STATE OF NEW MEXICO
COUNTY OF SOCORRO
SEVENTH JUDICIAL
DISTRICT COURT

CASE NO.: CV-2023-98
WOODS, ROSCOE

BOBBY L. MARTIN and
ELIZABETH A.
MOLL-MARTIN, Plaintiff(s)

V.

DARRELL D. SEPHUS,
Defendant.

COMPLAINT TO QUIET
TITLE

COMES NOW, Bobby L. Martin and Elizabeth A. Moll-Martin, Plaintiff(s),
in the above-styled and numbered cause, pro se, and files this Complaint against Defendant, Darrell D. Sephus, and in support thereof would show unto the Court the following matters and facts:
1. Plaintiff(s) are married adult citizens of Socorro County, New Mexico.
2. Defendant, Darrell D. Sephus, is an adult resident citizen of Bakersfield, California, and may be served with process and other writs of this Court at 621 Charlana Drive, Kern County, Bakersfield, California.
3. Michael Lee Ericson expired on the 6th day of April 2022. Prior to his death, Mr. Ericson removed defendant, Darrell D. Sephus, from the Special Warranty Deed (Joint Tenant) on the 10th day of March 2010 (Exhibit “A”).
4. The property which is the subject matter of this action situated in the County of Socorro County, State of New Mexico, and described as follows:
LOT 6, BLOCK 1006, UNIT 2, RIO GRANDE ESTATES.
SUBJECT TO COVENANTS AND EASEMENTS OF RECORD.
10 (FORMERLY 4) JACINTO ROAD, VEGUITA, NM 84062

5. Defendant designated as DOES paragraphs one (1) through nine (9), “all persons unknown, claiming any legal or equitable right, title, estate, lien, or interest in the property described in the Complaint.”
6. Plaintiff(s), are now, and at all times mentioned in the possession of all the real property described in Paragraph 5 above, said real property to be hereinafter referred to as the “Property.”
7. Defendant in this action claims an interest and estate in the Property adverse to plaintiff(s)
(Exhibit “B”).
8. Defendants’ claims are based on a Lease Purchase Agreement that [he did not sign and has not been a party to or had an interest in at any time in the past or present.]
9. Plaintiff(s) have exclusive, complete, actual, open, notorious, hostile, and continuous possession of the Property adverse to defendant for more than six (6) years. Defendant has failed and refused to pay for upkeep on the Property and their claim to ownership causes great and irreparable harm to plaintiff(s). Plaintiff(s) are unable to borrow against the property to make necessary repairs, which lack of repair results in waste of the Property. Further, the adverse claims of Defendant tend to depreciate the value of the Property.

WHEREFORE, Plaintiff(s) request judgment against Defendant as follows:
1. That Defendant be required to set forth the right, nature, and virtue of their claim to the Property, and that all adverse claims of the Defendant be determined by decree of this Court:
2. That it be declared and adjudged that Plaintiff(s) are the owners of the Property and entitled to possession;
3. That it be declared and adjudged that the Defendant has no estate, right, title or interest whatsoever in or to the Property;
4. That Defendant be permanently enjoined and restrained from asserting any estate, right, title or interest whatsoever, in or to the Property, adverse to Plaintiff(s);
5. For costs; and
6. For such other and further relief as the court may deem proper.

RESPECTFULLY SUBMITTED on this 20th day of July, 2023.

BOBBY L. MARTIN,
Plaintiff and
ELIZABETH A.
MOLL-MARTIN, Plaintiff
ATTORNEY(S) pro se

/s/ Bobby L Martin,
Plaintiff, pro se

/s/ Elizabeth A. Moll-Martin,
Plaintiff, pro se

Published in the El Defensor Chieftain on August 24, 31, 2023 and September 7, 2023

El Defensor Chieftain