The public needs a free press to show them how this accounting fraud works. Their signature cover is to divide and conquer the family they victimize. They make it appear as if the family destroyed itself fighting over money. Please understand that they intentionally destroy your family to coverup their accounting.

 

B&K All
(This is the html version of ALL-B&K (in progress))

B&K letters in pdf from b&k62p (So letters to be put into html):

  • 2012.05.25 Sarah Hall to me 3p DONE
  • 2012.05.31 Sarah Hall to me 1p (enclosure: Revocation of Power of Attorney) DONE
  • 2012.07.25 Sarah Hall to me (email 2:20pm) DONE
  • 2012.08.30 (Filed) Complaint 9p (print elsewhere?)
  • 2012.09.27 Betty Morrogh to me 2p (email 6:19am) DONE
  • 2012.09.28 Betty Morrogh to me 1p (email 11:47am) (Attached 2p) DONE
  • 2012.09.28 Betty Morrogh to me 3p (motion for tempoary injunction) DONE
  • 2013.07.03 Sarah Hall to Sheila and Anthony DONE
  • 2014.04.11 Sarah Hall to Sheila and Anthony 2p DONE
  • 2014.04.16 Sarah Hall to me (email 11:21am) DONE
  • 2014.04.17 Sarah Hall to me 1p (4 enclosures) DONE
    • 2013.01.25 Order by Chief Judge 3p
    • 2013.05.10 letter of intent 3p
    • 2013.06.20 sales contract 14p
    • 2013.09.18 Amendment 4p

 

2012.05.25 Sharon Hall to Anthony O'Connell
hall@bklawva.com
May 25,2012
Certified Mail - Return Receipt Requested
and U.S. First-Class Mail
Anthony M, O'Connell
439 S. Vista Del Rio
Green Valley, Arizona 85614
Re: Accotink Station Property
Dear Mr, O'Connell:
This firm has been retained by your sister Jean O'Connell Nader to represent her with
regard to your family's approximately 15 acre property in Springfield, Virginia identified on the
Fairfax County Tax Map as TM 90-4 «1)) 17. As you know, that property is in a Land Trust of
which you are Trustee and Jean is a beneficiary.
The Trust was established in 1992, the year following your mother's death. In addition to
Jean, its beneficiaries are yourself, your sister Sheila, and a Residuary Trust established by the
Will of your father, its current beneficiaries also being Jean, Sheila, and yourself. We
understand from Jean, and the correspondence at the time clearly confirms, that the family's
intent in establishing the Land Trust was to facilitate the sale of the property. To this end the
beneficiaries of the Land Trust also gave you a Power of Attorney with regard to the property,
Your appointment as Trustee and Attorney in Fact in 1992 made sense since you were the only
one of your siblings living in Virginia at that time.
To Jean's knowledge, during the almost twenty (20) years since you were appointed
Trustee, you have entered into no contract for the sale of the property. There were negotiations
with Bill Lynch, a family friend, and Andy SOtnIJ)ervillein 2007, but they came to naught. You
apparently did not list the property with a real estate broker when you left Virginia some years
ago, and we find no indication that the property is now being marketed.
Fairlax,Virginia WWVtI.BKLAWVA.COM Manassas,Virginia
(Page 2)
Real estate taxes have not been paid on the property since 2009, and Fairfax County has
turned the matter over to a collection agency. As of last month, the total amount due, including
interest and penalties; was $27,650.14. This figure will of course increase every day that the
delinquent taxes are not paid. Eventually Fairfax County could recover the taxes by selling the
property to enforce its-tax lien. As you recall in the past Jean sent you checks for her portion of
the real estate taxes, but you refused to accept them since they were made payable to Fairfax
County rather than to you.
The Land Trust Agreement provides for the expiration of the Trust twenty (20) years
after its establishment if all or any portion of the property remains in the Trust at that time.
Because the Trust was established on October 16, 1992, the date of its expiration is fast
approaching. The interests of you and your sisters would clearly best be protected if the three of
you agreed to and put in effect a plan to sell the property and to pay the overdue real estate taxes.
Such a plan would necessitate an amendment to the Land Trust Agreement or, better yet, an
alternative means of holding legal title to the property.
Since you now live in Arizona and are evidently not willing or able to perform your
fiduciary duties as Trustee, Jean has volunteered to serve as Trustee under an amended or
alternative trust arrangement. Living in Pennsylvania, she is geographically the closest ofthe
beneficiaries to the property, and this firm, which is located in Fairfax City, could assist her in
carrying out her duties as Trustee to manage and, most importantly, to sell the property. Jean has
been in touch with Sheila about this matter.
As counsel for Jean, we advise you that, effective immediately, she is revoking the 1992
Power ofAttorney. A document to that effect will be recorded among the land records of Fairfax
County, and we will send you a copy ofthe recorded document.
Jean has requested that you deal with this law firm rather than directly with her in moving
forward with this matter. Accordingly, we ask that you contact us at your very earliest
convenience. Given the approaching October 16, 2012 deadline for expiration of the Trust and
the real estate tax situation, it is imperative that action on the property not be further delayed. If
we have not heard from you by the end ofJune, Jean will have to consider all alternatives open
to her, including a suit in the Circuit Court of Fairfax County.
As counsel to Jean we look forward to working with you and Sheila in naming Jean as
Trustee and coming up with a plan for selling the property on terms that will benefit all of you.
(page 3)
Best regards.
Yours truely,
Sharon E. Hall

2012.05.31 Sharon Hall to Anthony OConnell
shall@bklawva.com
Anthony M. O'Connell
439 S. Vista Del Rio
Green Valley, Arizona 85614
Dear Mr. O'Connell:
Re: Accotink Station Property
By my letter to you of May 25,2012, I advised you that your sister Jean was revoking the
1992 Power of Attorney which named you as Attorney-in-Fact. Enclosed is a copy of the
Revocation of Power of Attorney which Jean executed and which was recorded yesterday among
the land records of Fairfax County.
Best regards.
Yours truly,
Sarah E. Hall


2012.07.25 Email 2:20pm Sharon Hall to Anthony OConnell
Sarah Hall <shall@bklawva.com>    Wed, Jul 25, 2012 at 2:20 PM
To: Anthony OConnell ~anthonymineroconnelI@gmail.com~
Mr. O'Connell:
Wed, July 25, 2012 at 2:20 PM
While we had earlier received formal confirnmation of your receipt of my letter of May 25, 2012, it was good to
hear directly from you that you had received it.
In your emails you rriention a number of issues regarding the respective estates arid trusts of your parents and
the title to the proprty in the 1992 Land Trust, and you provided a link to a websitc on which you raise more
,questions. We believe these issues were rnooted some time ago by findings of the Cornmissioner of Accounts
and the Circuit Court of Fairfax County.
We were sorry to hear of your recent illness. In light of your ill health and tlie great distance that you live
from the Virginia property, it would seen1 appropriate - and certainly understandable - .for you to resign as
Trustee of the I992 Land Trust.
Best regards,
Sarah Hall

 

2012.09.27 6:19am Betty Van Morrogh to Anthony OConnell
Gmail - Nader v. Anthony O'Connell, et al.
Nader v. Anthony O·Connell, et al.
Betty Van Morrogh <bvmorrogh@bklawva.com>
To: Anthony OConnell <anthonymineroconnell@gmail.com>
Cc: Sarah Hall <shall@bklawva.com>
Dear Mr. O'Connell:
9/27/12 6:31 AM
Thu, Sep 27, 2012 at 6:19 AM
I have received various e-mails from you over the past several days and wanted to clarify one issue that you
raised. As you know, you are named as a defendant in the Complaint filed by Jean Nader in your capacity as
trustee under the Land Trust agreement and in your individual capacity. The substantive claims against you in the
lawsuit arise out of your actions as trustee. You are named as a defendant in your individual capacity because you
are a beneficiary under the Land Trust agreement. As a beneficiary, you are an interested party to the legal
proceedings and must be notified that the lawsuit is pending.
The primary purpose of the lawsuit is to request your removal as trustee under the Land Trust. Are you willing to voluntarily resign as trustee, so that your sister Jean can work to try to sell the Accotink property for the benefit of
you and your sisters? If not, we will continue to seek a resolution of this difficult matter through the court proceedings.
Regards,
Elizabeth Morrogh


2012.09.28 Betty Morrogh to Anthony OConnell (email 11:47am) (Attached 2p)
Please see attached.

2012.09.28 Motion for Temporary Injunction (Attachment) (Prepared by B&K and B&K had Jean Nader sign it)
VIRGINIA:
IN THE CIRCUIT COURT OF FAIRFAX COUNTY
JEAN MARY O'CONNELL NADER,
Plaintiff,
v.
ANTHONY MINER O'CONNELL,
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'ConnelJ, et al.
Defendants.
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 ofapproximately 15 acres located near the Franconia area of Fairfax
County, Virginia.
(page 2)
3. The tenus ofthe Land Trust Agreement provide for the termination of the trust on
October 16,2012 and, upon the tenuination 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 ofthe 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 ofthe date of the filing ofthis 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
agreement.
7. Under the circumstances, the likelihood ofsuccess 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 ofthe Property for the benefit ofthe
beneficiaries ofthe 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 ofcontinuing the term of the Land Trust
until such time as a Final Order has been entered in this case;
(page 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
By Counsel
BLANKINGSHIP & KEITH, P. C.
4020 University Drive
Suite 300
Fairfax, VA 22030
(703) 691-1235
FAX: (703) 691-3913
By:
Elizabeth Chichester Morrogh
VSB 0.25112
Counselfor 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
Elizabeth Chichester Morrogh


2013.07.03 Sharon Hall to Sheila Anthony OConnell WRONGGGGGGGGG
Sarah E. Hall at the law firm of Blankingship and Keith, shall@bklawva.com
Ms. Sheila O'Connell Shevenell
663 Granite Street
Freeport, Maine 04032
Mr. Anthony M. O'Connell
439 S. Vista Del Rio
Green Valley, Arizona 85614
July 3, 2013Property in the Lee District, Fairfax County
TM 90-4 ((1)) 17
Dear Ms. Shevenell and Mr. O'Connell:
This finn is representing your sister Jean O'Connell Nader in her capacity as Successor
Trustee under the Land Trust Agreement dated October 16, 1992. Jean has asked us to bring you
up to date on the actions she has taken with regard to the approximately 15 acre trust property
("Property") identified above since she was appointed Successor Trustee on January 25, 2013.
It was apparent to Jean when she became Successor Trustee that the Property had to be
sold. The delinquent real estate taxes, which had been accruing interest and penalties, were
approaching a total of $30,000, and Fairfax County had turned the matter over to a collection
agency. Jean was advised that ifthe taxes were not brought current, there would eventually be a
tax sale which, given the Property's R-l zoning and the fact a large portion ofthe Property is in
the Resource Protection Area ("RPA"), would in all probability yield only a fraction ofthe
Property's true value.
Jean's first step was to have the Property appraised. She retained a highly regarded local
appraiser to prepare a Restricted Appraisal. Because it is difficult at this point to predict
accurately the density at which the Property may be approved for development, at our instruction
the appraiser provided a value range per townhouse lot. In detennining this range, he assumed
that the Property could be developed with approximately 30 to 39 townhouse units.
(Page2)
While Tony was Trustee he had been in negotiation with Bill Lynch and Andy
Somerville for the sale of the Property. A contract was never signed, but Bill and Andy
apparently did quite a bit of work in exploring how the Property could be developed. Knowing
that Bill and Andy remained interested in the Property, we on Jean's behalf asked them to submit
a non-binding letter of intent which set out the basic terms and conditions under which they
would be willing to purchase the Property. They did so, but Jean concluded that the price
offered was not acceptable. She responded with a counteroffer which was eventually accepted.
A letter of intent was executed on May 24,2013, and we immediately set out negotiating a
binding Real Estate Sales Contract ("Contract") based upon the letter of intent. By June 20,
2013, there was a fully executed Contract between Jean as Successor Trustee and Long Branch
Partners, L.L.C. ("Purchaser"), a limited liability company owned and controlled by Bill and
Andy.
The pertinent provisions of the Contract are as follows:
• There is a 90 day Feasibility Period during which Purchaser will determine
whether to proceed under the Contract or to terminate it.
• In the event Purchaser does not terminate the Contract, within ten (l0) days of
the close of the Feasibility Period, Purchaser shall pay off the delinquent real
estate taxes, and it shall continue to pay the real estate taxes on the Property as
they become due until Settlement or until termination ofthe Contract.
• The repayment of the real estate taxes to Purchaser will be reflected in a nonrecourse
promissory note which Jean will execute as Successor Trustee and
which will be secured by a Deed of Trust against the Property. At Settlement
there will be credited against the purchase price all the real estate taxes which
Purchaser has paid.
• Purchaser will be responsible, at its own expense, for rezoning the Property
and getting its subdivision approved. (The rezoning will be heard by the
Board of Supervisors in a decidedly political context; the subdivision process
is administrative.) Purchaser's obligation to purchase the Property is
contingent upon its getting approval of at least 30 townhouse lots.
• The purchase price will be determined by the number of approved townhouse
lots, the per lot price of $57,500 being the top of the value range established
by the appraiser.
(page 3)
It is anticipated, and the Contract provides, that Settlement will take place in late 2015 or
even early 2016, assuming the contingency is met. While it is unfortunate that Settlement cannot
take place sooner, getting the highest value for the Property necessarily requires having it
rezoned and having its subdivision approved. As noted above, Purchaser will undertake this
effort at its own expense, and that expense will be considerable. Also, while the entitlement
process is moving forward, Purchaser will be paying the real estate taxes on the Property.
Jean is delighted that Purchaser is committed to paying a good price for the Property, as
determined by the appraisal. In addition, because no broker was involved in the transaction, the
Trust will be spared paying a hefty commission out ofthe settlement proceeds.
Bill and Andy appear to be quite excited to have the Property under Contract. They are
experienced developers in Fairfax County and give every indication that they will aggressively
pursue the rezoning of the Property and subdivision approval. At this point there is reason for
cautious optimism that Settlement will eventually take place under the terms and conditions of
the Contract. Please be aware, however, that Settlement is far from certain and that you should
not assume that the contingency will be fulfilled and the Property sold to Purchaser.
We will keep you up to date on Purchaser's progress.
Best regards to you both.
Yours truly,
Sarah E. Hall
SEH/sp
cc: Jean Nader
Elizabeth V. C. Morrogh, Esquire


2014.04.11 Sharon Hall to Sheila Shevenell OConnell and Anthony OConnell
shall@bklawva.com

Ms. Sheila O'Connell Shevenell
663 Granite Street
Freeport, Maine 04032

Mr. Anthony M. O'Connell
439 S. Vista Del Rio
Green Valley, Arizona 85614

April 11, 2014
Re: Property in the Lee District, Fairfax County
TM 90-4 ((1 )) 17
Dear Ms. Shevenell and Mr. O'Connell:
As you recall, by letter of July 3, 2013 we advised you that Jean Nader as Successor
Trustee under the Land Trust Agreement dated October 16, 1992 had entered into a Real Estate
Sales Contract with Long Branch Partners, L.L.C. We gave you a summary of the pertinent
provisions of the Contract, the most important one being that settlement is contingent upon
Purchaser's getting the approximately 15 acre Property rezoned and getting its subdivision
approved. The purpose of this letter is to bring you up to date on what has happened since our
earlier letter was written.
During the Feasibility Period Purchaser determined that extending Thomas Grant Drive
to the Property from Island Creek would be considerably more expensive than it had anticipated.
Not only will the construction costs per se be high, but Purchaser will need to purchase from the
Fairfax County Park Authority slope and temporary construction easements. Purchaser's studies
also indicated that it might not be able to get approval for at least 30 townhouse lots, which the
Contract set as the contingency. Just prior to the end ofthe Feasibility Period Purchaser
requested that the Purchase Price be decreased to offset the cost of the road and that the
contingency be revised to reflect the very real possibility of a lower lot yield. Jean concluded
that it was necessary to amend the Contract to keep Purchaser from terminating. She agreed to
an Amendment to the Contract which provided that the Purchase Price would be $1,250,000 plus
$50,000 for each townhouse lot in excess of 25 and that the contingency would be approval,
through the rezoning and subdivision processes, of at least 25 townhouse lots. While lower than
(page 2)
the original price, the new Purchase Price is within the value range per townhouse lot in the
Restricted Appraisal which Jean commissioned.
With the Amendment in place, the 90 day Feasibility Period closed without Purchaser's
terminating the Contract. In compliance with the Contract's terms, Purchaser paid the delinquent
real estate taxes on the Property and will continue to pay the taxes until Settlement or until the
Contract terminates. Jean signed a Note as Successor Trustee to repay Purchaser for the taxes in
the event the Contract does not close, and the Note is secured by a Deed of Trust on the Property.
It is a great relief to have the tax matter resolved.
In December of 2013 Purchaser submitted to Fairfax County its application to rezone the
Property to the PDH-4 district, but the County did not accept it as "being complete", i.e. in
appropriate form for review, until March 21. The application is now being reviewed by the
various County agencies and the Virginia Department ofTransportation. On a parallel track
Purchaser is continuing to meet with neighboring civic associations and the Lee District Land
Use Committee. The public hearings will begin in the fall-first before the Planning
Commission, which will make a recommendation, and then before the Board of Supervisors,
which will take final action. The Planning Commission hearing has been tentatively scheduled
for October 2. If it in fact takes place then, there would be good reason to expect that the Board
of Supervisors would hear and take action on the application before the end of this year. Should
the rezoning be granted, as we all hope it will be, the next step would be Purchaser's pursuit of
subdivision approval.
Purchaser has along way to go, but it is on its way, and it has a good team of consultants
working toward the granting of its rezoning application. We will keep you advised as to
Purchaser's progress.
Best regards.
Yours truly,
Sarah E. Hall
SEH/jrj
cc: Jean Nader
Elizabeth V. C. Morrogh, Esquire


2014.04.16 Sharon Hll to Anthony OConnell
Sarah Hall <shall@bklawva.com>     Wed, Apr 16, 2014 at 11:21 AM
To: Anthony O'Connell <anthonymineroconnell@gmail.com>
Mr. O'Connell:
We will send you copies of the documents you request. Please confirm that your address is 439 S. Vista Del
Rio, Green Valley, Arizona 85614.
(page 11)
Thank you.
Sarah Hall


2014.04.17 Sarah Hall to Anthony O'Connell
April 17, 2014
CERTIFIED MAIL-RETURN RECEIPT REQUESTED
Mr, Anthony M. O'Connell
439 S. Vista Del Rio
Green Valley, Arizona 85614
Re: Fairfax County Property
Dear Mr. O'Connell:
In response to your request, we enclose copies of the following documents:
1. Order entered by the Circuit Court of Fairfax County, Virginia on January 25,
2013 which appointed Jean Nader as successor trustee under the Land Trust
Agreement dated October 16, 1992, and as trustee of the trust created under the
Last Will and Testament of Harold A. O'Connell;
2. Letter oflntent dated May 10,2013 between Long Branch Partners, L.L.C. and
Jean Nader, Successor Trustee, which by its terms was not a binding agreement;
3. Real Estate Sales Contract dated as of June 20, 2013 between Long Branch
Partners, L.L.C. and Jean Nader, Successor Trustee;
4. Amendment to Real Estates Sales Contract dated as of September 18,2013.
Best regards.
Yours truly,
Sarah E. Hall
SEH/jrj
Enclosures
cc: Jean Nader
Elizabeth V. C. Morrogh, Esquire
(w/o Enclosures)