NOTICE OF COMPLAINT ON A NOTE AND FOR FORECLOSURE OF MORTGAGE ON NON-OWNER OCCUPIED REAL ESTATE SUMMONS - SERVICE BY PUBLICATION

STATE OF INDIANA

SS: COUNTY OF HAMILTON

IN THE MADISON COUNTY CIRCUIT COURT

CAUSE NO.48C03-2412-MF-000240

COUNTY OF HAMILTON

ETC CUSTODIAN FBO 200334938 IRA, Plaintiff, 

vs.
PAIGE & ROSE PROPERTIES, LLC;

ROBERT JUSTIN BUCHANAN;

CAMAPLAN ADMINISTRATOR FBO

RANDY HAMMER ROTH IRA;

ROSE RIVER CONSULTING, LLC;

ANDREW HARRISON; MEGAN HARRISON; CB PROPERTIES GROUP, LLC; KAI CHUNG CHAN;
UNKNOWN TENANTS/OCCUPANTS.
Defendants.

NOTICE OF COMPLAINT ON A NOTE AND FOR FORECLOSURE OF MORTGAGE ON NON-OWNER OCCUPIED REAL ESTATE SUMMONS - SERVICE BY PUBLICATION

1. Notice of Complaint on A Note and For Foreclosure of Mortgage on Non—-Owner Defendants. Occupied Real Estate in the above captioned matter: The State of Indiana to the Defendant, Rose River Consulting, LLC, above named, and any other person who may be concerned. You are hereby notified that a Complaint on A Note and For Foreclosure of Mortgage on Non—-Owner Occupied Real Estate has been filed on December 17, 2024, against you and any interest you may have in the subject property of said complaint, described herein, may be subject to a Determination by this Court.
2. The nature of this Determination is concerning: the aforementioned Complaint on a Note and For Foreclosure of Mortgage on Non-Owner Occupied Real Estate.
   I. The Summons by Publication is specifically directed to the above-named Defendant whose last known address was: c/o Registered Agents, Inc., Registered Agent 8401 Mayland Dr. Ste. S. Richmond, VA 23294, and whose whereabouts, through diligent search, remain unknown to the Plaintiff. In addition to the above-named Defendant being served by this summons there may be other Defendants who have an interest in this matter.
   II. You must acknowledge the Notice of Complaint on A Note and For Foreclosure of Mortgage on Non-Owner Occupied Real Estate in writing, by you or your attorney, on or before the day of April 18, 2025, (the same being within thirty (30) days after the Third Notice of Complaint on a Note and For Foreclosure of Mortgage on Non-Owner Occupied Real Estate has been printed), and in the event you fail to do so, a default judgment and Determination may be entered against you for what the Plaintiff has demanded.
   WHEREFORE, Plaintiff submits this Complaint for on a Note For Foreclosure of Mortgage on Non-Owner Occupied Real Estate pursuant to all applicable Indiana Rules of Trial Procedure for complete and successful service upon the above-named Defendant.

Respectfully submitted,

CHURCH CHURCH HITTLE & ANTRIM

Kyle B. Blowers

Attorney Number: 291 12-48

Two North Ninth Street

Noblesville, IN 46060

Telephone: 317.773.2190

Facsimile: 317.572.1609

Attorney for Plaintiff

ATTEST:

Linda S. Smith

Clerk of the Madison County Circuit Court

Anderson, Indiana

March 3, 2025