DISTRICT COURT,
PUEBLO COUNTY,
STATE OF
COLORADO
Court Address: 501 N. Elizabeth St.
Pueblo, CO 81003
Court Phone: (719) 404-8700
Plaintiff:
PLANET HOME LENDING LLC
v.
Defendants:
HAYDN MICHAEL PRIMROSE; ZACHARY EDGER PRIMROSE; CITY OF PUEBLO, a municipal corporation; COLORADO HOUSING ASSISTANCE CORPORATION; SHOREHAM BANK FKA HOME LOAN INVESTMENT BANK, F.S.B.; UNITED STATES OF AMERICA, U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT; and KIMBERLY ARCHULETTA, IN HER CAPACITY AS THE PUBLIC TRUSTEE OF PUEBLO COUNTY, STATE OF COLORADO.
Case No.: 2025CV030755
Division: 501
Attorney: Jennifer C. Rogers
Kate M. Leason
Firm: IDEA Law Group, LLC
Address: 4530 S. Eastern Ave,
Ste. 10
Las Vegas, NV 89119
Phone: 877-353-2146
E-mail: jrogers@IDEALawgroupllc.com
kleason@idealawgroupllc.com
Atty. Reg. No. 34682, 41025
Our File No.: 48244187
SUMMONS
TO THE ABOVE-NAMED
DEFENDANTS:
YOU ARE HEREBY SUMMONED and required to file with the Clerk of this Court an answer or other response to the attached Complaint. If service of the Summons and Complaint was made upon you within the State of Colorado, you are required to file your answer or other response within 21 days after such service upon you. If service of the Summons and Complaint was made upon you outside of the State of Colorado or by publication, you are required to file your answer or other response within 35 days after such service upon you. If you were served by
publication, service shall be complete on the last day of publication. Your answer or counterclaim must be accompanied with the applicable filing fee.
If you fail to file your answer or other response to the Complaint in writing within the applicable time period, the Court may enter judgment by default against you for the relief demanded in the Complaint without further notice.
Dated: November 7, 2025
IDEA LAW GROUP, LLC
Original signature of Kate M. Leason s is on file with the law offices of IDEA Law Group, LLC pursuant to C.R.C.P. 121 §1-26(7).
/s/ Kate M. Leason
Jennifer C. Rogers, No. 34682
Kate M. Leason, #41025
ATTORNEYS FOR PLAINTIFF
PLANET HOME LENDING LLC