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Plaintiff,
v.
and
and
STANLEY C. ROBBINS
5139 Country Road
Rocky Mount, North Carolina 27803,
and
and
and
MARIA B. WATSON
13207 NC Highway 48
Whitakers, North Carolina 27891,
Defendants.
Plaintiff Atlantic Coast Pipeline, LLC (Atlantic), by counsel, and pursuant to Federal
Rule of Civil Procedure 71.1(d), hereby notifies you, O.J. Smith Farms, Inc., Stanley C. Robbins,
Georgia L. Robbins, Orpha Gene Watson, and Maria B. Watson, that Atlantic has filed a Complaint
in Condemnation (Complaint) in the United States District Court for the Eastern District of
North Carolina, Western Division. The property interests to be condemned are located on real
property in Nash County, North Carolina, described as (1) Parcel Identification No. 021295, as is
more particularly described in Deed Book 1551, Page 617 of the land records of Nash County,
North Carolina, comprising 28.5 acres, more or less (OJ Property); (2) Parcel Identification No.
103745, as is more particularly described in Deed Book 1803, Page 464, among the land records
of Nash County, North Carolina, and comprised of 34.145 acres, more or less (Robbins
Property); and (3) Parcel Identification No. 046314, as is more particularly described in Deed
Book 1451, Page 238, among the land records of Nash County, North Carolina, comprising 15.4
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Case 5:17-cv-00595-BO Document 1-10 Filed 12/01/17 Page 2 of 5
PLEASE TAKE FURTHER NOTICE THAT this is an action to condemn the following
property interests, consisting of 10.28 acres, more or less, which are also set forth in the Complaint
OJ Property
Robbins Property
Watson Property
PLEASE TAKE FURTHER NOTICE THAT the authority for the taking is based on
Section 7(h) of the Natural Gas Act, 15 U.S.C. 717f(h). The property interests taken will be used
for the construction, operation, and maintenance of a natural gas pipeline as authorized and
approved by the Federal Energy Regulatory Commission via the issuance of a Certificate of Public
PLEASE TAKE FURTHER NOTICE THAT you may serve, in writing, an answer and
grounds of defense to the Complaint, setting forth any objection or defense to the taking or
damaging of the property or to the jurisdiction of the Court to hear the case, and a request to
proceed with either the appointment of Commissioners or empanelment of a jury for the
determination of just compensation, on Atlantics attorney within twenty-one (21) days after being
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Case 5:17-cv-00595-BO Document 1-10 Filed 12/01/17 Page 3 of 5
PLEASE TAKE FURTHER NOTICE THAT the failure to serve an answer constitutes
consent to the taking and to the Courts authority to proceed with the action and fix the
compensation.
PLEASE TAKE FURTHER NOTICE THAT if you do not serve an answer, you may
PLEASE TAKE FURTHER NOTICE THAT Atlantic intends to request that the Court
ascertain just compensation for the subject property to be taken upon or after the expiration of
PLEASE TAKE FURTHER NOTICE THAT Atlantic intends to move for partial
summary judgment, followed by the right of immediate possession of the subject property to be
4
Case 5:17-cv-00595-BO Document 1-10 Filed 12/01/17 Page 4 of 5
Of Counsel:
John D. Wilburn
Email: jwilburn@mcguirewoods.com
Richard D. Holzheimer, Jr.
Email: rholzheimer@mcguirewoods.com
MCGUIREWOODS LLP
1750 Tysons Boulevard, Suite 1800
Tysons Corner, Virginia 22102
Telephone: (703) 712-5000
Facsimile: (703) 712-5050
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Case 5:17-cv-00595-BO Document 1-10 Filed 12/01/17 Page 5 of 5