STATE OF MINNESOTA
COUNTY OF POPE

IN DISTRICT COURT

EIGHTH JUDICIAL DISTRICT

Court File No. 61-CV-24-91

Quiet Title Action

___________________

Gail Wilson,

Plaintiff,

-vs-

Estate of Thomas J. Wilson, Christopher Paul Wilson, Margaret (a.k.a. “Maggie”) Mary Elander, Fred E. Kickertz, and Betty Brown (f.k.a. Elizabeth M. Kickertz), Brent Beckwith, Fast Global Solutions, Minnewaska Assembly of God, State of Minnesota, County of Pope, and all such other unknown heirs of all said 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:

1. YOU ARE BEING SUED.  The Plaintiff has started a lawsuit against you.  The Plaintiff’s 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, IN WRITING AND GET A COPY OF YOUR REPLY TO THE PERSON/BUSINESS WHO IS SUING YOU 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 received this Summons.  You must send a copy of your Answer to: Jeffrey Kuhn, Jeffrey Kuhn Law Office, 16 First Street SE, Glenwood, MN 56334.

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 PERSON WHO IS SUING YOU. 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 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. This lawsuit may affect or bring into question title to real property located in Pope County, State of Minnesota, legally described as follows:

EXHIBIT “A”

That part of the of the Northwest Quarter of the Northwest Quarter (NW¼NW¼) of Section 17, Township 125 North, Range 37 West, Pope County, Minnesota, described as follows:

Commencing at the northwest corner of said Section 17;

thence South 00 degrees 44 minutes 00 seconds West, assumed bearing along the west line of said Section 17, a distance of 697.05 feet to a point on the monumented line of the land as described in Document No. 273349;

thence South 89 degrees 23 minutes 44 seconds East along said monumented line of the land as described in Document No. 273349, a distance of 50.00 feet to a point being 50.00 feet easterly as measured perpendicular to said west line of Section 17, said point being the point of beginning of the land to be described;

thence continuing South 89 degrees 23 minutes 44 seconds East along said monumented line of the land as described in Document No. 273349, a distance of 272.02 feet to a 1 ½” iron pipe; 

thence North 51 degrees 14 minutes 48 seconds East along said monumented line of the land as described in Document No. 273349, a distance of 174.88 feet to a point being 75.00 feet southwesterly as measured perpendicular to the monumented centerline of Trunk Highway No. 55;

thence North 39 degrees 13 minutes 34 seconds West, parallel with said monumented centerline of Trunk Highway No. 55, a distance of 633.69 feet to a point being 50.00 feet easterly as measured perpendicular to aforesaid west line of Section 17;

thence South 00 degrees 44 minutes 00 second West, parallel with said west line of Section 17, a distance of 597.54 feet to the point of beginning.

The tract contains 3.14 acres more or less, subject to highway easements as per Document No. 133797 and 079713, further subject to other easements, reservations or restrictions of record, if any.

ALTERNATIVE DISPUTE RESOLUTION PROCESS

MINNESOTA STATUTE §543.22 REQUIRES US TO PROVIDE YOU WITH A STATEMENT CONTAINING INFORMATION ABOUT ALTERNATIVE DISPUTE RESOLUTION PROCESSES AS SET FORTH IN MINNESOTA GENERAL RULES OF PRACTICE (MGRP). PARTIES TO A CIVIL ACTION ARE ENCOURAGED TO ATTEMPT ALTERNATIVE DISPUTE RESOLUTION PURSUANT TO MINNESOTA LAW. ALTERNATIVE DISPUTE RESOLUTION INCLUDES MEDIATION, ARBITRATION, AND OTHER PROCESSES AS SET FORTH IN THE DISTRICT COURT RULES.  YOU MAY CONTACT THE COURT ADMINISTRATOR ABOUT RESOURCES IN YOUR AREA.  IF YOU CANNOT PAY FOR MEDIATION OR ALTERNATIVE DISPUTE RESOLUTION, IN SOME COUNTIES, ASSISTANCE MAY BE AVAILABLE TO YOU THROUGH A NONPROFIT PROVIDER OR A COURT PROGRAM.

Dated: Feb. 16, 2024.

SIGNED: /s/ Jeffrey D. Kuhn

Jeffrey D. Kuhn  #058907

Attorney for the Plaintiff

16 First Street SE

Glenwood, Minnesota 56334

Phone (320) 634-4584

jeffreykuhnlaw@gmail.com

March 18, 25, April 1