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STATE OF MINNESOTA IN DISTRICT COURT EIGHTH JUDICIAL DISTRICT COUNTY OF GRANT CIVIL DIVISION Quiet Title Court File No.: 26-CV-24-151 _________________________________________________________ Louise Bamba and Idrissa Bamba, Plaintiffs, vs. Theodore M. Reynen; Lila E. Reynen; Indian Mounds Resort and Campground, Ashby LLC; Scott A. Johnson aka Scott Johnson; Jerry L. Kaercher; Timona L. Kaercher aka Timona Kaercher; Mary Ellen Johnson, Trustee of the Mary E. Johnson Revocable Trust dated November 22, 2022; Amy L. Chase-Boylan; Jennifer M. Huebner; Andrew R. Chase; Jeanne L. Hodge; 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. AMENDED SUMMONS 1. YOU ARE BEING SUED. The Plaintiffs have started a lawsuit against you. The Plaintiff’s Complaint against you 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 Amended Summons. 2. YOU MUST REPLY WITHIN 21 DAYS TO PROTECT YOUR RIGHTS. You must give or mail to the person who signed this summons a written response called an Answer within 21 days of the date on which you received this Amended Summons. You must send a copy of your Answer to the person who signed this Amended Summons located at: Allen Haugrud 121 East Lincoln Avenue Fergus Falls, MN 56537 Attorney for Plaintiffs 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 AMENDED SUMMONS. If you do not answer within 21 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 Grant County, Minnesota, legally described as follows: That part of Lot A, SUBDIVISION OF LOT 5 IN GOVERNMENT LOT 4 OF SECTION 24, TOWNSHIP 130, RANGE 41, according to the recorded plat thereof described as follows: Commencing at the northeast corner of said Lot A; thence on an assumed bearing of North 88 degrees 23 minutes 55 seconds West along the north line of said Lot A 533.00 feet; thence South 01 degrees 36 minutes 05 seconds West 66.00 feet to the point of beginning of the land to be described; thence continuing South 01 degrees 36 minutes 05 seconds West 90.00 feet; thence North 88 degrees 23 minutes 55 seconds West 271 feet, along a northerly line of Document No. 158989 of record with the Grant County Recorder, more or less to the shoreline of Pelican Lake; thence northerly along said shoreline to the intersection of a line bearing North 88 degrees 23 minutes 55 seconds West from point the of beginning; thence South 88 degrees 23 minutes 55 seconds East 246 feet more or less to the point of beginning. Together with a 20.00 foot wide easement for ingress and egress purposes over, under and across that part of Lot A, SUBDIVISION OF LOT 5 IN GOVERNMENT LOT 4, AND OF GOVERNMENT LOT 5, OF SECTION 24, TOWNSHIP 130, RANGE 41, according to the recorded plat thereof. The centerline of said easement is described as follows: Commencing at the northeast corner of said Lot A; thence on an assumed bearing of North 88 degrees 23 minutes 55 seconds West along the north Line of said Lot A 533.00 feet; thence South 01 degrees 36 minutes 05 seconds West 137.23 feet to the point of beginning of the centerline to be described; thence South 82 degrees 45 minutes 16 seconds East 117.46 feet; thence South 73 degrees 54 minutes 24 seconds East 89.41 feet; thence easterly along a tangential curve, concave to the north, radius 130.91 feet, central angle 35 degrees 07 minutes 59 seconds 80.28 feet; thence North 70 degrees 57 minutes 37 seconds East along tangent 121.69 feet; thence northeasterly along a tangential curve, concave to the northwest, radius 241.86 feet, central angle 32 degrees 48 minutes 42 seconds 138.51 feet; thence North 38 degrees 08 minutes 54 seconds East along tangent 46.53 feet to the east line of said Lot A and said centerline there terminating. The sidelines of said easement are to be prolonged or shortened to terminate on a line bearing South 01 degrees 36 minutes 05 seconds West and North 01 degrees 36 minutes 05 seconds East from the point of beginning and on the north and east lines of said Lot A, respectively. Dated: June 20, 2024 By /s/ Allen Haugrud Allen Haugrud, #42420 121 East Lincoln Avenue Fergus Falls, MN 56537 Telephone No. 218-998-4299 Attorney for Plaintiffs (Published July 17, 24 and 31, 2024)


