STATE OF MINNESOTA
COUNTY OF OLMSTED
THIRD JUDICIAL DISTRICT
Todd C. Pagenhart and Stacy S. Zimmer, as Trustees of the John R. Pagenhart and Rosemerry A. Pagenhart Family Trust U/A dtd. 01/13/09,
Forrest Campbell; the unknown heirs of Forrest Campbell; and all other persons unknown claiming any right, title or interest in the real estate described in the Complaint herein,
Case Type: Quiet Title
Court File No.: 55-CV-21-4692
THIS AMENDED SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANTS.
1. YOU ARE BEING SUED. The Plaintiffs have started a lawsuit against you. The Plaintiffs' Amended Complaint against you is attached to this Amended 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 Amended Summons.
2. YOU MUST REPLY WITHIN 21 DAYS TO PROTECT YOUR RIGHTS. You must give or mail to the person who signed this Amended Summons a written response called an Answer within 21 days of the date on which you received this Amended Summons. You must send a copy of your Answer to the person who signed this Amended Summons located at:
Dunlap & Seeger, P.A.
Attention: William Ryan
30 Third Street SE, Suite 400
P.O. Box 549
Rochester, MN 55903-0549
3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiffs' Amended Complaint. In your Answer, you must state whether you agree or disagree with each paragraph of the Amended 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 AMENDED 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 the Plaintiffs everything asked for in the Amended 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 Amended 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 Amended 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 the County of Olmsted, State of Minnesota, legally described as follows:
Lot 13, Block 10, Homewood Addition.
The object of this action is to determine adverse claims and to establish Plaintiffs' title to the above-described property.
Dated: September 29, 2021
DUNLAP & SEEGER, P.A.
By: /s/ William J. Ryan
William J. Ryan,
Reg. No. 94900
Alison M. Kryzer,
Reg No. 0399752
Attorneys for Plaintiffs
30 Third Street SE, Suite 400 P.O. Box 549
Rochester, MN 55903-0549 Telephone: (507) 288-9111 Fax: (507) 288-9342
(Oct. 2, 9 & 16, 2021) 2906584