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2015-05-08_GENERAL DOCUMENTS - P2008003
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2015-05-08_GENERAL DOCUMENTS - P2008003
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Last modified
8/24/2016 6:00:07 PM
Creation date
5/8/2015 3:49:27 PM
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Template:
DRMS Permit Index
Permit No
P2008003
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
5/8/2015
Doc Name
Plaintiff's Motion for Default Judgment
From
US Bankruptcy Court - Miami
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DRMS
Email Name
MAC
Media Type
D
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No
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Case 10- 03623 -AJC Doc 179 Filed 04/29/15 Page 2 of 16 <br />DETERMINE THE VALIDITY, EXTENT, AND PRIORITY OF ANY LIENS, CLAIMS, <br />ENCUMBRANCES, AND INTERESTS IN THE BUENO AND BLACK ROSE MINING <br />PROPERTIES LOCATED IN BOULDER COUNTY, COLORADO, INCLUDING TBE <br />INTERESTS OF ANYONE LAYING CLAIM TO TBE ESTATE'S RIGHTS AND <br />INTERESTS IN SUCH PROPERTIES, PURSUANT TO 11 U.S.C. U63(n)(2) AND RULE <br />7001(2). FED. R BANIG2. P. <br />Plaintiff, Marcia Dunn, as the Chapter 7 Trustee (the "Trustee ") for the substantively <br />consolidated estate (the "Estate ") of the Debtor, Merendon Mining (Nevada), Inc.'s ( "Debtor" or <br />"Merendon "), by and through undersigned counsel, and pursuant to the Status Conference set by and <br />held before this Court on April 27, 2015 at 10 a.m. (D.E. 161, COS of same D.E. 162), at which <br />Status Conference only counsel for Plaintiff appeared, moves for a default final judgment upon her <br />December 16, 2011 Second Amended Complaint (the "Second Amended Complaint ") (D.E. 125) <br />seeking equitable and declaratory relief, brought pursuant to 11 U.S.C. §363(p)(2) and Fed. R. <br />Bankr. P. 7001(2), by way of an order, judgment and decree from this Court determining the <br />validity, priority, and extent of any liens, claims, encumbrances, and interests, including any <br />interests of anyone laying claim to the estate's rights and interests in the mining properties <br />generally known as the Bueno and Black Rose mines, located in Boulder County, Colorado, and <br />the Trustee's Motion for Default Final Judgment on the Second Amended Complaint (the <br />"Motion for Default Final Judgment ") (D.E. 177), and <br />based upon the allegations contained in the Second Amended Complaint, the record in <br />this adversary proceeding (the "363 Adversary Proceeding "), the above referenced Chapter 7 <br />Case of Debtor Merendon (the "Main Case "), the associated substantive consolidation adversary <br />proceeding brought by the Trustee in Adversary Proceeding No. 09- 02518 -AJC (the "Subcon <br />Adversary Proceeding "), and all of this Court's previous findings, Orders and Judgments, in <br />these three proceedings, Plaintiff is entitled to the entry of a Default Final Judgment, in this case <br />as a matter of law, and as grounds therefor states that: <br />OA <br />
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