01.20.22 Legal Notice 3

NLJ Staff






Civil Number: CV-2124

Bank of New York Mellon Trust Company,

N.A. as Trustee for Mortgage Assets

Management Series I Trust,



Elsie Marie Woodard; Unknown Heirs and Devisees of the Estate of David G. Paulley; Unknown Heirs and Devisees of the Estate of Frances M. Paulley; the Secretary of Housing and Urban Development; and Any Person in Possession of the property located at 886 Nefsy Avenue, Osage, WY 82723,






PLEASE TAKE NOTICE that the Plaintiff has filed with the Sixth Judicial District, Weston County, State of Wyoming, a Complaint requesting the sale of real property under a mortgage, lien, or other encumbrance or charge. Plaintiff is requesting the following:

A. Quiet Title Judgment against the Unknown Heirs and Devisees of the Estate of Frances M. Paulley declaring and affirming that any interest held by Frances M. Paulley was extinguished upon her death and the March 17, 2008 Warranty Deed recorded as Instrument No. 701923, in Book 305 at Page 0317 conveyed all rights, title, and interest in the property to David

G. Paulley and Elise Marie Woodward as of the date and time of its original recording.

B. Judgment reforming the Mortgage, and all related assignments to the Mortgage, to be reformed, as of its original recording date and time to reflect the correct and full legal description of the property as follows:

Lots 1, 2, 3, 13 and 14 in Block 23, and Lots 5 through 12 and Lots 14 and 15 in Block 32 of Nefsy Addition to Osage, Wyoming and a Tract of land including Lots 5 through 9 and Lots 14 and 15 and vacated alley in Block 32 of Nefsy Addition to Osage, Wyoming, more particularly described as follows:

Starting at the intersection of the West boundary of the CB&Q Railroad right-of-way with the North boundary of the SWI/4 of the NEl/4 of Section 9, Township 46 North, Range 63 West; thence running Sl5°26’E along the West boundary of the CB&Q Railroad right-of-way for a distance of 391.4 feet to a jog in the right-of-way; thence S73°12’W 50 feet to a jog in the right­ of- way line; thence S13°56’E along the West boundary of the CB&Q Railroad right-of-way for a distance of 252 feet to the point of beginning; thence S73°12’W for a distance of 193.4 feet to intersect the East boundary of the former U.S. Highway #16; thence Sl6°48’E along the East boundary of former U.S. Highway #16 for a distance of 113.0 feet; thence N73°12’E for a distance of 130 feet; thence Sl6°48’E for a distance of 75 feet; thence N73°12’E for a distance of 54 feet to intersect the West boundary of the CB&Q Railroad right-of-way; thence Nl3°56’W along the West boundary of the CB&Q Railroad right-of-way for a distance of 188.5 feet to the point of beginning.

C. A judgment in favor of Plaintiff on its claim for declaratory relief, declaring that Plaintiff is the Mortgagee of the Mortgage;

D. An order of sale and decree of foreclosure of the Property in accordance with Wyoming law, where (i) the Plaintiff is to provide such publication and notice as is required pursuant to W.S. § 1-18-101, (ii) the Plaintiff is permitted to be a purchaser at the foreclosure sale and is permitted to “credit  bid” the amount owed to it, (iii) when any time for redemption has elapsed, the Sheriff or other officer conducting the sale shall execute a deed to the purchaser of the Property at the sale and that the purchaser be let into possession of the Property on production of said deed;

E. Judgment affirming that any and all rights or claims held by Defendants to the Property will be extinguished upon successful completion of the foreclosure sale and full and complete title to the property will transfer to the purchaser pursuant to the Sheriffs Deed.

F. Attorney’s fees and costs to Plaintiff in its enforcement of its rights and remedies prior to and during this litigation, including all fees incurred up and until the date of foreclosure; and

G. Such other and further relief as the Court deems just and equitable under the circumstances.

YOUR RIGHTS MAY BE AFFECTED. You should read these papers carefully and discuss them with your attorney, if you have one in this case. If you do not have an attorney, you may wish to consult one.   You are required to appear and defend this suit within twenty (20) days of service upon you; if you were served in the State of Wyoming, and within thirty (30) days, if you were served outside of the State of Wyoming or by publication. In the event you do not appear and defend, judgment by default will be rendered against you for the relief demanded in the complaint.


DATED this 12th day of January, 2022.


Shelly M. Espinosa, 7-5983 

Halliday, Watkins & Mann, P.C. 

376 East 400 South, Suite 300 

Salt Lake City, UT 84111 

Phone: 801-355-2886

Facsimile: 801-328-9714 


Attorney for Plaintiff

HWM File Number: WYl 0346



(Publish January 20 and 27 and February 3 and 10, 2022)


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