2758DISTRICT COURT, COUNTY OF

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Placed on 11/24/2021
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2758
DISTRICT COURT, COUNTY OF LA PLATA, STATE OF COLORADO
Court Address: 1060 E. 2nd Ave., Rm 106 Durango, CO 81301
Plaintiff: ANDREW DAVIS, as Trustee of The Verna A. Davis Irrevocable Trust
v.
Defendant: AMOS MEL MARTINEZ, JURNEY MARTINEZ, MELVIN PENA, and ROSE GARCIA

ANDREW DAVIS, as Trustee of The Verna A. Davis Irrevocable Trust
273 Badger Rd
Pagosa Springs, CO 81147
Tel. 719-588-5458
andrewmadisondavis@gmail.com
Plaintiff
Case Number: 2021CV30084
SUMMONS
TO THE ABOVE-NAMED DEFENDANTS: MELVIN PENA & ROSE GARCIA

YOU ARE HEREBY SUMMONED and required to file with the Clerk of this Court an answer or other response
to the attached Complaint. If service of the Summons and Complaint was made upon you within the State of
Colorado, you are required to file your answer or other response within 21 days after such service upon you. If
service of the Summons and Complaint was made upon you outside of the State of Colorado, you are required to file
your answer or other response within 35 days after such service upon you. Your answer or counterclaim must be
accompanied with the applicable filing fee. If you fail to file your answer or other response to the Complaint in
writing within the applicable time period, the Court may enter judgment by default against you for the relief
demanded in the Complaint without further notice.

Claims for relief are as follows: 1. Quiet Title – As to All Defendants 2. Constructive/Resulting Trust – As
to Defendant Amos 3. Promissory Estoppel – As to Defendant Amos 4. Unjust Enrichment – As to All
Defendants 5. Breach of Contract – As to Defendant Amos 6. Declaratory Relief 7. Partition – As to All
Defendants Jurisdiction is proper in this Court as the real property at issue is located in La Plata County, State
of Colorado. Pursuant to C.R.C.P. 98, venue concerning an action involving real estate shall be tried in the
county in which the subject of the action is located, accordingly venue in La Plata County, State of Colorado is
proper. This action involves and affects the real property located at and described as: TRACT 2, MEL MARTINEZ
SUBDIVISION LOCATED IN A PORTION OF SECTION 15, T32N, R6W, N.M.P.M. LA PLATA
COUNTY, COLORADO, ACCORDING TO THE RECORDED PLAT THEREOF FILED FOR RECORD
APRIL 2, 2007 UNDER RECEPTION NO. 954348 with all and singular the hereditaments and appurtenances
thereunto belonging, orin anywise appertaining, the reversion and reversions, remainder and remainders, rents,
issues and profits, and all the estate, right, title, interest, claim and demand whatsoever. May also be known by
street number as: 2400 County Road 329, Ignacio, CO 81137.

/s/ Andrew M. Davis, TTE PR
273 Badger Rd, Pagosa Springs, CO 81147
Date: 11/16/2021

Published in Durango Herald
November 24, December 1, 8, 15, 22, 2021
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