Commonwealth of Massachusetts
Land Court Department
Trial Court
CASE NO. 25 MISC 000626 (MDV)
Bayberry Hollow Farm LLC v. William M. Mello, et al
TO: William M. Mello, William M. Mello, as Trustee of the Mello Family Trust, Edward Mello, as Trustee of the Mello Family Trust, John F. Nickerson, Frank Brown, Joseph Brown, Theophilia Brown, Henry Brown, Joseph M. Williams, Joshua S. Nickerson, Edward Brown, and Frank Brown, all of parts unknown, and their heirs, legal representatives, devisees, or appointees
You are hereby notified that a complaint has been filed by the above-named plaintiff in which you are named as an interested party. This complaint concerns a certain parcel of undeveloped land in Provincetown, Barnstable County, and said Commonwealth being known as and numbered 16R Blueberry Avenue, deed reference being Book 36934, Page 104 of the Barnstable County Registry
of Deeds. Plaintiff has filed this lawsuit to remove a cloud on the subject property's title, which he contends has arisen due to an inability to determine a source of title for the predecessor owners' interest. Plaintiff alleges his horse farm, Bayberry Hollow Farm, has been using the subject property for riding, grazing and housing of horses since at least 2003. The defendants are people
believed to have had a legal interest in the subject property. Plaintiff seeks a judgment declaring that he holds title to the subject property free and clear of any claims of the defendants and for such other relief deemed just.
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, Adam T. Sherwin, Esq., 529 Main Street, Suite P-200 Charlestown, MA 02129, an answer to the complaint on or before the twenty-ninth day of December, 2025, next, the return day, hereof, and a copy thereof must be filed in this court on or before said day.
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 in the Cape Cod Times, a newspaper of general circulation in Barnstable County, said Commonwealth at least thirty days before the twenty-ninth day of December, 2025.
Witness, Gordon H. Piper, Chief Justice of the Land Court, the thirteenth day of November, 2025.
Attest:
/s/ Deborah J. Patterson
Deborah J. Patterson
Recorder
November 21 2025
LNEO0410153