UNITED STATES OF AMERICA :
:
Plaintiff, :
:
v. :                                                                                                 CA #: 92-1761 CRR
:
REAL PROPERTY AND PREMISES :
KNOWN AS 1889 INGLESIDE TERRACE:
N.W., WASHINGTON D.C., :
FURTHER DESCRIBED AS LOT 125 :
SQUARE 2617, :
:
Defendant. :
 

Claimant, Helen Hoyle, through undersigned counsel, files this verified claim of ownership of the above described property. As grounds for this claim claimant states the following:

1. I am the co-owner of the real property located at 1889 Ingleside Terrace, N.W., Washington, D.C.. I acquired my interest in 1959, when my late husband, Oscar C. Hoyle, and I purchased the property as tenants by the entireties. When he died in 1984, I acquired his interest by survivorship. The property remained solely mine until 1985 (or thereabouts), when my daughter Doris assisted me in obtaining a $60,000 home improvement loan against the property so that we could remodel the house. At that point we put Doris on the deed as co-owner, and she has been paying about half of the payments on the note.

2. I hereby claim the right to defend this action.

I, Helen Hoyle, do hereby verify that I have read the foregoing Claim, and declare under penalty of perjury that the allegations therein are true and correct.
 

Executed on this ____ day of _______, 1992.

________________________
HELEN HOYLE
 

________________________
BY: Brenda Grantland, Esq.
D.C. Bar #362417
P.O. Box 7447
Arlington, VA 22207
(202)546-8890
 
 

I hereby certify that a copy of the foregoing verified claim was served, by hand, upon Assistant United States Attorney Noel Brennan, 555 4th Street N.W., Washington, D.C. 20001, this ________ day of ___________________, 1992.

_________________________________
Brenda Grantland