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SUMMONS
IN THE SUPERIOR COURT OF
THE STATE OF ARIZONA IN AND
FOR THE COUNTY OF COCHISE.
Case No. CV202200572.
Person Filing: Robert J. Pearson 18334 W Marshall Ave
Litchfield Park, AZ 85340.
Robert J. Pearson,
Plaintiff(s), V.
Edra Dickson and Frank
C. Willis and Cochise County
Treasurer,
Defendant(s).
FROM THE STATE OF ARIZONA
TO: Edra Dickson and Frank C. Willis and Cochise County Treasurer.
WARNING: THIS AN OFFICIAL DOCUMENT FROM THE COURT THAT AFFECTS YOUR RIGHTS. READ THIS SUMMONS CAREFULLY. IF YOU DO NOT UNDERSTAND IT, CONTACT AN ATTOR-NEY FOR LEGAL ADVICE.
1. A lawsuit has been filed against you. 2. If you do not want a judgment taken against you without your input, you must file an Answer in writing with the Court, and you must pay the required filing fee. To file your Answer, take or send the papers to Clerk of the Superior Court, PO Drawer CK, Bisbee, Arizona 85603, accompanied by the filing fee or Superior Court, 100 Colonia de Salud Suite 200, Sierra Vista, Arizona 85635 accompanied by the filing fee. A copy of the Response must be mailed to the Plaintiff, at the address listed on the top of this Summons. 3. If this Summons and the other court papers were served on you within the State of Arizona, your Answer must be filed within TWENTY (20) CALENDAR DAYS from the date of service, not counting the day of service. If this Summons and the other court papers were served on you outside the State of Arizona, your Answer must be filed within THIRTY (30) CALENDAR DAYS from the date of service, not counting the day of service. This is a legal document. If you do not understand its consequences, you should consult an attorney. Requests for reasonable accommodation for persons with disabilities must be made to the court by parties at least 3 working days in advance of a scheduled court proceeding.
GIVEN under my hand and the Seal of the Superior Court of the State of Arizona in and for the County of COCHISE.
SIGNED AND SEALED this date: December 7, 2022
Amy Hunley
Clerk of Superior Court
By: s/ Deputy Clerk
COMPLAINT TO FORECLOSE THE RIGHT TO REDEEM A TAX LIEN
IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF COCHISE.
Case No. CV202200572.
Person Filing: Robert J. Pearson 18334 W Marshall Ave
Litchfield Park, AZ 85340.
Robert J. Pearson,
Plaintiff(s), V.
Edra Dickson and Frank C. Willis
and Cochise County Treasurer, Defendant(s).
FROM THE STATE OF ARIZONA
TO: Edra Dickson and Frank C. Willis and Cochise County Treasurer.
Statement to the Court: 1) Plaintiff claims an interest in the property in Cochise County described below. Defendant(s) are not under age 18, legally incapacitated, or in military service. I gave notice of my intent to file for foreclosure, pursuant to ARS § 42-18202, on this date: 10/28/2022. 2) To pay for delinquent taxes legally levied and assessed against the property and interest, penalties, and charges, the Cochise County Treasurer sold the tax lien on the property to me as follows. The Certificate of Purchase has been issued or lawfully assigned to me. Assessor Parcel Number: 302- 32-005-02. Legal Description of Property: S2 SE SE SE SEC 17 13 28 5AC 3) Date of sale: 2/15/2017 4) Certificate of Purchase Number: 153211. The sale was valid, and the taxes due and owing on the property were delinquent at the time of sale. Over three years have passed since the date of sale. The Certificate of Purchase on the property was validly assigned to and owned by the Plaintiff, who has paid all amounts legally due thereon. No party has redeemed the property; therefore, Plaintiff is entitled to foreclose the rights of all Defendants to redeem the property and to be adjudged the owner of the prop- erty in fee simple, free and clear of liens, claims, rights and interests of any of the defendants herein. REQUEST TO THE COURT: 5) Order that, if Defendant(s) want to redeem the property from sale, Defendant(s) shall pay Plaintiff the costs incurred, if any, for title search, recording fees, court filing fee, service of process, reasonable attorney fees, and the amount of the Certificate of Purchase and payment of all subsequent taxes plus interest on that amount at the following rate of interest per annum from the date paid: 16%. OR, declare that the sale of the property, Certificate of Purchase and service of process are valid; that at the sale of the tax lien on the property the taxes on it were delinquent; that over three years have passed since the sale; that the property has not been redeemed; and that Defendant(s) right to re- deem the property is forever fore- closed and Defendant(s) are barred forever and stopped from having or claiming any right or title adverse to me. Enter a judgement in this matter pursuant to Rule 54, Arizona Rules of Civil Procedure, as there is no reason for delay. And, upon finding compliance with ARS § 42-18205, order the Cochise County Treasurer to execute and deliver to Plaintiff a deed conveying the property. Order any further relief for Plaintiff, including costs and attorney fees, that the court deems appropriate, based on Plaintiff(s) sub- mission of an itemized statement to the court. OATH OF AFFIRMATION State of Arizona County of Maricopa 6) I swear or affirm that the in- formation on this document is true and correct under penalty of perjury.
s/ Robert J. Pearson Plaintiff
April 7, 14, 21, 28, 2023 23-00983H