SMS Financial Recovery Services, LLC vs. David R. Coffman, Suzanne M. Coffman, and John/Jane Does 1-10 SUMMONS IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF CLACKAMAS CASE NO. 19CV24941 TO: John/Jane Does 1-10, the above-named defendant. You are hereby required to appear and defend the complaint filed against you in the above entitled action within thirty (30) days from the date of the first publication of this summons, and in case of your failure to appear and answer, plaintiff for want thereof will apply to the above entitled court for the relief prayed for in its complaint, to-wit: A. FIRST AND SECOND CLAIMS FOR RELIEF: 1. For a judgment against the defendants avoiding the transfers of the Property, more fully defined in the Complaint, to defendant Suzanne M. Coffman and/or John/Jane Does 1-10 and awarding Plaintiff a money judgment against Suzanne M. Coffman in the unsatisfied amount of the Foreign Judgment, in an amount to be proven at trial, up to the amount of $2,407,252.77, plus interest thereon; and 2. For a judgment awarding attachment or other provisional remedy against the Property; B. THIRD CLAIM FOR RELIEF: 1. For a judgment (a) imposing a constructive trust as to any and all distributions by and/or assets owned by the Axiom Entities that, but for David R. Coffman’s directions as described in paragraph 31 above, would have been distributed to D.R. Coffman Investments, LLC, and declaring that any person, trust or entity holding such distributions or assets holds them as property of D.R. Coffman Investments, LLC, and (b) declaring that the membership interest of David R. Coffman in D.R. Coffman Investments, LLC, is charged with payment of the unsatisfied amount of the Foreign Judgment, with interest, pursuant to ORS 63.259 C. ALL CLAIMS FOR RELIEF: 1. For Plaintiff’s costs and disbursements incurred herein; and 2. For such other relief as the court may deem appropriate. NOTICE TO DEFENDANT: READ CAREFULLY!! YOU MUST APPEAR IN THIS CASE OR THE OTHER SIDE WILL WIN AUTOMATICALLY. TO APPEAR YOU MUST FILE WITH THE COURT A LEGAL PAPER CALLED A MOTION OR ANSWER. THE MOTION OR ANSWER (OR REPLY) MUST BE GIVEN TO THE COURT CLERK OR ADMINISTRATOR WITHIN 30 DAYS OF THE DATE OF FIRST PUBLICATION SPECIFIED HEREIN ALONG WITH THE REQUIRED FILING FEE. IT MUST BE IN PROPER FORM AND HAVE PROOF OF SERVICE ON THE PLAINTIFF’S ATTORNEY OR, IF THE PLAINTIFF DOES NOT HAVE AN ATTORNEY, PROOF OF SERVICE UPON THE PLAINTIFF. IF YOU HAVE ANY QUESTIONS, YOU SHOULD SEE AN ATTORNEY IMMEDIATELY. IF YOU NEED HELP IN FINDING AN ATTORNEY, YOU MAY CONTACT THE OREGON STATE BAR’S LAWYER REFERRAL SERVICE ONLINE AT WWW.OREGONSTATEBAR.ORG OR BY CALLING AT (503) 684-3763 (IN THE PORTLAND METROPOLITAN AREA) OR TOLL-FREE ELSEWHERE IN OREGON AT (800) 452-7636. This summons is published pursuant to ORCP 7(D)(6)(e). Date of first publication: August 6, 2019. Date of last publication: August 27, 2019. Margot D. Seitz, OSB #075982 FARLEIGH WADA WITT Of Attorneys for Plaintiff 121 SW Morrison, Suite 600 Portland, OR 97204-3136 (503) 228-6044 Published Aug. 6, 13, 20 & 27, 2019. BT123405

ad: 123405

Publication: Miscellaneous

Section: Legals

Start Date: 2019/08/06

End Date: 2019/08/27

Court Number: 19CV24941

Owner: Farleigh Wada Witt


County: Clackamas