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Summons: Reed vs. Young

Tuesday, January 9, 2018 - 11:22pm

STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF GOODHUE
FIRST JUDICIAL DISTRICT
CASE TYPE: 14 OTHER CIVIL - QTA
File No.: 25-CV-17-3346
Jeffrey J. Reed and Becky L. Reed,
husband and wife,
Plaintiffs,
vs. SUMMONS
Vernon L. Young a/k/a Vernon Leroy Young, and his heirs: Sandra Mateffy, a single person; Dorothy A. Benson a/k/a Dorothy Aurelia Benson, and her heir: Dennis A. Benson and his wife Judy M. Benson; also the unknown heirs of Vernon L. Young and Dorothy A. Benson, who are all deceased; and also all other persons unknown claiming any right, title, estate, interest, or lien in the real estate described herein,
Defendants.
THIS SUMMONS IS DIRECTED TO: Vernon L. Young a/k/a Vernon Leroy Young, and his heirs: Sandra Mateffy; Dorothy A. Benson a/k/a Dorothy Aurelia Benson, and her heir: Dennis A. Benson and his wife Judy M. Benson; also the unknown heirs of Vernon L. Young and Dorothy A. Benson, who are all deceased; and also all other persons unknown claiming any right, title, estate, interest, or lien in the real estate described herein.
1. YOU ARE BEING SUED. The Plaintiffs have started a lawsuit against you. The Plaintiffs' Complaint against you is attached to this Summons. 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 TWENTY (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 twenty (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:
Richard D. Gorman
VOGEL & GORMAN, PLC
P.O. Box 39 - Masonic Building
454 West Fourth Street
Red Wing, MN 55066
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 twenty (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 Goodhue County, State of Minnesota, legally described as follows:
SEE ATTACHED EXHIBIT "A"
The object of this action is to quiet the title on the land described on Exhibit "A" against Defendants, and each of them, and their heirs, representatives and successors in interest.
Dated: December 15, 2017
VOGEL & GORMAN, PLC
Richard D. Gorman (No. 0202204)
P.O. Box 39 - Masonic Building
454 West Fourth Street
Red Wing, MN 55066
Telephone: (651) 388-2833
Facsimile: (651) 388-2836
Email: rgorman@vogelgormanplc.com
ACKNOWLEDGMENT
Pursuant to Minnesota Statutes § 549.211, Subd. 1, the undersigned hereby acknowledges that sanctions may be imposed against the attorneys, law firms or parties responsible for violation of Minnesota Statutes § 549.211, Subd. 2.
Dated: December 15, 2017
VOGEL & GORMAN, PLC
Richard D. Gorman
Attorney Reg. No. 0202204
P.O. Box 39 - Masonic Building
454 West Fourth Street
Red Wing, MN 55066
Telephone: (651) 388-2833
Facsimile: (651) 388-2836
Email: rgorman@vogelgormanplc.com
EXHIBT "A"
Parcel 1 -
The SW 1/4 of the NW l/4 of the NW 1/4; the NW 1/4 of the SW 1/4 of the NW 1/4; the SE 1/4 of the NW 1/4 of the NW 1/4; the SW 1/4 of the SW 1/4 of the NW 1/4; Also, the north 9 acres of the NE 1/4 of the SW 1/4 of the NW 1/4; Also the southwesterly 1/2 of the NE 1/4 of the NW 1/4 of the NW 1/4; All in Section 20, Township 111 north, Range 17 west.
Parcel 2 -
The E 1/2 of the NE 1/4 of Section 19, Township 111north, Range 17 west, except the north 1/3 of the SW 1/4 of the SE 1/4 of the NE 1/4 of said Section 19. Also except, the SW 1/4 of the SE 1/4 of the SE 1/4 of the NE 1/4 of Section 19 and the SE 1/4 of the SW 1/4 of the SE l/4 of the NE 1/4 of Section 19. Also except, that part of the NE 1/4 of the NE 1/4 of Section 19, Township 111 north, Range 17 west, lying north of the following described line: Commencing at the northeast corner of said NE 1/4 of the NE 1/4 of Section 19; thence on an assumed bearing of south, along the cast line of said NE 1/4 of the NE 1/4 of Section 19 a distance of 840.20 feet to an iron pipe at the beginning of the line to be described; thence south 89 degrees 49 minutes 40 seconds west a distance of 535.55 feet to an iron pipe; thence north 88 degrees 31 minutes 05 seconds west a distance of 784 feet, more or less to the west line of said NE 1/4 of the NE 1/4 of Section 19; and there terminating. Also except, that part of the Northeast Quarter of the Northeast Quarter of Section 19, Township 111, Range 17, Goodhue County, Minnesota, described as follows: Commencing at the northeast corner of said Northeast Quarter of the Northeast Quarter; thence South 0 degrees 06 minutes 14 seconds East (assumed bearing) along the East line thereof 825.66 feet to the easterly extension of the south line of the property described in Book I-13 of deeds, page 106, as established by the found iron pipes as cited therein; thence South 88 degrees 33 minutes 20 seconds West along said easterly extension and south line 421.94 feet to the point of beginning of the land to be described; thence continuing South 88 degrees 33 minutes 20 seconds West along said south line 150.00 feet to a found iron pipe as described in Book I-13 of deeds, page 106; thence North 89 degrees 47 minutes 25 seconds West along said south line 716.43 feet to the west line of said Northeast Quarter of the Northeast Quarter; thence South 0 degrees 02 minutes 47 seconds East along said west line 100.00 feet; thence South 89 degrees 47 minutes 25 seconds East 717.43 feet; thence North 88 degrees 33 minutes 20 seconds East 151.44 feet to the intersection with a line that bears South 1 degree 26 minutes 40 seconds East from the point of beginning; thence North 1 degree 26 minutes 40 seconds West 100.00 feet to the point of beginning.
Also Except that part of the South West Quarter (SW 1/4) of the South East Quarter (SE 1/4) of the North East Quarter (NE 1/4) of Section Nineteen (19) in Township One Hundred Eleven (111) North, Range Seventeen (17) West of the Fifth Principal Meridian, describcd as follows: Beginning at a point 26 2/3 rods North of the South West corner of said ten acre tract, and on the West line thereof; running thence North 13 1/3 rods to the North West corner thereof; thence East and parallel with the South line a distance of forty (40) rods, thence South 13 1/3 rods, thence West forty (40) rods to the point of beginning.
Parcel 3 -
The NW 1/4 of the NW 1/4 of the NW 1/4 of Section 20, Township 111 north, Range 17 west, EXCEPT THE FOLOWING:
That part of the Northwest Quarter of the Northwest Quarter of the Northwest Quarter of Section 20, Township 111, Range 17, Goodhue County, Minnesota, lying north of the following described line:
Beginning at an iron pipe on the west line of said Section 20 distant 165.00 feet South of the Northwest corner thereof; thence east, perpendicular to the west line of said Section 20 a distance of 660 feet more or less to the east line of said Northwest Quarter of the Northwest Quarter of the Northwest Quarter of said Section 20 and there terminating.
Parcel 4 -
The W 1/4 of the NW 1/4 of the SW 1/4 of Section 20, Township 111 north, Range 17 west.
AND
The east 15 acres of the NW 1/4 of the SW 1/4 of Section 20, Township 111north, Range 7 west.
Abstract Property. Goodhue County, Minnesota.
12/27/2017-01/10/2018


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