STATE OF MINNESOTA DISTRICT COURT
COUNTY OF DAKOTA
FIRST JUDICIAL DISTRICT
Rosemount Port Authority, a public body corporate and politic under the laws of the State of Minnesota,
Court File No. 19HA-CV-08-5794
Marie Nikel, aka Mrs. Julius Nikel; Unknown heirs and devisees of Marie Nikel, aka Mrs. Julius Nikel, deceased; and all other persons unknown claiming any right, title, estate, interest or lien in the real estate described in the Complaint herein,
THE STATE OF MINNESOTA TO THE ABOVE NAMED DEFENDANTS:
You are hereby summoned and required to serve on plaintiff's attorney an answer to the Complaint on file with the District Court, within twenty (20) days of the service of this Summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the Complaint. The real property involved, affected or brought in question by this action is described as follows:
That part of the East 150 feet of Lot Fourteen (14), Auditor's Subdivision No. 27, Rosemount, according to the plat thereof now on file and of record in the office of the County Recorder, Dakota County, Minnesota, lying Southerly of the North 580 feet of said Lot Fourteen (14), and lying northerly of line 1 as described below, and lying easterly of a line drawn parallel with and distant 75.00 feet westerly of the following described line: Beginning at a point on the south line of Section 29, Township 115, Range 19, Dakota County, Minnesota, distant 367.00 feet west of the South Quarter corner thereof; thence run northeasterly at an angle of 65 degrees 28 minutes with said south line for 757.3 feet; thence deflect to the left on a 06 degrees 30 minutes curve (delta angle 23 degrees 03 minutes) for 354.6 feet; thence on tangent to said curve for 800 feet, and there terminating.
Line 1: Commencing at the northeast corner of the Southwest Quarter of Section 29, Township 115, Range 19, Dakota County, Minnesota; thence South 1 degrees 03 minutes 04 seconds West, (assumed bearing) along the east line thereof a distance of 1246.50 feet; thence South 89 degrees 48 minutes 42 seconds West, parallel with the north line of said Southwest Quarter a distance of 73.24 feet to the westerly right of way line of State Trunk Highway No. 3 (formerly State Trunk Highway No. 218); thence continuing South 89 degrees 48 minutes 42 seconds West, parallel with said north line of the Southwest Quarter a distance of 125.95 feet to the east line of the plat of MARION TERRACE REPLAT, as on file and of record in the office of the County Recorder, Dakota County, Minnesota; thence South 1 degree 16 minutes 48 seconds West along said east line of MARION TERRACE REPLAT a distance of 449.44 feet, to the point of beginning of said line 1 to be hereinafter described; thence South 88 degrees 43 minutes 12 seconds East a distance of 122.75 feet, to said westerly right of way line of State Trunk Highway No. 3 (formerly State Trunk Highway No. 218), and said line 1 there terminating
and the purpose of this action is to quiet title and to obtain judgment that Plaintiff, Rosemount Port Authority is the owner in fee simple of the Property described herein, free and clear and discharged from all right, title, interest, estate, lien or encumbrance whatsoever, in law or equity, of said Defendants, known or unknown, but subject to a highway easement in favor of the State of Minnesota.
Dated: December 17, 2008.
KENNEDY & GRAVEN, CHARTERED
By: Corrine A. Heine
Corrine A. Heine (#149743)
200 South Sixth Street, Suite 470
Minneapolis, MN 55402
Attorneys for Plaintiff