Michael E-Patricia Kotten Summons

STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF OTTER TAIL SEVENTH JUDICIAL DISTRICT ——————————————- 14. OTHER CIVIL, REAL PORPERTY Court File # 56-CV-24-2186 Michael E. Kotten and Patricia A. Kotten, As Trustees of the Michael E. Kotten Trust Agreement dated September 15, 2004; Plaintiffs, vs. Wendy J. Schultz; Wendy J. Schultz as Trustee of the Wendy J. Schultz Revocable Living Trust dated November 28, 2018; Debra A. Danielson; Nancy J. Danielson; Carol J. Nelson; Edgar J. Shaw; Myrna H. Shaw; Ross Pederson; Ann Marie Littlefield; Roger C. Pederson; Reid M. Pederson; Christopher A. Pederson; Betty L Pederson; Dawn M. Howitz; Dennis M. Howitz; James G. Tomczik; Susan M. Tomczik; William Schulte; Linda Schulte; Otter Tail Power Company; Fred J. Kotten; Connie M. Kotten; Michael D. Berry; Grace L. Berry; the unknown heirs of Sam C. Lykken aka S. C. Lykken, deceased; the unknown heirs of Lorraine V. Lykken, deceased; Sam C. Lykken and Lorraine V. Lykken as Trustees under the Lykken Living Trust, dated February 29, 1992; Harry L. Anderson; Bella M. Anderson; Paul J. Seidel; the unknown heirs of Irene M. Seidel, deceased; Barbara E. Lein; Edward L. Johnson; Erthel K. Johnson; also the unknown heirs, successors or assigns of any of the above defendants, and all other persons unknown claiming any right, title, estate, interest or lien in the real estate described in the complaint herein. Defendants. ———————————————————————————————— SUMMONS ———————————————————————————————— THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANTS: You are hereby summoned and required to serve upon Plaintiff’s attorney an Answer to the Complaint which is on file in the office of the Court Administrator of the above-named Court, within twenty (20) days after service of this Summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the Complaint. THIS ACTION involves, affects or brings into question real property situated in the County of Otter Tail, State of Minnesota described as follows: All that part of Government Lot 4, Section 31, Township 133, Range 39, Otter Tail County, Minnesota, described as follows: Commencing at the south quarter of said Section 31; thence North 89 degrees 39 minutes 43 seconds West (bearing based on Otter Tail County Coordinates – 2011 adjustment) along the south line of said Section 31, a distance of 733.57 feet to the centerline of Statesboro Drive as described in Document No. 1213567, as filed in the office of the County Recorder; thence North 82 degrees 25 minutes 04 seconds West a distance of 37.44 feet; thence North 80 degrees 49 minutes 20 seconds West a distance of 266.09 feet; thence North 48 degrees 35 minutes 01 seconds West a distance of 50.95 feet to the point of beginning of the land to be described; thence North 27 degrees 07 minutes 08 seconds East a distance of 103.08 feet; thence North 48 degrees 28 minutes 20 seconds West a distance of 240 feet more or less to the shoreline of West Battle Lake; thence southwesterly along said shoreline to the intersection with a line which bears North 48 degrees 35 minutes 01 seconds West from the point of beginning; thence South 48 degrees 35 minutes 01 seconds East a distance of 255 feet more or less to the point of beginning. Containing 24,834 square feet more or less. AND All that part of Government Lot 4, Section 31, Township 133, Range 39, and that part of Government Lots 1 and 2, Section 1, Township 132, Range 40, Otter Tail County, Minnesota, all described as follows: Commencing at the south quarter of said Section 31; thence North 89 degrees 39 minutes 43 seconds West (bearing based on Otter Tail County Coordinates – 2011 adjustment) along the south line of said Section 31, a distance of 733.57 feet to the centerline of Statesboro Drive as described in Document No. 1213567, as filed in the office of the County Recorder; thence North 82 degrees 25 minutes 04 seconds West a distance of 37.44 feet to the point of beginning of the land to be described; thence North 80 degrees 49 minutes 20 seconds West a distance of 266.09 feet; thence North 48 degrees 35 minutes 01 seconds West a distance of 84.23 feet; thence South 37 degrees 47 minutes 26 seconds West a distance of 200.17 feet; thence South 45 degrees 13 minutes 06 seconds West a distance of 99.99 feet; thence South 41 degrees 14 minutes 53 seconds West a distance of 100.22 feet; thence South 23 degrees 10 minutes 09 seconds West a distance of 105.10 feet; thence South 51 degrees 30 minutes 17 seconds East a distance of 267.23 feet to the northerly line of the dedicated public road as dedicated in the plat of LURING ACRES, according to the recorded plat thereof; thence North 50 degrees 40 minutes 31 seconds East along said northerly line of the dedicated public road, a distance of 33.99 feet; thence North 52 degrees 00 minutes 51 seconds East along said northerly line of the dedicated public road, a distance of 396.70 feet; thence North 21 degrees 15 minutes 21 seconds East along said northerly line of the dedicated public road, a distance of 212.86 feet to said north line of Section 31; thence North 19 degrees 05 minutes 23 seconds East a distance of 4.99 feet to the point of beginning. Containing 186,355 square feet more or less. AND TOGETHER with and subject to a non-exclusive ingress and egress easement described as follows: All that part of Government Lot 4, Section 31, Township 133, Range 39, and that part of Government Lots 1 and 2, Section 1, Township 132, Range 40, Otter Tail County, Minnesota, all described as follows: Commencing at the south quarter of said Section 31; thence North 89 degrees 39 minutes 43 seconds West (bearing based on Otter Tail County Coordinates – 2011 adjustment) along the south line of said Section 31, a distance of 733.57 feet to the centerline of Statesboro Drive as described in Document No. 1213567, as filed in the office of the County Recorder; thence North 82 degrees 25 minutes 04 seconds West a distance of 37.44 feet; thence North 80 degrees 49 minutes 20 seconds West a distance of 266.09 feet; thence North 48 degrees 35 minutes 01 seconds West a distance of 18.00 feet to the point of beginning of the land to described; thence continuing North 48 degrees 35 minutes 01 seconds West a distance of 66.23 feet; thence South 37 degrees 47 minutes 26 seconds West a distance of 200.17 feet; thence South 45 degrees 13 minutes 06 seconds West a distance of 99.99 feet; thence South 41 degrees 14 minutes 53 seconds West a distance of 100.22 feet; thence South 23 degrees 10 minutes 09 seconds West a distance of 105.10 feet; thence South 51 degrees 30 minutes 17 seconds East a distance of 267.23 feet to the northerly line of the dedicated public road as dedicated in the plat of LURING ACRES, according to the recorded plat thereof; thence North 50 degrees 40 minutes 31 seconds East along said northerly line of the dedicated public road, a distance of 33.99 feet; thence North 52 degrees 00 minutes 51 seconds East along said northerly line of the dedicated public road, a distance of 33.73 feet; thence North 51 degrees 32 minutes 35 seconds West a distance of 231.67 feet; thence North 22 degrees 32 minutes 24 seconds East a distance of 44.82 feet; thence North 41 degrees 31 minutes 48 seconds East a distance of 87.11 feet; thence North 45 degrees 13 minutes 07 seconds East a distance of 102.27 feet; thence North 37 degrees 47 minutes 26 seconds East a distance of 200.06 feet to the point of beginning. YOU ARE FURTHER NOTIFIED that the object of this action is to obtain a judgment that Plaintiff and some of the defendants are the owners in fee simple of the above-described real property subject to and together with the above described easement; and other than described and allocated above, the Defendants, and each of them, be declared to have no right, title, estate, right to possession, lien or interest in the real estate described above. The Defendants will take notice that no personal claim is made by the Plaintiff against any of the Defendants. Civil cases are subject to Alternative Dispute Resolution processes as provided in Rule 114 of the General Rules of Practice for the District Courts. Alternative Dispute Resolution includes mediation, arbitration, and other processes set forth in the rules. You may contact the Court Administrator for information about these processes and about resources available in your area. Dated: 9-25-24 /S/ Penn C. Brandborg Penn C. Brandborg, Attorney for Plaintiff 315 S. Mill Street Fergus Falls, MN 56537 218-736-7447, Att. Reg. No. 166546 penn@brandborglaw.com (Published December 4, 11 and 18, 2024) ———————————————————————————————-