Case 10- 03623 -AJC Doc 179 Filed 04/29/15 Page 11 of 16
<br />the plaintiff, may assert a lien claims, encumbrance, or other interest in the Bueno and Black
<br />Rose Mining Properties.
<br />Service Upon and Defaults ALiainstThe RemaininLj Defendants
<br />28. On October 5 and 6, 2010, summonses were issued and served by mail with the
<br />Complaint (D.E. 3 & 4) at their last known address upon remaining Defendants, (a) Frank, (b)
<br />Jamestown, (c), Grieve, and (d) Werner requiring an answer be filed on or before November 4, 2010.
<br />None of these Defendants have ever answered or otherwise responded to the Complaint. As such,
<br />Plaintiff requests that Defaults be entered against (a) Frank, (b) Jamestown, (c), Grieve, and (d)
<br />Werner.
<br />29. On March 2 and 12, 2015, alias summonses were issued and served along with the
<br />Second Amended Complaint by mail (D.E. 165 & 170) at their last known address upon remaining
<br />Defendants, (a) Hittle, (b) Taylor, (c) the State of Colorado, (d) the Boulder Tax Collector, (e) the
<br />Boulder Clerk, and (f) Left Hand requiring an answer be filed on or before April 6, 2010. None of
<br />these Defendants have ever answered or otherwise responded to the Second Amended
<br />Complaint.
<br />30. As such, on March 27, 2015, the Trustee moved for defaults (D.E. 171), and on
<br />April 8, 2015, defaults were entered, against the State of Colorado, Hittle, Taylor, the Boulder
<br />Tax Collector, the Boulder Clerk, and Garfinkle (D.E. 172), and on April 24, 2015, the Trustee
<br />moved default (D.E. 175), and on April 27, 2015, a default was entered, against Defendant, Left
<br />Hand (D.E. 176).
<br />31. Further, no liens, claims, encumbrances, and interests against the Bueno and
<br />Black Rose Mining Properties have been filed as Proofs of Claims in the Main Case, nor any
<br />Adversary Proceeding, have been filed against those properties, that have not otherwise been
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