On December 13, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Wilbert Funeral Services Inc,
and
Alyssa Gallegos,
Robbie Quintana,
Rqx Inc,
for Money
in the District Court of Lake County.
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DISTRICT COURT, LAKE COUNTY, COLORADO
Court Address: P.O. Box 55
505 Harrison Ave. DATE FILED: February 7, 2022 10:20 AM
FILING ID: EFA70E1C12AAE
Leadville, CO 80461 CASE NUMBER: 2021CV30017
Phone Number: (719) 486-0535
______________________________________________
Plaintiff: WILBERT FUNERAL SERVICES, INC.
D/B/A VALLEY PRECAST
Defendants: RQX, INC. AND ROBBIE QUINTANA â–² COURT USE ONLY â–²
AND ALYSSA GALLEGOS, PERSONAL ___________________________
GUARANTORS
____________________________________________ Case No. 21CV30017
Attorney:
Brammer Law Office, P.C.
Jay M. Brammer #16787 Div.: C Ctrm.:
Ray Ann Brammer #17187
Address: P. O. Box 1827, Sterling, CO 80751
Phone Number: 970 521 0700
Fax Number: 970 521 0307
E-mail: brammer@brammerlaw.com
MOTION FOR DEFAULT JUDGMENT
The Plaintiff herein by and through its attorneys, BRAMMER LAW OFFICE, P.C., and
shows to the Court as follows:
1. Defendants have failed to appear or plead or otherwise defend this action as provided
by the Colorado Rules of Civil Procedure and are now in default herein;
2. Each of the Defendants is not a minor nor mentally incompetent, nor an officer nor
agency of the State of Colorado, nor in the military service. Affiant bases his knowledge upon
reasonable inquiry and on the fact that the Defendant, RQX, Inc. is a Colorado Corporation in
and around Lake County, Colorado;
3. Lake District Court is proper venue for this action as Defendants reside in Lake
County, Colorado.
4. The Defendants were served in accordance with Colorado law as follows:
The Defendant, Alyssa Gallegos was served by serving Robbie Quintana, her
husband on 12/8/2021.
The Defendant, RQX, Inc. was served by serving the Registered Agent, Robbie
Quintana on 12/8/21.
The Defendant Robbie Quintana was served personally and in person on 12/8/21.
The complaint was filed within fourteen days on 12/13/22.
5. The Plaintiff requests that judgment enter against the Defendants, RQX, Inc., Robbie
Quintana and Alyssa Gallegos, jointly and severally as follows:
Principal: $8,467.56
Interest at 18.00% $1,035.58
Court Costs: $309.50
Attorney Fees: $825.00
Total: $10,637.64
WHEREFORE, Plaintiff requests that judgment by default be entered.
Dated: 2/3/22
BRAMMER LAW OFFICE, P.C.
/s/ Jay M. Brammer
______________________________
Jay M. Brammer, No. 16787
Ray Ann Brammer, No. 17187
Attorney for Plaintiff
E-filed pursuant to C.R.C.P. 121. Duly signed original on file at Brammer Law Office.
Document Filed Date
February 07, 2022
Case Filing Date
December 13, 2021
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DISTRICT COURT, LAKE COUNTY, COLORADO Court Address: P.O. Box 55 505 Harrison Ave. DATE FILED: February 7, 2022 10:20 AM FILING ID: EFA70E1C12AAE Leadville, CO 80461 CASE NUMBER: 2021CV30017 Phone Number: (719) 486-0535 ______________________________________________ Plaintiff: WILBERT FUNERAL SERVICES, INC. D/B/A VALLEY PRECAST Defendants: RQX, INC. AND ROBBIE QUINTANA â–² COURT USE ONLY â–² AND ALYSSA GALLEGOS, PERSONAL ___________________________ GUARANTORS ____________________________________________ Case No. 21CV30017 Attorney: Brammer Law Office, P.C. Jay M. Brammer #16787 Div.: C Ctrm.: Ray Ann Brammer #17187 Address: P. O. Box 1827, Sterling, CO 80751 Phone Number: 970 521 0700 Fax Number: 970 521 0307 E-mail: brammer@brammerlaw.com MOTION FOR DEFAULT JUDGMENT The Plaintiff herein by and through its attorneys, BRAMMER LAW OFFICE, P.C., and shows to the Court as follows: 1. Defendants have failed to appear or plead or otherwise defend this action as provided by the Colorado Rules of Civil Procedure and are now in default herein; 2. Each of the Defendants is not a minor nor mentally incompetent, nor an officer nor agency of the State of Colorado, nor in the military service. Affiant bases his knowledge upon reasonable inquiry and on the fact that the Defendant, RQX, Inc. is a Colorado Corporation in and around Lake County, Colorado; 3. Lake District Court is proper venue for this action as Defendants reside in Lake County, Colorado. 4. The Defendants were served in accordance with Colorado law as follows: The Defendant, Alyssa Gallegos was served by serving Robbie Quintana, her husband on 12/8/2021. The Defendant, RQX, Inc. was served by serving the Registered Agent, Robbie Quintana on 12/8/21. The Defendant Robbie Quintana was served personally and in person on 12/8/21. The complaint was filed within fourteen days on 12/13/22. 5. The Plaintiff requests that judgment enter against the Defendants, RQX, Inc., Robbie Quintana and Alyssa Gallegos, jointly and severally as follows: Principal: $8,467.56 Interest at 18.00% $1,035.58 Court Costs: $309.50 Attorney Fees: $825.00 Total: $10,637.64 WHEREFORE, Plaintiff requests that judgment by default be entered. Dated: 2/3/22 BRAMMER LAW OFFICE, P.C. /s/ Jay M. Brammer ______________________________ Jay M. Brammer, No. 16787 Ray Ann Brammer, No. 17187 Attorney for Plaintiff E-filed pursuant to C.R.C.P. 121. Duly signed original on file at Brammer Law Office.