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Page 13 · column 9 of 11 · from the scan, no model involved
Smith Hitt by deed ot Second National Bank of Culpeper dated January 13, 1969 and recorded March 25, 1969 amongst the records in the Clerk s Office of this Court, in Deed Book 74. at page 283 Said suit seeks a declaratory judgment that the act of Floyd Daniel Hitt. Defendant. in conveying an interest in the above described real estate to the Individuals named in a deed of record in the Clerk's Office of this Court, in Deed Book 115, at page 595, was ultra vires and therefore void ab initio. or, alternatively that said act constitutes self dealing and a breach of fidicuary duty, and therefore requests, in the alternative, that the Court enter a Decree declaring said deed to be void ab initio, removing the cloud on the title to the subject real estate, and further appointing a Special Commissioner to convey title to said lands to the Plaintiff. Lucy Smith Hitt.
An Affidavit having been made and signed that Matthew Dean Hitt is a nonresident of the State of Virginia. and that his last known post office address is as indicated above, and that the address of Floyd Daniel Hitt is unknown and
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