STATE OF MINNESOTA
COUNTY OF GOODHUE
FIRST JUDICIAL DISTRICT
Court File Number: 25-CV-13-1081
Case Type: Quiet Title
Richard M. J. Reinsch
Mark Windhorst, Gwen Bosshart,
Scott Windhorst, the unknown heirs of James D. Windhorst, deceased,and Mary Windhorst, deceased, and all other persons unknown claiming any right, title, interest or estate in the real estate described in the Complaint herein,
THIS SUMMONS IS DIRECTED TO: Mark Windhorst, Gwen Bosshart,
Scott Windhorst, the unknown heirs of James D. Windhorst, deceased,and Mary Windhorst, deceased, and all other persons unknown claiming any right, title, interest or estate in the real estate described in the Complaint herein.
1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. A copy of the complaint 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 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:
1765 Greenview Dr. SW
Rochester, MN 55902.
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, 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:
The South Half (S ½) of the Northeast Quarter (NE ¼) of Section 31, Township 111 North, Range 16 West, Goodhue County, Minnesota, EXCEPT that part thereof described as follows:
Beginning at the Northwest corner of said South Half (S ½) of the Northeast Quarter (NE ¼); thence South 00 degrees 32 minutes 12 seconds West (assumed bearing) along the West line thereof to the Southwest corner of said South Half (S ½) of the Northeast Quarter (NE ¼); thence North 79 degrees 52 minutes 40 seconds East a distance of 133 feet; thence North 45 degrees 06 minutes 30 seconds East a distance of 103.1 feet; thence North 71 degrees 40 minutes 15 seconds East a distance of 710.5 feet; thence North 1 degrees 55 minutes 20 seconds West a distance of 280 feet; thence South 86 degrees 18 minutes 30 seconds East a distance of 400.8 feet; thence North 45 degrees 17 minutes 10 seconds East a distance of 981 feet, more or less, to its intersection with the North line of said South Half (S ½) of the Northeast Quarter (NE ¼); thence Westerly along said North line to the point of beginning.
The object of this action is to obtain a judgment, adjudging that plaintiff is the owner of the above described real property in fee simple absolute and that the defendants, and each of them, have no right, title, interest, lien or estate in said real property.
Dated: April 8, 2013
/s/ Frank J. McAnulty
Attorney License No. 0181213
1765 Greenview Dr. SW
Rochester, MN 55902
Tel (507) 529-2211
Email addr: email@example.com
Attorney for the Plaintiff
(May 22, 29, June 5)