Court Order - Keith, Mildred_10/2/1970\�.
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STATE OF INDIAP;A �
; �?asor, coun�rr o�T 6; i970
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PETITIO� TO QUIET TITLE TO REAL EST ���� .
AGAINST THE STATE OF INUTA�A
?o Tiie Honoraole Roy O�,iens
Auditor of Gibson County
Prirceton, Indiana
South Construction Company, Inc., by its duly authorized
at�orneys, does present znd fi7e here�•rith, in duplicate, tne claim
of ovmership of Mrs. -tdildred Keitn to the .follo�•iing dascribed
'ands situated in Ptontgomery To�:rnship, Gibson County, Indiana:
TNE P;ORTHEAST QUARTER OF THt i�ORTH!dEST QUARTER
Or StCTIO�� 9,.T0'rlf;SHIP 2 SOUTH, P.At;GE 72 :•;tST,
and her proof of possession thereof under claim of o�,rnership by
open, notorious, continuous, uninterrupted, adverse possession
as provided by the lat•rs of the state of indiana. Said claim and
proor are �iled in accordance arith the provisions of Chapter i62
of the Acts of 1931 (being Sections 3-1411 et seg. of Durns Indiana
r',nnotated Staiutes), and the Auditor of Gibson Courity is respect-
fuliy requested, as provided in Section 3-1413 of 6urns Indiana
Hr,rotated Statutes, to transmit one of sucn duplicate copies to—
tne Fuditor of the state of Indiana together :•iith any proof now of
record in the office of tne Gibson County kuditor of any clair
that the state of Indiana may have to such land, all as provided
in Section 3-1413 of 3urns Indiana Annotated Statutes.
The petitioner herein has succeeded to the benefits of a
contract iai th the sai d �lrs. i�'i 1 dred Kei th for the purchase of tne
a`oresaid lands, among others, ard expects to acquire title tnereto
from said t•1rs. hiildred Keith and is thereby ir�terested in the
relief prayed herei
Dated_this ��day of October, 1970.
E;I�I�O�I, EMlSON & DOOL!iTL[
P. O. 5ox 2i5
Vi�cennes, Ir.dicna 47591
Pncr.o (212) ES2-2220
EWIS ", E' SOF; & D00 IT E
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Fttorneys for petition r,
South Construction Company, Inc.
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!�erification
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Tnomas S. Emison, being first duly sviorn upon oath, deposzs
and says that he is one of the attorneys for the petitioner,
South Construction Company, Inc., and as such is duly authorized
to and does make the viithin verification and that all the facts and
matters set out i he foregoing petition are true.
Dated this� day of October, 1970.
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T omas S. Emison
Subscribed ard sworn to before me this a Q day of October, 1970.
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t•1y:commission expires:
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Septemoer- 13, 1974.
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�ftTea Laakma , hotary Pu i6�'c
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AFFIDAVIT OF ADVERSE POSSESSIC('J
TO BAR CLAIt•1 OF STATE
State of indiana
County of Daviess, ss;
i�irs, i•iildred Keith, being first duly s�•�orn upon oath,
deposes and says:
l. She is more than t�•ienty-one years of age and resides
at 11U1 East t•lalnut in the city of Wasiiington, Uaviess Courty,
Indiana.
2. The affiant is, as of the date iiereof, tne omner of
record of the -follo�•iing described land situated in hlontgor�ery
Townsiiip, Gibson County, Indiana: - - - - —
The ��ortheast Quarter of ti�e t;ortnt•rest Quarter of
Section 9, To�•+nshiP 2 South, Range 12 4lest.
3. This affi.davit is made pursuant to ti�e provisions o`
Section 3-1Gll, et seg., of [3urns Indiana Fnnotated Statutes re-
lating to lands formerly vested in tiie state o` Indiara and pro-
viding that the title to such lands may be sey at rest in an in-
dividual claimant as aoainst any claim of titie to such real estaie
by tne state of Indiana and barring the stat2 of Indiara from after.-
ti�iards setting up.or asserting any title to such real estai.e, and,
in support t'riereof; _the affiant does no�•i depose as follot•is:
3:01. Tiile to the aforesaid real estate �•ias formeriy
vested in the state of.Indiana as "S�•+amp Lands" under the provisiors
of Letters Patent issued on the 21st day of July,' 185G, �y tiie
United States of America to the state of Indiana, which patent
described, among others, the follo:•iing lands:
"...the l•J2st half or the lots numbered five, six, eignt
and nine....of section nine", Tot•�nship 2 Soutn of �ange -
12 l�lest.
3.02. The affiant took title to tlie suLjzct real estate
by virtue of tne warranty.deed of Rooert A. Ciiattin and his ��iife
Agnes Chattin, Enoch G. Chattin and iiis �•+ife Sarah Chattin, i;ati�enial
N. Chattin and 'nis �•�ife Zenabia Chattin, [lizabetii 4Jilliams (unr,arried),
arid P;ettie Chattin (unmarried) dated Decenber 22, 1930, and recorded
January 1G, 1931, in Deed Record 100, at page 3�U, in the office of
tne Recorder of Gibson County, Indiana,��•ihich warrar�ty deed conveye�,
among otners, tne folioti•iing lands:
"...the f;oriheast Quarter of the i;orthorest Quarter of
Section 9, Tot•�n 2 South, Range 12 ldest.:.." in Gibson
County, Indiana,
and tiie affiant has, from tlie date of said de2d until the date ii:reof,
neld said lands, claiming to be the o��.ner ti�ereof, by a conti��uous
and uninterrupted lir�e of possession under a claia� of �iiie anc
or�nersnip of the subject real estate. The affiant's grantors tock
title, in specific.terms, to said real estate oy the vrarranty tieed of
0. B. Rodrick and nis �,�ife, t•taud Rodrick, dated July 18, 1525, ai�d
recorded January 18, 1927, in Deed Record 96, page 159, in t�e office
of the Recorder of Gibson County, Indiana. And the suoject real estate
had been specifically described in three immediately prior �riarrai�ty
deeds, to�•iit: the de.ed of C. L. Trover and his tiiife ilayr:�e Trover to
0. Q. P,odric4: dated July 11 , 1918, and recorded i�1ay 5, 1919, in Deed
Record 85, page 313, in the office of the Recorder of Giusen Cour.ty,
intiiana; tne deed of 0, t3. Roderick and 'nis ��rife i•laud Roderick to .
C. L. Trover dated August 17, T917; and recorded August 23, 1917, ir
Ueed Record 83, page 60,. in the office of tne Recorder of Gibson
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County, Indiana; and the deed of Ed. Hartv�ick and his �•iife F,nna J.
Hart�+ick to.0. Q..,Rodrick dated February 21, 1910, ar�d recorded
August 4, 1925, in;:Ueed Record 94, page 367.
3.03. The affiant has openly, notoriousl�, coniinuously,
uninterrupteoly, and adversely possessed and enjoyed tne sucjeci
lands for a period of more tfian tvienty years prior iiereto ard, during
such period, I�as specifically exercised the followirg acts of domiriorr
and control:
3.0"sl. The affiant, her iiusband joining, executed
a mortgaae of tlie subject lands to The Peoples (':ational t3ar,k and
Trust Company of ;•lasl�ington, Uaviess County, Indiana, under date of
uecember 20, 193U, 4inicn mortgage mas recorded January 3, 19"sl, in
!•tortgage Record 110, page 332, in the office of the Recorder of
Gioson County, Indiana.
3.032. The affiant, ner husband joiring, executed
a second mortgage of tiie subject lands to Andrevr J. E3iddinger ar�d
Zed i•iorton of Daviess County, Indiana, under date of Decem�er 19,
1930, vihich mortaage t•�as recorded January 3, 1931 , ir i�iort9aac P,ecord
110, page 333, in the office of the Fecorder of Gibson County, Inuiana.
3.O:s3. The affiant, i�er iiusoand joiring, execut2d
a nortgage of the subj,ect lands to the.Land Qank Commissicner of
Louisville; Kentucky, under tne date of Decemuer 1C, 1933, �inich rori-
gage o-ras recorded on Deceriber 23, 1933, in �•iortgage Record 117, page
4�, in the office of the Recorder of Gibson County, Indiana.
• 3.034. Tiie affiant, her husuand joining, executed
an oil and gas lease of tiie subject lands to L. F. Henne�eroer under
date of December 4, 1938, which lease ti�ias recorded January G, i939,
in Fliscellaneou.s Record 3.7, page 593, in.the offic2 of tne Recorder
of Gioson County, Indiana:
3.035.. The affiant, her nusband jcining, zxecuted
an oil and gas lease of tfie:subject lands to [verett Grant dated
I�iarcn 26, 1949, aihicii lease was recorded hlarch 29, 1949, in i�iiscel-
laneous Record 75, page 195, in the office of the Recorder of Gibson
County, Indiana.
3.03u. The affiant, her husband joining, executad
an oil and gas lease of the,subjzct lands to Everett Grant dated
Ptarcn 2b, 1950, whicii lease was recorded �1larcn 29, 1950, ir f�iiscel-
laneous Record Sl, page 231, in tlie office of the Recorder of Gibsor�
County, Indiana.
3.037. The affiant, as an unreriarried wido�•�, executed
an Option and Purchase Agreement under date of Rpril 2�,.197G, in
favor of L. J. Hoing of Vincennes, Indiana, wnich option �•�as exercis2d
by the said optionee and his assignee under date of June 2, 1970.
3.04. The affiant has, during ali of such period o`
t�renty years or more, paid all taxes assessed agairst said real es-
tate and all essessments of every kind and nature, levied, assessed,
anG imposed against seid land, t•rhich taxes and assessments- have beer,- �.
assessed in the nane of tne affiant, specifically as follows, totiait:
3.041. Tfie subject real estate is assessec.for taxes
in tne name of i�lil�red Y.eitii as 40 acres iiavi�ig an assessed value or"
5380, all as shown by tax duplicate numuer 535 in the office of tiie
Tr2asurer of Gibsor� Coui�t�, Indiana. �
3.U42. In a proceeding in tlie Gibson Circuit Court
for the establishment of tiie so-called t3lood Levee, Cause t�o. 9927,
by tne ierms of a judgment of the court entered on Septeruber 2',,
1959, wheretiy the said levee was estaulished, tf�e affiant, under
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the name. "Keith, blildred" �•�as ass�essed �•�ith b2nefits to 40 acres
in the northeast quarter of the northwest quarter of Section 9,
To�vnsliip 2 South, Range 12 4;est, in the amount of 5960, all levies
under rrhich the affiant has paid.
4. l�y virtue of all of the foregoing and under the provisions
of Section 3-1414 of burns Indiana knnotated Statutes, the affiant
d.oes request the Auditor of ttie state of Indiana to certify i.n due
form tliat tiie state of Indiana has no claim or title to the su5ject
real estate and that the s.tate of Indiana snall thereafter be barred
froM setting up any claim or title to such real estate.
hnd furtner affiant saith not.
Subscr_iued and s�•iorn
G�/ (�'�I,o /��/2�G�
hir's. Mi dred Keitn
to before me this llth day of September, 1970.
h1y comnission expires:
8-18-73
(�otary u i c
J. Donald D.ayer
Above name typewritten or prir�ied)
THIS I�VSTRUI�ici;T PREPNRED BY THGt•IAS S
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Ei4IS0i�i, LA4JYER
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