SUMMONS
District Court: 1st
Santa Fe County, New Mexico
Court Address: P.O. Box 2268
225 Montezuma, Ave.
Santa Fe, New Mexico 87504-87501
Court Telephone No.:
505-455-8250
Case Number:
D-101-CV-2020-01005
Judge: FRANCIS J. MATHEW
Plaintiff(s): Mesa Negev: LLC
v.
Defendant(s):
1 Vidal Aragon
2 Judy M. Aragon
3 Marie Aragon
4 Alexander P. Valenzuela-42 Crestencia LN Santa Fe NM 87506
Defendant
Name: Vidal Aragon
324 Jane NE Alb NM 87123
TO THE ABOVE NAMED DEFENDANT(S): Take notice that
1. A lawsuit has been filed against you. A copy of the lawsuit is attached. The Court issued this Summons.
2. You must respond to this lawsuit in writing. You must file your written response with the Court no later than thirty (30) days from the date you are served with this Summons. (The date you are considered served with the Summons is determined by Rule 1-004 NMRA.) The Court’s address is listed above. · ·
3. You must file (in person or by mail) your written response with the Court. When you file your response, you must give or mail a copy to the person who signed the lawsuit
4. If you do not respond in writing, the Court may enter judgment against you as requested in the lawsuit
5. You are entitled to a jury trial in most types of lawsuits. To ask for a jury trial, you must request one in writing and pay a jury fee.
6. If you need an interpreter, you must ask for one in writing.
7. You may wish to consult a lawyer. You may contact the State Bar of New Mexico for help finding a lawyer at www.nmbar.org; 1-800-876-6657; or 1-505-797-6066.
Dated at Santa Fe, New Mexico, this 30th day of April, 2020 .
KATHLEEN VIGIL
CLERK OF COURT
By: /s/ Desiree Brooks
Attorney for Plaintiff or Plaintiff pro se
Name: Edward Arambula
Address: 201 Wayne Rd (NW) Alb NM 87114
Telephone No.: 480 241 9279
Fax No.: –
Email Address:-
STATE OF NEW MEXICO
COUNTY OF Santa Fe
FIRST JUDICIAL DISTRICT
D-101-CV-2020-01005
MESA NEGEV LLC
Plaintiff
PARTY ONE ALEXANDER P VALENZUELA
PARTY TWO VIDAL ARAGON, JUDY M. ARAGON AND MARIE ARAGON
PARTY THREE ALL UNKNOWN PARTIES
Defendants ,
COMPLAINT FOR QUIET TITLE
I.
The Plaintiff gives pendency of the above action, and claims he is the owner, of a certain Property in Santa Fe County, New Mexico, a description of which is herein:
T10N R 7E S27 2.50 AC NW4-SE4-SE4- NW4 LOT 49 EDGEWOOD ESTATES
(PARCIAL# 94439040)
(UPC# 1-040-056-214-317-000-000} SANTA FE COUNTY, NEW MEXICO
Which has the address of:
II.
The Plaintiff is credibly informed and believes, and upon such information and belief allege, that each of the Defendants herein named as GROUP ONE, or designated makes , or during their existence, made some claim of lien, interest, right, or title adverse to the aforementioned Property, or potion thereof, and is made a party Defendant herein by name, as near as the same can be ascertained.
III.
The Plaintiff is credibly informed and believes, and upon information and belief alleges that each of the Defendants herein above named as GROUP ONE of the Title of this Case, which is here adopted by reference, makes the claim alleged in paragraph II hereof, and exists, and is authorized to engage in business within the State of New Mexico.
IV.
The Plaintiff has made due search and inquiry ascertain whether each of the Defendants hereinabove named, or designated in GROUP TWO of the title of this case, which is here adopted by reference, whom it is desired to name as a party Defendant, is living/exists as an Entity, or dead, and if living It’s place of doing business, and if dead/inactive, the name and place of doing business of hires, assigns but such information is unknown and cannot be ascertained by them. Plaintiff is credibly informed, and beliefs, and upon such information and belief alleges, that each of such person, is living, makes; or if is inactive during its life time made; or if inactive, their unknown assigns now makes, the claim alleged on Paragraph II hereof; and that such Defendants and are made parties Defendants herein by name, if living; if dead/inactive, their unknown assigns, under the name and style set forth in GROUP TWO of the title of this case, and that constructive service of process only can be obtained upon them.
V.
The Plaintiff is Credibly informed and believes, and upon such information and belief allege, that each of the Defendants hereinabove named, or designated in GROUP THREE of the Title of this case, which is here adopted by reference whether nonexistent, or existing, and during It’s life time made the claims in Paragraph II hereof. Due search and inquire have been made to ascertain the names of all their assigns of such a sun-setted Corporation and all assignees so ascertain have been named. Plaintiff is credibly informed and beliefs allege, that there are unknown Hires/Assignees of the said deceased persons who now make the claim alleged in Paragraph II hereof. Due search and inquiry have been made to ascertain the names, residence, or whereabouts of such assignees, but such information is unknown to the Plaintiff and cannot be ascertained by them. The unknown assignees of said nonexistent Persons are made Parties Defendants under the style of unknown assignees of said deceased Person/ non existing Entity and constructive service of process only can be obtained upon them.
VI.
The Plaintiff is credibly informed and believes, and upon such information and belief allege, that there are other Persons unknown to the Plaintiff who make the claim alleged in Paragraph II hereof.
Plaintiff has made due search and inquiry to ascertain the names, or whereabouts of such persons, but such information is unknown to the Plaintiffs and cannot be ascertained by them. Such persons have been made parties Defendants herein by name and style of Unknown Claimants of Interest in the premises Averse to the Plaintiff,” and constructive service of process only can be obtained upon them.
VII.
Each of the Defendants herein named or designated make some claim averse to the estate of the Plaintiff in the Property herein described. This action is brought by the Plaintiff to quite their title to all of the said property against the claims of each and all Defendants. Any claims, or pretension of any Property, right, title, or interest in or too, or lien upon, the premises hereinabove described, or any portion thereof, averse to the Property of the Plaintiff, by any of the defendants herein made, or designated, or by any person/ Corp. claiming by, though, or under the Defendants or any of them, is without foundation or right, either in law or in equity.
WHEREFORE, the Plaintiff asks for the establishment of said Property in fee simple in and into the said Property against the adverse claims of the Defendants and each of them, and everyone claiming by, though, or under them, Be Barred and Forever Estopped from having or reclaiming any lien upon, or any right, title or interest in or to the said Property averse to the Property of the Plaintiff, and that the title of the Plaintiffs thereto in fee simple Be Forever Quieted and Set at Rest.
The Plaintiff further asks that He Be Permitted to have service by publication upon all of the Defendants upon whom personal service Cannot be obtained; and for such other and further relief as the Plaintiff Is Entitled to In The Premises.
MESA NEGEV LLC BY EDWARD ARAMBULA
,Plaintiff
/s/ Edward Arambula
210 Wayne road NW
Albuquerque, New Mexico 87114
480.241.9279
VERIFICATION
STATE OF NEW MEXICO
)ss.
COUNTY OF SANTA FE
———— being first dully sworn, upon their oath depose and state: That are the Plaintiffs herein and that they have read the foregoing Complaint and know the contents thereof, and that the same is true and correct of their own knowledge, information and belief .
/s/ Edward Arambula
SUBSCRIBE AND SWORN to before me this 30 day of April 2020,
By Edward Arambula
/s/ Desiree Brooks
PURSUANT TO
§14-14-3 NMSA 1978
By Deputy Court Clerk
HCS Pub. May 8, 15, 22, 2020
