Quiet title action
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF ROCK FIFTH JUDICIAL DISTRICT
Case Type: Quiet Title
Kristen Deane Johnson, successor trustee of
the Dean R. Johnson Revocable Trust dated
July 19, 1990, as amended,
Plaintiffs,
v.
Dean R. Johnson, deceased, the unknown
heirs of Dean R. Johnson; Jeraldine R.
Johnson, deceased; the unknown heirs of
Jeraldine R. Johnson; Karen Rae Howard;
Kathy Jo St. Antoine; Kristen Deane Johnson;
Dean Robert Johnson, II; Kristen Deane
Johnson and Dean R. Johnson, II, co-trustees SUMMONS
of the Dean R. Johnson Revocable Trust
dated September 19, 2006; Kathy Jo St. Case No. 67-CV-24-53
Antoine and Karen Rae Howard, co-trustees
of the Jeraldine R. Johnson Revocable Trust
dated September 19, 2006; Karen Rae
Howard, trustee of the Dean R. Johnson P.C.
Defined Contribution Plan and Trust dated
December 1, 1996; and all other persons
claiming any right, title, estate, interest, or
lien, in the real estate described in the
Complaint herein,
Defendant(s).
TO: THE ABOVE-NAMED DEFENDANTS
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.
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: Klosterbuer & Haubrich, LLP, PO Box 538, 120 N. McKenzie Street, Luverne, MN 56156.
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 requested by the Complaint, you must say so in your Answer.
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 be given the opportunity to tell your side of the story, and the Court may decide against you and award the Plaintiff the relief requested in the Complaint. If you do not wish to contest the claims stated in the Complaint, you need not respond. A default judgement can then be entered against you for the relief requested in the Complaint.
LEGAL ASSISTANCE. You may wish to seek legal counsel. If you do not have legal representation, the Court Administrator may have information about resources and opportunities where you may obtain legal assistance. Even if you cannot obtain legal help or retain counsel, you must still provide a written Answer to protect your rights or you may lose the case.
ALTERNATIVE DISPUTE RESOLUTION. The parties may agree 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 the dispute.
THIS LAWSUIT MAY AFFECT OR BRING INTO QUESTION TITLE TO REAL PROPERTY located in Rock County, State of Minnesota, and is legally described as follows:
THE EAST 825 FEET OF THE WEST 1888 FEET OF THE SOUTH 396 FEET OF THE SOUTHEAST QUARTER (SE 1/4) OF SECTION TWO (2), TOWNSHIP ONE HUNDRED TWO (102) NORTH, RANGE FORTY-SIX (46) WEST OF THE 5TH P.M., ROCK COUNTY, MINNESOTA, EXCEPT THE FOLLOWING DESCRBED TRACT:
BEGINNING AT THE SOUTHEAST CORNER OF THE SOUTHEAST QUARTER (SE 1/4) OF SECTION TWO (2), TOWNSHIP ONE HUNDRED TWO (102) NORTH, RANGE FORTY-SIX (46), THENCE GOING IN A WESTERLY DIRECTION 679.00 FEET ALONG THE SOUTH LINE OF SAID SECTION, TO THE POINT OF BEGINNING; THENCE CONTINUING IN A WESTERLY DIRECTION ALONG THE SOUTH SECTION LINE 633.00 FEET; THENCE GOING IN A NORTHERLY DIRECTION 435.00 FEET PARALLEL WITH THE WEST LINE OF SAID SECTION; THENCE GOING IN AN EASTERLY DIRECTION 181.00 FEET PARALLEL WITH THE NORTH LINE OF SAID SECTION; THENCE GOING IN A SOUTHERLY DIRECTION 123.00 FEET PARALLEL TO THE EAST LINE OF SAID SECTION; THENCE GOING IN AN EASTERLY DIRECTION 193.00 FEET PARALLEL WITH THE NORTH LINE OF SAID SECTION; THENCE GOING IN A SOUTHEASTERLY DIRECTION 263.00 FEET TO A POINT 265.00 FEET DUE NORTH OF THE POINT OF BEGINNING; THENCE GOING IN A SOUTHERLY DIRECTION 265.00 FEET PARALLEL WITH THE EAST LINE OF SAID SECTION TO THE POINT OF BEGINNING.
The object of this action is to Quiet Title to the above-described property.
Dated this 8th day of March, 2024.
/s/ Donald R. Klosterbuer
Donald R. Klosterbuer, Esq. (MN# 56674)
Klosterbuer & Haubrich, LLP
120 N. McKenzie, PO Box 538
Luverne,MN56156
Phone: 507-283-9111
Fax: 507-283-9113
Email: drklosterbuer@khlawmn.com
Attorneys for Plaintiff
(03-14, 03-21, 03-28)
