010-25 - NOTICE BY PUBLICATION
STATE OF INDIANA, PULASKI COUNTY
PULASKI CIRCUIT COURT
66C01-2501-PL-000001
CHRISTINA FRITZ
V.
FRANK CALABRESE
&
ALL OTHER PERSONS UNKNOWN
Claiming any right, title, estate, lien, or interest in the real estate
described in this Complaint adverse to the Plaintiff’s ownership
or any cloud upon the Plaintiff’s title
NOTICE BY PUBLICATION
NOTICE OF COMPLAINT FOR QUIET TITLE
IN THE PULASKI CIRCUIT/SUPERIOR COURT
PULASKI COUNTY, STATE OF INDIANA
CAUSE NO. 66C01-2501-PL-000001
TO: FRANK CALABRESE, and ALL OTHER PERSONS UNKNOWN Claiming any right, title, estate, lien, or interest in the real estate described in this Complaint adverse to the Plaintiff’s ownership or any cloud upon the Plaintiff’s title: Plaintiff filed an action for quiet title which states: Plaintiff owns real estate in Pulaski County, Indiana located at 404 W. Main, Winamac, IN 46696 and described as: 011-01392-00 PT SW NE 33X132’ SEC. 14 .10A; Parcel No. 66-14-14-111-027.000-011. Plaintiff is the owner of the Property, having acquired interest in it by virtue of quitclaim deeds from her siblings, who were co-heirs to the Property following the passing of their mother, Sharon Kay Shanks. Defendant, Frank Calabrese is one of the heirs to Sharon Kay Shanks. The Property was originally owned by Sharon Kay Shanks, who passed away intestate, leaving her children, including Plaintiff and Defendant, as co-heirs. Following the death of Sharon Kay Shanks, her children, with the exception of Defendant, executed quitclaim deeds transferring all their interests in the Property to Plaintiff, Christina Fritz, effectively making her the sole owner in interest of the Property among the siblings. Plaintiff has fulfilled all financial obligations associated with the Property, including, but not limited to:- Payment of the mortgage balance in full; - Payment of property taxes and homeowner’s insurance; - Maintenance and improvements necessary for the upkeep of the Property. Defendant, Frank Calabrese, has not contributed financially to the acquisition, maintenance, or improvement of the Property and has no rightful claim or interest in it. A recent title search performed on the Property reveals no encumbrances or liens other than those which Plaintiff has satisfied, and all co-heirs, except Defendant, have relinquished their interest to Plaintiff. Plaintiff is in exclusive possession of the real estate. Plaintiff’s interest and title to the real estate is superior to all persons and entities who have any interest therein and the purpose of this action is to quiet title to the real estate as against the world. Plaintiff has named as Defendant all persons within his knowledge through whom any hostile claim might be asserted in and to said real estate. Plaintiff has named ALL OTHER PERSONS UNKNOWN claiming any right, title, estate, lien, or interest in the real estate described in this Complaint adverse to Plaintiff’s ownership or any cloud upon Plaintiff’s title. Wherefore, Plaintiff requests that the Court declare and adjudge the Plaintiff is (1) the owner in fee simple of the real estate, (2) the Plaintiff is entitled to the quiet and peaceful possession of the real estate, and (3) the Defendants and all person who may claim under them, have no estate, right, title, lien or interest in and to said real estate or any part thereof, and for all other proper relief. The case is pending in the St. Joseph Circuit/Superior Court, 101 S. Main St., South Bend, IN 46601, (574)235-9657. You have twenty (20) days to file an answer to this complaint. If you do not file an answer the Court may enter default against you and for the relief demanded in the complaint. The attorney for Plaintiff is Gary L. Griner 121 E. Grove St. Mishawaka, IN 46545 (574) 255-1776.
JoLynn Behny
Clerk, PULASKI Circuit/Superior Court
010-25 N 1/22, 1/29, 2/5