STATE OF MINNESOTA
COUNTY OF GOODHUE
FIRST JUDICIAL DISTRICT
Norm D. Doty and Tamara R. Doty,
CASE NO.: 25-CV-13-1428
v. CASE TYPE: Other Civil
Curtis Perkins Featherstone, aka Curtis P. Featherstone, Ruth I. Green, Kay Lee Davis, Dorothy Ann Molera, Margaret Brady, Herbert Green Jr., Marshall Green, Constance Phillips, Robert Green, Tom Brady, Dan Brady, Kevin Brady, and Brian Brady, also the unknown heirs of any of the aforementioned Defendants who are deceased, and all other persons unknown claiming any right, title, estate, interest or lien in the real estate described in the Complaint herein,
THIS SUMMONS IS DIRECTED TO THE ABOVE NAMED DEFENDANTS.
1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiffs 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 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: Speight & Lappegaard, P.A., 411 West Third Street, Red Wing, MN 55066.
3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiffs 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, Minnesota, legally described as follows:
That part of vacated Lots 24 and 25, Block 6 of WACOUTA BEACH, Goodhue County, Minnesota, that part of the vacated street lying between said Lots 24 and 25 and Lot B of said Block 6, that part of vacated Pleasant Avenue as designated in said plat of WACOUTA BEACH, and that part of Government Lot 1 of Section 32, Township 113 North, Range 13 West, Goodhue County, Minnesota, described as follows:
Commencing at the southwesterly corner of Lot 19, Block 6 of said plat of WACOUTA BEACH; thence North 17 degrees 55 minutes 29 seconds West, oriented with the Goodhue County Coordinate System, NAD 1983, 1996 Adjustment (HARN), along the westerly line of Lots 19, 18, 17 and 16, of said Block 6, a distance of 206.02 feet; thence South 72 degrees 04 minutes 31 seconds West, a distance of 30.00 feet to the northeasterly corner of said vacated Lot 24, being the point of beginning of the land to be described; thence South 72 degrees 04 minutes 31 seconds West, along the northerly line of said vacated Lot 24, and its southwesterly extension, a distance of 160.13 feet to the centerline of said vacated street lying between vacated Lot 24 and Lot B; thence South 17 degrees 55 minutes 33 seconds East, along said centerline, a distance of 135.93 feet to the northerly line of said vacated Pleasant Avenue; thence South 05 degrees 12 minutes 56 seconds West, a distance of 25.00 feet to the centerline of said vacated Pleasant Avenue; thence easterly, a distance of 138.40 feet, along said centerline of vacated Pleasant Avenue, being a curve, not tangent with the last described line, said curve is concave to the north, has a radius of 2025.00 feet, a central angle of 03 degrees 54 minutes 57 seconds and a chord bearing of South 86 degrees 44 minutes 32 seconds East, and a chord distance of 138.37 feet to the southeasterly right of way line of Greens Point Road, as now located and established; thence northeasterly a distance of 32.89 feet, along said southeasterly right of way line of Greens Point Road, being a non-tangential curve, having a radius of 93.00 feet, a central angle of 20 degrees 15 minutes 49 seconds, a chord bearing of North 41 degrees 10 minutes 35 seconds East, and chord distance of 32.72 feet to the northerly line of said vacated Pleasant Avenue, being the southerly line of said vacated Lot 25; thence easterly a distance of 13.55 feet, along said southerly line of vacated Lot 25, being a non-tangential curve, concave to the north, having a radius of 2000.00 feet, a central angle of 0 degrees 23 minutes 17 seconds, a chord bearing of South 89 degrees 29 minutes 43 seconds East, a chord distance of 13.55 feet to the southeasterly corner of said vacated Lot 25; thence North 17 degrees 55 minutes 29 seconds West, along the easterly line of said vacated Lots 25 and 24, a distance of 196.39 feet to the point of beginning.
Dated this 19th day of June, 2013.
ACKNOWLEDGEMENT: 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 violations of Minnesota Statutes § 549.211, Subd. 2.SPEIGHT & LAPPEGAARD, P.A.By: /s/ Jennifer L. Lappegaard
Jennifer L. Lappegaard (#286795)
Attorneys for Plaintiffs
411 West Third Street
Red Wing, MN 55066