The text below is the actual filing that we used to Quiet Title various properties in one filing. Use this only as a reference and follow the local court rules as they may apply to your circumstances or situation. We are not attorneys and do not offer legal advice by posting the noted documents.

THIRTEENTH JUDICIAL DISTRICT COURT

COUNTY OF SANDOVAL

STATE OF NEW MEXICO

Paul Salas and

Mary F. Salas, husband and

wife,

Plaintiffs,

vs. No. D1329 CV 02-492

DESERT TRADING, INC., Bernard Rizzi, Georgio Landi, May H. Rutherford, WALTER T. ELLIOTT, CAROL K. ELLIOTT, JUNE R. DHEIN, LESLIE C. LEASON, CARLTON E. HELFTER, CAROLYN MEIN, THOMAS GENOVESE AND CHRISTINA GENEVOSE, THEIR ASSIGNS OR SUCCESSORS IF LIVING; IF DECEASED, HIS OR HER HEIRS AND UNKNOWN HEIRS, AND ALL UNKNOWN CLAIMANTS OF INTEREST IN THE PREMISES ADVERSE TO PLAINTIFFS,

Defendants.

COMPLAINT FOR QUIET TITLE

Plaintiffs allege:

1. The Plaintiffs they are the owners in fee simple of that certain real estate in Sandoval County, New Mexico, a description of which is attached hereto, made a part hereof, a labeled Schedule A.

2. The Plaintiffs are credibly informed and believe, and upon such information and belief allege, that each of the defendants herein above named or designated makes, or during his or her lifetime made, some claim of lien, right or title adverse to the estate of Plaintiffs in and to the real estate, or a portion thereof, and is made a party Defendant herein by name, as near as the same can be ascertained.

3. The Plaintiffs are credibly informed and believe, and upon such information and belief allege, that each of the Defendants named herein was a corporation in the State of New Mexico and do not have a place of business within the State of New Mexico or that each of the Defendants named herein are residents of a state other than the State of new Mexico.

4. The Plaintiffs have made due search and inquiry to ascertain whether each of the Defendants herein above is living or dead, and if living, his or her place of business or residence, and, if deceased, the names and places of residence of his or her heirs, but such information is unknown or uncertain and cannot be ascertained by them. Plaintiffs are credibly informed and believe, and upon such information and belief allege, that each of such persons, if living, makes, or if deceased, during his or her lifetime made; or if deceased, his or her unknown heirs now make, the claim alleged in paragraph 2 hereof; and that such Defendants are made parties Defendant herein by name, if living; if deceased, their unknown heirs, under the name and style as set forth in the title of this case, and that constructive service of process only can be obtained upon them.

5. Plaintiffs are credibly informed and believe, and upon such information and belief allege, that there are other persons unknown to the Plaintiffs who make the claim alleged in paragraph 2 hereof. The Plaintiffs have made due search and inquiry to ascertain the names, residences, 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 Defendant herein by the name and style of "unknown claimants of interest in the premises adverse to the Plaintiffs", and constructive service of process only can be obtained upon them.

6. Each of the Defendants herein named makes some claim adverse to the estate of the Plaintiffs in the real estate herein described. This action is brought by the Plaintiffs to quiet their title to all of the real estate against the claims of each and all of the Defendants. Any claim or pretension of any estate, right, title or interest in or to, or lien upon, the premises herein above described, or any portion thereof, adverse to the estate of the Plaintiffs, by any of the Defendants herein named or designated, or by any person claiming by, through, or under the Defendant or any of them, is without foundation or right, either in law or in equity.

WHEREFORE, the Plaintiffs pray for the establishment of their estate in fee simple in and to the real estate against the adverse claims of the Defendants, and each of them, and everyone claiming by, through or under them, and that the Defendants, and each of them, and everyone claiming by, through or under them, be barred and forever estopped from having or reclaiming any lien upon, or right, title or interest in or to the real estate adverse to the estate of the Plaintiffs, and that the title of the Plaintiffs thereto in fee simple be forever quieted and set at rest. The Plaintiffs further pray that they 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 Plaintiffs are entitled to in the premises.

Respectfully submitted:

By: ______________________

Paul Salas, Pro Se

Post Office Box 45741

Rio Rancho, New Mexico 87174

(505) 867-2899 or (505) 238-1485

page 2

Attachment A

Lots numbered Thirty-three (33) and Thirty-four (34) in Block numbered One Hundred-four (104), of Unit Twenty (20), Rio Rancho Estates, Town of Alameda Grant, Sandoval County, New Mexico, as shown and designated on the map of said Rio Rancho Estates, filed in the office of the County Clerk of Sandoval County, New Mexico in Rio Rancho Estates Plat Book No. 2, page 58 on October 5, 1970.

Lot numbered Thirty-three (33) in Block numbered Forty-nine (49), of Unit Seventeen (17), Rio Rancho Estates, Town of Alameda Grant, Sandoval County, New Mexico, as shown and designated on the map of said Rio Rancho Estates, filed in the office of the County Clerk of Sandoval County, New Mexico in Rio Rancho Estates Plat Book No. 1, page 82 on January 6, 1969.

Lots numbered Five (5), Six (6) Seven (7) and Eight (8) in Block numbered One Hundred Seventy-nine (179), of Unit Twenty (20), Rio Rancho Estates, Town of Alameda Grant, Sandoval County, New Mexico, as shown and designated on the map of said Rio Rancho Estates, filed in the office of the County Clerk of Sandoval County, New Mexico in Rio Rancho Estates Plat Book No. 2, page 62 on November 20, 1972.

Lots numbered Twelve (12), Thirteen (13) Fourteen (14) and Fifteen (15) in Block numbered One Hundred Seventy-nine (179), of Unit Twenty (20), Rio Rancho Estates, Town of Alameda Grant, Sandoval County, New Mexico, as shown and designated on the map of said Rio Rancho Estates, filed in the office of the County Clerk of Sandoval County, New Mexico in Rio Rancho Estates Plat Book No. 2, page 62 on November 20, 1972.

Lots numbered Three (3) in Block numbered Twelve (12), of Unit Twenty-two (22), Rio Rancho Estates, Town of Alameda Grant, Sandoval County, New Mexico, as shown and designated on the map of said Rio Rancho Estates, filed in the office of the County Clerk of Sandoval County, New Mexico in Rio Rancho Estates Plat Book No. 2, page 3 on September 15,1969.

Lots numbered Eighteen (18) and Nineteen (18) in Block numbered Forty-seven (47), of Unit Twenty-two (22), Rio Rancho Estates, Town of Alameda Grant, Sandoval County, New Mexico, as shown and designated on the map of said Rio Rancho Estates, filed in the office of the County Clerk of Sandoval County, New Mexico in Rio Rancho Estates Plat Book No. 2, page 6 on October 16, 1969.

Page 3

AFFIDAVIT AND VERIFICATION

STATE OF NEW MEXICO )

) ss.

County of Sandoval

Paul Salas and Mary F. Salas, being first duly sworn, upon oath, depose and state:

Our names are Paul Salas and Mary F. Salas. We are the Plaintiffs in the above captioned case. We have read over, know and understand the contents of the foregoing Complaint, the statements therein are true of our own knowledge, except those statements that are made upon information and belief, and as to those, we believe them to be true.

________________________

Paul Salas

________________________

Mary F. Salas

SUBSCRIBED AND SWORN to before me this _______ day of _______________, 2001 by Paul Salas and Mary F. Salas

____________________________

Notary Public

SEAL My Commission Expires on the ________ of ______________, __________

Page 4

THIRTEENTH JUDICIAL DISTRICT COURT

COUNTY OF SANDOVAL

STATE OF NEW MEXICO

Paul Salas and

Mary F. Salas, husband and

wife,

Plaintiffs,

vs. No. D1329 CV 02-492

Defendants.

AFFIDAVIT OF DUE AND DILIGENT SEARCH

STATE OF NEW MEXICO ) ss.

COUNTY OF SANDOVAL

Paul Salas, being first duly sworn, states:

1. He is acting Pro Se on behalf of Plaintiffs in the above entitled cause.

2. He has made due and diligent search of inquiry to ascertain the present whereabouts of the Defendant named herein, but such information is unknown and cannot be ascertained, and accordingly only constructive service of process can be obtained on said Defendant.

_______________________

Paul Salas

Subscribed and sworn to before me this __________ day of _______________________ 2002 by Paul Salas, Plaintiff Pro Se.

(SEAL) _________________________

Notary Public

My Commission Expires on the _______ of _____________, _________

Page 5

THIRTEENTH JUDICIAL DISTRICT COURT

COUNTY OF SANDOVAL

STATE OF NEW MEXICO

Paul Salas and

Mary F. Salas, husband and wife,

Plaintiffs,

vs. No. D1329 CV 02-492

Defendants.

NOTICE OF PENDENCY OF SUIT

THE STATE OF NEW MEXICO:

To the following named Defendants against whom constructive service is sought to be obtained, to-wit:

1. The following named Defendants by name, if living; if deceased, their unknown heirs: Desert Trading, Inc., Bernard Rizzi, Georgio Landi, May H. Rutherford, Walter T. Elliott, Carol K. Elliott, June R. Dhein, Leslie C. Leason, Carlton E. Helfter, Carolyn Mein, Thomas Genovese and Christina Genovese and all unknown claimants of interest in the premises adverse to Plaintiffs.

2. You, the above named Defendants, and each of you, are hereby notified that the Plaintiffs have commenced a suit against you, and each of you, as Defendant in Cause No. D1329 CV 02-492, now pending in the District Court of the Thirteenth Judicial District Court of the State of New Mexico, sitting within and for the County of Sandoval, by filing therein their verified Complaint.

3. That the general object of the suit is to determine and quiet the fee simple title of the Plaintiffs against you, the Defendants, and each of you, in and to the property described as follows:

Lots numbered Eighteen (18) and Nineteen (19) in Block numbered Forty-seven (47), of Unit Twenty-two (22), Rio Rancho Estates, Town of Alameda Grant, Sandoval County, New Mexico, as shown and designated on the map of said Rio Rancho Estates, filed in the office of the County Clerk of Sandoval County, New Mexico in Rio Rancho Estates Plat Book No. 2, page 6 on October 16, 1969.

Together with all and singular the hereditaments and appurtenances thereunto belonging and or in anywise appertaining, and the reversion and reversions, remainder and remainders, rents, issues and profits thereof;

4. That unless you, the said Defendant, and each of you, enter or cause to be entered your appearance in said cause on or before the ____________day of ________________ 2002, judgment as prayed for in Plaintiffs' Complaint will be rendered in said cause by default against you, and each of you so failing to appear;

5. That the Plaintiffs are Advocates Pro Se and the address is Post Office Box 45741, Rio Rancho, New Mexico 87174.

Dated at Sandoval County, New Mexico this _________ day of _____________ 2002.

_______________________________

Clerk

(SEAL) By _____________________________

Deputy

Page 6

THIRTEENTH JUDICIAL DISTRICT COURT

COUNTY OF SANDOVAL

STATE OF NEW MEXICO

Paul Salas and

Mary F. Salas, husband and

wife,

Plaintiffs,

vs. No. D1329 CV 02-492

Defendants.

APPLICATION FOR DEFAULT JUDGMENT

COME NOW the Plaintiffs, advocates Pro se, and move the Court for a default judgment in the captioned case. As grounds therefore, Plaintiffs state:

1. The Defendants Desert Trading, Inc., Bernard Rizzi, Georgio Landi, May H. Rutherford, Walter T. Elliott, Carol K. Elliott, June R. Dhein, Leslie C. Leason, Carlton E. Helfter, Carolyn Mein, Thomas Genovese and Christina Geneovese were unable to be located and were therefore served by publication, as more fully shown on the Affidavit of Publication filed herein on July 19, 2002

2. No appearance has been entered on behalf of said Defendants and no answer, motion or other pleading has been filed herein on behalf of any persons interested in the property, including but not limited to Defendants Desert Trading, Inc., Bernard Rizzi, Georgio Landi, May H. Rutherford, Walter T. Elliott, Carol K. Elliott, June R. Dhein, Leslie C. Leason, Carlton E. Helfter, Carolyn Mein, Thomas Genovese and Christina Genovese, their assigns or successors, if living or her heirs or unknown heirs, if deceased. The Defendants are now in default.

WHEREFORE, Plaintiffs pray that judgment be entered against the Defendants Desert Trading, Inc., Bernard Rizzi, Georgio Landi, May H. Rutherford, Walter T. Elliott, Carol K. Elliott, June R. Dhein, Leslie C. Leason, Carlton E. Helfter, Carolyn Mein, Thomas Genovese and Christina Geneovese, their assigns or successors, if living, if deceased, her heirs and unknown heirs, and all unknown claimants of interest in the premises adverse to Plaintiffs in the subject property and quiet title in Plaintiffs Paul Salas and Mary F. Salas.

Respectfully submitted __________________________________

Mary F. Salas

August 5, 2002

Page 7

THIRTEENTH JUDICIAL DISTRICT COURT

COUNTY OF SANDOVAL

STATE OF NEW MEXICO

Paul Salas and

Mary F. Salas, husband and

wife,

Plaintiffs,

vs. No. D1329 CV 02-492

Defendants.

AFFIDAVIT UNDER THE SOLDIERS’

AND SAILORS’ RELIEF ACT

SATE OF NEW MEXICO )

)

COUNTY OF SANDOVAL )

The undersigned, Pro Se for the Plaintiffs, after duly being sworn on oath states:

That in compliance with the Soldiers’ and Sailors’ Relief Act, as amended, I make this Affidavit for and on behalf of the Plaintiffs, and state upon information and belief that defendants are not members of the military service of the United States of America.

Respectfully Submitted

By: _________________

Paul Salas

Post Office Box 45741

Rio Rancho, New Mexico 87174

(505) 867-2899 or (505) 238-1485

SUBSCRIBED AND SWORN TO BEFORE ME this ______ day of ________________, 2001 by Paul Salas.

_______________________

Notary Public

SEAL My Commission Expires the _______ day of ______________, _________

DEFAULT JUDGMENT AND

THIS CAUSE came before the Court on Plaintiffs' Complaint to Quiet Title. The Plaintiffs appeared as Advocates Pro Se. Defendants Desert Trading, Inc.., Bernard Rizzi, Georgio Landi, May H. Rutherford, Walter T. Elliott, Carol K. Ellliott, June R. Dhein, Leslie C. Leason, Carlton E. Helfter Carolyn Mein, Thomas Genovese and Christina Genovese, their assigns or successors if living, if deceased, his or her heirs, and unknown heirs if living, if deceased his or her heirs and unknown heirs, have been duly and regularly served with process for the time and in the manner required by law, all of which more fully appears from the Clerk's Certificate As to the State of the Record, and the instruments and documents therein referred to in the file herein, having examined the file herein, and being now and all things in the premises fully advised, makes the following findings of fact:

1. This action was properly brought by the Plaintiffs to determine and quiet title to the land and real estate described in the Complaint, describing the nature and extent of the estate and accurately describing the premises; that said Complaint is in all respects regular and sufficient and contains all allegations and other matters necessary and appropriate for the joinder of all of the Defendants herein and the quieting of title to the subject premises.

2. That all of the Defendants herein have been duly and regularly served with process herein for the time and in the manner required by law, and this Court has jurisdiction over the parties and subject matter herein.

4. The Court therefore concludes as a matter of law that the relief prayed for in the Complaint should be granted and that the Court has jurisdiction of the parties and the subject matter of this cause of action.

1. That Paul Salas and Mary F. Salas are the absolute owners in fee simple of the following described land lying and being in the County of Sandoval, State of New Mexico, to-wit:

Lots numbered Twenty-five (25) and Twenty-six (26) in Block numbered One Hundred-six (106), of Unit Twenty (22), Rio Rancho Estates, Town of Alameda Grant, Sandoval County, New Mexico, as shown and designated on the map of said Rio Rancho Estates, filed in the office of the County Clerk of Sandoval County, New Mexico in Rio Rancho Estates Plat Book No. 2, page 10 on December 9, 1969.

together with all and singular the hereditaments and appurtenances thereunto belonging or in any wise appertaining and the reversion and reversions, remainder and remainders, rents, issues and profits thereof,

2. That the title of Plaintiffs, Paul Salas and Mary F, Salas, as joint tenants with rights of survivorship, in and to the land and real estate above described be, and here is, forever quieted and set at rest against the claims and demands of the Defendants, and each of them, and of all persons claiming or to claim from under them or any of them.

3. The Clerk is hereby ordered and directed to enter this Judgment and Decree forthwith.

Prior to signing off on the order, the judge inquired through the court clerk why there were so many properties in one filing.

AMMENDED AFFIDAVIT OF DUE AND DILIGENT SEARCH

2. He has made due and diligent search of inquiry to ascertain the present whereabouts of the Defendants named herein, but such information is unknown and cannot be ascertained, and accordingly only constructive service of process can be obtained on said Defendant.

3. Plaintiff’s acquired title or interest in the properties noted in this action through Quit Claim Deed, payment of delinquent taxes and/or Tax Deed issued by the State of New Mexico Taxation and Revenue. The Plaintiffs are credibly informed and believe, and upon such information and belief allege, that each of the defendants herein above named or designated makes, or during his or her lifetime made, some claim of lien, right or title adverse to the estate of Plaintiffs in and to the real estate, or a portion thereof, and is made a party Defendant herein by name, as near as the same can be ascertained.

4. Plaintiff’s seek relief in Quiet Title from Defendant’s on the basis that during his or her lifetime made, some claim of lien, right or title adverse to the estate of Plaintiffs.

5. Defendant DESERT TRADING, INC., was a New Mexico Corporation and ceased to operate as a business entity in 1990. Defendant’s Bernard Rizzi and Georgio Landi, were incorporating officers of Desert Trading, Inc., and the Plaintiffs have made due search and inquiry to ascertain whether each of the Defendants herein above is living or dead, and if living, his or her place of business or residence and their whereabouts can not be determined.

6. Defendant’s May H. Rutherford and JUNE R. DHEIN are known to the Plaintiff’s to be deceased.

7. Defendant’s WALTER T. ELLIOTT, CAROL K. ELLIOTT, LESLIE C. LEASON, CARLTON E. HELFTER, CAROLYN MEIN, THOMAS GENOVESE AND CHRISTINA GENEVOSE, could not be located by Plaintiff’s at the last known address on record with the Sandoval County Assessor. United States Postal mail was returned undelivered. Plaintiff’s affirm that the present whereabouts of the Defendants named herein is unknown. Defendant’s are not residents of the State of New Mexico and the actual place of residence of the Defendants is unknown and cannot be ascertained by Plaintiff’s.

Subscribed and sworn to before me this __________ day of _______________________ 2002 by Paul Salas, Plaintiff Pro Se.