STATE OF MINNESOTA
COUNTY OF FILLMORE
THIRD JUDICIAL DISTRICT
CASE TYPE: OTHER CIVIL (REFORMATION OF INSTRUMENT/ QUIET TITLE)
Court File No. 23-CV-20-443
Kathleen Betcher and Colleen H. Crew,
Lewis G. Hanson, Carrie G. Hanson, George Melvin Hanson, Amy Mabel Hanson, Albin Herbert Hanson, Laura Cornelia Hanson, Agnes Theresa Hanson, Lillian Elvina Hanson, Gladys Viola Hanson, Augustus Beach, Agnes Hingeveld, Floyd Hingeveld, Alice Simonson, Wayne Simonson, Janet Simonson, Mary Berg, State of Minnesota, Lance M. Bergeson, Charles S. Forland, JoAnn K. Forland, Tracy J. Clement, also, all other persons or entities unknown claiming any right, title, estate, interest, or lien, in the real estate described in the complaint herein, including the heirs at law, and legatees and devisees of any of the foregoing defendants who are deceased or dissolved,
THIS SUMMONS IS DIRECTED TO THE ABOVE NAMED DEFENDANTS.
1. YOU ARE BEING SUED. The Plaintiffs have started a lawsuit against you.
The original Plaintiffs’ Complaint is on file at the office of the Court Administrator of the above named Court. Do not throw these papers away. They are official papers that affect your rights. You must respond to this lawsuit even though it may not yet be filed with the Court and there may be no court file number on this Summons.
2. YOU MUST REPLY WITHIN 20 DAYS TO PROTECT YOUR RIGHTS. You must give or mail to the person who signed this Summons a written response called an Answer within 20 days of the date on which you received this Summons. You must send a copy of your Answer to the person who signed this Summons located at the following address:
Law Office of Shawn Vogt Sween LLC
Shawn Vogt Sween, Attorney at Law
104 Main Street
Grand Meadow, MN 55936
3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiffs’ Complaint. In your Answer you must state whether you agree or disagree with each paragraph of the Complaint. If you believe the Plaintiffs should not be given everything asked for in the Complaint, you must say so in your Answer.
4. YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTEN RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THIS SUMMONS. If you do not answer within 20 days, you will lose this case. You will not get to tell your side of the story, and the Court may decide against you and award the Plaintiffs everything asked for in the Complaint. If you do not want to contest the claims stated in the Complaint, you do not need to respond. A default judgment can then be entered against you for the relief requested in the Complaint.
5. LEGAL ASSISTANCE. You may wish to get legal help from a lawyer. If you do not have a lawyer, the Court Administrator may have information about places where you can get legal assistance. Even if you cannot get legal help, you must still provide a written Answer to protect your rights or you may lose the case.
6. ALTERNATIVE DISPUTE RESOLUTION. The parties may agree to or be ordered to participate in an alternative dispute resolution process under Rule 114 of the Minnesota General Rules of Practice. You must still send your written response to the Complaint even if you expect to use alternative means of resolving this dispute.
7. THIS LAWSUIT MAY AFFECT OR BRING INTO QUESTION TITLE TO REAL PROPERTY located in Fillmore County, State of Minnesota, legally described on the attached Exhibit A. The object of this action is to determine that the defendants have no right, title, estate, interest, or lien in or on the above described real estate.
8. 557.03 NOTICE OF NO PERSONAL CLAIM. Pursuant to Minn. Stat. § 557.03 you are hereby served with notice that no personal claim is made against you and that any defendant upon whom this notice is served who unreasonably defends this action shall pay full costs to the plaintiff.
Dated: September 2, 2020
LAW OFFICE OF SHAWN VOGT SWEEN, LLC
/s/Shawn Vogt Sween
Shawn Vogt Sween
104 Main St S
Grand Meadow, MN 55936
That part of the Northeast Quarter of the Northeast Quarter (NE 1/4 NE 1/4) of Section 21, Township 102 North, Range 13 West, Fillmore County, Minnesota, described as follows: Commencing at the Northeast Corner of said NE 1/4 NE 1/4; thence South 00 degrees 16 minutes 27 seconds East (assumed bearing) along the East line of said NE 1/4 NE 1/4, 661.86 feet to the Southeast Corner of the Northeast Quarter of said NE 1/4 NE 1/4 (NE 1/4 NE 1/4 NE 1/4); thence South 89 degrees 48 minutes 35 seconds West along the South line of said NE 1/4 NE 1/4 NE 1/4, 95.56 feet to the Westerly Right-of-Way line of Minnesota Trunk Highway No. 63 and to the point of beginning of the tract of land to be herein described; thence continuing South 89 degrees 48 minutes 35 seconds West along said South line, 38.82 feet; thence South 01 degree 27 minutes 48 seconds West, 15.76 feet; thence North 88 degrees 32 minutes 12 seconds West, 58.65 feet; thence North 01 degree 27 minutes 48 seconds East, 14.07 feet to said South line of said NE 1/4 NE 1/4 NE 1/4; thence South 89 degrees 48 minutes 35 seconds West along said South line, 466.97 feet; thence South 00 degrees 16 minutes 20 seconds East, 330.92 feet; thence North 89 degrees 53 minutes 30 seconds East, 165.04 feet; thence South 00 degrees 16 minutes 27 seconds East, 110.00 feet; thence North 89 degrees 53 minutes 30 seconds East, 397.49 feet to said Westerly R.O.W. line; thence North 00 degrees 01 minute 15 seconds West along said R.O.W. line, 441.72 feet to the point of beginning and containing 5.27 acres, more or less. Subject to any easements of record.