Commonwealth of Massachusetts
Land Court Department
Trial Court
NORFOLK, SS.
CASE NO. 25 MISC 000486 (STF)

Village Cemetery Association, Inc.
v.
Nicholas D. Thomas, et al.

TO: Nicholas D. Thomas, of parts unknown, believed to be homeless in the state of Florida

You are hereby notified that a complaint has been filed by the above-named plaintiffs in which you are named as an interested party. This complaint concerns a certain parcel of land in Weymouth, Norfolk County, and said Commonwealth being known as and numbered 33 Congress Street. Plaintiff, Village Cemetery Association, Inc., alleges it is in actual possession of and holds title to the Subject Property, as evidenced by a deed dated September 10, 1993, from Donald R. Thomas to Village Cemetery Association of Weymouth, recorded with the Norfolk County Registry of Deeds in Book 10096, Page 530. Plaintiff contends that title to the Subject Property is clouded as the 1993 Deed granted the property to “Village Cemetery Association of Weymouth” and there are no records of “Village Cemetery Association of Weymouth” filed with the office of the Commonwealth of Massachusetts Secretary of State Corporations Division. Upon information and belief, Village Cemetery Association, an unincorporated association, was the intended grantee of the premises as it owns the property that abuts the Subject Property. Plaintiff is the successor in interest to Village Cemetery Association. Plaintiff contends it has maintained the land in a manner consistent with the typical owner of a single-family residence since September 10, 1993. Plaintiff seeks a judgment quieting title to the subject property, declaring that it holds title to the subject property free and clear of any claims of the defendants, and for additional relief deemed just and equitable.

This complaint may be examined at the Land Court, Boston, Massachusetts, or online at www.masscourts.org. Information on how to search Land Court dockets is available on the Land Court website: www.mass.gov/how-to/find-a-land-court-case-docket. A copy of said complaint may also be obtained from plaintiff’s attorney.

If you intend to make any defense, you are hereby required to serve upon the plaintiff’s attorney, Tiffany L. Stichel, Esq., Schlossberg | LLC, 35 Braintree Hill Office Park, Suite 401, Braintree, MA 02184, an answer to the complaint on or before the eighth day of December, 2025, next, the return day, hereof, and a copy thereof must be filed in this court on or before said day.

If you fail to do so, judgment by default will be taken against you for relief demanded in the complaint. Unless otherwise provided by Rule 13(a), your answer must state as a counterclaim any claim which you may have against the plaintiff which arise out of the transaction or occurrence that is the subject matter of the plaintiffs’ claim, or you will thereafter be barred from making such claim in any other action.
10/22/25, 10/29/25, 11/05/25 61312b