Summons Served by Publication
Summons Served by Publication
Superior Court of Washington,
County of King
No. 25-2-25171-3 SEA
Summons Served by Publication
(SMPB)
In re:
TABERNACLE MISSIONARY
BAPTIST CHURCH,
Plaintiff:
HELGA A. LAPRE AND/OR
JOHN G. SKUSE:
Defendant
Summons Served by Publication
To: HELGA A. LAPRE AND/OR JOHN G. SKUSE
I have started a court case by filing a complaint. The name of the complaint is: Tabernacle Missionary Baptist Church, Plaintiff against Helga A. Lapre and/or John G. Skuse, Defendant.
You must respond in writing if you want the court to consider your side.
Deadline! Your Response must be filed and served within 60 days of the date this Summons is published: December 3, 2025. If you do not file and serve your Response or a Notice of Appearance by the deadline:
- No one has to notify you about other hearings in this case, and
- The court may approve the requests in the Complaint without hearing your side (called a default judgment).
Follow these steps:
1. Read the Complaint and any other documents that were filed at court with this Summons. Those documents explain what the other party is asking for.
2. Fill out a Response on this form: Other: Motion for Quiet Title
You can get the Response form and other forms you may need at:
- The Washington State Courts' website: www.courts.wa.gov/forms
- Washington LawHelp:
www.washingtonlawhelp.org, or
- The Superior Court Clerk's office or county law library (for a fee).
3. Serve (give) a copy of your Response to the person who filed this Summons at the address below, and to any other parties. You may use certified mail with return receipt requested. For more information on how to serve, read Superior Court Civil Rule 5.
4. File your original Response with the court clerk at this address: Superior Court Clerk, of King County at: 516 Third Avenue, Room E-609, Seattle, WA 98104.
5. Lawyer not required: It is a good idea to talk to a lawyer, but you may file and serve your Response without one.
Person filing this Summons or his/her lawyer fills out below:
/s/ Gregory E. Jackson WSBA #17541
12/01/25
I agree to accept legal papers for this case at
Lawyer's address: PO BOX 1615 Renton Washington 98507
Note: You and the other party/ies may agree to accept legal papers by email under Superior Court Civil Rule 5 and local court rules.
This Summons is issued according to Rule 4.1 of the Superior Court Civil Rules of the state of Washington.
IN THE OF THE STATE OF
WASHINGTON IN AND FOR THE
COUNTY OF KING
NO. 25-2-25171-3 SEA
COMPLAINT FOR QUIET TITLE
TABERNACLE MISSIONARY
BAPTIST CHURCH,
Plaintiff,
vs
HELGA A. LAPRE AND/OR
JOHN G. SKUSE,
Defendant(s).
I. PARTIES
1.0 Plaintiff Tabernacle Missionary Baptist Church (TMBC) is a non-profit corporation under the laws of the State of Washington with its general place of business in Seattle Washington.
1.1 Gustav A. Schuman and Alwine Schumann, formerly owed the real property identified as King County Parcel Number 125020-1090, described in the sale documents as: [The west half of lot 12, block 14, Burke's Second Addition to the City of Seattle, according to plat recorded in volume 1 of plats, page 248, in King County, Wahington, EXCEPT the east 20 feet thereof]. See Attachment A.
1.2 Helga A. Lapre, formerly Helga A. Schumann, is the daughter of Gustave A. Schuman and Alwine Schumann.
1.3 John G. Skuse is the son of Helga A. Schuman and her former husband Robert G. Skuse, and the grandson of Gustav A. Schuman and Alwine Schumann.
II. JURSIDICTION AND VENUE
2.0 Jurisdiction and venue are properly with this Court because the subject matter of this suit is the ownership of real property located in King County Washington.
III. FACTUAL ALLEGATIONS
3.0 On January 18, 1967, Gustav A. Schumann and Alwine Schumann entered into a Contract of sale of the real property identified as King County Parcel Number 125020-1095, with the legal description [The west half of lot 12, block 14, Burke's Second Addition to the City of Seattle, according to plat recorded in volume 1 of plats, page 248, in King County, Wahington, EXCEPT the east 20 feet thereof], to TMBC upon terms identified in the contract.
3.1 The Contract terms provided for TMBC to pay the Schumann's $5,000, with a $500 down payment, and $50 each month thereafter to include interest of 7% per annum until the principal was satisfied. [108 months or 9 years later]
3.2 TMBC took possession of the property on or about January 18, 1967, has maintained the property and paid the taxes assessed on the property, and the property remains in TMBC's possession and control.
3.3 Paragraph 7 of the Contract prescribes in pertinent part that the seller agrees upon receiving full payment and interest shall execute and deliver to purchaser a statutory warranty deed to the property.
3.4 TMBC fulfilled the terms of the contract by providing full payment plus interest on or before January 18, 1976, but TMBC failed to obtain a statutory warranty deed from Gustave or Alwine Schumann establishing Title in the name of TMBC.
3.5 Gustave A. Schumann died on October 30, 1981, and Alwine Schuman's died on July 3, 1983. Neither Gustav A. Schumann nor Alwine Schumann made any claim of title, ownership, or a right of possession of the property after executing the above mentioned contract for sale, nor has any other person or entity claimed title to the property that has been in TMBC's possession and control since 1967.
3.6 TMBC Now brings this action to Quiet Title in the name of TMBC.
IV. CAUSE OF ACTION
4.1 The factual allegations support a claim to Quiet Title.
V. PRAYER FOR RELIEF
WHEREFORE, PLAINTIFF prays for the following relief:
5.0 For an Order of this Court to Quiet Title in Plaintiff
5.1 For such further equitable relief as may be determined by this Court.
DATED September 2, 2025
WSBA #17541
LAW OFFICE OF
GREGORY E. JACKSON, PLLC
PO Box 1615
Renton, WA 98057
(206) 582-6001
CERTIFICATE OF SERVICE
I certify that I electronically filed the foregoing with the Court through King County ECF and served on all parties or their counsel of record a copy of this document addressed as follows:
- King County E-service
- King County E-service
DATED December 1, 2025, at Renton, Washington.
/s/ Gregory E. Jackson
Law Office of Gregory E. Jackson
P.O. Box 1615
Renton, WA 98057
206-582-6001
Superior Court of Washington,
County of King
No. 25-2-25171-3 SEA
Summons Served by Publication
(SMPB)
In re:
TABERNACLE MISSIONARY
BAPTIST CHURCH,
Plaintiff:
HELGA A. LAPRE AND/OR
JOHN G. SKUSE:
Defendant
Summons Served by Publication
To: HELGA A. LAPRE AND/OR JOHN G. SKUSE
I have started a court case by filing a complaint. The name of the complaint is: Tabernacle Missionary Baptist Church, Plaintiff against Helga A. Lapre and/or John G. Skuse, Defendant.
You must respond in writing if you want the court to consider your side.
Deadline! Your Response must be filed and served within 60 days of the date this Summons is published: December 3, 2025. If you do not file and serve your Response or a Notice of Appearance by the deadline:
- No one has to notify you about other hearings in this case, and
- The court may approve the requests in the Complaint without hearing your side (called a default judgment).
Follow these steps:
1. Read the Complaint and any other documents that were filed at court with this Summons. Those documents explain what the other party is asking for.
2. Fill out a Response on this form: Other: Motion for Quiet Title
You can get the Response form and other forms you may need at:
- The Washington State Courts' website: www.courts.wa.gov/forms
- Washington LawHelp:
www.washingtonlawhelp.org, or
- The Superior Court Clerk's office or county law library (for a fee).
3. Serve (give) a copy of your Response to the person who filed this Summons at the address below, and to any other parties. You may use certified mail with return receipt requested. For more information on how to serve, read Superior Court Civil Rule 5.
4. File your original Response with the court clerk at this address: Superior Court Clerk, of King County at: 516 Third Avenue, Room E-609, Seattle, WA 98104.
5. Lawyer not required: It is a good idea to talk to a lawyer, but you may file and serve your Response without one.
Person filing this Summons or his/her lawyer fills out below:
/s/ Gregory E. Jackson WSBA #17541
12/01/25
I agree to accept legal papers for this case at
Lawyer's address: PO BOX 1615 Renton Washington 98507
Note: You and the other party/ies may agree to accept legal papers by email under Superior Court Civil Rule 5 and local court rules.
This Summons is issued according to Rule 4.1 of the Superior Court Civil Rules of the state of Washington.
IN THE OF THE STATE OF
WASHINGTON IN AND FOR THE
COUNTY OF KING
NO. 25-2-25171-3 SEA
COMPLAINT FOR QUIET TITLE
TABERNACLE MISSIONARY
BAPTIST CHURCH,
Plaintiff,
vs
HELGA A. LAPRE AND/OR
JOHN G. SKUSE,
Defendant(s).
I. PARTIES
1.0 Plaintiff Tabernacle Missionary Baptist Church (TMBC) is a non-profit corporation under the laws of the State of Washington with its general place of business in Seattle Washington.
1.1 Gustav A. Schuman and Alwine Schumann, formerly owed the real property identified as King County Parcel Number 125020-1090, described in the sale documents as: [The west half of lot 12, block 14, Burke's Second Addition to the City of Seattle, according to plat recorded in volume 1 of plats, page 248, in King County, Wahington, EXCEPT the east 20 feet thereof]. See Attachment A.
1.2 Helga A. Lapre, formerly Helga A. Schumann, is the daughter of Gustave A. Schuman and Alwine Schumann.
1.3 John G. Skuse is the son of Helga A. Schuman and her former husband Robert G. Skuse, and the grandson of Gustav A. Schuman and Alwine Schumann.
II. JURSIDICTION AND VENUE
2.0 Jurisdiction and venue are properly with this Court because the subject matter of this suit is the ownership of real property located in King County Washington.
III. FACTUAL ALLEGATIONS
3.0 On January 18, 1967, Gustav A. Schumann and Alwine Schumann entered into a Contract of sale of the real property identified as King County Parcel Number 125020-1095, with the legal description [The west half of lot 12, block 14, Burke's Second Addition to the City of Seattle, according to plat recorded in volume 1 of plats, page 248, in King County, Wahington, EXCEPT the east 20 feet thereof], to TMBC upon terms identified in the contract.
3.1 The Contract terms provided for TMBC to pay the Schumann's $5,000, with a $500 down payment, and $50 each month thereafter to include interest of 7% per annum until the principal was satisfied. [108 months or 9 years later]
3.2 TMBC took possession of the property on or about January 18, 1967, has maintained the property and paid the taxes assessed on the property, and the property remains in TMBC's possession and control.
3.3 Paragraph 7 of the Contract prescribes in pertinent part that the seller agrees upon receiving full payment and interest shall execute and deliver to purchaser a statutory warranty deed to the property.
3.4 TMBC fulfilled the terms of the contract by providing full payment plus interest on or before January 18, 1976, but TMBC failed to obtain a statutory warranty deed from Gustave or Alwine Schumann establishing Title in the name of TMBC.
3.5 Gustave A. Schumann died on October 30, 1981, and Alwine Schuman's died on July 3, 1983. Neither Gustav A. Schumann nor Alwine Schumann made any claim of title, ownership, or a right of possession of the property after executing the above mentioned contract for sale, nor has any other person or entity claimed title to the property that has been in TMBC's possession and control since 1967.
3.6 TMBC Now brings this action to Quiet Title in the name of TMBC.
IV. CAUSE OF ACTION
4.1 The factual allegations support a claim to Quiet Title.
V. PRAYER FOR RELIEF
WHEREFORE, PLAINTIFF prays for the following relief:
5.0 For an Order of this Court to Quiet Title in Plaintiff
5.1 For such further equitable relief as may be determined by this Court.
DATED September 2, 2025
WSBA #17541
LAW OFFICE OF
GREGORY E. JACKSON, PLLC
PO Box 1615
Renton, WA 98057
(206) 582-6001
CERTIFICATE OF SERVICE
I certify that I electronically filed the foregoing with the Court through King County ECF and served on all parties or their counsel of record a copy of this document addressed as follows:
- King County E-service
- King County E-service
DATED December 1, 2025, at Renton, Washington.
/s/ Gregory E. Jackson
Law Office of Gregory E. Jackson
P.O. Box 1615
Renton, WA 98057
206-582-6001
Posted Online 1 week ago
