(Published in the Brainerd Dispatch, Jul
(Published in the Brainerd Dispatch, July 27, August 3, 10, 2022, 3t.) SUMMONS STATE OF MINNESOTA COUNTY OF CROW WING DISTRICT COURT NINTH JUDICIAL DISTRICT Case Type: Quiet Title Court File No.: 18-CV-22-2493 Knife River Corporation – North Central a Minnesota Corporation, Plaintiff, vs. The City of Baxter, a Minnesota Municipal Corporation; Robert L. Abear and Sandra J. Abear, husband and wife; Gary Roth; CreditAmerica Savings Company, an inactive Minnesota Corporation; The Estates of any deceased Defendants; The unknown heirs of any deceased Defendants; and also all other persons unknown claiming any right, title, estate, interest, or lien in the real estate described in the Complaint herein. Defendants. THIS SUMMONS IS DIRECTED TO DEFENDANTS ABOVE-NAMED. 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: Gammello-Pearson, PLLC Daniel M. Hawley P.O. Box 2629 14275 Golf Course Drive, Suite 200 Baxter, MN 56425 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. REAL ESTATE. This legal action involves real estate located in the County of Crow Wing State of Minnesota legally described as follows: That part of the Southeast Quarter of the Northwest Quarter (SE1/4 of NW1/4), Section Eight (8), Township One Hundred Thirty-three (133), Range Twenty-eight (28), described as follows: Beginning at the southwest corner of said Southeast Quarter of Northwest Quarter (SE1/4 of NW1/4); thence North One Degree Three Minutes Thirty-one seconds (01°03’31”) West, assumed bearing, Six Hundred Sixty and Forty Hundredths feet (660.40) along the West line of said Southeast Quarter of Northwest quarter (SE1/4 of NW1/4) to a point on the north line of the South Six Hundred Sixty feet (660) of said Southeast Quarter of Northwest Quarter (SE1/4 of NW1/4), said point also being on the southerly right-of-way line of Baxter Industrial Park Road; thence North Eighty-six Degrees Forty-eight Minutes Eighteen Seconds (86°48’18”) East Three Hundred Twenty-seven and Seventy-eight Hundredths feet (327.78) along said southerly right-of-way line of the Baxter Industrial Park Road; thence South One Degree Three Minutes Thirty-one Seconds (01°03’31”) East six Hundred sixty-one and Sixteen Hundredths feet (661.16) to the South line of said Southeast Quarter of Northwest Quarter (SE1/4 of NW1/4); thence South Eighty-six Degrees Fifty-six Minutes Seventeen Seconds (86°56‘17”) West Three Hundred Twenty-seven and Seventy-five Hundredths feet (327.75) along said south line of the Southeast Quarter of Northwest Quarter (SE1/4 of NW1/4) to the point of beginning. AND That part of the SE1/4-NW1/4, Sec. 8, Twp. 133, Rge. 28, described as follows: Commencing at the southwest corner of said SE1/4-NW1/4; thence North 86 degrees 56 minutes 42 seconds East 327.75 feet along the south line of said SE1/4-NW1/4 to the point of beginning of the tract to be described; thence continuing North 86 degrees 56 minutes 42 seconds East 204.82 feet along said south line of the SE1/4-NW1/4; thence North 00 degree 54 minutes 10 seconds West 661.72 feet to the south right—of-way line BAXTER INDUSTRIAL PARK ROAD; thence South 86 degrees 48 minutes 37 seconds West 206.36 feet along said south right-of-way line of BAXTER INDUSTRIAL PARK ROAD; thence South 01 degree 02 minutes 08 seconds East 661.18 feet to the point of Beginning, Crow Wing County, Minnesota PID#s: 40080760 and 40080761 AND That part of the Southeast Quarter of the Northwest Quarter, Section 8, Township 133, Range 28, Crow Wing County, Minnesota, being described as follows: Commencing at the southwest corner of said Southeast Quarter of Northwest Quarter thence North 01 degree 03 minutes 31 seconds West, along the west line of said Southeast Quarter of Northwest Quarter, 660.40 feet to a point on the southerly right-of-way line of Baxter Industrial Park Road; thence North 86 degrees 48 minutes 18 seconds East, along said southerly right-of-way line, 327.78 feet to the point of beginning; thence South 01 degree 03 minutes 31 seconds East 661.16 feet to the south line of said Southeast Quarter of Northwest Quarter; thence North 01 degree 02 minutes 33 seconds East 661.17 feet to said southerly right-of-way line of Baxter Industrial Park Road; thence South 86 degrees 48 minutes 18 seconds West, along said southerly right-of-way line 0.19 feet to the point of beginning. The purpose of the proceeding is to quiet title to the above-described real estate in Plaintiff and to determine that Plaintiff is the owner in fee of the above-described real estate, free from any claims of any right, title, estate, lien, or interest, by or on behalf of Defendants. GAMMELLO-PEARSON, PLLC Dated: June 28, 2022 /s/ Daniel M. Hawley (#390337) 14275 Golf Course Drive, Suite 200 P.O. Box 2629 Baxter, MN 56425 Phone: 218/828-9511 ATTORNEYS FOR PLAINTIFF