Commonwealth of Massachusetts

Land Court Department

Trial Court

ESSEX, SS. CASE NO. 25 MISC 000761 (GHP)

Commonwealth of Massachusetts Land Court Department Trial Court ESSEX, SS. CASE NO. 25 MISC 000761 (GHP) Christina M. Monge and Jeffrey A. Thurlow v. The Unknown Heirs of Loretta A. Lee, et al. TO: Loretta A. Lee, deceased, formerly of Woodbridge, Virginia; and Barbara L. Gilbreath, deceased, formerly of Crofton, Maryland and any unknown heirs, assigns, devisees or 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 parcel of land in Newbury, Essex County, in said Commonwealth being known as and numbered 132 High Road (the "Property"). Plaintiffs, Christina M. Monge and Jeffrey A. Thurlow, are the current owners of the Property. Plaintiffs allege that title to the Property is clouded by a prior questionable conveyance of a fiduciary under a power of attorney in their chain of title. Barbara L. Gilbreath ("Barbara") acquired title to the Property by deed recorded with Essex South Registry of Deeds ("Registry") in Book 14063, Page 102 on April 18, 1997. Loretta A. Lee ("Loretta") granted power of attorney to Barbara L. Gilbreath pursuant to a power of attorney recorded at the Registry on October 29, 1999, in Book 16018, Page 102 ("Power of Attorney"). Subsequently, Barbara conveyed the Property to herself individually and Loretta with no tenancy listed in a deed recorded at the Registry in Book 16018, Page 105. Pursuant to a deed recorded with the Registry on October 17, 2000 in Book 16624, Page 201, Barbara purported to convey the Property to herself individually under the Power of Attorney for one dollar. Plaintiffs allege that the Power of Attorney did not expressly grant authority for gifts, and as such Barbara's conveyance to herself is arguably an invalid act as fiduciary under the Power of Attorney. Plaintiffs seek a judgment to quiet title to the Property, that they hold title to the Property free and clear of any claim or interest of the defendants, and for such other relief that this Court deems just and proper. 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, Scott C. Owens, Esq., whose address is First American Law Group, 250 First Avenue, Suite 104, Needham, Massachusetts 02494, an answer to the complaint on or before the eleventh day of May, 2026, 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 Newburyport Daily News, a newspaper of general circulation in Newbury, Essex County, Massachusetts, at least thirty days before the eleventh day of May, 2026. It is FURTHER ORDERED that notice be given by publishing a copy of this notice once in the Prince Williams Times, a newspaper of general circulation in Woodbridge, Virginia at least thirty days before the eleventh day of May, 2026. It is FURTHER ORDERED that notice be given by publishing a copy of this notice once in the Capital Gazette, a newspaper of general circulation in Crofton, Maryland at least thirty days before the eleventh day of May, 2026. Witness, Gordon H. Piper, Chief Justice of the Land Court, the first day of April, 2026. Attest: /s/ Deborah J. Patterson Deborah J. Patterson Recorder