Legal Notices-Non-government

MORE THAN DIRT LLC,
Plaintiff,

vs.
GROUP I:
FRANK O. BURGESS Deceased; KATHERYN BURGESS, Deceased;

GROUP II:
ALL OTHER UNKNOWN CLAIMANTS
OF INTEREST IN THE PREMISES ADVERSE TO THE PLAINTIFF

Defendants.

COMPLAINT FOR EXTINGUISHMENT OF LIENS AND TO QUIET TITLE
PLAINTIFF, More Than Dirt LLC, complaining of the Defendants, alleges:
1. Plaintiff is a New Mexico limited liability company.
2. This court has subject matter jurisdiction over this action pursuant to §42-6-1
NMSA 1978.
3. Plaintiff is the owner in fee simple of the following described real estate in
Catron County, New Mexico, (hereinafter, “PARCEL 1”), pursuant to a Deed from the Property
Tax Division of the Taxation and Revenue Department of the State of New Mexico to More Than
Dirt LLC dated July 5, 2022, and recorded August 17, 2022 as Instrument No.2022-01344,
in the records of Catron County, New Mexico, a copy of which is attached hereto and
incorporated herein as “EXHIBIT 1″:

PARCEL 1:
Township 7 S Range 19 W Section 27 A TRACT IN S2SW4SW4; CONT. 7.62 AC. M/L LESS3.31 ACRES TO BURGESS, F&C BK84 PG442 1120 SQ. FT. MH HERE

4. PLAINTIFF is credibly informed and believes, and upon such information and
belief alleges, that each of the Defendants hereinabove named or designated, makes, or during
his or her lifetime made, some claim of lien, interest, right, or title adverse to the PLAINTIFF in
and to the said real estate and is made a party-Defendant by name as near as the same can be
ascertained.
5. PLAINTIFF is credibly informed and believes, and upon such information and belief alleges, FRANK O. BURGESS Deceased; KATHERYN BURGESS, Deceased; hereinabove named or designated in “Group I” of the title of this case, which is here adopted by reference, may claim an interest in and to PARCEL 1 as alleged in paragraph 4 hereof.

6. PLAINTIFF is credibly informed and believes, and, upon such information and
belief, alleges that there may be other persons unknown to the PLAINTIFF who make the claim
alleged in paragraph 4 hereof. PLAINTIFF has made due search and inquiry to ascertain the
names, residences, or whereabouts of such persons, but such information is unknown and cannot be ascertained; and that they have been made parties defendant herein by the name and style of: “Group III: ALL OTHER UNKNOWN CLAIMANTS OF INTEREST IN THE PREMISES
ADVERSE TO THE PLAINTIFF”, and that constructive service of process only can be obtained
against them.

7. Each of the Defendants herein named or designated makes some claim adverse to
the PLAINTIFF in the real estate herein described. This action is brought by the PLAINTIFF to
quiet its title to all said 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 hereinabove described, or any portion thereof, adverse to the PLAINTIFF, by any of the Defendants herein named or designated or by any person claiming by, through or under the Defendants or any of them, is without foundation or right, either in law or in equity.
WHEREFORE, Plaintiff, MORE THAN DIRT LLC, prays for the establishment in the
PLAINTIFF of its estate in fee simple, in and to the said real estate described herein as
PARCEL1, against the adverse claims of the Defendants, and each of them, and everyone claiming by, though, or under them, and that the Defendants and each of them, and everyone claiming by, though, or under them be barred and forever estopped from having or claiming any lien upon, or any right, title or interest in or to the said real estate adverse to the PLAINTIFF and that the title of the PLAINTIFF thereto in fee simple be forever quieted and set at rest.
The PLAINTIFF further prays that it be permitted to have service by publication upon the
Defendants upon whom personal service cannot be obtained; and for such other and further relief as the PLAINTIFF may be entitled to in the premises.

MORE THAN DIRT LLC
By: Mackenzie Baldridge (owner)
PO Box 133
Reserve, NM 87830
Telephone: (575) 654-5572
Email: [email protected]
Plaintiff pro se