Illegal takeover of Accotink and Farm
after I tried to expose the accounting at bk467p191
by posting http://www.canweconnectthedots.com
Seventeen (17) of my eighteen (18) responses to the Complaint against me disappeared after being received by the Court.
At least 4 of the 17 included a copy of the Trust Deed at bk8307p1446 which says "Anthony Miner O'Connell, Trustee," owns the Trust property in fee simple. This Deed has been ignored since 1992.
The images below are the first page of each of my 18 responses. The link below each image is to a complete copy of the response in PDF. The only protection the public has against this accounting fraud is to recognize the patterns before it's too late.
(Above) This is the front page of the one (1) response apparently recognized as being received by the Court. It was received by the Court on 9/24/2012 at 10:01 AM.
Rodney Bass signed for it. It weighed 12 ounces and cost $18.95. USPS EI637303496. Please click the link http://www.chiefjudgesmith.com/18responses/overview62p.pdf and compare what you see with that of B&K's Elizabeth Chichester Morrogh's September 28, 2012, description of it:
information and belief, Defendant Anthony M. O'Connell has filed a response to the Complaint, which consisted of a one-page letter directed to the Clerk of Court, and the filing of numerous documents and records containing his annotations."
(Below) The following pages are the front pages of my seventeen (17) responses that vanished after being received by the Court on 9/25/2012 at 10:44 AM. Stephanie Walker signed for it. It weighed 6 lbs and 1 oz and cost $62.85. USPS EI480187651US
(Below) How far would the public have to go before they find a just power who would, for example, recognize the 1992 Trust Deed or say why it should not be recognized? http://www.book8307page1446deed.com . The recipients in the email below are a suggested start.
BLANKINGSHIP & KEITH, P. C., September 28, 2012
IN THE CIRCUIT COURT OF FAIRFAX COUNTY
JEAN MARY O'CONNELL NADER,
Individually and in his capacity as
Trustee under a Land Trust Agreement
Dated October 16, 1992 and as
Trustee under the Last Will and
Testament of Harold A. O'Connell, et al.
Case No. 2012-13064
MOTION FOR TEMPORARY INJUNCTION
COMES NOW the Plaintiff, Jean Mary O'Connell Nader, by counsel, and moves this
Court pursuant to Va. Code § 8.01-629 for a temporary injunction for the purpose of continuing
the term of the Land Trust pending a Final Order in this action. In support of her motion,
Plaintiff states the following.
I. This is an action by which Plaintiff seeks to, inter alia, remove Defendant
Anthony M. O'Connell as trustee under a Land Trust Agreement dated October 16, 1992 (the
"Land Trust"). The beneficiaries under the Land Trust are Plaintiff and her siblings, Defendants
Sheila O'Connell and Anthony M. O'Connell, individually.
2. As alleged in the Complaint, the Land Trust holds title to certain real property
(the "Property") consisting of approximately 15 acres located near the Franconia area of Fairfax
(page 2 of 3)
3. The terms of the Land Trust Agreement provide for the termination of the trust on
October 16,2012 and, upon the termination date, the trustee is directed to convey record title of
the Property to the beneficiaries or sell the Property at a public sale.
4. A conveyance of the Property to the beneficiaries or a public sale of the Property
before a Final Order has been entered in this case would result in irreparable harm to the
Plaintiff, as a beneficiary of the Land Trust.
5. As of the date of the filing of this Motion, Defendant Sheila O'Connell has been
served with the Complaint and the time period for her to file an answer is pending. Upon
information and belief, Defendant Anthony M. O'Connell has filed a response to the Complaint,
which consisted of a one-page letter directed to the Clerk of Court, and the filing of numerous
documents and records containing his annotations.
6. By his own admission, Defendant Anthony M. O'Connell, as trustee, has not paid
the real estate taxes on the Property or sold the Property, contrary to the terms in the Land Trust
7. Under the circumstances, the likelihood of success on the merits and the balance
of equities favor the Plaintiff
8. It is in the public interest to allow the Trust to continue in order for Plaintiff to
pursue a remedy that will allow for the orderly sale of the Property for the benefit of the
beneficiaries of the Trust.
WHEREFORE, Plaintiff Jean O'Connell Nader, by counsel, respectfully requests the
entry of an Order as follows:
A. Providing injunctive relief in the form of continuing the term of the Land Trust
until such time as a Final Order has been entered in this case;
(page 3 of 3)
B. Enjoining Anthony M. O'Connell, as trustee under the Land Trust Agreement,
from conveying record title of the Property to the beneficiaries or selling the
Property at a public sale; and
C. For all such further relief as this Court deems reasonable and appropriate.
JEAN MARY O'CONNELL NADER
BLANKINGSHIP & KEITH, P. C.
4020 University Drive
Fairfax, VA 22030
FAX: (703) 691-3913
th Chichester Morrogh
VSB No. 25112
Counsel for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that on this 28th day of September, 2012, a true and correct copy of
the foregoing Motion for Temporary Injunction was sent as follows:
By regular and electronic mail to:
Anthony Miner O'Connell
439 S. Vista Del Rio
Green Valley, AZ 85614
By regular mail to:
Sheila Ann O'Connell
663 Granite Street
Freeport, ME 04032
(seal) Elizabeth Chichester Morrogh
Elizabeth Chichester Morrogh
Chief Judge Dennis J. Smith, January 25. 2013
(Note: I believe "are deemed
to be admitted by Defendant" means Judge Smith says I'm guilty)
THIS CAUSE eame on to be heard upon the motion of the Plaintiff, Jean Mary
O'Connell Nader, by counsel, for summary judgment pursuant to Va. Sup. Ct. Rule 3:20; upon
the reply to the motion filed by Sheila Ann O'Connell, pro se; and upon the argument of counsel;
IT APPEARING TO THE COURT as follows:
1. The material facts set forth in the Complaint filed by Plaintiff in this action are deemed to be admitted by Defendant Anthony M. O'Connell pursuant to Va. Sup. Ct. Rule
1:4(e);- based on the failure of Defendant Anthony M. O'Connell to deny such facts in the
responsive pleading filed by him, entitled "Response to Summons Served on September 8,
2. In her Answer to the Complaint and Reply to Motion for Summary Judgment, the
remaining party-in~interest, Defendant Sheila Aim O'Connell, agrees with the facts set forth in
the Complaint and the relief requested by Plaintiff.
3. Because there are no material facts in dispute in this action and the facts alleged
in the Complaint support the relief requested therein, summary judgment pursuant to Va. Sup.
Ct. Rule. 3:20 on all counts alleged in Plaintiffs Complaint is appropriate.
IT IS THEREFORE ORDERED:
A. That judgment in favor of Plaintiff Jean Mary O'Connell Nader as to Count 1 of
the Complaint be, and hereby is, granted; that Anthony Miner O'Connell is hereby removed as
trustee under the Land Trust Agreement dated October 16, 1992, pursuant to Va. Code § ·64.21405
(formerly Va. Code § 26-48), effective immediately; and that all fees payable to Anthony
Minor O'Connell under the terms of the Land Trust Agreement, including but not limited to, the
trustee's compensation under paragraph 9~01, and all interest on advancements by the trustee to
the trust for payment of real estate taxes pursuant to paragraph 9.03; are hereby disallowed and
B. That judgment in favor of Plaintiff Jean Mary O'Connell Nader as to Count II of
the Complaint be, and hereby is,granted; that Anthony Minor O'Connell is hereby removed as
trustee of the trust created under the Last Will and Testament of Harold A. O'Connell, pursuant
to Va. Code § 64.2:-759 (formerly Va. Code § 55-547.06), effective immediately;
C. That judgment in favor of PlaiIitiff as to Count III oft he Complaint be, and
hereby is, granted; that Plaintiff Jean Mary O'Connell Nader is here by appointed as successor
trustee under the Land Trust Agreement and as trustee of the trust under the Last Will and
Testament of Harold A. O'Connell; that the term of the Land Trust Agreement is hereby
continued until further Order of this Court or until the real property held under the Land Trust is
sold and final distribution of the net proceeds is made to the trust's beneficiaries, whichever
occurs first; and that Plaintiff, as successor trustee Under the Land Trust Agreement, shall
proceed forthwith to sell the real property held by such trust as soon as reasonably practicable
upon such terms and conditions as she deems appropriate and consistent with her fiduciary
D. That Plaintiff is hereby awarded reasonable attorney's fees and costs in this
action in the amount of $ l7,504.12, to be paid from the Land Trust at such time as funds
ENTERED this 25th day of January, 2013.
Judge Dennis J. Smith
Comment: Why do the Motion and Order not recognize, for example, the Trust Deed in 5 of the Trustee's 18 responses?
- overview62p (Includes all 7 pages of Deed)
- overview72p (Includes all 7 pages of Deed)
- trust-deed-invisible175p (Includes all 7 pages of Deed)
- trust-documents42p (Includes all 7 pages of Deed)
- unknown14p (First 3 pages of Deed)
http://www.chiefjudgesmith.com/18responses/overview62p.pdf (Includes Deed)
http://www.chiefjudgesmith.com/18responses/10-overview72p.pdf (Includes Deed)
http://www.chiefjudgesmith.com/18responses/14-trust-deed-invisible175p.pdf (Includes Deed)
http://www.chiefjudgesmith.com/18responses/15-trust-documents42p.pdf (Includes Deed)
http://www.chiefjudgesmith.com/18responses/16-unknown14p.pdf (Includes text of Deed)