PRVPI Report Page 3

Gang harassment, justice system abuse. The Boyd Gang.

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Ethel Boyd…Terri (Boyd) Davis….Deanna L Barrett…….Brian F Davis…

Page Three

Fence Gone, more Gang harassment on

After I removed the field fence from both sides of the Boyd Gang’s Tiger Lily Lane through Mary’s property. I built a wooden privacy fence for Mary, between the Boyd Gang’s “Tiger Lily Lane” and Mary’s front porch.

On May 7, 2021, My fiancée and I drove to town. As we were driving back to Mary’s residence along the Upper Pack River Road this white, four door PU truck’s driver, (pictured below), reminded us that the Boyd Gang are definitely out to harm us. We already knew that. Like I said, the Boyd Gang’s treachery is like a virus. And I believe that that condition prompts individuals like this John or Jane Doe #??, to act maliciously against innocent people.

John or Jane Doe #?? flips his or her middle finger at my fiancée and me. Boyd Gang associate?.

Who is this?, and why in the world would this person want to victimize us?. Boyd Gang associate?.

My fiancée and I departed Mary’s residence the very next day, May 8, 2021. And we did not return to Mary residence, at all, during the Summer of 2021. But I did begin creating this website.

I wanted to visit and help Mary during the summer of 2021. But I did not. Not while the Boyd Gang has free run through Mary’s front yard. I felt like The Boyd Gang could and would set me and my fiancée up. And who knows, have us arrested and jailed by the Bonner County Sheriff and the Bonner County Idaho Justice System. I believe that both of which are victims of and yet seem complicit to the Boyd Gang. That is a profound condition. The Boyd Gang’s treacherous manipulation is very powerful.

Or maybe the Boyd Gang might catch me outside and shoot me dead. After all, they have made open threats aimed at me. Deanna L. Barrett stated, “I’ll blow your fucking brain out, I mean it, don’t mess with me“. And something like, this is a stand your ground law state and we, (Boyd Gang), have lots of guns. And Brian F. Davis patrols through Mary’s front yard with a firearm.

So, my fiancée and I decided to not visit Mary during the summer of 2021.

I also believe that the Boyd Gang have associates who live near Mary’s residence, and, that keep an eye on Mary’s residence. I believe that the Boyd Gang’s associates, of which I speak to, did inform the Boyd Gang that my fiancée and I returned to Mary’s residence with our little RV trailer in mid October 2021. Because shortly after our arrival…

Brian F Davis in Mary’s front yard on October 19, 2021.

On October 19, 2021,

At around 1:52 pm, Boyd Gang enforcer Brian F Davis made his presents felt in Mary’s front yard.

Brian F. Davis stop in Mary’s front yard, just checking his load? Is that a gun under his shirt there?

Two days later, on October 21, 2021, Boyd Gang enforcer, Brian F Davis, made his presents felt in Mary’s front yard again. Is that a firearm under his shirt there?.

During the summer of 2021, the Boyd Gang obviously had the Ace Septic Service set up the chemical “porta-potty” on the FEMA designated floodway portion of the Boyd Gang’s vacant property. Typical.

Then…

On October 28, 2021,

At around 9:55 am, the Ace Septic Service truck drove in along the Boyd Gang’s Tiger Lily Lane. up to Mary’s front gate. The driver disembarked his vehicle, made a threatening “Kung Fu” gesture at Mary’s residence and then opened the gate and drove in through Mary’s front yard to the Boyd Gang’s property.

At around 10:10 am, the Ace Septic Service truck drove out from the Boyd Gang’s property, with the “porta potty” loaded on the truck, through Mary’s front yard and on out, leaving Mary’s front gate wide open.

The glaring issue is the threatening gesture that he made towards Mary’s residence when he arrived. Why would he want to do that? Maybe he thinks that gang harassment is some kind of a joke. Well, it is not a joke! It is frightening and hurtful! Boyd Gang inspired harassment?. Why would he take part in this harassment? I believe the answer is in the Boyd Gang treachery that he has been manipulated with.

Hey Ace Septic Service representative…. The Boyd Gang do not care about you at all. Obviously! I believe that this ACE Representative is another complicit victim of the Boyd Gang and their treacherous manipulation.

I wonder what lie the Boyd Gang told this individual, John Doe #??, in order to prompt him to do the Boyd Gang’s harassing for them.

October 2019 ACE septic service truck purposely litters TP in Mary’s front yard.

Is this the same individual who NOTORIOUSLY littered rolls of toilet paper in Mary’s front yard during October, 2019? I believe it is the same, misguided, Boyd Gang associate.

Partial Historical Narrative

Now that I have exposed some of what the Boyd Gang and their misguided associates do with the Boyd Gang’s arguably illegal “Tiger Lily Lane” which traverses through Mary’s front yard.

This is how Tiger Lily Lane, (10 Ft. wide easement through Mary’s front yard), came to be.

In 1980, Mary Pandrea, (“Mary”), with the help of her sister Kari Clark,(“Kari), put a cash down payment towards the purchase of Mary’s land and residence, known then as 4687 Upper Pack River Road, Sandpoint, Idaho, (Parcel 1). Recorded at the Bonner County Recorders Office as instrument # 226223 (Exhibit 2).

It was severed from a much larger parcel of land in 1980, (Harry and Edith Clark trust land) and sold to Mary at that time. There was and still is to this day, a one lane driveway leading from the County road (Upper Pack River Road) to Mary’s residence on her land, (Parcel 1). Following the purchase, Mary quit-claimed a 50% interest in Parcel 1 to her sister Kari.

Mary and Kari where both raised at that residence on Parcel 1 during the 1940’s and 1950’s.

Mary’s residence as it was under construction in around 1946

Mary, (my mother), Debbie (my sister) and I resided there at my grandparents house from 1968 until 1972. Mary was recently divorced with two small children. She moved back in with her parents at that time. I attended 1st and 2nd grade in North Idaho, (at Colburn Elementary School) in 1970-1972. My Sister Debbie attended 1st-4th grade there from 1968-1972.

Mary purchased a small horse for her daughter Debbie around 1970. Debbie named her little horse “Babe”.

Mary’s daughter Debbie pictured with her horse “Babe” at the forth of July Parade in Sandpoint, ID 1972

Babe pastured with my grandparents cattle at their (Clark) farm.

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Me, pictured on the front page of the Bonner County Daily Bee Newspaper in 1972 as I won 1st place at the Forth of July Kiddy parade. Mary made my “Uncle Sam” costume and stilts.

I resided in North Idaho from 1968 -1973 and I have very little memory of Ethel Boyd from that time. I know that she is my mothers sister.

I believe that Ethel resided in California at that time.

Ethel Boyd is one of seven Clark children, along with Mary and Kari, who were all raised there at Harry and Edith Clark’s residence. All of the Clark children had left home, (flew the nest), prior to 1960.

In 1980, I was a 10th grader and my sister Debbie was a 12th grader. Mary was single, (divorced since about 1966), working full time and raising two kids. We resided in Vancouver, WA. Mary’s mother, Edith, (Grandma), had moved in with us in 1977, following my grandfathers passing in 1975. It was then that Edith Clark, (grandma) became a part of my immediate family. Edith remained a part of my immediate family until she passed in 2009. Mary also helped her sister Kari during my childhood and during my adult life. Kari was not nearly as capable as Mary and Kari leaned on Mary, even though they lived far from each other. Kari also helped Mary when she could. They had a close relationship.

I have very little memory of Ethel Boyd from that time during my growing up years. I believe that she resided in California during that time.

In 1991, Kari, with the help of her sister Mary, put a cash down payment towards the purchase of a parcel of land, (Parcel 2). Recorded at the Bonner County Recorders Office as Instrument # 396781 (Exhibit 3).

Kari immediately quit claimed a 50% interest in Parcel 2 to Mary. Parcel 2 is adjacent to Parcel 1. Parcel 2 was also severed from that larger parcel of land, in 1991. Parcel 2 was severed and sold with its own separate easement access description (as written on the original land grant title)“together with and subject to” a 30 ft. wide access road, (now known as Tavern Creek Drive), for road right of way and utilities. (Exhibit 3)

That road, (Tavern Creek Drive), was constructed during the 1950’s by the original land owner, Harry F. Clark, (my Grandfather). It was all a single and much larger parcel of land at that time. Both, Parcel 1 in 1980, and Parcel 2 in 1991,where severed from that larger parcel. Tavern Creek Drive provided access to H F Clark’s land including what became Parcel 2. However, not Parcel 1, which was H.F. Clark’s residence and had its own unique driveway.

Parcel 2 was severed and granted “together with” that existing 30 ft. wide easement road, (Tavern Creek Drive). Also, Parcel 2 was, (and still is), “subject to” that road, (Tavern Creek Drive), because that road, (Tavern Creek Drive), traverses directly over parcel 2 and provides access to other parcels of land farther up that road. All of this land was part of HF Clark’s land. The existing 30 ft. wide easement road, (Tavern Creek Drive), is distinctly and physically separate from Mary’s Parcel 1 driveway. And, Mary purchased her land, (in 1980), with no easement running through her front yard. Obviously!

Around that time In 1991, when Mary and Kari purchased Parcel 2. I have very little memory of Ethel Boyd. I believe that Ethel resided in California at that time. To the best of knowledge Ethel had absolutely no personal interest in Mary and Kari’s jointly owned Parcel 1 and Parcel 2.

I recall visiting Mary’s jointly owned Parcel 1, with Mary, many times between 1980 and 2000, and Parcel 2 beginning in 1991. It was a lonely place. Parcel 1 was the location of my grandparents old house.

The old house was vacant.

I do not recall ever seeing Ethel or any of her family in the area between 1980 and 2000. Except during a family reunion that Mary hosted in 1994. Many members of the Clark family traveled to, and attended Mary’s Clark family reunion in 1994, including Ethel and some of her offspring.

In 2002 Mary Pandrea and Kari Clark established the Clark/Pandrea Revocable Trust. And both of their parcels, Parcel 1, (about 5 acres) and Parcel 2, (about 15 acres), were placed into that Trust. And, both Mary and Kari were named as trustees of that Clark/Pandrea Trust. Kari’s independently owned Parcel 10, (about five acres), was also placed into that trust. Kari’s Parcel 10, like Parcel 2, is accessed via the appurtenant easement of record access road, Tavern creek Drive and Kari’s parcel 2 is located adjacent to the eastern boarder of Parcel 2.

In 2002, I along with my fiancee, visited Mary. And we walked with Mary and Kari all around the entire property that made up the Clark/Pandrea trust, (Parcel 1, Parcel 2, and along with Kari’s independently owned Parcel, known as Parcel 10). At that time Mary asked me if I would build her a house on Parcel 1 someday. I suggested that I could help Mary renovate and modernize “grandma and grandpa’s” old house, located on Parcel 1. In 2002 the old house was extremely dilapidated and completely rat infested. However, I could see potential in the old house, because it was made of logs and very solid. Mary thought that was a good idea.

During that same conversation in 2002, I also told Kari that I could help her build a house up on the hill at a location of her choosing. Kari expressed that she wanted a house up on the hill, (Parcel 10). I was serious about my offer. I told the two of them to make plans. Mary immediately began planning.

I began renovating Mary’s old log house in 2004 and I was present there in the Pack River Valley sporadically, at various times during the summertime during the following years. 2 to 3 weeks at a time.

I tore Mary’s old house down to the logs and dirt and then completely rebuilt and modernized it for her.

I never saw or spoke with Kari for years following 2002. To the best of my knowledge Kari never did spend any time at all in the Pack River Valley. Maybe 1 day per year at best.

Ethel Boyd spent the vast majority of her adult life, not in Idaho. I believe that Ethel Boyd resided in California for most of her life. Ethel Boyd established herself in North Idaho during the early 2000s.

Ethel Boyd is related to me, (John Pandrea). She is my aunt. However, she is not and has never been part of my family.

During the early 2000s, Ethel Boyd reached out to Kari Clark of Sutherland OR, and began influencing Kari. Ethel also reached out and attempted to influence Mary. Notwithstanding, Mary wasn’t as susceptible to Ethel’s guile as Kari obviously was.

Mary told me that sometime in around 2005, Ethel Boyd, out of the blue, asked Mary if Ethel could be included in the ownership of Mary and Kari’s jointly held Land Trust. Mary said no to Ethel. Ethel acted spiteful and distant toward Mary after that.

Mary told me that Kari began acting distant and spiteful toward Mary around that same time. That was sad news. I believe that Mary and Kari had a good relationship prior to that time.

Ethel Boyd’s daughter, Terri (Boyd) Davis, also established herself in the North Idaho area during the early 2000’s. Terri (Boyd) Davis became a paralegal (officer of the court) in Kootenai County, Idaho around that time. Terri (Boyd) Davis grew up in, not Idaho. Terri Boyd Davis spent most of her adult life in, not Idaho.

Terri (Boyd) Davis, like Ethel, is related to me, (John Pandrea). However, like Ethel, Terri is in no way part of my family. Same for all of Ethel’s children.

Beginning in around 2005, Ethel Boyd and sometimes accompanied by her daughter Terri (Boyd) Davis began physically harassing Mary and Edith there in the Pack River Valley during the summer months. For no good reason at all.

Neither Ethel Boyd or Terri (Boyd) Davis ever made any issue out of Mary’s relationship with Edith until Edith’s mental capacity waned and she could no longer defend Mary. That was around 2005.

In 2007 Ethel Boyd and her daughter Terri (Boyd) Davis made reports to the Idaho State AAA, (Area Agency on Aging) and the Washington State DSHS, (Department of Social and Health Services). Boyd and (Boyd) Davis reported that Mary was abusing her mother Edith Clark. (“Edith”). Mary had been her mother (Edith’s) helper and advocate for about 30 years prior to that. Mary and Edith were very close and enjoyed and very good relationship. The Boyd Gangs reports of elder abuse were nothing more than harassment and where found to be “unsubstantiated” by those agencies. However, those false reports harmed both Mary and Edith.

In 2009 Terri (Boyd) Davis made another false (fraudulent) report to the Washington State DSHS, again reporting that Mary was abusing Edith. However, unknown to Terri (Boyd) Davis, Edith was, (and had been for several months prior), residing at the Cheney Care Center and not at the location, (Mary’s residence), which (Boyd) Davis reported that the abuse was taking place. And again, that report was found to be “unsubstantiated”. Obviously!

I (John Pandrea) contacted the local law enforcement at that time in 2009 regarding the Boyd and (Boyd) Davis’s false and hurtful reports of elder abuse. I was told that nothing could be done and that I should keep a record of the illegal activity, in order to show a pattern. That was a long time ago. It has been a hurtful nightmare since. I have made many reports and documented a lot.

During the fall of 2009, Mary attempted to have a Washington State guardian ad litem appointed for Edith, because Mary figured that Ethel Boyd would continue attacking Mary somehow. Ethel Boyd found out and hired a lawyer (Jeffrey Swindler) in order to block the timely appointment of a state appointed guardian for Edith.

Ethel also found out that Edith was residing comfortably at the Cheney nursing home during the fall of 2009. Ethel immediately began visiting Edith at the nursing home. Not long after Ethel began visiting Edith, Edith died. Edith died within days of when a guardian was to be appointed. The next day following Edith’s death, Ethel Boyd arranged and had Edith’s body cremated. Mary found out about her mothers passing and cremation after the fact.

I mention the above because it was odd to me how that all went down.

In November of 2009, Edith died at the age of 96 years. And when Edith died, all of her final expenses where paid in full. And, Edith had no assets.

Shortly after Edith died in 2009,… Ethel Boyd (“Ethel”) took it upon herself to file for letters of administration and establish the Edith E. Clark Estate, (“Clark Estate”), in Spokane County Washington. The Clark Estate was insolvent, (no assets). Ethel’s lawyer, Jeffrey Swindler, (of Spokane, WA). along with Ethel’s paralegal daughter, Terri (Boyd) Davis, assisted Ethel in establishing the Clark Estate, insolvent as it was.

Then Ethel, with the help of her legal team, filed a lawsuit in 2010, in the Spokane County Superior Court, Case No. 10-2-02042-4, (lawsuit),on behalf of the “Clark Estate” against Mary Pandrea, claiming that Mary had stolon $100,000.00 from Edith back in 2002. Ethel filed that lawsuit without court permission and falsely stated that Ethel had been “appointed personal representative of the Clark Estate”, (it was a stand alone statement with absolutely no proof). Ethel also stated that the Clark Estate was solvent and that her lawsuit against Mary made up the assets in the estate. Mary was blindsided by the lawsuit.

Ethel’s allegations were untrue, and included in Ethel’s evidence, and argument, were the false reports of elder abuse that she and her daughter Terri (Boyd) Davis made in 2007 and 2009. The case went before a judge named Sypolt of the Spokane County Superior Court. The Estate and Lawsuit, (“case”), was originally assigned to a different judge and nobody paid any attention to how Judge Sypolt became assigned to that case. It is a mystery how that happened because there is no record of how and when that change in judges occurred. And, even though Ethel’s claims were patently false, legal harassment and justice system abuse. The Sypolt Court awarded Ethel and her legal team a judgment, for about $247,000.00, ($100,000.00 summery judgment (Exhibit4 A), plus attorney fees and interest). against Mary.

The, (Sypolt, Swindler, (Boyd) Davis and Ethel Boyd created), judgment was appealed by Mary in the Washington State Appellate Court, and was vacated, and remanded back to the Sypolt Court and dismissed.

Following the Sypolt Court Judgment against Mary and prior to the Washington State Appellate Court review of the judgment, Ethel attempted to settle with Mary through communications from Ethel’s lawyer, Swindler, to Mary’s lawyer, Julie Watts. The settlement offers included Mary giving up some of her assets to Ethel. (Exhibit 4B)

Mary refused to settle and it went to the Appellate Court, where the Sypolt Court Judgment was Vacated! Thank you Julie Watts!, (attorney for Mary).

However, that Sypolt court judgment is a written document. I believe that Ethel Boyd and her gang still wave that Sypolt court judgment around to this day. As in, “Mary stole from our family’s estate”. That is one of several false narratives which these individuals have created .

False Narrative, Mary is a thief.

Also, in 2010, Mary Pandrea received an envelope in her mailbox, which was sent from her sister Kari Clark, of Sutherland, OR. Inside the envelope there was no letter. However, there was a deed describing Mary’s 50% interest in Parcel 1. And, there was no mention of the larger, but vacant land, Parcel 2, or what became of it.

Mary was well aware that Ethel Boyd had turned Kari against Mary prior to that time. So Mary figured that Ethel had to have had something to do with what Kari had done. Mary knew that Kari never was an industrious individual. And, Mary also knew that Ethel was, not only industrious, but very treacherous and manipulative. Mary also knew that Kari was easily manipulated by Ethel.

Mary searched the Bonner County Recorders Office. There, Mary found that Kari had slandered title in Mary’s 50% interest in Parcel 2, and then recorded that slanderous deed in the Bonner County Idaho Recorders Office as instrument #795212 (Exhibit 5 A). In 2010, Kari owned a 100% interest in parcel 2, by virtue of that slander of Mary’s title.

From 2010 and into 2011, Mary made several attempts to contact Kari in order to correct what Kari had done. Kari ignored Mary’s correspondence, and Mary had no choice but to file a Partition Action in the Bonner County District Court in order to protect her property rights. Mary filed Bonner County CV-2011-0835 partition action.

Mary had made the majority of payments on the bank loans for both Parcel 1 and Parcel 2. Mary also paid all of the land tax on the two parcels. Mary spent a great deal of time and money improving her jointly held property. I personally (John Pandrea) spent, and continue to spend a great deal of time and energy improving and maintaining Mary’s residence and property.

Mary filed a partition action known as Bonner County CV 2011-0835 and that case was assigned to a Bonner County Idaho Court. Kari hired a lawyer named Richard Kuck, (of Kootenai County, ID), to represent Kari in her response to Mary’s partition action. And then at one point in time and at the request of Kari through her lawyer Kuck, the case was reassigned to Judge J. P. Luster’s Court in Kootenai County, ID. Kootenai County, ID, is also where Terri (Boyd) Davis is a paralegal.

Ethel Boyd, along with her daughters Terri (Boyd) Davis and Deanna L. Barrett were very present during the court proceedings in CV 2011-0835, displayed a relationship with Kari’s lawyer Richard Kuck and also with Judge Luster. And they obviously followed the case very closely.

Prior to the June 12-13, 2012 trail in CV 2011-0835, which was also prior to the Washington State Appellate Court review of the “Sypolt Court Judgment”. Kari, through her lawyer Richard Kuck attempted to settle the matter with Mary. Richard Kuck’s communication, sent to Mary’s lawyer Doug Marfice in CV 2011-0835, were similar to those communications of Swindler to Watts in Spokane WA, and were also tied directly to that Sypolt Judgment. (Exhibit 5C)

Mary declined that settlement offer.

Item No. 5 in Richard Kucks (Exhibit 5C) communication, (I believe) refers to an easement that was established in the early1900’s and was with respect to a lumber company and there logging operation of that time and with regard to a much larger parcel of land at that time. It erroneously appeared on the 1979 survey of, and the description of Parcel I as it was severed and sold to Mary in 1980, and it did not pertain to the parcels of property involved in the CV-2011-0835 case, as the CV 2011-0835 Court properly determined. The Parcels, II and IX, which Kuck erroneously said that it serves, did not exist in 1979.

Item No. 2 in Kucks (Exhibit 5C) communication. The materialmans lien filed by me, (for the work that I had done in renovating Mary’s house on Parcel 1), in accordance with Idaho Law. I filed that legitimate lien because I believed that it provided additional protection for Mary in defending against the Boyd gangs Justice System abuse, (Spokane County, WA, Sypolt Judgment, and the fact that they were attempting to bring that Judgment to the CV 2011-0835 court). I stand by that lien.

Kari was absent from most of the proceedings in CV 2011-0835. Kari was present at the CV-2011-0835 trial held on June 12 and 13, 2012.

The slander of title that Kari had created in 2010 was done through a lawyer named Shirley Bede of Kootenai County ID. Kari Clark admitted during her testimony in open court at trial in CV 2011-0835, that Terri (Boyd) Davis worked for Shirley Bede when that slander of title was created in 2010. (Exhibit 5B) Kari’s sworn testimony was “FANTASTIC” to me.

More than a year had past since Kari’s 2010 slander of Mary’s title. Following Mary attempting to contact Kari to straighten it out to no avail. And, following Mary filing CV 2011-0835 in 2011, did Kari file a corrective deed in 2011, where she took back her slander and properly deeded Mary a 50% interest in parcel 2. The Corrective Deed was filed at the Bonner County Recorders Office as instrument # 813590 (Exhibit 6).

Terri (Boyd) Davis testified in open court, during proceedings in CV 2011-0835, that Surely Bade with the assistance of Terri(Boyd)Davis prepared the corrective deed in 2011. (Exhibit 7), Another FANTASTIC line of sworn testimony.

Richard Kuck argued in open court during proceedings in CV 2011-0835, that “Parcel 1 and Parcel 2 were two legally distinct and separate parcels of land”. (Exhibit 8) Now, that is a fact.

Richard Kuck also argued in open court during proceedings in CV 2011-0835 that “Mary embezzled $100,000.00 from her families estate”.(Exhibit 9) Kuck was referring to Judge Sypolts Judgment in a Spokane County Washington Court, which was later vacated by the Washington Appellate Court. Said Judgment was based on an gift which Edith gave Mary, a $100,000.00 check, in 2002, of her own free will, and that ultimately benefited Edith in doing so. The Sypolt Judgement was completely irrelevant in Bonner County Idaho CV 2011-0835. And, in 2002 the Edith E Clark estate did not exist. Edith was alive and well at that time.

False Narrative, Mary is a thief.

Terri (Boyd) Davis also testified, (I believe that this is one of many lies that she has told while under oath) in open court during proceedings in CV 2011-0835, that she had enjoyed Mary’s and Kari’s jointly held property her entire life. That statement is not reality based at all. (Exhibit 10).

Terri (Boyd) Davis also testified in open court during proceedings in CV 2011-835 that Kari could not reach the Pack River, riverfront portion of Parcel 2 by way of the easement access to Parcel 2 along the 30 ft wide access road, (Tavern Creek Drive).(Exhibit 11),Terri (Boyd) Davis testified: “…the road turns this way. And this is—you know, continues the descent down to the water. But like I said, I’ve never walked to the water from there because there is no access”. That statement was made under oath. One sentence truth and then the next sentence is a contradicting lie, (amazing). A visit to parcel 2 would show clearly what I speak to. There is no way to walk along that road without walking directly along the river. It would be impossible. Terri knew that. Why would anyone want to purposely defraud the Court?

False Narrative, Kari (parcel 2) couldn’t reach the river from her existing easement along the Upper Access Road, (Tavern Creek Drive).

Richard Kuck argued that same erroneous, no access to the Pack River from Parcel 2’s legal access, (Tavern Creek Drive).(Exhibit 12) “Some of this is –especially up here in the northwestern corner of Parcel 2, I think the evidence will be that that is very steep slope, and it’s very difficult to get down to the water in that area…”…Richard Kuck.

False Narrative, Kari (parcel 2) couldn’t reach the river from her existing easement along the Upper Access Road, (Tavern Creek Drive). You can drive a car across parcel 2 from Tavern Creek Drive directly to the river, easily.

Judge Luster stated that he was aware of the 30 ft. wide access road, (Tavern Creek Drive), easement to Parcel 2, (Exhibit 13).

Obviously, because the original land deed for Parcel 2, which included that written easement, was part of the court record by virtue of it being an exhibit in CV 2011-835, and is also a deed of record filed at the Bonner County Recorders Office as instrument #396781, (Exhibit 3). Mary argued during proceedings in CV 2011-0835, that the appurtenant easement of record for parcel 2, the “access road”,(Tavern Creek Drive), was a very viable road that was continuously used by many people. And that the Boyd Gang wanted to harass Mary and that there was no reason for the court to order a second easement through Mary’s yard. (Exhibit14). Mary’s argument was backed up by all documentary evidence and it was all ignored by the Court in favor of blatant word of mouth fraud. Why?

Judge Luster stated that he was not concerned with easement law, and that he had a right to order the “additional easement” (through Mary’s front yard) as a matter of access for Kari. And then Judge Luster ordered that a,(additional),10 ft. wide easement be created and surveyed through the lower portion of Parcel 1,(through Mary’s front yard), for the benefit of Parcel 2, (Exhibit 13) as part of his Judicial partition. Even though, his judicial partition was a lot line adjustment between Parcel 1, (became larger), and Parcel 2, (became smaller), and, where each Parcel would retain their respective access easements.

During proceedings in CV 2011-835, Richard Kuck argued that the 30 ft. wide easement of record for road right of way and utilities for Parcel 2 along the “access road” (Tavern Creek Drive) was nothing more than a “a two wheel track….”.(Exhibit 15)

False Narrative, 30 Ft. wide easement, access road, (Tavern Creek Drive) was not a viable road.

And, Richard Kuck also argued; that the only way anyone ever accessed Parcel 2, for 70 years since the 1940’s, was by traversing the existing road across parcel 1, (Exhibit 15) (through Mary’s front yard). Richard Kuck went on to argued that the 10 Ft. wide easement which Judge luster had created by court order and traversed through Mary’s front yard was the “existing road“.

False Narrative; The Judge Luster court ordered 10 ft wide easement through Mary’s yard for Parcel 2, was actually the existing road and the only access for parcel 2 for 70 years prior to 2012.

Mary had established a tree farm on her property during 2003 and the only road that existed across Mary’s land prior to the court ordered 10 ft. wide easement through her front yard was Mary’s little service road that she created and used to service her tree farm and was only used by her.

And, Parcel 1 was severed (created) in 1980. Parcel 2 was severed (created) in 1991. So, in 2012, “70 years” and “since the 1940’s”, didn’t work at all as a legal argument with regards to Parcel 1 and Parcel 2.

Later, at that same hearing in CV 2011-835, Judge Luster erroneously referred to the appurtenant, (primary easement), easement of record for road right of way and utilities for Parcel 2 along the 30 ft. wide access road (Tavern Creek Drive) as the “secondary access” to Parcel 2.(Exhibit 16)