STATE OF MINNESOTA
COUNTY OF DAKOTA
FIRST JUDICIAL DISTRICT
CASE TYPE: 14-QUIET TITLE
Court File No. 19HA-CV-15-656
Assigned Judge: _____________
Gary T. Raak,
The State of Minnesota,
Northern States Power Company, Arlo
Rhodes, Renee Rhodes, Matthew H. Ailts,
Claire J. Ailts, Douglas T. Allen, Witney A.
Allen, Darin J. Blume, Karla J. Blume,
Duane Hicks, Regina Hicks, William Rohr,
Bonita M. Rohr, Jacquelyn B. Bosma, Angela
C. Crowe-Lawrence, Joseph S. Lee, Michael
D. Samuelson, Randi Jo Samuelson, Kristin
M. Kimm, Christop Kimm, Matthew Larsen,
Lisa Lindstedt Larsen, Michael T. Bodette,
Trista Bodette, Gena Anderson, James
Anderson, Rose Terrace Apartments LLC,
Dakota Electric Assn., Rajan T.
Chattanathan, Revathy Rajaraman, Shayna
M. Fleming, Peyton J. Fleming, Steven D.
Webb, Heather D. Webb, Joseph A. Bennett,
Meghan A. Bennett, Jeremy Ockwig, Nora
Ockwig, Scott A. Gilbertson, Erica A.
Gilbertson, Steven A. Dobin, Sara J. Cerar-
Dobin, Robert E. Powers, Julianne Powers,
Alfred M. Hanson, Jan M. Hanson, City of
Rosemount, Michael D. Gehlhar, Katherin
Gehlhar, John I. Vo, Katie Vo, Deborah K.
Ausen, Jenica Adams, and any and all other
persons unknown claiming any right, title,
estate, interest, or lien upon the real estate
described in the complaint herein,
THIS SUMMONS IS DIRECTED TO THE ABOVE NAMED DEFENDANTS.
1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you.
The Plaintiffs Complaint against you is on file in the office of the Court Administrator of the
above-named Court. 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 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:
16233 Kenyon Avenue
Lakeville, MN 55044
3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response
to the Plaintiffs 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 20 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 Dakota County, State of Minnesota, legally described as follows:
The North 330.8 feet of the Southwest Quarter of the Northeast Quarter of Section
20, Township 115, Range 19, lying Westerly of the occupied right of way for
State Trunk Highway No. 3, Dakota County, Minnesota, EXCEPT: Commencing
at a point on the North line of the Southwest Quarter of Section 20, Township
115, Range 19, said point being 607.8 feet East of the Northwest corner of the 2
Southwest Quarter of the Northeast Quarter; thence East along the said North line
of the Southwest Quarter of Northeast Quarter, 50 feet, thence South 40 feet,
thence West 50 feet, thence North 40 feet to the point of beginning.
Subject to the easement and limitation of access in the Final Certificate recorded
as Document No. 235249; Dakota County Right of Way Map No. 9 recorded as
Document No. 178886 and the Right of Way of Dodd Boulevard; the easement
for electrical transmission line purposes recorded as Document No. 827195; and
Resolutions recorded as Document Nos. 735009 and 708972.
8. OBJECT OF THIS ACTION. The object of this action is to obtain a judgment that
Plaintiff is the owner, in fee simple, of the above-described real property and that none of the
said Defendants have any right, title, estate, interest therein or lien thereon.
NOTICE OF NO PERSONAL CLAIM.
No personal claim is being made against the defendants. However, if the defendants
unreasonably defend the action, Plaintiffs are requesting an order of the court directing that the
defendants shall pay full costs and attorneys fees to Plaintiffs.
Dakota Law, P.L.L.C.
/s/ Rachel Estrella
Rachel Estrella MN# 0392594
16233 Kenyon Avenue
Lakeville, Minnesota 55044
ATTORNEY FOR PLAINTIFF