Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1 :07-cv-00066-GIVIS Document 13 Filed O4/19/2007 Page 1 0f 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Richard Snyder * CA-07-00066 GMS
Plaintiff *
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GPM2 et ai. AFR t ti ESQ? {E 5 1
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Defendants *
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OPPOSITION TO MOTION(S) TO DISMISS E
AMENDED COMPLAINT ;
REQUEST FOR HEARING Q
1. This complaint involves a frustrated contract to purchase real property.
2. The seller (GPM2) agreed to certain terms and conditions which were
breachedbyit. I li hl n S if in l
3. Seller subsequently sold the property to itsitenant as
Christy Management, a defendant). The lender (also a defendant), Felton Bank
as well as the other defendants were at all times aware of plaintii`f’s equitable
interest in the property.
4. A title search by the "unknown title company" (also a defendant) failed to note
the filing of a copy of the contract in the real property records of Sussex County,
Delaware. This title company is now identified as First American Title and is
represented by counsel also representing Christy Management and Felton Bank:
J. Newcomer, Jr.
5. Buyer had always been ready, willing, and able topurchase the
including at the present time, and at the contract price today.

Case 1:07-cv-00066-G|\/IS Document 13 Filed 04/19/2007 Page 2 0f 3
(2)
6. Plaintiff seeks damages to be determined at trial or in the alternative, specific
performance.
7. Plaintiff has lost the benefit of the bargain, as well as significant tax
consequences of which the sellers were aware at the time of the agreement.
8. In amending the complaint, plaintiff desires to change the name of "unknown
title company" to that of First American Title Company and to delete the name of
Sergiovic & Ellis as defendant(s). t
9. Plaintiff requests a trial on the merits. As well as a hearing on the Motion to
Dismiss. /61
Richard nyde
P.O. Box 374
Davidsonville, MD 21035 mail address
Certification of Service
Copies of this pleading have been sent by first—class postage to GPM2, 7443 Lee
Davis Highway #301, Mechanicsville, VA 23111
Christy Management LLC, First American Title, and Felton Bank c/o
John Newcomer, Jr. 500 Delaware Ave #1500, Wilmington, DE 19801
James P Connor, Jr. at his address of record tiled with the Sussex County
Land records with respect to this transaction:189'77 Munchy Branch Rd.
Rehoboth, DE 19971
Bonnie Benson, Pa 34385—B Carpenter’s Way, Lewes, DE 19958
Seriovic & Ellis, PA 9 N. Front St or et n, DE 19947
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Richard nyd

Case1:07-§v—000?6é?i{§&i?é|S D0cument13 Filed 04/19/2007 Page30f3
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