Lake Region Pioneer Threshermens Association Summons

STATE OF MINNESOTA IN DISTRICT COURT
SEVENTH JUDICIAL DISTRICT
COUNTY OF OTTER TAIL CIVIL DIVISION
Other Civil
Court File No.   56-CV-18-1053
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Lake Region Pioneer Threshermens Association,
Plaintiff,
v.
Leona Zimmerman, State of Minnesota, City of Dalton, Angela M. Nelson, Sara L. Nelson, Garrett Eastwood, Sheila Nelson aka Sheila A. Nelson, Julie Schmidt, Jennifer K. Soliah aka Jennifer K. Hammer,  Larry D. Ripplinger, Stacy Underhill, Philip A. Isaacson, Michele D. Isaacson, Lacy Nordick aka Lacy D. Nordick, Donald L. Funkhouser aka Donald L. Funkhauser, Betty M. Funkhouser aka Betty M. Funkhauser, Denise Cabana Leitch aka Denise L. Cabana, Eugene D. Hanson, Myrna Clauson Hanson, Otter Tail County, Ole C. Dahl, Dalton Creamery Company, Jens A. Stortroen, Otilie Rustad, J. H. Gregory, Mary Gregory, George Bere, E. M. Heald, Tilda O. Rustad, Oliver A. Rustad, Christian B. Formo, James E. Formo, Hazel Formo, Northwestern Bell Telephone Company, Rosella Walvatne, Carl Roger Van Horn, Linda A. Van Horn, S. M. Skrove, Oline Skrove, Berton M. Skrove, Andria Skrove, Sanford O. Skrove, Beatrice Skrove, Bennie J. Johnson, Anna Martha Johnson, Oscar T. Lien, H. A. Ryen, Ingeborg Ryen, O. J. Frigaard, Edw. M. Minge, Amanda Josephine Minge, Andrew Bahle, Anna Bahle, Berit Grue aka Beret Grue, Simon Christofferson, Hilma Josephine Knutson, Dan C. Formo, J. P. Rasmussen aka Peter J. Rasmussen, Janet Rasmussen, Lois Rasmussen, Victor Spitsberg, Orpha Spitsberg, LeRoy Brown, Eleanore Brown, Franklin Hittle, Rita Hittle, Willard Ness, Phyllis Ness, Darrel W. Ness, Susan Ness, Dean A. Ness, Barbara A. Ness, Gary L. Ness, Linda R. Ness, Barbara J. Olson, Donald P. Olson, Randy Hustad aka Randy Earl Hustad, Mary Hustad, Ronnie Spangler, Teresa Spangler, Erick A. Earl, Peter C. Johnson, Hans L. Eggum, Carrie Eggum, Henry Bardalen, Ida Frigaard, Gerda J. Bardalen, Peder Pederson, Dorothy Sonmor, William Ringstad, Sidney W. Nelson, Betty J. Nelson, Cyrus Synstelien, Gilbert A. Olson, Mary Olson, Ernest V. Johnson, Cecile M. Johnson, Gene L. Hanson, Kathryn Hanson aka Kathryn W. Hanson, Oscar A. Rude, Magna A. Rude, Michael L. Moss, Matthew L. Moss, Ashley Earl, The First National Bank of Battle Lake, Merchants Bank, National Association, Otter Tail County Housing and Redevelopment Authority, Lila Pederson, Ronald W. Brown, Jeanette E. Brown, Morris S. Ness, H. N. Johnson, Ella Johnson, Robert S. Adams, Helen T. Adams, Robert Rude, Verna Rude, Marwood E. Rude, Marion E. Rude, David R. Schroeder, Mary Jo Schroeder, Kim B. Hammer, Teresa R. Nordick,  Dale H. Christopherson, Cynthia M. Christopherson, Carl Samuelson, Joyce Samuelson, Neal Johnson, Trustee of the Johnson Family Living Trust, dated February 21, 1992, Verna Dahlen, Diane R. Bares, Galen Bares, Park Meadows Place, LLC, Jerry L. Ewert, Bruce Allen Finkelson, Barbara Lynn Finkelson, Katherine Anne Peter, Jason Lee Funkhouser, Callie Funkhouser, Jill Merie Swendsrud, Peter Swendsrud, United States of America, and the unknown heirs of the above-named persons now deceased and any and all other persons unknown claiming any right, title, or interest in the premises described herein, Defendants.
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SUMMONS
THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANTS, and the unknown heirs of any of the above named persons now deceased, also all other persons unknown claiming any right, title, estate, interest or lien in the real estate described in the Complaint herein.
1. YOU ARE BEING SUED: The Plaintiff has started a lawsuit against you.  The Plaintiff’s Complaint against you is attached to this Summons and is on file in 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 REPLY WITHIN 60 DAYS IF YOU ARE THE UNITED STATES OF AMERICA.  You must give or mail to the person who signed this summons a written response called an Answer within 20 days – or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) – 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:
Paul S. Jensen
Attorney at Law
125 S. Mill Street
Fergus Falls, MN 56537
3. YOU MUST RESPOND TO EACH CLAIM.  The Answer is your written response to the Plaintiff’s 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 – or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) – you will lose your 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 Otter Tail County, State of Minnesota, legally described as follows:
Being a certain tract or parcel of land lying and being in the Northwest Quarter of Southwest Quarter (NW 1/4 of SW 1/4) of Section Twelve (12), Township One Hundred Thirty-one (131) North, Range Forty-two (42) West, Otter Tail County, Minnesota, and is more particularly described as follows:
Commencing at the West Quarter Corner of Section 12; thence coincident with the west section line of Section 12, South 00 degrees 00 minutes 45 seconds West (assumed bearing) a distance of 991.61 feet; thence leaving said section line South 89 degrees 52 minutes 54 seconds East a distance of 33.00 feet to 5/8 inch rebar set with Cap 23968 on the east right-of-way of South Central Avenue, this being the point of beginning of the parcel herein described; thence leaving said right-of way South 89 degrees 52 minutes 54 seconds East a distance of 231.00 feet to a 5/8 inch rebar set with Cap 23968; thence North 00 degrees 00 minutes 45 seconds East a distance of 240.00 feet to a capped iron pipe; thence North 89 degrees 52 minutes 26 seconds West a distance of 33.00 feet to a capped iron pipe; thence North 00 degrees 00 minutes 02 seconds West a distance of 50.00 feet to a capped iron pipe; thence South 89 degrees 52 minutes 19 seconds East a distance of 16.00 feet to a capped iron pipe; thence North 00 degrees 00 minutes 42 seconds East a distance of 278.84 feet to a 5/8 inch rebar set with Cap 23968, this being the most Northwesterly corner of the parcel herein described; thence South 89 degrees 03 minutes 23 seconds East a distance of 727.65 feet to a 5/8 inch rebar set with Cap 23968, this being the Northeast corner of the parcel herein described; thence South 00 degrees 00 minutes 45 seconds West a distance of 903.59 feet to a 5/8 inch rebar set with Cap 23968, this being the Southeast corner of the parcel herein described; thence North 89 degrees 10 minutes 45 seconds West a distance of 794.68 feet to a 5/8 inch rebar set with Cap 23968 on the former Easterly railroad right-of-way line of the Burlington Northern Railroad, this being the Southwest corner of the parcel herein described; thence coincident with said former right-of-way line North 34 degrees 56 minutes 39 seconds West a distance of 256.43 feet to a 5/8 inch rebar set with Cap 23968 on the east right-of-way of South Central Avenue; thence leaving said former right-of-way line and coincident with said road right-of-way line North 00 degrees 00 minutes 45 seconds East a distance of 125.58 feet to the point of beginning.
INCLUDING AND SUBJECT TO right-of-way easements to City of Dalton, Minnesota, including said right-of-way described as follows:
Being an easement for roadway purposes over and across a certain tract or parcel of land lying and being in the Northwest Quarter of the Southwest Quarter of Section 12, Township 131 North, Range 42 West, Otter Tail County, Minnesota, and is more particularly described as follows:   Commencing at the west Quarter Corner of Section 12; thence coincident with the east-west Quarter Line of Section 12 South 89 degrees 03 minutes 23 seconds East (assumed bearing) a distance of 737.08 feet; thence leaving said Quarter Line South 00 degrees 00 minutes 42 seconds West a distance of 33.00 feet to the south right-of-way of East Main Street and the point of beginning; thence South 89 degrees 03 minutes 23 seconds East a distance of 15.00 feet; thence South 00 degrees 00 minutes 42 seconds West a distance of 386.21 feet; thence North 89 degrees 03 minutes 23 seconds West a distance of 505.06 feet; thence North 00 degrees 00 minutes 42 seconds East a distance of 57.89 feet; thence South 89 degrees 03 minutes 23 seconds East a distance of 130.04 feet; thence North 00 degrees 00 minutes 42 seconds East a distance of 8.28 feet; thence South 89 degrees 03 minutes 23 seconds East a distance of 335.03 feet; thence North 00 degrees 00 minutes 42 seconds East a distance of 170.02 feet; thence South 89 degrees 03 minutes 23 seconds East a distance of 25.00 feet; thence North 00 degrees 0 minutes 42 seconds East a distance of 150.02 feet to the point of beginning containing 41384.95 square feet or 0.95 acres, more or less.
AND SUBJECT TO Otter Tail County Highway 35.
The object of this action is to determine the title and adverse claims to the real property described above and to have Plaintiff adjudged the owner thereof in fee simple.
CLINE JENSEN P.A.
Dated:  April 11, 2018 By /s/ Paul S. Jensen
Paul S. Jensen, #337420
125 South Mill Street
Fergus Falls, MN  56537
Telephone No. 218-998-4088
Attorneys for Plaintiff.
(April 25, May 2 and 9, 2018)