend, as per Vol. I of Plats, page 42, records of Jefferson County, Washington (APN 963-
300-703), has and claims no private right of way, prescriptive easement or way of necessity over
and across the East half of platted Third Street, the West half of platted Second Street, the South
haIf of platted Cedar Street lying between the centerlines of Second and Third Streets, and
Florence Street lying between the centerlines of Second and Third Streets, each adjacent to Block
21, Irving Park Addition, Jefferson County, Washington.
2. Judgment is hereby entered that title is quieted to Plaintiffs ARNOLD C. WOOD and
ALISON E. WOOD, individually and as husband and wife and a marital community, and
WOOD SURVEYD~G, DIC., a Delaware Corporation, against any private rights of way,
prescriptive easements or ways of necessity against Michnel P. Regan who shall have no further
interest in the East half of platted Third Street, the West half of platted Second Street, the South
half of platted Cedar Street lying between the centerlines of Second and Third Streets, and
Florence Street lying between the centerlines of Second and Third Streets, each adjacent to Block
21, Irving Park Addition, Jefferson County, WasNngton
3. Upon entry of this judgment, these defendants ~d fron)~
are further ' ed fron s case.
Juti e/C urtq2ommi;'sior r
Presented by:
W.C. Hen~
STIPULATION TO JUDGMENT - 2
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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Agreed, and judgment may be entered
~/)u)~urther, notic r prps~ntation:
i~iehael P. Rega~
State of Washington )
County of Jefferson )
2002.
Subscribed and signed before me by Michael P. Regan this
~ day of. ,5~_~. ,
~t~Public in an~for ihe State of
Washington residing at
Commission expires: ~e_~-, _ o~ 0-5---'
STIPULATION TO JUDGMENT - 3
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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II
IN THE SUPERIOR COURT OF THE STATE OF WASH.UNGTON
IN AND FOR JEFFERSON COUNTY
ARNOLD C. WOOD and ALISON E. WOOD, )
individually and as husband and wife and a marital )
community~ and WOOD SURVEYENrG, hNC., a )
Delaware Corporation, )
Plaintiffs,
Vs.
JEFFERSON COUNTY, a nmnicipal corporation; and
SUSAN WARE; and MONIKA J. MARRIOTT; and
JAMES W. & SAUNDRA PERKINS; and JOSEPHEN;E)
M. SWIlrT; and GARY W. KRYSTOFIAK; and )
TB/IOTIIY FURST & PAUL MAGID; and JAN )
ANDERSON; and GERALD L. HOOD; and GARETH )
J. PHILLIPS; and TIMOTHY C. PETERMAN and )
JAMES T. WALTZ; and MICHAEL P. REGAN; and )
ELDEN D. and SHARON F. McKENZIE; and KWO )
HWA TSENG and NORMAN GLASS.MAN; and )
ALASKA RESOURCES, INC.; and WILLIAM M. )
CAMPBELL IV and CATHERINE F. CAMPBELL; )
and KATtqLEEN MARTINELLI; and UNKNOWN )
AND UNNAMED OWNERS OF LOTS ~ IRVING )
PARK ADDITION, )
Respondents. )
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NO. 02-2-00328-1
STIPULATION AND
J-Uq)GMENT FOR
PLAINTIFF FOR
QUINT TITLE (PARTLaJ~)
(Marriott)
Parties to this action, as witnessed by their signatures, stipulate to the entry of a judgment
ti'ds action, as set out below:
STIPULATION TO JUDGMENT - 1
W.C, Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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1. Monika J. Marriott as the owner of Lots 1 & 2, and the North half of Lots 3 & 8, and Lots
9 & 10, Block 20, lying Easterly of Old Discove~ Road, Irving Park Addition to the City of Port
Townsend, as per Vol. 1 of Plats, page 42, records of Jefferson County, Washington, together
with those portions of Third Street and Alder Street that would attach thereto by operation of the
law (APN 963-302-001), has and claims no private right of way, prescriptive easement or way of
necessity over and across the East half of platted Third Street, the West half of platted Second
Street, the South half of platted Cedar Street lying between the centertines of Second and Tkird
Streets, and Florence Street lying between the centerlines of Second and Third Streets~ each
adjacent to Block 21, Irving Park Addition, Jefferson County, Washington.
2. Judgment is hereby entered that title is quieted to Plaintiffs ARb'OLD C. WOOD and
ALISON E. WOOD, individually and as husband and wife and a marital community, and
WOOD SURVEYL-NG, L-N'C., a Delaware Corporation, against any private rights of way,
prescriptive easements or ways of necessity against Monika Marriott who shall have no further
interest in the East half of platted Third Street, the West half of platted Second Street, the South
half of platted Cedar Street lying between l~he centerlines of Second and Third Streets, and
Florence Street lying between the centerlines of Second and Third Streets, each adjacent to Block
21, Irving Park Addition, Jefferson Count5,, Washington
3. Upon entry of this judgment, this defendant is further dis~ from this/x~e_~,~ ..
Presented by:
W.C. Henry, WSB/~'~2
STIPULATION TO IUT)GNIENT - 2
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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Attorney for Plaintiffs
Agreed, and judgment may be entered
without further notice or presentation:
lVIonika Marriott
State of Washington )
)SS:
County of JetTerson )
Subscribed and signed before me by Monika Marriott this 73' -~ay of
2002.
Notary Public in and for the State of
Washington residing at /q~.,.2d/~,~.~ r-~.,~
Commission expires: /? -<~/-d 5~
STB°ULATION TO JUDGMENT - 3
W.C, Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR JEFFERSON COUNTY
ARNOLD C. WOOD and ALISON E. WOOD, )
individually and as husband and wife and a marital )
community, and WOOD SURVEYING, INC., a )
Delaware Corporation, )
Plaintiffs, )
V$o
JEFFERSON COUNTY, a municipal corporation; and
SUSAN WARE; and.MONllCA J. MARRIOTT; and
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JAMES W. & SAUNDRA PERKI1NS; and JOSEPHINE)
M. SWIFT; and GARY W. KRYSTOFiAK; and )
TIMOTHY FURST & PAUL MAGID; and JAN )
ANDERSON; and GERALD L HOOD; and GARETH )
J. PHI~LLIPS; and TIMOTHY C. PETERMAN and )
JAMES T. WALTZ; and MICHAEL P. REGAN; and )
ELDEN D. and SHARON F. McKENZYE; and KSVO )
ITWA TSENG and NORMAN G'LASSMAN; and )
ALASKA RESOURCES, ~NC.; and WILLIAM M. )
CAMPBELL IV and CATHERINE F. CAMPBELL; )
and KATHLEEN MARTINELLI; and UNKNOWN )
AND UNNAMED OWNERS OF LOTS IN IRVENG )
PARK ADDITION, )
Respondents. )
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NO. 02-2-00328-1
STI]PULATION AND
JUDGMENT FOR
PLAINTIFF FOR
QUImT TITLE (PARTIAL)
(McKenzie)
Parties to this action, as witnessed by their signatures, stipulate to the entry' of a judgment
in this action, as set out below:
STH:'ULATION TO JUDGMENT - I
W.C. Henu: & S.J, Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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1. Elden D, & Sharon F, McKenzie as the owners of Lots 6, 7 & 8, Block 7, Irving Park
Addition to the City of Port Townsend, as per Vol. 1 of Plats, page 42, records of Jel%rson
County, Washington (APN 963-300-703), have and claim no private right of way, prescriptive
easement or way of necessity over and across the East half of platted Third Street, the West half
of platted Second Street, the'South half of platted Cedar Street lying between the centerlines of
Second and Third Streets, and Florence Street lying between the centerlines of Second and Third
Streets, each adjacent to Block 21, Irving Park Addition, Jefferson County, Washington.
2. Judgment is hereby entered.that title is quieted to Plaintiffs ARNOLD C. WOOD and
ALISON E. WOOD, individually and as husband and wife and a marital community, and
WOOD SURVEYING, [NC., a Delaware Corporation, against any private rights of'way,
prescriptive easements or ways of necessity against Elden D. & Sharon F. McKenzie who shall
have no further interest in the East half of platted Third Street, the'West half of platted Second
Street, the South half of platted Cedar Street lying between the centerlines of Second and Third
Streets, and Florence Street lying between the centerlines of Second and Third Streets, each
adjacent to Block 21, Irving Park Addition, Jefferson County, Washington
5. Upon entry of this judgment, these defendants are further~t~harged from this case.
:4udg4 Co commi ,io/.e.
Presented by:
.C. Henry, WSBA'M'6~2
Attorney for Plaintiffs
Agreed, and judgment may be entered
STIPULATION TO JUDGMENT - 2
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229
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without fuah.~4, notice or presentation:
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State ofWashin~on )
)SS:
County of Mason )
Subscribed and signed before me by Elden D. McKenzie and Sharon F. McKenzie this
-)ay of ,~~ ,2002.
Notary Public in an~'for the State of
Washington residing at
Commission expires:
STIPULATION TO JUDGMENT - 3
W.C. Henry & S.J. Allen
ATTORNEYS AT LAW
2000 Water St / P.O. Box 576
Port Townsend, WA 98368
(360) 385-2229