CASE TYPE: Quiet Title Action

Court File No. 56-CV-22-2588

Assigned Judge: _____________________

R & R Land LLC



Kenneth Hendrickx; Josie Hendricks; Daniel R. Welter; Bonnie S. Welter; Duane C. Frost, Irene V. Frost, Dean A. Simpson, Kathleen M. Simpson, Seip Holdings, LLC; Clarion V. Hamari; Shirley M. Hamari; Gary D. Schultz and Barbara A. Schultz; Scott J. Olds; Noah J. Olds; also, the unknown heirs, successors, or assigns of the above and all other parties unknown claiming any right, title, estate, interest, or lien in the real estate described in the Complaint; 




1. YOU ARE BEING SUED.  The Plaintiff has started a lawsuit against you.  The Plaintiffs’ 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 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 the person who signed this Summons located at:

Pemberton Law, P.L.L.P.

110 North Mill Street

Fergus Falls, MN 56537

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 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. 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 Otter Tail County, State of Minnesota, legally described as follows:

That part of the Southwest Quarter of the Northeast Quarter (SW¼NE¼) of Section 8, Township 135, Range 37, Otter Tail County, Minnesota, described as follows: 

To find the point of beginning of the parcel to be described, commence at Boundary Corner No. B21 in State Highway Right of Way Plat No. 56-17, said plat being on file and of record in the office of the Otter Tail County Recorder; then run North 58 degrees 17 minutes 35 seconds West on an assumed bearing along the southerly boundary line of said plat, 556.34 feet to an iron monument; thence South 00 degrees 29 minutes 26 seconds West 214.55 feet; thence North 58 degrees 17 minutes 35 seconds 1.28 feet to the point of beginning of the parcel to be described; thence continue North 58 degrees 17 minutes 35 seconds West 117.53 feet, more or less, to the point of intersection with a line that is 264 feet East of, measured at right angles to, and parallel with, the west line of said Southwest Quarter of Northeast Quarter (SW ¼ NE ¼); thence North 00 degrees 23 minutes 14 seconds East, on and along said parallel line, 214.78 feet, more or less, to said highway plat boundary line; thence South 58 degrees 17 minutes 35 seconds East, along said highway plat boundary line; 227.41 feet to a line bearing North 31 degrees 09 minutes 17 seconds East from the point of beginning; thence South 31 degrees 09 minutes 17 seconds West 183.50 feet, more or less, to the point of beginning, subject to public right of way.  

The object of this action is a Quiet Title Action.

Dated:   November 2, 2022.                 PEMBERTON LAW, P.L.L.P.

By:  Chad R. Felstul, License No. 0345684

110 North Mill Street

Fergus Falls, MN 56537

Telephone:  218-736-5493



Published November 9, November 16, November 23, 2022

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