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Apple Valley Resort Information

   None of these materials are offered, nor should be construed, as legal advice. Communication of information by or through these materials and your receipt or use of such information is not intended to create an attorney-client relationship with Critchfield, Critchfield & Johnston, Ltd. (“CCJ”) or any of the firm's attorneys. The creation of the attorney-client relationship would require direct, personal contact between you and CCJ through one or more attorneys and would also require an explicit agreement by CCJ that confirms that an attorney-client relationship is established and the terms of that relationship.  CCJ is representing no party other than Plaintiff Apple Valley Resort Unit Owners’ Association in this case. You should not act or rely upon information contained in these materials without specifically seeking professional legal advice.



 Memorandum by Plaintiff's Attorney - Including Answers to Frequently Asked Questions

 Court Approved Form


            You will find in these materials:

  • A copy of the partition complaint filed in the Knox County Court of Common Pleas for partition of the Apple Valley Resort Condominium.
  • A memorandum filed by the Plaintiff which provides general information regarding the case.
  • An entry and approved forms from Judge Richard Wetzel, Knox County Common Pleas Court Judge should you desire to waive the issuance of summons and service of a copy of the complaint and to consent to the issuance of an Order of Partition of the property set forth in the complaint and that the proceeds be paid to Plaintiff and Defendants according to their interests. If you wish to use the Court approved waiver of service and consent to process and order of partition, you may sign and print your name on the appropriate form and return it to:

                Knox County Clerk of Courts
                  117 E. High Street, Suite 201
                  Mount Vernon, Ohio 43050

Please note that if you call CCJ and wish to discuss the case with an attorney, you will be directed back to this website where you can view the materials for informational purposes only.  As CCJ is representing no party other than the Plaintiff Apple Valley Resort Unit Owners’ Association, CCJ is unable to provide legal representation to any other party in the case.

If you are a defendant and wish to hire a local Mount Vernon, Ohio attorney to represent you in this case, please contact your personal attorney.  If your attorney is unable to assist you, our firm does not recommend one of the numerous competent local attorneys over the others, but we have been informed by Attorney Morgan Giles of the Giles Law Group that he is interested in representing defendants in this case.   Mr. Giles may be contacted at:

                  Morgan Giles
                  The Giles Law Group
                  109 East High Street
                  Mount Vernon, Ohio 43050
                  Phone: 740-397-5321

UPDATE: May 2, 2017

The Board and Plaintiff’s counsel met on May 1, 2017 to discuss various matters regarding the case.  The information provided below were questions posed by the Board that may be helpful to Defendants.

Q: I am married.  Both myself and my spouse received a summons from the Court.  Our “unknown spouses” also received copies of the complaint from the Court.  Why did we get served with the complaint as well as our unknown spouses?

A:  The goal of the case is to sell the property free from claims of every owner/prior owner.  Because the defendants are not personally known by the real estate records to be married/unmarried, all persons and their unknown spouses must be named as defendants.  If your “unknown spouse” does not appear (file an answer) in the case, any claims to the property by an unknown spouse will be extinguished.

Q: Do I have to make a Court appearance as a result of being named a defendant?

A:  Initially no – If you sign and return the court approved form, returning the form is an act of “appearing” in the case.  The Court may later set hearings in the case which you may wish to attend.

Q:  Will I receive notice from the Court or Plaintiff of later filings in the case if I do not file an answer/appearance in the case?

A:  If you do not enter yourself into the case by filing an Answer, you will not receive a copy of subsequent pleadings filed by the Plaintiff, which may include the notice of sale date and appraisal information.