STATE OF MINNESOTA
COUNTY OF POPE

IN DISTRICT COURT

EIGHTH JUDICIAL DISTRICT

Court File No. 61-CV-23-295

QUIET TITLE ACTION

___________________

Mark Robert Erenberg,

David William Erenberg,

Susan Kay Palenik and 

Anita Ellen Gallagher

Plaintiffs,

-vs-

Knut Wrolson aka Knud Wrolson aka Knud Vraalson, aka Knut Vrolson; Karen Margerette Wrolson; Adam Olson; Ole S. Strate, Else Strate aka Ellen Strate; H. Sather aka Hagen Sather; H.O. Sather aka Henry O. Sather; Tillie Sather, Blanche Sather aka Blanche Lonnstrom, Myrtle Sather, Gladys Sather aka Gladys Larson, Harry Sather, Reuben Sather, Vivian Sather; Walter Gensler; Paul Peterson aka Paul H. Pederson, Julie N. Pederson aka Gunhilde Nicoline Pederson; J.S. Lee, Dina Lee; Robert Hill, Berniece Hill; Paul S. Pederson, Susanne Pederson, Julie Pederson, Heidi Pederson; Theodore A. Lee aka Theo Lee; Belle Olson, Ole Olson aka O.E. Olson, Mabel Olson; Axel Newfield; Stanley J. Blasey aka Stan Blasey, Marianne Blasey aka Marianne O. Blasey; David Rudningen, Sheryl R. Rudningen; James R. Allis Revocable Trust; State of Minnesota and all other persons unknown claiming any right, title, estate, interest, or lien in the real estate described in the Complaint herein,

Defendants.

AMENDED 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 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 at 14 Franklin Street S., 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 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. ALTERNATE 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 alternate means of resolving this dispute.

7. 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”

Land Description – 10.0 +/- Acres

That part of Government Lot 5, Section 20, Township 123 North, Range 37 West of the Fifth Principal Meridian, Pope County, Minnesota and also that part of Lot 9, of the recorded plat entitled COUNTY AUDITOR’S SUBDIVISION NUMBER 13, on file in the office of the Pope County Recorder, described as follows:

– Commencing at the northeast corner of Government Lot 3 of said Section 20, marked by a 3/4” iron pipe;

– thence on an assumed bearing of South 0 degrees 05 minutes 16 seconds West, along the east line of said Section 20, a distance of 1298.44 feet to the northeast corner of Government Lot 4 of said Section 20, marked by an iron pipe;

– thence on a bearing of South 89 degrees 50 minutes 57 seconds West, along the north line of said Government Lot 4 and also the south line of the record plat entitled SCANDIA WOODS, on file in the office of the Pope County Recorder, a distance of 1325.10 feet to an iron pipe at the northeast corner of said Government Lot 5, which is the point of beginning of the land to be described;

– thence on a bearing South 0 degrees 14 minutes 19 seconds West, along the east line of said Government Lot 5, a distance of 697.69 feet to a illegible capped iron pipe;

– thence on a bearing of South 89 degrees 22 minutes 25 seconds West a distance of 707.10 feet to an RLS 18145 capped iron pipe;

– thence on a bearing of North 37 degrees 03 minutes 11 seconds West a distance of 140.94 feet to the west line of said Lot 9, marked by an RLS 18145 capped iron pipe;

– thence on a bearing of North 21 degrees 00 minutes 07 seconds West, along the west line of said Lot 9, a distance of 42.90 feet to a 1” iron pipe;

– thence continuing on a bearing of North 21 degrees 00 minutes 07 seconds West, along the west line of said Lot 9, a distance of 19 feet, more or less, to the shore of Scandinavian Lake;

– thence northeasterly, along the shore of Scandinavian Lake, a distance of 666 feet, more or less to the south line of said record plat entitled SCANDIA WOODS;

– thence on a bearing of 89 degrees 50 minutes 57 seconds East, along the south line of said record plat entitled SCANDIA WOODS, a distance of 5 feet, more or less, to an RLS 10046 capped iron pipe;

– thence continuing on a bearing of North 89 degrees 50 minutes 57 seconds East, along the south line of said record plat entitled SCANDIA WOODS, a distance of 502.73 feet to the point of beginning.

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 this 6th day of September, 2023.

JEFFREY KUHN LAW OFFICE, LTD.

BY: /s/ Jeffrey D. Kuhn

Jeffrey D. Kuhn  #0058907

Attorney for the Plaintiff

16 First Street SE

Glenwood, Minnesota 56334

Phone (320) 634-4584

Sept. 11, 18, 25