FIRST JUDICIAL DISTRICT COURT OF
NEVADA, CARSON CITY
RANDAL S. KUCKENMEISTER, Trustee
of the GARTH S. & JOAN M. RICHARDS
FAMILY TRUST, as amended and restated,
Plaintiff,
v.
ROBERT GREGORY GALLAGHER, A/K/A
BOBBY FREEMAN, BETTY FRANKLIN,
MEYR RICHARD JAY, RICHARD JAY and
DOES I-X, DOE CORPORATIONS XI-XX,
Defendants.
Case No.: 23 MT 000601D
Dept. No.: I
SUMMONS
NOTICE! YOU HAVE BEEN SUED. THE
COURT MAY DECIDE AGAINST YOU
WITHOUT YOU BEING HEARD UNLESS
YOU RESPOND IN WRITING WITHIN 21
DAYS. READ THE INFORMATION BELOW
VERY CAREFULLY.
To the Defendant: BETTY FRANKLIN,
an individual,
A civil complaint has been filed by the
Plaintiff, RANDAL S. KUCKENMEISTER,
Trustee of the GARTH S. & JOAN M.
RICHARDS FAMILY TRUST, as amended and
restated, against you for the relief as set forth
in that complaint. The object of this action is:
A. For Declaratory Relief declaring and
decreeing the Trust as the sole owner of the
collateral as set forth herein to dispose of to
offset the loan balance, to applied to accrued
interest, and further seeking authority for the
Court Clerk to execute said titles in lieu of
Defendants above named;
If you intend to defend this lawsuit, within
21 days after this summons is served on you
(not counting the day of service), you must:
1. File with the Clerk of the Court a
formal answer to the complaint.
2. Pay the required filing fee to the
court, or file an Application to
Proceed In Forma Pauperis and
request a waiver of the filing fee.
3. Serve a copy of your answer upon
the Plaintiff whose name and
address is shown below.
If you fail to respond, the Plaintiff can
request your default. The court can then
enter a judgment against you for the relief
demanded in the complaint.
/s/ William Scott Hoen
CLERK OF THE COURT
By: __/s/_________August 18, 2023
Deputy Clerk
Issued on behalf of Plaintiff:
Plaintiff: Plaintiff, RANDAL S.
KUCKENMEISTER, Trustee of the GARTH S.
& JOAN M. RICHARDS FAMILY TRUST, as
amended and restated,
Attorney: Handelin Law, Ltd
P.O. Box 4568
Carson City, NV 89702
(775) 882-8032
Steven P. Handelin, Esq.
steve@handelinlaw.com
Nevada Bar #: 9575
Pub Date: November 25,
December 2, 9, 16, 2023
Ad # 38733