IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA IN AND FOR THE COUNTY OF WASHOE Case No. CV26-01142 Department No. 1 8900 LAKESIDE, LLC, a Nevada limited liability company, Plaintiff, vs. ESTATE OF WALTER R. BELL, Deceased; DACOLE INVESTMENT CO., a Nevada General Partnership; ESTATE OF JOSEPH I. AND DOROTHY H. RICHARDSON, Deceased; and WASHOE COUNTY, a political subdivision of the STATE OF NEVADA, Defendants. _______________________/ SUMMONS TO THE DEFENDANT: YOU HAVE BEEN SUED. THE COURT MAY DECIDE AGAINST YOU WITHOUT YOUR BEING HEARD UNLESS YOU RESPOND IN WRITING WITHIN 21 DAYS. READ THE INFORMATION BELOW VERY CAREFULLY. A civil complaint or petition has been filed by the plaintiff(s) against you for the relief as set forth in that document (see complaint or petition). When service is by publication, add a brief statement of the object of the action. The object of this action is: QUIET TITLE 1. If you intend to defend this lawsuit, you must do the following within 21 days after service of this summons, exclusive of the day of service: a. File with the Clerk of the Court, whose address is shown below, a formal written answer to the complaint or petition, along with the appropriate filing fees, in accordance with the rules of the Court, and; b. Serve a copy of your answer upon the attorney or plaintiff(s) whose name and address is shown below. 2. Unless you respond, a default will be entered upon application of the plaintiff(s) and this Court may enter a judgment against you for the relief demanded in the complaint or petition. Dated this 13th of April, 2026. Issued on behalf of Plaintiff(s): Name: Stephen C. Mollath, Esq. Address: 6560 SW McCarran Blvd., Suite A Reno, NV 89509 Phone Number: 775-786-3011 Email: stephen@prezantmollath.com ALICIA L. LERUD CLERK OF THE COURT By: /S/ Y. VILORIA, Deputy Clerk Second Judicial District Court 75 Court Street Reno, Nevada 89501 VERIFIED COMPLAINT FOR QUIET TITLE (NRS 40.010) TO CORRECT A CLOUD IN TITLE CAUSED BY ERRANT LEGAL DESCRIPTION CONTAINED IN DEED OF CONVEYANCE COMES NOW Plaintiff 8900 LAKESIDE, LLC, a Nevada limited liability company (hereinafter referred to as "8900 LAKESIDE"), by and through its counsel Stephen C. Mollath, Esq. of PREZANT & MOLLATH, and pursuant to NRS 40.010 complains and alleges as follows: 1. Parties and Properties. ESTATE OF WALTER R. BELL, Deceased (BELL), DACOLE INVESTMENT CO., a Nevada General Partnership (DACOLE), and ESTATE OF JOSEPH I. AND DOROTHY H. RICHARDSON, Deceased (RICHARDSON) are the predecessors in interest in the real property situate in Washoe County, Nevada described in Exhibit 1 attached to this Complaint. 8900 LAKESIDE is the successor in interest to the real property set forth in Exhibit 1, except as to certain real property described in Paragraph 4 of this Complaint. 8900 LAKESIDE acquired title to said property on May 26, 2023. WASHOE COUNTY, a political subdivision of the STATE OF NEVADA has interest in the triangular portion of Holcomb Ranch Road, as set forth in Paragraph 4 of this Complaint. NRS 40.010 governs this action. APN 041-130-58 is the parcel at issue. 2. Historical Context. By the 1920s or 1930s Holcomb Ranch Road/Lakeside Drive had a set width, although the records do not show who originally made that determination. The landowners on the west side of the road were given to believe that the most easterly 14' of Section 11 was part of the roadway so by the 1950s their deeds were excepting out the 14' strip. There is no evidence the 14' strip was ever granted as a right-of-way to the Nevada Department of Transportation (NDOT) or WASHOE COUNTY. The above is also true for the northerly adjacent property based on Records of Survey 643, 2200 and 2432, which all show the easterly 8900 LAKESIDE property line being 14 feet west of the Section Line. The 8900 LAKESIDE property was shown on the 1947 NDOT map as belonging to A.S. Page. The chain of title indicates that the original owner took title to an aliquot part of section 11 so there was no exclusion of the strip. That was circa 1902. In 1938 the land was deeded to A.S. Page (including the current 8900 LAKESIDE adjacent to the north) and in 1958 the southerly portion was deeded from Page to Walter Bell. By 1969, Walter Bell thought his ownership excluded the 14' strip, as shown on R/S 643 (for BELL). And the 1974 BELL ESTATE deed specifically excluded the strip. It is likely the heirs to the BELL ESTATE own the 14' strip through what used to be their parcel. It is likely the same is true for the property to the north (aka Page parcel). As such, the entire 14' strip was all under a single ownership (Page) until Page conveyed the southerly parcel to BELL in 1958. The property to the northeast, shown on the 1947 NDOT map as belonging to RICHARDSON is probably the same situation. The original grant would likely have been aliquot, that is to say, it would have extended to the section line. But that parcel was also subject to an understanding of some nominal portion of the parcel was right-of-way and so later deeds excluded that right-of-way, which explains why Tract Map 4464 was prepared showing the boundary as being the northerly and easterly right-of-way lines, consistent with the 1947 NDOT map. The triangular piece is a portion of the original RICHARDSON parcel. 3. The 14' Strip of Real Property Between the Real Property of 8900 LAKESIDE and the East Line of Section 11, at issue. There is a 14' strip of land lying between the easterly boundary of the 8900 LAKESIDE real property per Tract Map 5596 and the east line of Section 11 that was not conveyed to 8900 LAKESIDE by its predecessors who presently hold title of record. This odd circumstance can be traced to an errant legal description in a deed of BELL in 1974 (Document No. 318627) that omitted the 14' strip (with metes and bounds) instead of including the strip in the legal description of the deed. Therefore, the strip, in error, was never conveyed. When the property was subdivided by BELL on Parcel Map 1431 in 1982, the strip was shown as lying outside the parcel boundary and was not conveyed. When BELL conveyed to DACOLE in 1986, it conveyed Parcel D of that Parcel Map, which, in error, did not include the 14' strip. A later Record of Survey (No. 5169) for lot line adjustment in 2009 and the Cobble Hill Tract Map in 2025, all followed the boundary shown on Parcel Map 1431, again leaving the 14' strip out of the legal description. It is very likely that BELL, DACOLE, or RICHARDSON, retain ownership of the strip. A description map setting forth the error is attached hereto and marked Exhibit 2. 4. Triangular portion of Holcomb Ranch Road originally intended to be dedicated to Washoe County. NDOT Right-of-Way plans indicate that the road right-of-way for Lakeside Drive / Holcomb Ranch Road is an easement only, meaning that underlying fee title is retained by persons unknown, possibly Defendants BELL, DACOLE, and RICHARDSON. The Section 12 chain of title, together with available record maps including Record of Survey 3951 from 2001 and Record of Survey 5956 from 2018 indicate that the northerly boundary of those lands is contiguous to the original NDOT (and now WASHOE COUNTY) right-of-way and therefore erroneously does not include lands within that right-of-way. A description map setting forth the triangular error is also attached hereto and marked Exhibit 2. It is likely that the ESTATE OF JOSEPH I. AND DOROTHY H. RICHARDSON has retained ownership of the fee title beneath the NDOT (now WASHOE COUNTY) right-of-way is shown on the 1947 NDOT right-of-way map. This land was later subdivided on Tract Map No. 4464 in 2005 and the northerly right-of-way of the NDOT easement is shown on that map as the subdivision boundary. The land lying within the NDOT right-of-way is shown as being outside the boundary. It seems likely that the NDOT right-of-way corridor was in error and never conveyed to NDOT in Fee, or to WASHOE COUNTY. 8900 LAKESIDE's interest in the triangular portion of Holcomb Ranch Road (now Lakeside Drive) is needed in order to comply with the Washoe County Code-required flared entrance into Brady Ranch Road of the Cobble Hill Custom Lot Subdivision. The triangular error is also set forth in Exhibit 2 (a portion of which is the aforementioned 14' strip). 5. The legal description of the 14' strip is attached hereto and marked Exhibit 3. The legal description of the triangular portion of Holcomb Ranch Road is attached hereto and marked Exhibit 4. WHEREFORE, Plaintiff requests Judgment as follows: 1. Defendants, and each of them, and all persons or entities claiming under them, be required to set forth the nature of the claims set forth in this Complaint. 2. The Court adjudicate and determine by decree the allegations set forth in this Complaint and authorize the correction of the errors contained in the deeds that created the 14' strip, so as to convey that 14' strip to 8900 LAKESIDE. 3. The Court should authorize the correction of the error contained in the deed or deeds that created the triangular parcel so as to convey that parcel to WASHOE COUNTY. The undersigned does hereby affirm that the preceding document does not contain the social security number of any person. Dated this 13th day of April, 2026. PREZANT & MOLLATH By /s/ Stephen C. Mollath Stephen C. Mollath, Esq. Attorney for Plaintiff May 21, 28, June 4, 11 2026 LNVS0523547