37 Green Street, Holliston, MA
Commonwealth of Massachusetts
Land Court Department
Trial Court
MIDDLESEX, SS. CASE NO. 24 MISC 000452 (STF)
Kevin Carey and Alix Carey v.
Heirs and/or Legal Representatives of Marion A. Jonah, et. al.
TO: Marion A. Jonah, deceased, formerly of Polk, Florida; Bessie Jonah, deceased, formerly of Polk, Florida; Nelson Jonah, now or formerly of Polk, Florida; Bruce Chandler, now or formerly of Springfield, Virginia; Bonnie Handcock, now or formerly of Avon, North Carolina or their known and unknown heirs, devisees, and legal representatives.
You are hereby notified that a complaint has been filed by the above-named plaintiffs in which you are named as an interested party. This complaint concerns a certain parcel of land in Holliston, Middlesex County, in said Commonwealth being known as and numbered 37 Green Street (the "Property"). The plaintiffs' interest in the Property is evidenced by a deed dated October 8, 1997 and recorded with the Middlesex South Registry of Deeds on October 14, 1997 at Book 27765, Page 280. Plaintiffs allege that the Property is made up of a front parcel ("Front Parcel") and a rear parcel ('Rear Parcel"), which make up the front and back yard respectively. Plaintiffs further allege that the Town of Holliston Assessor's card regarding the Property indicates that the Front and Rear Parcels belong to the plaintiffs' Property. The plaintiffs claim to have paid taxes on the entirety of the Property, including the Rear Parcel, for as long as they have owned it and have always treated and maintained the entirety of the Property as described on the Assessor's card as theirs. The plaintiffs allege that, for reasons unknown, many years back in plaintiffs' chain of title, the Rear Parcel was never conveyed to the plaintiffs or their predecessors in title, but instead remained in the name of Marion A. Jonah, who retained the Rear Parcel at the time the Front Parcel was transferred over 100 years ago. Plaintiffs' claim that their use of the Property is consistent with the Assessor's valuation; that is, plaintiffs have used both the Front and Rear Parcels as their own for nearly 27 years, and their predecessors-in-interest also made the same total use of both parcels. Plaintiffs seek a judgment that they hold title to said land free from any claims of the defendants, the plaintiffs claiming to have established their title by adverse possession, and such other relief as the Court shall deem just and equitable.
This complaint may be examined at the Land Court, Boston, Massachusetts, or online at www.masscourts.org. Information on how to search Land Court dockets is available on the Land Court website: www.mass.gov/how-to/find-a-land-court-case-docket. A copy of said complaint may also be obtained from plaintiff's attorney.
If you intend to make any defense, you are hereby required to serve upon the plaintiff's attorney, Stephen Ryan, Jr., Esquire of Petersen and Ryan PLLC, whose address is 11 Maple Ave, Shrewsbury, MA 01545, an answer to the complaint on or before the third day of November, 2025, next, the return day, hereof, and a copy thereof must be filed in this court on or before said day.
CASE NO. 24 MISC 000452 (STF)
If you fail to do so, judgment by default will be taken against you for relief demanded in the complaint. Unless otherwise provided by Rule 13(a), your answer must state as a counterclaim any claim which you may have against the plaintiff which arise out of the transaction or occurrence that is the subject matter of the plaintiffs' claim, or you will thereafter be barred from making such claim in any other action.
It is ORDERED that notice be given by publishing a copy of this notice once at least thirty days before the third day of November, 2025, in the following newspapers: (1) Lakeland Ledger - 300
W. Lime Street, Lakeland, FL 27943, (2) Island Free Press - 58248 Fulcher Lane, Hatteras, NC 27943, (3) Fairfax County Times - P.O. Box 879, Reston, VA 20195.
Witness, Gordon H. Piper, Chief Justice of the Land Court, the sixteenth day of September, 2025.
Attest:
/s/ Deborah J. Patterson
Deborah J. Patterson Recorder
September 28 2025
LSAR0374436