Case No.  SW-2023-CV-000045

(First Published in the High Plains Daily Leader & Times, Liberal Kansas May 4, 2023)t3

IN THE DISTRICT COURT OF Seward County, KANSAS


MARIO BOSQUEZ and EMILIA CUELLAR,
Plaintiffs, vs. KANSAS DEPARTMENT OF REVENUE,  MERLIN MARTINEZ and the unknown heirs,
executors, administrators, devisees, trustees, 
creditors and assigns of any deceased
Defendants; the unknown spouses of any 
Defendants; the unknown guardians,  conservators and trustees of any Defendants 
that are minors or are under any legal disability; and the unknown heirs, executors,  administrators, devisees, trustees, creditors and  assigns of any person alleged to be deceased,
Defendants.

Case No.  SW-2023-CV-000045
NOTICE OF SUIT

STATE OF KANSAS, TO:  Merlin Martinez and the unknown heirs, executors, administrators, devisees, trustees, creditors and assigns of any deceased Defendants; the unknown spouses of any Defendants; the unknown officers, successors, trustees, creditors and assigns of any Defendants that are existing, dissolved or dormant corporations; the unknown executors, administrators, devisees, trustees, creditors, successors and assigns of any Defendants that are or were partners or in partnership; the unknown guardians, conservators and trustees of any Defendants that are minors or are under any legal disability; and the unknown heirs, executors, administrators, devisees, trustees, creditors and assigns of any person alleged to be deceased.

YOU ARE HEREBY NOTIFIED that a Petition has been filed in the District Court of Seward County, Kansas, by Mario Bosquez and Emilia Cuellar, praying for judgment quieting Plaintiffs' title in and to the following described personal property, to-wit:
1982 Shar mobile home VIN #8904;
and praying that all Defendants set up any right, title, lien, claim or security interest they may have in and to the above-described personal property and in the event of their failure to do so, that Defendants be forever barred and enjoined from setting up any right, title, lien, claim or security interest in and to the above-described personal property of Plaintiffs and for a further order directing the State of Kansas, Department of Revenue, to issue a Certificate of Title to the mobile home in the name of the Plaintiffs and you are required to plead to the Petition of Plaintiffs on or before June 15, 2023, in said Court in Liberal, Seward County, Kansas.  Should you fail therein, judgment and decree will be entered in due course upon said Petition.

Mario Martinez and Emilia Cuellar, Plaintiffs

Ryan D. Reddick, #29998
YOXALL, ANTRIM & FRYMIRE, LLP
101 West Fourth Street
Liberal, Kansas 67901
(620) 624-8444 phone
(620) 624-8221 fax
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Attorney for Plaintiffs