Thu Mar 21, 2024

Clarity Points. No TRO obtained. Options?

Monday Mar 18, 2024

They rebutted on Saturday, introducing controversy where there is none
'Laughable' regarding them destroying our trees - will the guilty be punished here or is all fiction until proven as fact?
One clear picture with No Trespassing signs should prove it.
If we pursue TRO, we are ok with any bond amount

Other notes:

It is interesting that they are using our survey to prove their case

In particular:

No controversy exists in paragraph 2
Paragraph 3 - ludicrous. They are using our survey and claiming we don't have a survey. Will the guilty be punished severely?
Par 3 - according to local authorities, defendant has removed vehicles.
Par 4 - I'm ok with their proposed bond as long as it is refundable upon win
Par 5 - 'damages laughable' - guilty will be punished. Further, there is no controversy regarding location of boundary or pins, Hook is trying to create controversy.
What next?

Fri Mar 15, 2024

They have been served

Thu Mar 14, 2024

Documents drafting day.
Concluded meetings at 5 PM, next step is to sign.

Wed Mar 13, 2024

First review of the 2 documents
Accelerated petition by decision to engage TRO offer at about 3 PM.

Tue Mar 12, 2024

Met with Seth, got things rolling.

Mon Mar 11, 2024

Jere Loyd called back. Mentioned that lawsuits start with principle and end up with talking about money. He suggested an appraisal as a first step to see if the case would be economically feasible. However, principle is not for sale here. Interaction did not meet Microasshole Test.

Fri Mar 8, 2024

Dana McCubrey office called back. I did not end up committing to a Monday meeting.
Seth Slayden - A Five Star Reviewed by "Marcy" Said "Highly recommend Seth Slayden - Seth Slayden handled the drafting of our estate plan for my husband and me. He was knowledgeable, kind and considerate. He explained the entire process and sought input from us on what we wanted. He was very professional and the result gave us piece of mind. It was a very positive experience." The Avvo Review for Seth Wyatt Slayden
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- Seth Slayden shows pure professionalism. His hard work assisted us through every process, stayed in communication, and was honest. You can tell he has pure compassion for what he does.
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- Seth Slayden and Lindsey Holcumbrink handled our estate plan and they were both very helpful, professional and explained everything so that my husband and I understood all that was involved and what we needed to do. It was a very positive experience and gave us piece of mind.
- Mr. Slayden help was above and beyond what I excepted. He returned phone calls which in today’s world is MOST appreciated. He gave answer in Layman's terms for complete understanding.
Seth LinkedIn - [2]
earned a "Good" rating on Avvo - Seth Wyatt Slayden's Super Lawyers Page
4.9 on Birdeye [3]
4.8/5 in customer reviews [4]
5/5 on Avvo [5]
4.8 on Lawyers.com - [6]

Thu, Mar 7, 2024

Met Seth Slayden - https://www.taylorsiemenslaw.com/attorneys/seth-w-slayden/
Met Lauren 2 days ago - https://pucketthorsmanlawoffice.com/Lauren-Horsman
Regrid map - [7]
Tree destruction before and after photos [8]
More before and after pictures
Prepare these for Taylor-Siemens
Remedy sought:
- Towing-related expenses paid $1200 ($550 impound+$500 towing back+$150 new battery)
- Triple damages for trees - $158,760 total after triple damages.
  - Tree replacement, trees - 126 trees at anywhere between about $150 each for young tree at low cost [9] which is very generous given that there were many large, adult trees in the mix (about ______________)
  - Tree replacement, labor - $270 per tree
  - Tree replacement total - $420 per tree * 126= $52920
  - After Triple damages for trespassing, negligence, fraud, and vandalism - $158,760. Respondent deliberately informed me that he is allowed to go 20 feet onto our land according to 'fence law'
- Criminal charges for failure to notice, failure to communicate or agree, car theft via illegal towing, negligence, vandalism (our fence destroyed allowing 2 Great Pyrenees dogs to escape), tree destruction, trespassing, and general bad faith in the matter of destroying our fence, and removing the jointly-owned fence without notice or permission, going up to 33 feet onto our land with a Komatsu PC210LC (165 hp) excavator, and tree theft.
Tree replacement is not cheap. Even at the very low cost of $55 for saplings and $85 for labor, this is $140*126*3=$52920 for damages. Minimum cost here is $300, with range of $300-$10000.
Or remedy sought: tree replacement being done; 2x damages for cost of tree replacement. Same as above, except respondent transplants the trees. However, this is our second choice because we do not trust the respondent to do the job to spec.

Wed Mar 6, 2024

Talked to Puckett&Horsman again regarding signing on, visiting Taylor&Siemens tomorrow
Sheriff visited to take down his side of report - requested before and after pictures.

Tue Mar 5, 2024

Judge Warren recommended to get _________ immediately.
Talked to Taylor Siemens - Thursday 1 PM appointment. Did intake.

Met with Puckett&Horsmann, met with Lauren. on feelings; on cost

$4k w/o trial (bench, no jury), $8-10k with trial
Judge Elliott is likely to handle this, or Judge Davis, or Darren Adtkins, or Ryan Horsman (husband) or Judge Lehmer.
Did not feel the hunger or feeling. Objective and competent.
Ideal case: here's what I would cost, here's what you're likely to get, etc.
Ills: trespass, adverse possession, separate trespass for fence, separate trespass for fence, separate trespass for car,

Lawyer qeustions.

Who will be the presiding judge?
What is the presiding judge's record in tree replacement cases/similar cases?
What case do we have?
- trespassing, negligence, property damage (tree destruction, 127 counts), car theft by neighbor, tree theft, fence theft, cattle panel fence destruction, joint property fence destruction , fraud, etc. 272.060 - notice; 272.120 - consent. Deputy officer - approval of car theft. Sheriff's office - illegal towing.
- Who has oversight over Form 4569?
- Intent to defraud - stating that he is allowed to go 20 feet on us;
- Vandalism - told operator to destroy panels; destroyed panels; cut panels without our permission
What remedies do you see?
- Replacement cost?
- Damages?
- Lost work time?
- Triple damages, for which parts.
- Out of court agreement?
- If out of court, how is rest handled?
- Adverse possession?
- Insurance of equipment operator pays? But that would not address punitive damages for preventing case in future?
Does Prompt Payment Act guarantee that prevailing side legal fees are covered?
Do you work on contingency? What is your cut if so? 30-40% of total recovery is standard. [10]. See more about Lawyer Contingency Fees
Do you work hourly? Can you provide your hour accounting method in writing?
Do you work flat fee?

Maysville Case Photos - https://photos.app.goo.gl/i6pMeryXcbqtE2Ze7 - bit.ly/3Tkwirk

Macoubrie called back. Will call back after checking conflict of interest.
Missy - County Commission Clerk. Will refer 2 lawyers.

Mon Mar 4, 2024

Talked to Kawun - https://kakaradvocates.com/team. Tom Kraemer joined - Looking at Chambers.com for references - https://chambers.com/
- Settle with excavator company with their insurance - for a quick settelment. Wach My Uncle Vinnie
Calling Matt Arendt, Cameron - 816.390.7165 - MO Consulting Foresters Association . matt@mattsheathywoods.com. Recommends Ferguson & Schieber - worked with Keith Schieber there on tree recovery issues.
- $185/hr consulting fee for tree evaluation, travel, office time, field time, all communications - billable. Replacement cost may be appropriate method. We require restoration, however, law appears to provide remedy for 'functional restoration' only. Functions include privacy, visual break from road, windbreak, easthetics, shade in summer, warmer in winter.
- Conversation conclusion: trees will always be worth more to you than anyone else. Is there any way to remedy this situation regarding legal remedy for wrongdoing? Is there no available legal recourse for this issue, which may be acquired privately only? Can restoration restore all functions, short of restoring 100 year old trees?
- Methods for restoration: large tree spade, $2k+ for each tree about 20' tall, or seedlings + 35 years interest, or gallon RPMs + 15 year interest - etc - costs could be comparable in each case.
  - 20' trees are doable with an 8' tree spade [11]
- Would take a day or 2 to take down information on trees
- One case Matt was in - involved separating brush piles to determine count of valuable black walnuts. Usually separating brush piles is not relevant.
- It all together appears that restoration cost could be significant. No further info provided. I would be interested in more contact with tree assessors, I definitely did not feel great about the billing method.
- Judge decides if legal fees are reimbursed to winner - MO Prompt Payment Act [12]
McCoubrey from Contacts (suggested by Jere Loyd, thus calling back at (660) 646-4522 - [13]. Someone will call me back tomorrow.
Note - one guy from St. Joseph, seemed quite forthcoming last week and sticks in my mind - should reconsult with him. See Jere Loyd with in contacts section far down- (816) 364-3020. Will contact me back.
Heather with Taylor Siemens Law Firm called back. You had called last week about a property line dispute matter. You can give us a call back 816-364-6677. Thank you. - all together firm seems quite forthcoming and kind, which in absence of recommendations is a good thing.
Phil Smith from Blackwell Creek does timber assess only, not 'shadetree assessment' which is what he thinks this is. 'Cooling, heating, aesthetics etc'. Suggeste Matt Arendth 816.390.7165, matt@mattshealthywoods.com. Phil dealt with Chillicothe, Iowa, etc.
Found that James L. Griffith operates from Maysville, this is not the same as Griffin, Dietrich, Elliott
Documented 'tree graveyard' with white stakes to preserve evidence. Took more pictures, and fenced off car theft area.

Sun Mar 3, 2024

Beckie Boyle suggested talking to Griffith, attorney above Subway, young guy, in Maysville. [14]
Fence wire [15], no trespassing sign [16], drone - [17]
Preserving evidence is the key right now. First, make sure that we take photographs compliant with admissibility of evidence criteria - for all the trees that they took and are lying in piles on their land. Second, how to preserve the van location so it is admissible evidence for car theft by illegal towing. Evidence is clear, how to document?
How to capture Sheriff's testimony when he is not cooperating fully? How does one force a deputy or sheriff to make a statement for the record? If this cannot be verbal, what kind of notice would hold in court? Can it be done through administrative process for presentment where silence is acquiescence? Can a process in writing produce evidence through administrative process? Simple offer-counteroffer recorded at the courthouse. It may look like something like this: "here are the car tracks. I hereby testify that the car track is 42" this barbed wire, pictured and documented. Thus, take pictures and print them, with measurements." The reward would be closure of the illegal towing situation.
Routes suggested are aerial drones, game cams, a few stakes with wire from monument to the next surveyed corner, and no trespassing signs or paint. So that any fence built by the aggressor on our land would be made accountable to the law.

Sat, Mar 2, 2024

Afternoon

HOW are 'costs of replacement' measured? [18]
Does law in MO provide for the emotional insult or ecological loss of trees that are wrongfully removed?
whether the removed tree or trees was part of the landscaping on the property or simply a part of a woodland is itself a question to be answered by the court - in PA [19]
Courts would determine what constitutes “landscaping” and what constitutes “replacement.” - [20]
Find an arborist - [21]
Mature oak tree replacement - $3k each [22]. Contact.
Appraiser of trees can cost a lot. [23]
Order to preserve evidense?
CA Law - basics of tree law but likely relevant to MO [24]
Ohio cases - establish negligence clearly in favor of victim [25]
Costs - 4 ways to determine tree value - [26]
Replacement cost for big tree is 3-5 smaller ones [27]. $140k bill for cleared tree cluster
CA replacement cost $1M for a huge tree, and award was $100k by court. [28]
Both Plaintiffs, due to the large trees involved, the size of which could not be replanted, took the total diameter of all trees and then planned to replant as many 2 inch trees as needed to meet the total diameter. - [29]. Submitted consultation request.
Being made whole appears to be the intent and practice of existing law. In civil claims it is not solely to make the injured party whole, but also to penalize the defendant. - [30]. Making whole is not about market value, it can be much higher.
Treble in stumpage theft because otherwise people would sell other peoples' lumber.
It's what would it cost to be made whole. Part of being made whole is the extremely high cost of replacing - [It's what would it cost to be made whole. Part of being made whole is the extremely high cost of replacing]
Replacement cost of 156 mature trees in hedgerow at $1M - [31], Kansas case ongoing.
action to recover for injuries to real estate - [32]. Preserving evidence and substantiating the loss is key to recovery.
Legal research - https://revisor.mo.gov/main/OneSection.aspx?section=537.340 states triple damages for tree damage. Period.
Market value of trees charged - [33]. Otherwise, case is one based on someone trying to defraud the other. Judge reversed $28/tree, and lanscaper got trees for free because landowner tried to defraud the landscaper?
More often, the courts hold that the proper measure of damages is the replacement cost of trees rather than the value of real estate And a multiplier is used because trees are irreplaceable - [34]
Medium tree (5-9 feet) costs $255 to plant. large 10-19 feet - costs $2k, largest 20-30 feet - $3500 [35]

Morning

Jeff Tucker visited.
Keith Derr and County Commissioner Kyle Carroll visited.
Tree data collection. Rules of evidence: search warrant [36]
Major success yesterday informs an proactive search for remedy that is not in a defensive mode like yesterday. Yesterday I succeeded in having the offender cease-and-desist from any further digging and tree damage on our land, as they trucked their Komatsu PC210LC [37] off the site. See [38]
Data collection - pictures of damaged cattle panels taken __________
Data collection - total length of treeline destroyed measured - _______________ feet in length from NW corner, one bite around fence __________________feet by _______________ feet roughly on each side and _________________ feet into our land, another bite by the Faculty House, about ________________ by ______________ and ____________________ feet into our land. Last bit - about 40x40 land cleared by water line on SW Willow, east and north of southwest corner monument.

Fri Mar 1, 2024

Newest on top.

Sheriff did not call us back today, we want him to take a look at some of the details for the police report.
Talked to Kyle White, West District Commissioner - helpful, will stop by tomorrow to take a look at the right of way issue. Note that Ryan Murphy told me yesterday that he already checked in with the County Commission regarding the right of way, and Kyle White knew nothing about the right of way issue prior to talking to me. Kyle White told me he will bring this issue up with Kyle Carroll, the other County Commissioner. Missy said to set ourselves up on the agenda Monday if we would like to. I sent
Missy from County Clerk's office called back regarding County Commission meeting on Tuesday, suggested Kyle White, honorable helpful person, from County Commission to talk to.
Dec
Catarina mentioned that Ryan's helper asked what to do about our fence panels, and Ryan said to crumple them in the brush pile or something to that effect.
Pictures show clear taking of trees from our land, with clear before and after with fence at the boundary showing and trees on our side.
Cease and desist (handed to machine operator, Tom Logston). Operator stopped. Notice submitted:
- 272.060. Whenever the owner of real estate desires to construct or repair a lawful fence...such owner shall give written notice of such intention to the adjoining landowner
- 272.120. No division fence shall be removed without the consent of all the owners thereof.
- You are hereby noticed that you are trespassing on my land without my permission. Missouri law allows triple damages for destroying and carrying off trees while trespassing.
- Missouri has had the tradition of cleaning out 10 feet on each side to maintain the fence for over 100 years. Unfortunately, it is a tradition and not a law so legally, no, you cannot if the neighbor opposes.
- A partition fence is the joint property of adjacent landowners. [39] End of notice.
Went to courthouse, talked to County Prosecutor, Erik Tate - quite an honorable guy. Catarina likes that he 'Defends the poor from million dollar lawyers'.
- Turns out county prosecutor, criminal, does not file for Temporary Restraining Orders, which are civil. Recommended any civil attorney.

Thu Feb 29, 2024

Catarina's pix.

Day of Destruction

As soon as the offending party began destruction of trees and fence from our land without notice or permission while trespassing up to 35 feet onto our land along the tree line, I dressed up in distress to my work clothes in order to scuttle or salvage the fence. Our first cattle panel, from our fence that was 1' within our surveyed boundary line, was removed, they put it in their brush pile [40]. That's when I started to remove t-posts and remaining cattle panels from up to 12 feet of the fence line. Saved all the panels, some were damaged and cut

RSMO 272

Full text - https://revisor.mo.gov/main/OneSection.aspx?section=272.010 - click next. Displayed in small snippets.
272.060. Division fences — rights of parties in, how determined. — 1. Whenever the owner of real estate desires to construct or repair a lawful fence, as defined by section 272.020, which divides his or her land from that of another, such owner shall give written notice of such intention to the adjoining landowner.
272.120. Division fences not to be removed without consent of owners. — No division fence shall be removed without the consent of all the owners thereof, unless for the purpose of opening a public road or highway.
272.320. Division fence not to be removed — exceptions. — No division fence shall be removed without the consent of all the owners thereof, unless for the purpose of opening a public road or highway or making repairs.
s. First, the tradition in Missouri is that 10 feet on each side of the boundary fence would be cleared before putting in a new fence, but this is not required in the statutes. In plain words, you cannot force a neighbor to clear anything that is not in the fence itself. [41]
There is a 10 foot each way tradition in MO, but clearing 10 feet into neighbor's land without permission of neighbor is not permitted - [42]
Bingo:

- [43] - [44]

- From Brent@hadenlaw.com
you do not have the legal right to remove a fence without your neighbor's permission. [45] & [46] p16. You can remove brush or trees that are obstructing the fence. However, you cannot remove trees that are not physically obstructing the fence that are on the neighbor's side of the boundary without their consent.
U. MO Extension contact, 660.947.2705 - Joe Koenen
Adverse possession - [47]
Tree value calculation - cost of replacing the tree [48]. Triple damages in Missouri [49]
Removing a division fence required consent since 1877 [50]

Other Legal Means

Temporary Restraining Order, or Temporary Injunction, Beresford Booth, (425) 776-4100. Can be used in real estate law for immediate remedy where the damage could be irreparable [51]
Court-ordered cease and desist -
Criminal charge types - [52]. Trespassing can be a Class 1 or Class 2 misdemeanor [53]. Class one when noticed.
Mo does not require consent of second party to record a conversation [54]

Data Collection

Cheapo drone - [55].

Various Legal Resources

UMKC Law Clinic allows coaching with a lawyer, but does not include DeKalb county [56]. However, does have a legal research library open to the public - [57]. 816-235-1650
Call local bar association for a consultation at $50/hr. You can call your local bar association’s lawyer referral service to find a licensed, private lawyer who has experience with your type of legal problem. The lawyer will meet with you for 30 minutes about your case for a fee of less than $50. [58]. Or local bar association - a volunteer lawyer volunteer lawyer project; a pro bono project (another word for a volunteer lawyer project); a free legal workshop; a self-help clinic

Narratives

Excavator guy from a company in Chillicothe started removing our treeline without notice, I asked if he knows where the property line is, and Ryan said that he is allowed to go 20 feet onto our land.
I asked the sheriff is he is acting honorably, citing 'In God We Trust' on the back of his car. He said that he was.
Neighbor John Murphy stopped by with Sharon, in amazement of what is going on. Ryan is John's nephew.
Some places they went in 40'
Keith Derr suggested to take as much evidence and pursue it in court.

Notes

Civil vs criminal law -
Civil court victory - To win, you must prove your civil case by the “preponderance of the evidence.”
Cease and desist - https://gdelaw.com/real-estate-matters/ - earliest we can get an appointment is next Thu or Fri. Would not work for now. Fence Law Issues is a thing.
Erik Tate - Dekalb County Prosecutor - 816-449-2279
Fence law issues - [59] - Paul Law Firm - Neosho - (417) 451-1600. Don't do Cease and Desist? Double check.
- Dillan Thomas [60] + William Weber - pineville Mo - does C&D - 417-223-5366. Must be in same county.
- Fence Law Cease & Desist Order - Bradley and Bradley - 660.259.2288
- Inglish & Monaco - 573.634.2522
Demand letter may be used for remedy under the silence is acquiescence doctrine.
C&D from a lawyer is not same as court order - [61]
48 hr c&d letter service online $199 [62]
Mo Fence Law - https://extension.missouri.edu/publications/g810 - rsmo 272

Wed Feb 28, 2024

Deputy Oulman participated in the car heist.

Form 4569. Used by enforcement to tow a car. https://dor.mo.gov/forms/4569.pdf

An ABV owner/lienholder may file a petition with the Associate Circuit Court in the county

where the ABV is stored to determine if the ABV was wrongfully taken or withheld from the owner. The petition must: • Be filed within ten days following receipt of the notification from the towing company; and...

Naturally it would reason that proof of property being abandoned must exist.
The owner may petition in court if the property was wrongly taken or withheld. [63]
Def of abandoned property - 304.001 [64]
SB0560 [65]. Consumer protection against towing companies.
Demand Letter - you can request a remedy by writing a letter to your neighbor addressing grievance. [66]
We just want clarity. Is there an agreement that a mistake was made, or was the car stolen?
If we get a lawyer it will be to sue your ass, there is no property dispute.
They are complicit in theft if they have to evidence.
Dispute is not about the property line. Dispute is about the location of the my car. What evidence does the officer have?
We are not disputing property lines, we are disputing the tow.
Private individuals can't sue. You are allowed to sue a sheriff.
File a complaint with Office of Professional Standards
St. Joseph office of complaints - [67]
It was not stolen. It was towed.
- Towing was used as the execution of the theft. You have to provide evidence that the car was located not on our land.
Is county sheriff's office immune from prosecution? Qualified immunity applies to personal charges against officials, not against the government itself [68]

Contacts

Blackwell Creek Forestry - Philip Sneed - (660) 973-2714
Judge Warren McElwain on Cherry St - Brent Irwin, Kyle Carroll's son in law sent me here to ask some advice if you have five minutes. We lived and owned property for nearly 20 years here in Dekalb Co and we are being terrorized by our land neighbors and want to know our rights.
Ed Proctor, Kyle White suggested him. 816.471.7466 - [69]. Scott Gum, Ed Proctor.
Keith Derr got a recommendation, Nancy Potter Lyle atty, 816.364.6677. Taylor Siemens Elliott Creedy & Lyle P.C. Will get back to me.
Temporary Restraining Order -
Welch&Webb - [70] (816) 858-3007, returned call, suggested the next contact (can send more referrals if I can call back - I did but no answer):
- Mark Campbell 816.592.6079 -packed schedule - Recommends to look around more. They are busy.
Day Miller - (816) 449-2132. Can't help, semiretired.
Griffin, Dietrich, Elliott - https://gdelaw.com/ - apporintment next Thursday available (816) 632-3033. But, has a conflict of interest. Would not tell us what it is.
Puckett&Horsman - 1-816-632-5297. Tue 12:30 free consultation.
https://hartstacklaw.com/ - 1 816 632 2525 LM
Kim Brown - (816) 632-2004. Phone free consult - Tuesday 12 th at 11 AM. Dropped the ball - missed this call.
St. Joe - Kale Griffin -
Joe Gagnon - 816.336.2260 - Plattsburgh. No TROs.
David R Schmitt - temp restraint order. Don't handle it. 816-233-0303
Peppard - St. Joe - (816) 273-0040. Put them on notice. Guy was helpful but booked. Familiar with matter - 20 feet into our land is ridiculous by him, said this guy is fried. Will be available late next week, holler early in the week if need him.
Todd Griffe (816) 232-8001. Sounded busy, suggested calling the sheriff. Suggested - Jerry Loyd/ Troy Dietrich - Dietrich.
Troy Dietrich- same as Griffin, Dietrich, Elliott. Conflict.
Jere Loyd - (816) 364-3020. Can't do it quickly. Need notice to get a temp restrain order. Does TRO every 10 years. Booked for 3 weeks, suggested next two contacts. Very helpful as teacher running down the process - notice of hearing, private server, etc, avail of circuit judge.
Chillicothe - Robert Cowherd law firm- (660) 646-0627 - Sugg. by Jere. Not judge. $5000. TRO with petition for trespass. See if judge would enter without hearing, would need to post a bond. Hearing next - next week. I talked to Trent Miller.
- Robert Cowherd. No conflict of interest. See if atty is available. Yes, can do it, I can call Monday if issue persists.
Circuit Judge - file a petition in a court but circuit judge may be elsewhere is one of the logistics challenges.
McCoubrey - (660) 646-4522 - suggestion from Jere Loyd

Maysville Case

Contents