Court File No:
Case Type: Quiet Title
AMENDED SUMMONS
STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF BELTRAMI NINETH JUDICIAL DISTRICT
Michael W. Carpenter and Castle Highlands Golf Course, LLC,
Plaintiffs,
v.
Danielle M. Lesh f/k/a Danielle Carpenter, John Doe, Mary Roe, XYZ Corporation, and all other persons unknown claiming any right, title, estate, interest, or lien in the real estate described in the Complaint herein,
Defendants.
THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANTS.
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 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 receive this Summons. You must send a copy of your Answer to the person who signed this Summons located at:
Christensen Sampsel, PLLC
305 North Fifth Avenue, Suite 375
Minneapolis, Minnesota 55401
3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to Plaintiffs” Complaint. In your Answer you must state whether you agree or disagree with each paragraph of the Complaint. If you believe the Plaintiffs 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 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 Plaintiffs 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 Scott County, State of Minnesota, legally described as follows:
Beltrami County, Minnesota:
The NW¼ of NW¼, Section 28, Township 148, Range 32, Less the West 751 feet of the North 580 feet thereof;
And
The SW¼ of NW¼, Section 28, Township 148, Range 32, Less that part lying northeasterly of the Turtle River;
And
The East 660 feet of that part of the SW¼ of NW¼, Section 28, Township 148, Range 32, lying northeasterly of the Turtle River;
And
That part of the N½ of SW¼, Section 28, Township 148, Range 32, lying northwesterly of Railway, and less that part South and East of Turtle River;
And
The NE¼ of NW¼, Section 28, Township 148, Range 32;
And
That part of the SE¼ of NW¼, Section 28, Township 148, Range 32, described as follows: Commencing at the southwest corner of the SE¼ of NW¼, thence north along the west boundary line a distance of 510.6 feet to an iron pipe which is the point of beginning of the tract to be conveyed; thence east at an angle of 90° a distance of 875 .2 feet to an iron pipe; thence south at an angle of 90° a distance of 205 feet to an iron pipe; thence east at an angle of 90° to the east boundary line of said SE¼ of NW¼; thence north along the east boundary line of said SE¼ of NW¼ to the northeast corner; thence west along the north boundary line of the said SE¼ of NW¼ to the northwest corner; thence south along the west boundary line to the point of beginning and there terminating;
And
That part of the SE¼ of NW¼, Section 28, Township 148, Range 32, described as follows: Beginning at the southwest corner of said SE¼ of NW¼; thence north along the west line a distance of 510.6 feet to an iron pipe which point is the point of beginning of the tract to be conveyed; thence south along the west line of said SE¼ of NW¼ a distance of 115.31 feet more or less to its point of intersection with the north bank of the Turtle River to a point designated as point A; thence return to the point of beginning; thence east at an angle of 90° a distance of 150 feet to a point designated as point B; thence south at an angle of 90° a distance of 107. 7 feet more or less to the north bank of the Turtle River which point is designated as point C; thence along the north bank of the Turtle River to Point A and there terminating. Less that part of the two following described tracts: 1. That part of the NW¼ of SW¼, Section 28, Township 148, Range 32, lying northwesterly of the railway and west of Turtle River; 2. That part of the SE¼ of NW¼, Section 28, Township 148, Range 32, lying northwesterly of the railway and described as follows: Commencing at the southwest corner of the SE¼ of NW¼ of said Section 28, thence north along the west boundary line a distance of 510.6 feet to an iron pipe, which is the point of beginning of the tract to be conveyed; thence east at an angle of 90° a distance of 875.2 feet to an iron pipe; thence south at an angle of 90° a distance of 205 feet to an iron pipe; thence east at an angle of 90° to the east boundary line of said SE¼ of NW¼, thence north along the east boundary line of said SE¼ of NW¼ to the northeast corner; thence west along the north boundary line of said SE¼ of NW¼ to the northwest corner; thence south along the west boundary line to the point of beginning; which lies southeasterly of a line run parallel with and distance 100 feet northwesterly of the following described line: Beginning at a point, on the north line of said section 28 distant 832.4 feet west of the northeast corner thereof; thence run southwesterly at an angle of 57°35’20” from said north section line for 523.4 feet, thence deflect to the right on a 00°30’00” curve (delta angle 13°31 ‘21 “) for 2704.5 feet; thence on tangent to said curve for 503.1 feet; thence deflect to the right on a 00°30’00” curve (delta angle 12°53’20”) for 2577.8 feet and there terminating; together with all that part of the first above described tract adjoining and northwesterly of the above described strip, which lies southeasterly of a line run parallel with and distant 140 feet northwesterly of the following described line: Beginning at a point on the above described line distant 1402.9 feet northeasterly of its point of termination; thence run northeasterly on said line for 200 feet and there terminating; in addition to the existing highway.
And
That part of the SW¼ of SW¼, Section 28, Township 148, Range 32, lying Northwesterly of State Trunk Highway No. 71 as relocated in 1973.
And
All that portion of the SW¼ of NW¼, Section 28, Township 148, Range 32, lying North and East of Turtle River, less the East 660 feet thereof. The object of this action is to remove a cloud on title, specifically, quiet title and declaratory judgment to determine ownership or lien interests in property. CHRISTENSEN SAMPSEL PLLC
Dated: September 20, 2024 /s/ Robert J. Kouba
Robert J. Kouba (MN #398428)
Carl E. Christensen (MN #350412)
Robert J. Kouba (MN #398428)
305 North Fifth Avenue, Suite 375
Minneapolis, Minnesota 55401
(612) 473-1200
carl@christensensampsel.com robert@christensensampsel.com
Attorney for Plaintiffs
IDX-
October 7, 14, 21, 28, November 4, 11, 2024
