IN THE THIRTIETH JUDICIAL DISTRICT
DISTRICT COURT, BARBER COUNTY, KANSAS
GERALD L. BROWN, JACQUELYN R.
BROWN, GERALD B. BROWN, KYLIE M.
BROWN, JOHN EARL CARROLL, AND
HEATHER W. CARROLL
Plaintiff,
vs.
V&S RAILWAY, INC., V&S RAILWAY, LLC,
and executors, administrators, devisees, trustees, creditors, and assigns of the defendant as may be deceased, any unknown officers, successors, and assigns of the defendant as are or were partners or in partnership; and any unknown guardians and trustees of the defendants as are minors or in any wise under legal disability.
Defendants.
Case No. 2026-CV-000020
________________________________________
Pursuant to K.S.A. Chapter 60
NOTICE OF SUIT
THE STATE OF KANSAS to the above named defendants:
You and each of you are hereby notified that you have been sued in the above-entitled action by the above named Plaintiff, and that you must answer the Petition to Quiet Title filed by the Plaintiffs in said Court on or before the 10th day of February, 2027, or said Petition will be taken as true, and judgment rendered against you and each of you, the nature of which said judgement will be that Plaintiffs are the owners of the legal and equitable title and are in possession, and have the right to possession, of the hereinafter described real estate, and a decree will be entered quieting Plaintiffs’ title and excusing you and each of you from any interest in, claim to, or lien upon said described real estate or any part thereof, and restraining and enjoining you, and each of you, and all persons holding by, through, or under you, or either of any of you from setting up or asserting any right, title, interest estate or equity of redemption in and to the following described real estate in Barber County, Kansas, to-wit:
a. THE SURFACE INTEREST ONLY IN AND TO:
A tract of land located in the Northwest Quarter (NW ¼ ) of Section 28, Township 31 South, Range 13 West of the 6th Principal Meridian, Barber County, Kansas, more particularly described as follows: Beginning at the Southeast corner of said Northwest Quarter (NW ¼), thence North along the East line of said Northwest Quarter (NW ¼ ) a distance of 1970.51 feet, more or less, to the South line of the railroad right of way, thence North 54 degrees 48 minutes 07 seconds West along said right of way a distance of 1128.76 feet to the North line of said Northwest Quarter (NW ¼ ), thence North 89 degrees 43 minutes 27 seconds West along said North line a distance of 53.88 feet, thence South 5 degrees 34 minutes 54 seconds West a distance of 404.07 feet, thence South 64 degrees 49 minutes 01 seconds West a distance of 233.77 feet, thence South 35 degrees 16 minutes 05 seconds West a distance of 271.14 feet, thence South 19 degrees 09 minutes 05 seconds West a distance of 675.70 feet thence South 55 degrees 07 minutes 12 seconds West a distance of 762.17 feet, thence North 86 degrees 06 minutes 32 seconds West a distance of 237.92 feet, thence North 45 degrees 06 minutes 10 seconds West a distance of 245.14 feet to the West line of said Northwest Quarter (NW ¼ ), thence South 0 degrees 03 minutes 16 seconds East a distance of 1013.88 feet, thence North 89 degrees 59 minutes 23 seconds East a distance of 2640.65 feet to the Point of Beginning.
b. THE SURFACE INTEREST ONLY IN AND TO:
A tract of land located in the East Half of the Southwest Quarter (E ½ SW ¼ ) of section 21, Township 31 South, Range 13 West of the 6th Principal Meridian, Barber County, Kansas, more particularly described as follows: Beginning at the Southwest corner of the said East Half of the Southwest Quarter (E ½ SW ¼ ) of Section 21, thence N00°02’25”E a distance of 407.97 feet along the West line of the said East Half of the Southwest Quarter (E ½ SW ¼ ) of Section 21 to the South line of River Road: thence along said South line of River Road S64°00’56”E a distance of 117.86 feet; thence S39°04’03”E a distance of 465.79 feet to the South line of the said East Half of the Southwest Quarter (E ½ SW ¼ ) of Section 21; thence N89°14’22”W a distance of 399.83 feet to the Point of Beginning.
c. The East Half (E ½ ) and the East Half of the Southwest Quarter (E ½ SW ¼ ) of Section 28, Township 31 South, Range 13 West of the 6th Principal Meridian, Barber County, Kansas, except a tract commencing at Right of Way of the Atchison, Topeka and Santa Fe Railroad Company on center of Section line between Sections 27 and 28, Township 31 South, Range 13 West if the 6th Principal Meridian, Barber County, Kansas, thence due North 154 feet on Section line, thence due West 272 feet, thence due South to Right of Way of railroad, thence Northeasterly along right of way of said railroad to place of beginning.
each of you, and the unknown heirs, executors, administrators, devisees, trustees, and assigns of any of you, or any of you, you may be dead, and the unknown trustees, successors, officers, and assigns, if any, of defendant corporations; if they be in existence, and the unknown trustees, successors, officers and assigns, of defendant corporations, if they or either or any of them be dissolved, and all other persons holding by, through, or under you, or any of you, will be forever excluded from any interest in, claim, to or lien upon said described premises, or any part thereof, and Plaintiffs’ title will be quieted in them, and the Plaintiffs will be given a judgment for the costs of this action and Plaintiffs shall have such other and further relief as to this Court may deem right and proper.
/s/ Hannah L. Molz
Hannah L. Molz, #27626
124 E Kansas
PO Box 148
Medicine Lodge, KS 67104
(620) 886-5611
(620) 886-5560 (facsimile)
office@bclawks.com
