STATE OF MINNESOTA  COUNTY OF FILLMORE DISTRICT COURT  THIRD JUDICIAL DISTRICT  CASE TYPE: OTHER CIVIL (REFORMATION OF INSTRUMENT/ QUIET TITLE) Court File No. 23-CV-25-711

Kathryn Caldbeck, Plaintiff, V. Dolores Caldbeck,

Citizens Right to Purchase Property, Chicago Great Western Railway Company, Chicago and North Western Transportation Company,

Winona and Southwestern Railway Company, 

Wisconsin Minnesota and Pacific Railroad Company, 

Chicago, Milwaukee, St. Paul and Pacific Railroad, 

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,

Defendants.

SUMMONS

SUMMONS

THIS SUMMONS IS DIRECTED TO THE ABOVE NAMED DEFENDANTS.

1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you.

The original Plaintiff’s 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 Plaintiff 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 Plaintiff 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 Exhibits A and B.

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.

LAW OFFICE OF 

SHAWN VOGT SWEEN, LLC

Dated: December 15, 2025

Shawn Vogt Sween 

MN# 0387368

104 Main St S

Grand Meadow, MN 55936 

Telephone: 507-754-4555

Facsimile: 507-754-4554

e-mail: shawn@svslawoffice.com

EXHIBIT A

That part of the West 50 acres of the South Half of the Northeast Quarter of Section 32, Township 103, Range 13, Fillmore County, Minnesota, lying south of the centerline of the now abandoned Chicago, Milwaukee, St. Paul and Pacific Railroad Right-of-Way,

EXCEPT that part of the South One-Half of the Northeast Quarter (S 1/2 NE 1/4) of Section 32, Township 103 North, Range 13 West, Fillmore County, Minnesota, described as follows: Commencing the Southeast Comer of said S 1/2 NE 1/4; thence North 89 degrees 32 minutes 54 seconds West (assumed bearing) along the South line of said S 1/2 NE 1/4, 996.87 feet; thence North 01 degree 14 minutes 31 seconds East along the East line of the West 50 acres of said S 1/2 NE 1/4, 1085.16 feet to the point of beginning of the tract of land to be herein described; thence North 89 degrees 17 minutes 07 seconds West parallel with the North line of said S 1/2 NE 1/4, 1087.96 feet to the centerline of the now abandoned Chicago, Milwaukee, St. Paul and Pacific Railroad Right-of-Way; thence North 82 degrees 05 minutes 21 seconds East along said centerline, 1101.94 feet to said East line of said West 50 acres; thence South 01 degree 14 minutes 31 seconds West along said East line, 165.27 feet to the point of beginning and containing 2.06 acres, more or less. Subject to any easements of record.

EXHIBIT B

That part of the South One-Half of the Northeast Quarter (S 1/2 NE 1/4) of Section 32, Township 103 North, Range 13 West, Fillmore County, Minnesota, described as follows: Commencing the Southeast Comer of said S 1/2 NE 1/4; thence North 89 degrees 32 minutes 54 seconds West (assumed bearing) along the South line of said S 1/2 NE 1/4, 996.87 feet; thence North O1 degree 14 minutes 31 seconds East along the East line of the West 50 acres of said s 1/2 NE 1/4, 1085.16 feet to the point of beginning of the tract of land to be herein described; thence North 89 degrees 17 minutes 07 seconds West parallel with the North line of said S 1/2 NE 1/4, 1087.96 feet to the centerline of the now abandoned Chicago, Milwaukee, St. Paul and Pacific Railroad Right-of-Way; thence North 82 degrees 05 minutes 21 seconds East along said centerline, 1101.94 feet to said East line of said West 50 acres; thence South 01 degree 14 minutes 31 seconds West along said East line, 165.27 feet to the point of beginning and containing 2.06 acres, more or less. Subject to any easements of record.

Publish 5,12,19