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McLeod County - State of Minnesota

McLeod County

STATE OF MINNESOTA COUNTY OF MCLEOD DISTRICT COURT
FIRST JUDICIAL DISTRICT
CASE TYPE: Quiet Title
Court File No. 43-PR-18-1114

Ronald J. Pulkrabek
a/k/a Ronald James Pulkrabek,
and Eileen A. Pulkrabek
a/k/a Eileen Ann Pulkrabek,
spouses married to each other
Plaintiff
vs.
Daniel R. Pavlik and
Debra A. McKenzie, spouses married to each other;
Neil w. Posusta, a single man;
Any other person unknown claiming anyright, title, estate, interest, or lien in the real estate described in the
complaint herein.
Defendant.

SUMMONS
THIS SUMMONS IS DIRECTED TO Daniel R. Pavlik and Debra A. McKenzie, spouses married to each other; Neil W. Posusta, a single man; any other person unknown claiming any right, title, estate, interest, or lien in the real estate described in the complaint herein.
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 located at:
Gavin, Donley & Ostlund
1017 Hennepin Ave N
Glencoe, MN 55336
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 McLeod County, State of Minnesota, legally described as follows:
That part of the Southeast Quarter of the Northeast
Quarter of Section 20, Township 116 North, Range 28
West, McLeod County, Minnesota, described as follows:

Beginning at the southeast corner of said Northeast Quarter: thence westerly, along the south line of said Northeast
Quarter 594.00 feet; thence northerly, parallel with the east line of said Northeast Quarter about 683 feet to the center of the Crow River; thence northeasterly along the center of said Crow River to the east line of said Northeast Quarter: thence southerly, along said east line about 1067 feet to the point of beginning.
AND ALSO
That part of the Southeast Quarter of the Northeast Quarter of Section 20, Township 116 North, Range 28 West, McLeod County, Minnesota, described as follows:
Commencing at southeast corner of said Northeast Quarter; thence westerly, along the south line of said Northeast Quarter 594.00 feet to the point of beginning of the land to be described: thence continuing westerly, along said south line about 242 feet to the center of the Crow River; thence northerly and northeasterly, along the center of said Crow River to the intersection with a line parallel with the east line of said Northeast Quarter, as measured northerly from the point of beginning;; thence southerly, along said parallel line about 683 feet to the point of beginning.
ALSO KNOWN AS
The Northeast Quarter of the Northeast Quarter (NE¼ of NE¼) of
Section Twenty (20)
Township One Hundred Sixteen (116) North
Range Twenty-eight (28) West.
EXCEPTING THEREFROM the following described parcel, to-wit: That Part of the Northeast Quarter of the Northeast Quarter (NE¼ of NE¼) of Section Twenty (20), Township One Hundred Sixteen (116) North, Range Twenty-eight (28) West, described as follows: Commencing at the Northeast corner of said Northeast Quarter; of the Northeast Quarter; thence South 00 degrees 29 minutes 32 seconds West, assumed bearing, along the East line of said Northeast Quarter of the Northeast Quarter 961.00 feet to the point of beginning of the land to be described; thence South 89 degrees 53 minutes 03 seconds West, parallel with the North line of said Northeast Quarter of the Northeast Quarter 999.00 feet; thence South 00 degrees 29 minutes 32 seconds West 288.29 feet; thence South 89 degrees 50 minutes 02 seconds West 325.39 feet to the West line of said Northeast Quarter of the Northeast Quarter; thence South 00 degrees 22 minutes 24 seconds West 66.00 feet to the Southwest corner of said Northeast Quarter of the Northeast Quarter; thence North 89 degrees 50 minutes 02 seconds East 1324.27 feet to the Southeast corner of said Northeast Quarter of the Northeast Quarter; thence North 00 degrees 29 minutes 32 seconds East, along said East line 353.42 feet to the point of beginning.
AND
Blocks Five (5) Six (6), Seven (7), Eight (8) and Nine (9) of Koniska
The object of this action is to quite title thereto and establish boundaries as it relates to the meandering Crow River.
Dated: July 2, 2018. Gavin, Donley and Ostlund, ltd.
/s/ Mark W. Ostlund
MN# 0395238
1017 Hennepin Ave N
Glencoe, MN 55336
Telephone: 320-864-5142
Facsimile: 320-864-5146
Email: mostlund@goslawfirm.com
ATTORNEY FOR PLAINTIFF
(Published in The McLeod County Chronicle September 19, 26 and October 3, 2018)