Case No. CV-2007-01175

| July 31, 2007 9:00 PM

IN THE DISTRICT COURT OF THE FIRST JUDICIAL DISTRICT OF THE STATE OF IDAHO, IN AND FOR THE COUNTY OF BONNER

SUMMONS

THE NORMAN AND TRACY WALDO, REVOCABLE INTER VIVOS TRUST;

NORMAN G. WALDO and

TRACY M. WALDO, husband and wife, in their capacity as Trustees for The Norman and Tracy Waldo, Revocable Inter Vivos Trust; THE RICHARD AND CAROL WALDO, REVOCABLE INTER VIVOS TRUST; RICHARD G. WALDO and CAROL A. WALDO, husband and wife, in their capacity as Trustees for The Richard and Carol Waldo, Revocable Inter Vivos Trust;

Plaintiffs,

vs.

ROBERT C. MOTER and LUCY E. MOTER, husband and wife;

Defendants,

NOTICE; YOU HAVE BEEN SUED BY THE ABOVE-NAMED PLAINTIFF, THE COURT MAY ENTER JUDGMENT AGAINST YOU WITHOUT FURTHER NOTICE UNLESS YOU RESPOND WITHIN 20 DAYS. REA THE INFORMATION BELOW:

TO: ROBER C. MOTER and LUCY E. MOTER, husband and wife

AND

The Estates of ROBERT C. MOTER and/or LUCY E. MOTER

YOU ARE HEREBY NOTIFIED that in order to defend this lawsuit, an appropriate written response must be filed with the above-designated court within 20 days after service of this Summons on you. If you fail to so respond, the court may enter judgment against you as demanded by the Plaintiff in the Complaint.

A copy of the Complaint is served with the Summons. If you wish to seek the advice or representation of an attorney in this matter, you should do so promptly so that your written response, if any, may be filed in time and other legal rights protected.

The nature of this legal action is for quiet title and declaratory judgment of certain real property in Boundary County, Idaho.

An appropriate written response requires compliance with Rule 10(a)(1) and other Idaho rules of Civil Procedure and shall also include:

1. The title and number of this case.

2. If your response is an Answer to the Complaint, it must contain admissions or denials of the separate allegations of the Complaint and other defenses you may claim.

3. Your signature, mailing address and telephone number, or the signature, mailing address and telephone number of your attorney.

4. Proof of mailing or delivery of a copy of your response to Plaintiff's attorney, as designated above.

To determine whether you must pay a filing fee with your response, contact the Clerk of the above-named court.

The real property subject of this action is described as follows:

Tract 1:

A tract of land located in Section 24, Township 56 North, Range 6 West of the Boise Meridian, Bonner County, Idaho, more particularly described as follows:

Beginning at a point on the Southerly right of way line of "Mill Road" said point being North 69°32'00" East, 100.76 feet from an existing rebar which bears South 65°38'20" West, 2334.27 feet from the East quarter corner (Aluminum cap by P.E.C., per record of Survey by RLS No. 882, Instrument No. 287960) of said Section 24; thence North 69°32'00" East, along said Southerly line of "Mill Road", 142.50 feet to its intersection with the Westerly right of way line of "Diamond Lumber Road", thence Southeasterly along said Westerly line of "Diamond Lumber Road", along the arc of a curve to the right 197.88 feet (Delta = 25°46'04", Radius = 440.00 feet and Chord = South 53°06'57" East 196.22 feet) to an existing rebar (by RLS No. 882); thence South 48°59'29" West 192.56 feet; thence North 89°25'47" West 72.89 feet; thence North 20°28'00" West 206.62 feet to the point of beginning.

(See Record of Survey Instrument Nos. 454885 and 287960).

Tract 2:

A tract of land located in Section 24, Township 56 North, Range 6 West of the Boise Meridian, Bonner County, Idaho, more particularly described as follows:

Beginning at an existing rebar on the Southerly right of way line of "Mill Road", said rebar being South 65°38'20" West, 2334.27 feet from the East Quarter corner (Aluminum Cap by P.E.C. per Record of Survey by RLS No. 882, Instrument No. 287960) of said Section 24; thence North 69°32'00" East, along said Southerly line of "Mill Road", 100.76 feet; thence South 20°28'00" East, 206.62 feet; thence South 89°25'47" East 72.89 feet, thence North 48°59'29" East, 192.56 feet to its intersection with the Southwesterly right of way line of "Diamond Lumber Road" at an existing rebar (By RLS No. 882); thence South 40°13'55" East, along the said Southwesterly line of "Diamond Lumber Road", 90.00 feet to an existing rebar (By RLS No. 882); thence South 41°00'31" East, along said Southwesterly line of "Diamond Lumber Road" , 61.19 feet; thence South 48°59'29" West, 121.12 feet to its intersection with the Northerly line of the existing BPA Powerline Easement; thence North 88°55'07" West, along said Northerly line of existing BPA Powerline Easement, 156.70 feet; thence South 0°26'28" west, 100.01 feet to the Southerly line of said BPA Powerline Easement; thence South 31°50'34" West 78.52 feet to an existing pipe at the Northwesterly corner of "Albeni Falls Mill Addition"; thence South 31°50'34" West 154.15 feet to an existing pipe at the Southwesterly corner of said "Albeni Falls Mill Addition"; thence North 65°01'26" West, 234.18 feet; thence South 54°28'15" West 93.23 feet to a 3/4" Rebar (By RLS No. 6019) on top of the Pend Oreille River Bank; thence continuing South 54°28'15" West 57 feet, more or less, to its intersection with the ordinary high water line of the Pend Oreille River, thence Northwesterly along said ordinary high water line of the Pend Oreille River to its intersection with a line projected South 54°28'15" West, 11 feet, more or less, from a Rebar (by RLS No. 6019) on top of the Pend Oreille River Bank; thence North 54°28'15" East, 11 feet, more or less, to said rebar on top of the Pend Oreille River Bank; thence North 54°28'15" East, 470.70 feet; thence North 25°28'01" West, 149.77 feet to the point of beginning. (See Record of Survey Nos. 454885 and 287960).

LESS:

A portion thereof beginning at the Northwesterly corner of "Albeni Falls Mill Addition:, as described above; thence South 31°50'34" West, 154.15 feet to the Southwesterly corner of said "Albeni Falls Mill Addition' as described above; thence North 65°01'26" West; 90.65 feet; thence North 31°50'34" East, (90 feet Northwesterly of and parallel with the Northwesterly line of said "Albeni Falls Mill Addition") 189.94 feet to a point on the Southerly line of said BPA Powerline Easement; thence South 89°55'07" East, along the Southerly line of said BPA Powerline Easement, 104.74 feet; thence South 31°50'34" West, 78.52 feet to the point of beginning.

SUBJECT TO a 60 foot wide perpetual Right of Use and Easement granted to the City of Oldtown, and Idaho Municipal Corporation, beginning at a point which is located South 25°28'01" East, 149.77 feet and South 54°28'15" West 330.44 feet all from an existing rebar located on the Southerly right of way line of said "Mill Road", (Said existing rebar being located South 65°38'20" West, 2334.27 feet from the East 1/4 corner of said Section 24, see record of Survey by RLS No. 882, Instrument No. 287960); thence South 36°01'46" East, 62.53 feet; thence along an arc of a curve to the left 20.25 feet (Delta = 28°59'54", Radius = 40.00 feet, Chord = South 50°31'26" East, 20.03 feet); thence South 65°01'26" East 71.51 feet; thence South 54°28'15" West 68.93 feet; thence north 65°01'26" West 37.57 feet; thence along a curve to the right 50.60 feet (Delta =28°59'54", Radius = 100.00 feet, Chord = North 50°31'29" West 50.07 feet); thence North 36°011'46" West 63.05 feet; thence North 54°28'15" East 60.00 feet to the point of beginning.

AND SUBJECT TO a 15 foot wide easement beginning at the point of beginning as described for Tract 2 above; thence North 69°32'00" East 15.06 feet; thence South 25°28'01" East 40.00 feet; thence South 61°31'59" West 15.00 feet; thence North 25°28'01" West, 41.31 feet to the point of beginning.

DATED this 26th day of July, 2007.

GLENDA POSTON

Clerk of the District Court

By: Carolyn Brachett, Deputy Clerk

FEATHERSTON LAW FIRM, CHTD

Stephen T. Snedden

ISB No. 7554

113 South Second Avenue

Sandpoint, ID 83864

(208) 263-6866

Legal SNP 8842

July 31, August 7, 14, 21, 2007