SHERRY BELLAMY, et al. * IN THE

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1 SHERRY BELLAMY, et al. * IN THE Plaintiffs * CIRCUIT COURT v. * FOR PROPERTY OWNERS ASSOCIATION * ANNE ARUNDEL COUNTY OF ARUNDEL ON THE BAY, INC., et al. * Case No.: C IJ Defendants * RESPONSE TO MOTION TO STRIKE COUNTERCLAIM Defendants, Property Owners Association of Arundel on the Bay, Inc. ( Association ), Frank Florentine, Barry Dempsey, R. Rebecca Morris, David Zeman and Michael Merrigan, by their undersigned attorneys, Wayne T. Kosmerl, Susan T. Ford and Council, Baradel, Kosmerl and Nolan, P.A., hereby respond to the Motion to Strike Counterclaim. A. The Counterclaim Was Timely Filed Plaintiffs make the argument, without any supporting authority, that under Rule 2-331(d), a Counterclaim must be filed before a Court rules on a Rule motion to dismiss a complaint and the ensuing answer is filed. This argument is patently frivolous and the Motion to Strike should be denied. The Plaintiffs filed a six count Complaint on July 5, Defendants filed a Motion to Dismiss all counts except one and an Answer to one count on August 8, The Plaintiffs filed an opposing memorandum on August 28, The Court ruled on the Motion to Dismiss by Order dated September 5, 2006, but not entered on the docket until September 8, 2006, denying the motion to dismiss. Exhibit A. Accordingly, pursuant to Maryland Rule 2-321, the time for filing an answer to the complaint was

2 extended without special order to 15 days after entry of the court s order disposing of the motion. Fifteen days from the date of the entry of the order disposing of the motion was September 23, 2006, a Saturday. If a time period by which a document must be filed ends on a Saturday, Sunday or holiday, then the required filing day is the next day the court is open, or in this case, September 25, Maryland Rule The Answer to the Complaint was filed on September 25, The Counterclaim was filed within thirty days of the date of filing the Answer to the Complaint, on October 25, Maryland Rule (d). Plaintiffs statement at page 3 of their Memorandum that Defendants even failed to file the Counterclaim within 30 days after the time for filing their answer to Counts I - IV and VI of the Complaint is completely without merit. Thirty days from September 25 th is October 25 th. Obviously, the Counterclaim was timely filed. Plaintiffs argue that because Defendants filed a limited Answer to one of the counts of their six count Complaint along with the Rule Motion to Dismiss, they were required to file a Counterclaim within 30 days of the date they filed their Motion to Dismiss and limited Answer, despite the fact that a Rule motion to dismiss the majority of the Complaint was pending. Plaintiffs cite no authority for this proposition and indeed it is not supported by the Maryland Rules, case law or common sense. The Maryland Rules clearly allow the filing of a Counterclaim within 30 days of filing an Answer. The Defendants filed a Counterclaim within 30 days of filing an Answer to Counts I, II, III, IV, and VI of the Complaint. If Plaintiffs argument prevails, then Defendants would have been in the position of having to file a Counterclaim against a Complaint which the Court could have dismissed. Under this reasoning the Plaintiffs 2

3 would then have been in the position they profess to object to, being forced to expend resources to respond to a Counterclaim which could be moot. B. Plaintiffs Are Not Prejudiced By The Counterclaim Presuming for the sake of argument that the Counterclaim should have been filed before the Court ruled on Defendants Rule Motion to Dismiss and filed an Answer, or was otherwise not timely filed, Defendants hereby seek leave of court to permit the filing. Plaintiffs have not been prejudiced by the filing of the Counterclaim. Plaintiffs admit that the Counterclaim addresses the same issues raised in Defendants defenses to the Complaint filed months ago, namely a dispute over title to platted streets in Arundel on the Bay. Plaintiffs claim that they will be prejudiced by the timing of the filing of the Counterclaim and that they may need to extend the Scheduling Order. Plaintiffs filed their Complaint in July, 2006, over four months ago and still have not propounded any discovery requests nor sought to take any depositions. Indeed, Plaintiffs waited until the date the Scheduling Order mandated that they name experts, November 8, 2006, to request an extension of time to name their experts. Plaintiffs chose not to use four months of available time to conduct any discovery. They can not now claim to be prejudiced by the filing of the Counterclaim. Plaintiffs admit that the Counterclaim refers to the same issues raised in Defendants defenses to the Complaint filed months ago, namely a dispute over title to platted streets in Arundel on the Bay. Plaintiffs claim superior title to certain platted streets in the community of Arundel on the Bay pursuant to Maryland Real Property Code Ann They also seek injunctive relief to prevent the Defendants from 3

4 trespassing upon portions of the platted streets which Plaintiffs claim to be their properties and to prevent the Defendants from constructing any improvements on the same platted streets. As was raised in the listed defenses to Count V of the Complaint filed over three months ago, the Defendants put Plaintiffs on notice the Association has held a deed to the same streets claimed by the Plaintiffs since 1951 which the Association was granted upon the dissolution of the town of Arundel on the Bay ( 1951 Deed ) and that it claims title to the streets pursuant to that deed. The Plaintiffs now assert, more than fifty years after the 1951 Deed to the Association was recorded, that the deed is invalid and request that this Court quiet title and grant declaratory relief regarding the ownership of the platted streets in their favor. The Counterclaim filed by Defendants seeks declaratory relief and to quiet title regarding the ownership of the roads based upon the 1951 Deed. The Plaintiffs are apparently requesting that the Court rule on their claims of ownership of the platted streets in a vacuum, without considering the import of the deed held by the Association for over fifty years and surrounding circumstances regarding the scheme of development in Arundel on the Bay. As discussed in Defendants Motion to Dismiss and Response to Memorandum in Opposition to Motion to Dismiss Complaint, invalidating the Association s 1951 Deed to the streets in Arundel on the Bay could have serious repercussions for all property owners in the community. Based upon the 1951 Deed, the Association has granted deeds conveying certain streets in Arundel on the Bay to Anne Arundel County and the County now maintains those streets. The Association has also conveyed utility easements in the streets to the County and community recreational amenities have been built on certain street ends which can be used and 4

5 enjoyed by all property owners in the community. Decades ago, the community voted to impose a Special Community Benefit Taxing District whereby all the property owners in Arundel on the Bay are specially taxed for purposes which include the maintenance of non-county owned roads in the community. The Association administers the Special Community Benefit Taxing District. If this court finds the Association s 1951 Deed to the streets invalid (and thus presumably from the Plaintiffs argument, also that the deeds to the County for certain streets and utility easements are invalid) and that the hundreds of private property owners in Arundel on the Bay each individually own small segments of the streets, complex liability and maintenance issues arise which could impact all the property owners in Arundel on the Bay, particularly as Plaintiffs are seeking to prevent the Association from making any improvements to the platted streets. As Plaintiffs acknowledge, the Defendants expressly raised the existence and claim of validity of the 1951 Deed in their Answer and Defenses to Count V of the Complaint. The Counterclaim was not filed late, and even if it were, there is no prejudice arising from filing the Counterclaim. It specifically counters the claims for declaratory judgment and quiet title made in the Complaint. Plaintiffs were put on notice of those claims months ago, as they acknowledge, and have chosen not to undertake discovery. Last, Plaintiffs argue that Defendants know that the 1951 Deed is invalid and argue that they should not be required to defend the Counterclaim and prove the invalidity of the 1951 deed by hiring experts and taking depositions. Plaintiffs cite as support for this proposition portions of depositions from litigation to which none of them were parties (although Plaintiffs Bumbrays and Bellamys predecessors in title were parties to the Durant litigation) and in which litigation no court has ruled on the title issue 5

6 presented in this case. The same issue raised by Plaintiffs herein, of a property owner s claim of superior title to the streets in Arundel on the Bay by virtue of Md. Real Property Code 2-114, was, however, raised by the Defendant in the McManus litigation referenced by Plaintiffs in a motion for summary judgment supported by an affidavit of a title expert. The Court refused to grant summary judgment to the defendant in that case on her claim of superior title pursuant to Md. Real Property Code Ann The Court did not rule on the title issue in its Memorandum Opinion and Order, much less rule that the Association s deed was invalid. 1 Indeed, the Court stated at page 6 of its decision in the McManus litigation, Exhibit C to Plaintiff s Motion to Strike, that if it made a finding for the Defendant in that case based upon adverse possession, it did not need to reach the title issue. The Court s final order at page 16 of the McManus decision was only made based upon adverse possession. Likewise, in the 1996 Durant Opinion, Exhibit D to the Motion to Strike, this Court did not rule on the issue of title to the streets, although the Court commented on page 10 of its Opinion that [t]here was evidence presented before the Court that supported the Plaintiff s argument that it had obtained title decades earlier by means of the grant from the Trustees of Arundel on the Bay. Both the Durant and McManus cases involved the removal of fences which obstructed platted streets in Arundel on the Bay which were decided based upon grounds other than fee simple title. Further, the 1951 deed is an ancient document and is entitled to a presumption of validity. Siemiesz v. Amend, 237 Md. 438 (1965), Homewood Realty Corp. v. Safe Deposit and Trust Co. of Balt., 160 Md. 457, 473 (1931). When there is a missing link in a historic chain of title, the court is permitted to supply the missing link in the chain 1 There is a pending Rule Motion to Alter or Amend Judgment filed in the McManus litigation which has not been ruled upon as of the date of the filing of this Opposition. 6

7 through the legal fiction of presuming the existence of the missing deed if doing so would further the public purpose and promote equity. Baltimore Chemical Manufacturing v. Dobbin, 23 Md. 210 (1865). Defendants are entitled to have this Court determine whether Plaintiffs claims are barred by laches and/or limitations because they have waited over fifty years to challenge the Association s deed to the streets. Defendants are entitled to have this Court determine whether it will invalidate the 1951 Deed with all the resulting potential shifts in liability and maintenance responsibilities for the platted streets in Arundel on the Bay, or whether to promote justice and equity, it will presume the missing deed as it is entitled to do and leave in place the status quo that has existed for over fifty years. Plaintiffs claim they will have to depose all the residents in Arundel on the Bay to determine the scope of the prescriptive easement claimed by Defendants. The Durant Opinion at page 11 expressly found that the portion of Chesapeake Avenue abutting Plaintiff Bellamys and Bumbrays deeded property boundary was subject to a prescriptive easement. Despite that finding by the Court, Plaintiffs chose to seek equitable relief prohibiting the Defendants from trespassing on platted streets which they deem to be their house or yard, including Chesapeake Avenue. They chose to seek a court order prohibiting Defendants from constructing any improvements to the disputed portions of paper streets despite settled Maryland precedent granting the holders of easements the right to construct improvements consistent with the scope of their easement. Shallow Run Limited Partnership v. State Highway Administration, 113 Md. App. 156, 171, 686 A.2d 1113 (1996). Paradoxically, Defendants admit there is a right of ingress and egress over Chesapeake Walk for the benefit of property owners. 7

8 Plaintiffs chose to bring an action which on its face seeks injunctive relief limiting rights of use of property owners in Arundel on the Bay. The Counterclaim seeks relief regarding settled and important rights in easements that the Plaintiffs put at issue by filing Count VI of the Complaint seeking to enjoin Defendants trespassing on their properties and from constructing any improvements thereon. They should not now be permitted to complain because they are being forced to litigate the scope of property rights which they chose to put in dispute. Wherefore, for the reasons set forth above, Defendants respectfully request that the Motion to Strike be denied. COUNCIL, BARADEL, KOSMERL & NOLAN, P.A. By: Wayne T. Kosmerl Susan T. Ford 125 West Street, 4 th Floor P. O. Box 2289 Annapolis, MD (410) Attorneys for Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the _22_ day of November, 2006, a copy of the Response to Motion to Dismiss Counterclaim was mailed first class, postage prepaid, to: Ava E. Lias-Booker, Esquire Jessica E. Morrison, Esquire Robert T. Johnson, Esquire McGuireWoods, LLP 7 Saint Paul Street, Suite 1000 Baltimore, Maryland Eileen E. Powers, Esquire Blumenthal, Delavan & William, P.A. 8

9 170 Jennifer Road, Suite 240 Annapolis, Maryland Susan T. Ford 9

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