IN THE CHANCERY COURT OF HARRISON COUNTY,
MISSISSIPPI
FIRST JUDICIAL DISTRICT
SUMMIT WILLIAM BELL APARTMENTS, LTD.
VERSUS
CITY OF GULFPORT, MISSISSIPPI; UNITED STATES OF AMERICA; and ANY AND ALL PERSONS WITH AN INTEREST IN THE PROPERTY DESCRIBED IN THE SUBJECT PETITION
CIVIL ACTION NO. 25-2055
SUMMONS BY PUBLICATION
THE STATE OF MISSISSIPPI
TO: ANY AND ALL OTHER PERSONS, FIRMS OR CORPORATIONS HAVING OR CLAIMING TO HAVE ANY LEGAL OR EQUITABLE TITLE OR INTEREST IN THE SUBJECT REAL PROPERTY.
You have been made Defendants in the lawsuit filed in this Court by Summit William Bell Apartments, LTD. seeking the vacation of easements of certain real property located in Harrison County, Mississippi by virtue of that certain Special Warranty Deed, dated February 12, 2008, recorded February 19, 2008 as Instrument No. 2008-1366-D-J1 in the land records of Harrison County, Mississippi, First Judicial District; that Warranty Deed, dated October 18, 2024, recorded October 24, 2024 as Instrument No. 2024-0021751-D-J1 in the land records of Harrison County, Mississippi, First Judicial District; and that Special Warranty Deed, dated October 21, 2024, recorded October 24, 2024 as Instrument No. 2024-0021752-D-J1 in the land records of Harrison County, Mississippi, First Judicial District and more accurately described as follows:
Parcel 1- The 2nd Avenue Easement:
 
a.  Parcel 1- The 2nd Avenue Easement:
 
A parcel of land located in the Northwest 1/4 of the Northwest 1/4 of Section 7, Township 8 South, Range 11 West, St. Stephens Principal Meridian, First Judicial District, Harrison County, Mississippi, and is 2nd Avenue, Pine Grove Addition, Plat Book 8, Page 19 being more particularly described as follows:
Commence at a 1 inch iron rod being the northwest corner of said Section 7; thence North 89 degrees 55 minutes 04 seconds East 320.30 feet; thence South 00 degrees 06 minutes 13 seconds East 24.99 feet to a 1/2 inch iron rod with cap being the northwest corner of Block 8 of said Pine Grove Addition, the northwest corner of the property conveyed to Summit William Bell Apartments, LTD per Instrument Number 2008-1366-D-J1, and the Point of Beginning, said Point of Beginning having grid coordinates of N 316206.55 and E 888954.87 based on the Mississippi State Plane Coordinate System, East Zone, NAD 83 (U.S. Survey Feet), bearings and distances herein are grid values based on said coordinate system using a scale factor of 0.999960404 and a convergence angle of -00 degrees 09 minutes 09.980 seconds (at the P.O.B.); thence South 00 degrees 06 minutes 13 seconds East 841.45 feet along the west line of Blocks 8 and 11 of said Pine Grove Addition and the east line of said 2nd Avenue to the north margin of Allen Road and a 1/2 inch iron rod with cap; thence South 61 degrees 24 minutes 01 second West 45.51 feet along the north margin of said Allen Road to a 1/2 inch iron rod with cap; thence North 00 degrees 06 minutes 13 seconds West 448.71 feet along the east line of Block 10 of said Pine Grove Addition and the west line of said 2nd Avenue to a 1/2 inch iron rod; thence North 00 degrees 06 minutes 13 seconds West 40.00 feet to a 1/2 inch iron rod with cap; thence North 00 degrees 06 minutes 13 seconds West 374.57 feet along the east line of Block 9 of said Pine Grove Addition and the west line of said 2nd Avenue to a 1/2 inch iron rod with cap; thence South 89 degrees 56 minutes 47 seconds East 40.00 feet along the south margin of Commission Road to the Point of Beginning.
Said parcel containing 0.783 acres, more or less.
b. Parcel 2- The Main Street Easement:
 
A Parcel of land located in the Northwest 1/4 of the Northwest 1/4 of Section 7, Township 8 South, Range 11 West, St. Stephens Principal Meridian, First Judicial District, Harrison County, Mississippi, and is Main Street, Pine Grove Addition, Plat Book 8, Page 19 being more particularly described as follows:
Commence at a 1 inch iron rod being the northwest corner of said Section 7; thence South 35 degrees 09 minutes 18 seconds East 488.13 feet to a 1/2 inch iron rod with cap being the southeast corner of Block 9 of said Pine Grove Addition, the southeast corner of the property conveyed to Summit William Bell Apartments, LTD per Instrument Number 2024-21752-D-J1, and the Point of Beginning, said Point of Beginning having grid coordinates of N 315832.02 and E 888915.54 based on the Mississippi State Plane Coordinate System, East Zone, NAD 83 (U.S. Survey Feet), bearings and distances herein are grid values based on said coordinate system using a scale factor of 0.999960413 and a convergence angle of -00 degrees 09 minutes 10.185 seconds (at the P.O.B.); thence South 00 degrees 06 minutes 13 seconds East 40.00 feet along the west line of 2nd Avenue to the northeast corner of Block 10 of said Pine Grove Addition and a 1/2 inch iron rod; thence South 89 degrees 50 minutes 46 seconds West 120.07 feet along the north line of said Block 10 to a 1/2 inch iron rod with cap; thence North 00 degrees 06 minutes 13 seconds West 40.00 feet to the southwest corner of said Block 9 and a 1/2 inch iron rod with cap; thence North 89 degrees 50 minutes 46 seconds East 120.07 feet along the south line of said Block 9 to the Point of Beginning.
Said parcel containing 4,803 square feet, more or less.
c. Parcel 3- The Block 11 Easement:
 
A parcel of land located in the Northwest 1/4 of the Northwest 1/4 of Section 7, Township 8 South, Range 11 West, St. Stephens Principal Meridian, First Judicial District, Harrison County, Mississippi, and is in Block 11 of the Pine Grove Addition to Gulfport, Plat Book 8, Page 19 being more particularly described as follows:
Commence at a 1 inch iron rod being the northwest corner of said Section 7; thence North 89 degrees 55 minutes 04 seconds East 320.30 feet; thence South 00 degrees 06 minutes 13 seconds East 582.98 feet along the east margin of 2nd Avenue of said Pine Grove Addition to a scribed "X" in concrete and the Point of Beginning, said Point of Beginning having grid coordinates of N 315648.55 and E 888955.88 based on the Mississippi State Plane Coordinate System, East Zone, NAD 83 (U.S. Survey Feet), bearings and distances herein are grid values based on said coordinate system using a scale factor of 0.999960403 and a convergence angle of -00 degrees 09 minutes 09.941 seconds (at the P.O.B.); thence South 28 degrees 09 minutes 55 seconds East 249.12 feet to a ½ inch iron rod with cap; thence South 61 degrees 24 minutes 01 seconds West 133.35 feet to a ½ inch rod with cap; thence North 00 degrees 06 minutes 13 seconds West 283.46 feet along the west line of said Block 11 to the Point of Beginning.
Said parcel containing 16,610 square feet, more or less.
You are required to mail or hand deliver a copy of a written response to the Complaint filed against you in this action to Brant Pettis, the attorney for the Plaintiffs, whose post office address is Post Office Box 130, Gulfport, Mississippi 39502, and whose street address is 1310 Twenty-Fifth Avenue, Gulfport, Mississippi 39501.
YOUR RESPONSE MUST BE MAILED OR DELIVERED NOT LATER THAN THIRTY (30) DAYS AFTER NOVEMBER 2, 2025, WHICH IS THE DATE OF THE FIRST PUBLICATION OF THIS SUMMONS.  IF YOUR RESPONSE IS NOT SO MAILED OR DELIVERED, A JUDGMENT BY DEFAULT WILL BE ENTERED AGAINST YOU FOR THE RELIEF DEMANDED IN THE COMPLAINT.
You must also file the original of your Response with the Clerk of this Court within a reasonable time afterward.
GIVEN UNDER MY HAND AND SEAL of said Court and issued this the                         day of October, 2025.
ANGELA THRASH,
CHANCERY COURT CLERK, HARRISON COUNTY, MISSISSIPPI
BY: CLERK
IPL0283957
Nov 2,9,16 2025