{"id":4091,"date":"2022-01-23T20:56:19","date_gmt":"2022-01-23T20:56:19","guid":{"rendered":"https:\/\/packrivervalleypi.com\/?page_id=4091"},"modified":"2023-03-25T17:07:41","modified_gmt":"2023-03-25T17:07:41","slug":"prvpi-report-page-4","status":"publish","type":"page","link":"https:\/\/packrivervalleypi.com\/?page_id=4091","title":{"rendered":"PRVPI Report Page 4"},"content":{"rendered":"\n
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Ethel Boyd…Terri (Boyd) Davis…..Deanna L Barrett……..Brian F Davis.<\/p>\n\n\n\n

Page Four <\/h2>\n\n\n\n

Partial Historical Narrative continued<\/h3>\n\n\n\n

During April of 2013,<\/strong> while CV 2011- 835 was pending. Mary discovered, (while Mary was researching a different issue at the Bonner County Recorders Office), that an additional slander of title had been covertly created in May of 2012, and never disclosed to the CV 2011-0835 court<\/strong>.<\/p>\n\n\n\n

The 2012 slander of Mary’s title was executed between Kari Clark as grantor, and Kenneth J. and Deanna L. Barrett as beneficiary’s and recorded it at the Bonner County Recorders Office as Instrument No. 826342, (Exhibit 17<\/strong>). Where the entirety<\/strong> of Mary\u2019s land, COMMONLY KNOWN AS 4687 UPPER PACK RIVER ROAD, SANDPOINT IDAHO, 83864,<\/em> had been granted to the Barretts, by Kari Clark, in exchange for the Barretts loaning Kari Clark $10,000.00 to be used for attorney fees to assist Kari in responding to CV-2011-835 as described in the slanderous document. Members of the Boyd Gang had created this fraudulent Deed of Trust, (Exhibit 17<\/strong>).<\/p>\n\n\n\n

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In addition to Kari Clark, and Kenneth J and Deanna L Barrett. The names Shirley Bade (Law), Terri Boyd-Davis and Ethel Boyd also appear on that slanderous Deed of Trust, created in May, 2012, (Exhibit 17<\/strong>). <\/p>\n\n\n\n

In 2013, shortly following Mary’s discovery of the second slander of Mary’s title, Mary filed a Motion for Reconsideration in CV 2011-0835 seeking quite title in both parcel 1 and parcel 2. A hearing date was set for around June 13, 2013. Kari filed for an extension, and the new hearing date was set for June 26, 2013.<\/p>\n\n\n\n

On June 25, 2013, the Barrett\u2019s filed Instrument No. 846245 \u201cCorrective Affidavit\u201d (Exhibit 20), at the Bonner County Recorders office, with regards to the slanderous deed of trust of 2012, (Exhibit 17).<\/p>\n\n\n\n

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That 2012 slander of Mary\u2019s title, (Exhibit 17), was done covertly and was never disclosed to the CV 2011-835 Court until Mary discovered it and disclosed it to the court in 2013.<\/p>\n\n\n\n

At the June 26, 2013 hearing, Judge Luster commented, stating; A motion for reconsideration is not a proper avenue to simply ask this court to re-design the framework of the lawsuit\u2026<\/em>(Exhibit 18A).<\/em><\/p>\n\n\n\n

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Mary’s Motion for reconsideration was denied.<\/p>\n\n\n\n

On August 30, 2013 Mary filed a MOTION for Leave to File an Amended Complaint<\/strong> in CV2011-0835, (to include Slander of Title) and to add Defendants, (the Barretts), (Exhibit 19 A).<\/p>\n\n\n\n

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A hearing was held on Oct. 18, 2013 on Mary\u2019s Motion for Leave to File an Amended Complaint<\/strong> in CV-2011-0835. Richard Kuck argued on behalf of Kari. Kuck argued, <\/em>(<\/strong>Exhibit 18B<\/strong>) ,that, the 2012 slander which Mary discovered in 2013 was already BEFORE THE COURT PRIOR TO TRIAL,<\/em> (Trial in CV2011-0835 was held on June 12 and 13, 2012). Notwithstanding Kuck\u2019s argument, Mary did not have a crystal ball or taro cards prior to the 2012 trial, and neither did the court.<\/strong> My point is, is that the said slander of title between Kari and the Barrett’s was executed in May of 2012, which was prior to the June, 2012 trial in CV-2011-0835, and said slander was never disclosed to the Court until Mary discovered and disclosed it to the Court in 2013. For Kuck to argue that is was before the court prior to trial was a fraudulent argument. <\/p>\n\n\n\n

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And Kuck went on to argue that Kari and the Barretts were only referring to that portion of property that Kari would receive after the partition action had completed as the Barrett\u2019s 2013 corrective affidavit, <\/em>(Exhibit 20)<\/strong>, confirms.<\/em> However, there was no evidence of that on the face of the slanderous deed of 2012, (Exhibit 17).<\/p>\n\n\n\n

And then, during that same hearing held on 10.18.2013, Judge Luster commented about Mary\u2019s Motion for Leave to Amend, stating; “I recognize that discretion generally on a motion to amend should be freely considered, liberally considered by the court, but I think the timing of this motion in light of the issues that were litigated creates some more complex issues for the court to consider than would be formally taken up in a motion that was advanced prior to trial”.<\/em>(Exhibit 19 C<\/strong>).<\/p>\n\n\n\n

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Judge Luster denied Mary\u2019s MOTION FOR LEAVE TO AMEND.<\/strong> <\/em>Richard Kuck prepared the ORDER Denying Mary\u2019s MOTION FOR LEAVE TO AMEND, which was purposely and erroneously written for the record as “ORDER DENYING<\/em> PLAINTIFF’S RE-FILED MOTION FOR RECONSIDERATION”, <\/strong><\/em>which Judge Luster signed. And then Mary was presented a copy of. (Exhibit 19 B<\/strong>)<\/p>\n\n\n\n

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In 2013, after the 2012 slanderous fact, and after Mary cried foul in CV 2011-0835, Kenneth J. and Deanne L. Barrett prepared the \u201cCORRECTIVE AFFIDAVIT\u201d <\/em>(and filed it in the Bonner County recorders office as instrument # 846245, (Exhibit 20<\/strong>), Within that Corrective Affidavit, the Barrett’s swore to the following.<\/p>\n\n\n\n

Kenneth J and Deanna L Barrett swore: (Exhibit 20)<\/strong> see above<\/p>\n\n\n\n

\u201cThat for many years…Kari Clark and Mary Pandrea have jointly owned an approximate 20 acre parcel of land in Bonner County Idaho…\u201d<\/em>(The Barretts were well aware, as Richard Kuck argued, (Exhibit 8), and all court records and deeds of record clearly show, that Mary and Kari owned 2 distinct and separate parcels of land known as parcel 1(since 1980) and parcel 2, (since 1991),).<\/p>\n\n\n\n

False Narrative, one 20 acre parcel.<\/strong><\/p>\n\n\n\n

Kenneth J and Deanna L Barrett swore:(Exhibit 20)<\/strong> see above<\/p>\n\n\n\n

\u201cIn 2011 Pandrea sued Clark in Bonner County, Idaho District Court Case No. CV 2011-0835 requesting that the court order the Bonner County property sold\u201d <\/em>(The Barretts were well aware that Mary Pandrea filed CV 2011-0835 because (Kari) Clark slandered (Mary) Pandrea\u2019s title to her (50% interest in Parcel 2) land in 2010.)<\/p>\n\n\n\n

False Narrative, Mary wanted to sell her land and that Mary, just, out of the blue, sued Kari in order to do so.<\/strong><\/p>\n\n\n\n

Kenneth J and Deanna L Barrett swore:(Exhibit 20)<\/strong> see above<\/p>\n\n\n\n

\u201cClark informed Deanna Barrett that<\/em> she did not want to be forced to sell the Bonner County Property because it held great sentimental value to her…\u201d<\/em>,<\/strong><\/p>\n\n\n\n

I don\u2019t know how to address this BS. The Barretts , (Boyd Gang), now own Kari\u2019s property.<\/strong><\/p>\n\n\n\n

Kari Clark, who resided then and still resides in Sutherland Oregon, showed very little interest throughout the years and decades in her jointly held property, (Parcel 1 and Parcel 2), which Mary payed for and then payed all taxes for and worked hard to improve and maintain. Kari testified during proceedings in open court in CV-2011-0835… That she, (Kari Clark)\u201cIf I was lucky I came one day a year\u201d (<\/em>Exhibit 21<\/strong>).<\/em><\/p>\n\n\n\n

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Kenneth J and Deanna L Barrett swore:(Exhibit 20)<\/strong> see above<\/p>\n\n\n\n

\u201cWe agreed to loan Clark $10,000.00 to enable her to retain legal counsel to protect her interest in the Bonner County Property.\u201d<\/em><\/p>\n\n\n\n

Ya, now the Boyd Gang (Barrett’s) own it. You can see how well Kari’s interest was protected. <\/p>\n\n\n\n

Kenneth J and Deanna L Barrett swore:(Exhibit 20)<\/strong> see above <\/p>\n\n\n\n

\u201cThis affidavit shall confirm that we release all interest under the Deed of Trust recorded in the Bonner County Recorders office on May 17, 2012 under instrument No. 826342 in any and all property awarded to Mary E. Pandrea as a result of the partition action in the Bonner County, Idaho District Court Case No. CV 2011-0835.<\/strong> We do NOT release our interest in said Deed of Trust to the property awarded to Clark.\u201d<\/em><\/p>\n\n\n\n

The above statement appears to be the Barrett\u2019s taking back their blatant slander of Mary\u2019s title, instrument No. 826342,(Exhibit 17), after the fact, and after Mary exposed the additional slander to the CV 2011-0835 court.<\/p>\n\n\n\n

Yep, the Barretts took back their slander of Mary\u2019s title, Or did they?<\/p>\n\n\n\n

On June 28, 2017, a DEED OF RECONVEYANCE was filed at the Bonner County Recorders Office as Instrument No. 907366 (Exhibit 17 X) wherein,<\/p>\n\n\n\n

PIONEER TITLE COMPANY OF KOOTINAI COUNTY, <\/strong>an Idaho Corporation, as Trustee in the DEED OF TRUST <\/em>(Exhibit 17, slander of Mary’s title) executed by KARI A. CLARK, INDIVIDUALLY AND AS TRUSTEE OF THE KARI A. CLARK REVOCABLE TRUST, U\/A JUNE 21, 2010,<\/strong><\/em><\/p>\n\n\n\n

Recorded MAY 17, 2012,<\/strong> Instrument No.826342<\/strong><\/em>, (Exhibit 17, slander of Mary’s title), <\/strong>Mortgage records of BONNER <\/strong>County, Idaho<\/em><\/p>\n\n\n\n

pursuant to the written request of the beneficiary, (Kenneth J. and Deanna L Barrett)<\/strong>, does hereby GRANT and RECONVEY unto the Parties Entitled Thereto, (The Barrett\u2019s),<\/em><\/p>\n\n\n\n

Legal Owners<\/em><\/p>\n\n\n\n

without warranty, ALL the estate and interest derived to it by or through said Deed of Trust, in the lands therein described\u2026<\/strong><\/em><\/p>\n\n\n\n

I recently, (2022) discovered this \u201cdeed of reconveyance\u201d document of 2017, (Exhibit 17 X<\/strong>). What does this document represent?<\/strong> Troubling.<\/p>\n\n\n\n

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page 1 of the 2012 slanderous deed of trust Instrument No. 826342, (Exhibit 17).<\/figcaption><\/figure>\n\n\n\n

In 2013, that false narrative (one twenty acre parcel),<\/strong> was also provided by Terri (Boyd) Davis through a sworn affidavit before the Bonner County Idaho CV 2013-1334 court, which was heard by Judge Mitchell’s Court in Kootenai County, Idaho, (Exhibit 22<\/strong>).<\/em><\/p>\n\n\n\n

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Terri (Boyd) Davis swore:<\/em><\/p>\n\n\n\n

\u201cI am aware that the property abutting the Thornton property to the north, which encompasses over 20 acres, has been jointly owned by my aunts, Kari A Clark and Mary E. Pandrea since the 1980s<\/strong>. Kari Clark and Mary Pandrea have completed the process of dividing that land into two separate parcels via a partition action in Bonner County Case No. CV-2011-835. <\/em>(I believe that was just another blatant perjury by an officer of the court and one of many fraudulent statements by Terri (Boyd) Davis within that sworn affidavit).<\/p>\n\n\n\n

\u201dFalse Narrative, one 20 acre property since the 1980s!<\/strong><\/p>\n\n\n\n

During the June 26, 2013 hearing in CV 2011-0835<\/strong> Judge Luster made a statement concerning the CV 2013-1334<\/strong> lawsuit and weather or not there was an easement across the Thornton’s land for the benefit of parcel 2. Judge Luster stated: “If there’s an easement there, there’s an easement there that obviously has been established expressly by some other document that is not in front of the Court, or, um, um, some other operation of law.<\/em>” <\/p>\n\n\n\n

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I believe that , “…some other document that is not in front of the<\/em> (CV 2011-0835) court.”<\/em>, was the Affidavit of Terri (Boyd) Davis in CV 2013-1334, where she perjures to the Court<\/strong>. And the “…um, um, some other operation of law”<\/em>. I don’t believe that fraud on the Court is an operation of Law. <\/p>\n\n\n\n

Bonner County Court Case CV 2013-1334, was originally before a Bonner County Idaho Court and then was conveniently moved and heard by Judge Mitchell\u2019s Kootenai County Idaho Court. Judge Mitchell relied on Terri (Boyd) Davis\u2019s sworn statement via affidavit, in determining, ordering, GRANTING, (Exhibit 23), that Kari Clark\u2019s Parcel 2 did<\/strong> have an existing easement across the Thornton\u2019s property. which then connected to Parcel 2\u2019s, (CV 2011-0835), court ordered 10 ft. wide easement (through Mary\u2019s front yard).<\/p>\n\n\n\n

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Judge Mitchel also denied that Mary had standing in his court, even though Mary owned Parcel 1 in 2013, (Instrument No. 226223). Mary and Kari were joint owners of Parcel 1 in December of 1992, as it pertained to instrument No.416381, which reserved an easement for Parcel 1. Parcel 2 Instrument No. 396781 (Exhibit 3), is not described at all in instrument No. 416381 (Exhibit 2X). Terri (Boyd) Davis’s phantom “20 acre parcel” is not described in instrument No. 416381. <\/p>\n\n\n\n

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Instrument No. 416381, (Exhibit 2X) describes an easement across the now Thornton’s land reserved for Parcel 1, via a boundary description for Parcel 1 as outlined in red. This boundary description language is very similar to that found on Instrument No. 226223 for Parcel 1, (Exhibit 2). Instrument No. 416381 does not describe Terri Boyd Davis’s phantom 20 acre parcel at all. Instead, it describes parcel 1, (which consisted of approximately 5 acres in 1992), and is located to the north of, and adjacent to the Thornton property. <\/p>\n\n\n\n

Judge Mitchell\u2019s CV-2013-1334 Court, had instrument No 416381 (Exhibit 2X) and the original deed of record for Parcel 1 Instrument No. 226223 (Exhibit 2) before it, by virtue of them both being exhibits in that case. <\/p>\n\n\n\n

The Original title, (deed of record) for Parcel 2 as it was severed in 1991 and sold to Kari Clark and recorded at the Bonner County Recorders Office as instrument No. 396781, (Exhibit 3), includes the following appurtenant easement language;<\/p>\n\n\n\n

\u201cTogether with and subject to<\/strong> a 30.0 foot wide easement for road right of way and utilities on existing road as surveyed or to be surveyed\u201d<\/em><\/p>\n\n\n\n

The existing road, (Tavern Creek Drive), was surveyed in 1976 <\/strong>where it passes over parcel 2, and again it was Surveyed in 2019<\/strong> where it passes over Parcel 1, Both surveys depict Parcels 1 and 2 as they are today, post lot line adjustment per CV-2011-0835 judgment. (Exhibit 24)<\/p>\n\n\n\n

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The judicial partition, lot line adjustment of CV 2011-0835, awarded Mary all of Parcel 1 and part of Parcel 2.<\/em><\/p>\n\n\n\n

And awarded Kari part of parcel 2.<\/em><\/p>\n\n\n\n

They both received all and any easement rights that went with those two parcels respectively and Kari’s Parcel 2 was awarded additional access through Mary\u2019s front yard.<\/p>\n\n\n\n

Mary argued that the original easements of record for Parcel 1 and Parcel 2 should be included in the language of that judgment. Kari, through her lawyer Richard Kuck, (the Boyd Gang), argued against that concept, and Kari was granted the following judgment language by the Luster court. (Exhibit 25 A)<\/p>\n\n\n\n

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This survey of Parcel 1 and Parcel 2, was provided by Kari Clarks legal team (Richard Kuck and Terri (Boyd) Davis) in CV-2011-0835 and purposely excluded the existing easement of record for Parcel 2 along the existing access road (TAVERN CREEK DRIVE). <\/figcaption><\/figure>\n\n\n\n

Mary was awarded ALL<\/strong>, (but was incorrectly written as \u201ca portion\u201d) of parcel 1 and a portion of Parcel 2 \u201cand any appurtenances thereon<\/em>\u201d.<\/p>\n\n\n\n

Kari was awarded a portion of parcel 2 \u201cand any appurtenances thereon\u201d,… \u201cbeing a portion of that parcel described in instrument No. 396781; More particularly described as follows:<\/em><\/p>\n\n\n\n

…Together with and subject to<\/strong> an easement appurtenant to the land for ingress and egress and through and over the parcel awarded to Plaintiff Mary E Pandrea as the servient parcel and estate, legally described above, which easement is described as follows:<\/em><\/p>\n\n\n\n

An easement for ingress and egress…being the width of the existing road,<\/strong> ten(10) feet wide in most areas\u2026\u201d<\/em><\/p>\n\n\n\n

I<\/strong>t was a court ordered 10 ft wide easement, not \u201cthe existing road\u201d<\/em> and parcel 2 was not \u201csubject to” <\/em>it. <\/em>Parcel 2 is subject to<\/strong> the 30 ft. wide road, known as Tavern Creek Drive.<\/p>\n\n\n\n

The Bonner County CV 2011-0835 judgment was filed at the Bonner County Recorders office as instrument # 856497 (Exhibit 25A), above.<\/p>\n\n\n\n

In 2014 Kari quit claimed her property (Parcel 2) to the Barretts and that quit claim deed was filed at the Bonner County Recorders Office as instrument # 860871, (Exhibit 25B). In that deed, the easement to the Barrett\u2019s parcel is described as follows:<\/p>\n\n\n\n

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\u201cTogether with<\/strong> an easement for ingress and egress through and over the parcel awarded to Plaintiff Mary E. Pandrea by Judgment recorded February 26, 2014 as Instrument No. 856497……as follows:<\/em><\/p>\n\n\n\n

…being the width of the existing road, ten feet wide in most areas…\u201d<\/em><\/p>\n\n\n\n

The new easement for Parcel 2 now excluded the language \u201csubject to\u201d.<\/em><\/p>\n\n\n\n

The original easement language for parcel 2 had now disappeared completely except it did include the words \u201cexisting road\u201d<\/em> But, was now used to describe the 10 ft. wide easement, (through Mary’s front yard), which Judge Luster had ordered as additional access for parcel 2.<\/p>\n\n\n\n

Deanna L. Barrett and Kenneth J. Barrett substituted, (in the stead)<\/em> for Kari Clark in CV 2011-0835, because they had acquired Kari\u2019s parcel 2 prior to March, 2015. During a March , 2015, hearing<\/strong> in that case, Deanna L Barrett argued prose. (Exhibit 32)<\/p>\n\n\n\n

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Deanna L. Barrett argued; \u201c…the Court\u2019s decision leaves us with NO EASEMENT ACCESS to our parcel, <\/em>(2); because the legal description of the previous parcel two (2), from which our property was divided, does not describe an easement by the upper road, (Tavern Creek Drive), despite Pandrea\u2019s misleading argument to the contrary.\u201d, <\/em>(Judge Luster was still the presiding Judge in CV 2011-0835 and he had both of the original deeds of record for Parcel 1 and Parcel 2 before him, which proved that Barrett was lying to the court)<\/strong>… \u201cOur access to the upper road, (Tavern Creek Drive), is not a result of us having an easement up it that serves Parcel 2. But rather we are able to use the upper road, (Tavern Creek Drive) because my grandfather\u2019s grave is up there, and because Aunt Kari Allows us to to access her Parcel 10 along, ooh, this road\u2026.There is a locked gate at the bottom of the upper road, and we have never had a key to this gate. I also need to discuss that there is no road that reaches the lower portion of our property from the upper road…\u201d<\/em>. The no key and never had one is another lie. The Boyd Gang most definitely have a key to that gate. <\/p>\n\n\n\n

Remember (Exhibit 3), Parcel 2 <\/strong>and the easement for road right of way and utilities, Tavern Creek Drive (the upper road). AND, there is a perfectly good road that traverses across the Barrett’s land (Parcel 2), which provides perfectly good access down to the river front portion of their land. Barrett, was and still is fully aware of that fact.<\/p>\n\n\n\n

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On 4\/27\/2016 Deanna (L.) Barrett applied for <\/strong>and was granted A RIGHT-OF-WAY USE & ENCROACHMENT PERMIT<\/strong> (Exhibit 30), by Bonner County Road and Bridge Department. On that application, the CV 2011-0835 court ordered 10 ft. wide additional easement access, (through Mary\u2019s front yard), in order to provide additional access for the Barrett\u2019s Parcel 2 is described as follows:<\/p>\n\n\n\n

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(Exhibit 30 Page 1)<\/p>\n\n\n\n

Encroachment Type: RESIDENTIAL DRIVEWAY PERMANENT EXISTING<\/em> (10Ft. wide court ordered additional access easement through Mary’s front yard) <\/p>\n\n\n\n

Directions\/Notes: NEW RD – 3rd<\/em><\/sup> ADDRESS <\/em>( vacant property) – Clarks Place, <\/strong><\/em>(Tiger Lily Lane)<\/strong><\/p>\n\n\n\n

The<\/strong>, to be filed out by Road Department, (section at the bottom of the application), was dated 4\/28\/16<\/p>\n\n\n\n

And Described<\/strong><\/p>\n\n\n\n

Width of Driveway 20\u2019<\/em>, (10 Ft. wide court ordered additional access easement through Mary’s front yard)<\/p>\n\n\n\n

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Within the \u201cGENERAL PROVISIONS\u201d on this application provided the following: (Exhibit 30, page 2)<\/p>\n\n\n\n

8.<\/strong> This permit or privilege granted under this permit shall not be deemed or held to be an exclusive one and shall not prohibit Bonner County from using any of its, roads or public places or effects its right to full supervision and control over all or any part of them, non of which is hereby surrendered. The Bonner County Road and Bridge Department reserves the right to make at any time such modification,<\/strong> addition repair, RELOCATION OR REMOVAL of an existing encroachment(s) or its appurtenances or any encroachment(s) or subject(s) authorized by this permit<\/strong> within the right-of-way<\/strong> as may be necessary<\/strong> to<\/strong> permit the relocation, reconstruction, widening and maintenance of the road and PROVIDE PROTECTION TO LIFE AND PROPERTY ON OR ADJACENT TO THE ROAD.<\/strong><\/em><\/p>\n\n\n\n

Tiger Lily Lane is the Barrett\u2019s RIGHT-OF-WAY encroachment through Mary\u2019s front yard. The Boyd Gang uses that illegal RIGHT-OF-WAY to access Mary\u2019s front yard, where they gang harassment Mary and her family<\/strong>, purposely harming them.<\/p>\n\n\n\n

Bonner County has the authority to remove that RIGHT-OF -WAY encroachment along Tiger Lily Lane, and\/or, to relocate it to TAVERN CREEK DRIVE where it legally belongs.<\/strong><\/em><\/p>\n\n\n\n

In 2017, Neil O’Neill III, owner of property which is situated to the north of the Barrett (Boyd Gang) owned Parcel 2, filed a lawsuit in the Bonner County District Court, CV 2017-0356. Asking the court to determine that an easement existed along Tavern Creek Drive. Or in the alternative, an easement existed along Tiger Lily Lane. And then, either way, continued along the road across Parcel 2, providing access to his property located just beyond the US Forest Service Land. <\/p>\n\n\n\n

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Mr. O’Neill’s property is located to the north of the Barrett (Boyd Gang)’s parcel 2, just beyond the US Forest service land. <\/figcaption><\/figure>\n\n\n\n

Mr. O’Neill filed the lawsuit because the Barrett\u2019s, (Boyd Gang) had blocked the road which traverses across their property from Tavern Creek Drive, by erecting a locked gate at the entrance to that road, where it originates from Tavern Creek Drive, (Tavern Creek Drive traverses across the corner of the Barrett\u2019s property, Parcel 2).<\/p>\n\n\n\n

Deanna L. Barrett filed DECLARATION OF DEANNA L. BARRETT IN SUPPORT OF DEFENDANT BARRETTS\u2019 MOTION FOR PARTIAL SUMMERY JUDGMENT in CASE NO. CV 2017-0356, (Exhibit 31)<\/p>\n\n\n\n

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Within that DECLARATION Deanna L. Barrett swore to the following;<\/p>\n\n\n\n

Deanna<\/em> L. Barrett swore: (Exhibit 31)<\/p>\n\n\n\n

In 2011, Mary (Pandrea) brought a partition action against Kari (Clark). Judgment was entered in that case on January 24, 2014. The Court divided the Property between Kari and Mary. Kari acquired the parcel known herein as the Barrett Property (Parcel 2) and Mary acquired the parcel known herein as the Gadbaw property (Parcel 1). Because the partitioning of the property resulted in cutting off access to the Barrett Property from the county road, as part of the partition action, the court created an easement across the Gadbaw property (Parcel 1) to serve the Barrett Property (Parcel 2).<\/strong><\/em><\/p>\n\n\n\n

There is that False Narrative again. <\/strong> Parcel 2\u2019s easement of record (Tavern Creek Drive) isn\u2019t going away no matter what lie Barrett tells.<\/p>\n\n\n\n

Deanna L. Barrett swore: (Exhibit 31)<\/strong><\/p>\n\n\n\n

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On or about July 8, 2014, I arrived in Idaho from my home in Michigan and stayed at my mother\u2019s home in the Pack River Valley, a short walk from the Barrett Property, (Parcel 2). I was anxious to walk across the Barrett Property, (Parcel 2), that I had recently acquired, so my mother and I headed to my property, (Parcel 2). We were walking across the Barrett Footpath<\/strong> when we encountered O’Neill driving<\/strong> across it. I told him I didn\u2019t want him driving<\/strong> on my property and he said he had a right to, claiming that he had an easement across it\u2026.<\/em><\/p>\n\n\n\n

Mr. O\u2019Neill<\/strong> had driven his motor vehicle<\/strong> from the Upper Pack River Road (county road), along the Upper Access Road, AKA Southern Access Road, AKA Tavern Creek Drive, to the Barrett\u2019s (Boyd Gang’s) property (Parcel 2). And then he continued driving his vehicle across Parcel 2. And, then he continued across the US Forest Service land. Mr. O’Neill had already applied for and easily and properly received a permit from the USFS in order to legally cross said USFS land, in order to access his property in accordance with his appurtenant easement of record, as written on his property deed\u2019s legal description, which is similar easement language to that written on the original deed for Parcel 2. While driving his motor vehicle across Parcel 2 he encountered Deanna L. Barrett and her mother Ethel Boyd walking across Parcel 2, AKA Barrett\u2019s (Boyd Gang’s) vacant property.<\/p>\n\n\n\n

Deanna L Barrett Swore: (Exhibit 31)<\/p>\n\n\n\n

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\u201cA few days later in a further effort to prevent additional damage to my property, I had a locked gate erected in the same location where Mary and Kari\u2019s gate had been for well over a decade when they owned the property, (Parcel 2)\u201d\u2026..<\/em>The gate that Barrett speaks to here is located where the road which traverses across Parcel 2 originates from Tavern Creek Drive as it passes directly over Parcel 2. And Mary and Kari,(when they were co-owners of parcel 2), did maintain a gate there at that entrance to parcel 2 from parcel 2\u2019s appurtenant easement of record, (Tavern Creek Drive). And Barrett was and still is well aware of that, obviously.<\/p>\n\n\n\n

The CV 2017-0356 Court, Judge B. Buchanan OF BONNER COUNTY<\/strong>, <\/em>confirmed that Mr. O\u2019Neill\u2019s property did have an easement access for road right of way and utilities along the, so called, Southern Access Road, AKA, TAVERN CREEK DRIVE and then continuing along the road over parcel 2, AKA Barrett (Boyd Gang) property, in order to access the O\u2019Neill property. And, that same Court denied O\u2019Neill\u2019s claimed access through Mary\u2019s front yard, AKA, Tiger Lily Lane. (Exhibit 33)<\/p>\n\n\n\n

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Deanna L Barrett Swore:(Exhibit 31)<\/p>\n\n\n\n

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\u201cIn 2016, I asked Bonner County Road and Bridge Department to provide me with a physical address to the Barrett property (Parcel 2). I was informed by employees at the road and bridge department that Bonner County ordinance required that the ROAD CREATED BY THE COURT in the partition action would require an official name.<\/strong> They explained that this was because the easement coming off the county road served three properties\u2014the Thornton Property, the Gadbaw Property (parcel 1) and the Barrett Property (parcel 2) and the county ordinances requires if more than two properties are served by a road that the road have its own name. It was at that time that the EASEMENT ROAD THAT WAS CREATED BY THE COURT IN 2014, (CV 2011-0835) as a result of the partition action was officially named Tiger Lily Lane by the County\u201d.<\/em><\/p>\n\n\n\n

BARRETTS\u2019 MOTION FOR PARTIAL SUMMERY JUDGMENT in Bonner County CASE NO. CV 2017-0356 was denied.<\/p>\n\n\n\n

I believe that Judge Buchanan of Bonner County was an impartial Jurist who did her best to uphold the law. <\/p>\n\n\n\n

On April 27, 2016 Deanna L Barrett applied for<\/strong> a RIGHT-OF-WAY use and ENCROACHMENT PERMIT<\/strong> at the Bonner County ROAD AND BRIDGE DEPARTMENT. Bonner County granted Barrett a permitted driveway right-of-way encroachment through Mary\u2019s front yard. (exhibit 30) above. <\/p>\n\n\n\n

That Right-of-Way encroachment for the Barrett\u2019s land (Parcel 2) should be along the appurtenant easement for road right-of-way and utilities for parcel 2, the 30 Ft. wide access road, AKA (Tavern Creek Drive) as written on the original land deed of record for Parcel 2 as it was severed in 1991.<\/p>\n\n\n\n

\u201cTiger Lily Lane\u201d is a Bonner County Government Permitted trespass on an innocent land owner, and was imposed as a direct result of the fraud perpetrated by Barrett and other members of the Boyd Gang. And Tiger Lily Lane is now used by the Boyd Gang in order to gang harass Mary and her family in Mary’s front yard.<\/p>\n\n\n\n

So my questions are:<\/p>\n\n\n\n

Why did Officer of the Court, Terri (Boyd) Davis, along with Officer of the Court, Richard Kuck, defraud the CV 2011-0835 Court in order to obtain an unnecessary 10 Ft. wide secondary easement through Mary\u2019s front yard for parcel 2, which went against all documentary evidence before that court and which Mary argued against?<\/p>\n\n\n\n

Why did Officer of the Court, Terri (Boyd) Davis, along with Officer of the Court, Joel P. Hazel, defraud the CV 2013-1334 Court in order to obtain an unnecessary easement across the Thornton\u2019s land for Parcel 2, which went against all documentary evidence before that court and which the Thorntons and Mary argued against?<\/p>\n\n\n\n

Why did Deanna L Barrett defraud the CV 2011-0835 court, arguing (prose) that Tavern Creek Drive was not the primary easement of record for Parcel 2, and that you can not reach the riverfront portion of parcel 2 from Tavern Creek Drive, which went against all documentary evidence before that court and which Mary argued against?<\/p>\n\n\n\n

Why did Deanna L Barrett defraud the CV-2017-0356 court, swearing that the easement through Mary\u2019s front yard, which was created for Parcel 2 in CV 2011-0835, was created by that Court because the judicial partition resulted in there being no other access to Parcel 2?<\/p>\n\n\n\n

Why did Deanna L Barrett defraud the Bonner County Road and bridge department requesting that a Right-of-Way encroachment by established through Mary\u2019s front yard for the benefit of the vacant Parcel 2 instead of where it belongs along Tavern Creek Drive?<\/p>\n\n\n\n

Why did Deanna L. Barrett defraud the CV-2017-0356 court, swearing that Bonner County, on its own, established Tiger Lily Lane and assigned the vacant Parcel 2 an address at the end of it?<\/p>\n\n\n\n

The answer is; Because the Boyd Gang like to have access to Mary\u2019s front yard where they can impose themselves on Mary and Mary\u2019s family. Where they can gang harass Mary and Mary\u2019s family, while they collude how they will \u201cget\u201d Mary’s property from her someday.<\/p>\n\n\n\n

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Ethel Boyd…Terri (Boyd) Davis…..Deanna L Barrett……..Brian F Davis. Page Four Partial Historical Narrative continued During April of 2013, while CV 2011- 835 was pending. Mary discovered, (while Mary was researching a different issue at the Bonner County Recorders Office), that an additional slander of title had been covertly created in May of 2012, and never […]<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":1020,"menu_order":4,"comment_status":"closed","ping_status":"closed","template":"","meta":{"om_disable_all_campaigns":false,"_monsterinsights_skip_tracking":false,"footnotes":""},"class_list":["post-4091","page","type-page","status-publish","hentry"],"aioseo_notices":[],"aioseo_head":"\n\t\t\n\t\n\t\n\t\n\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t