Court File No.  35-CV-17-63
Webster Land, LLLP,         )
a North Dakota limited         )
liability limited partnership,    )
Plaintiff,        )
vs.        )
Clifford Clow, Muriel Ash Clow,     )
aka Muriel Irma Clow,         )
Thomas Charles Clow,     )
William Clow, Ruth Ann Clow,     )
and all other persons unknown     )
claiming any estate or interest     )
in or lien or encumbrance     )
upon the real property         )
described in the Complaint,     )
whether as heirs, legatees,     )
devises, creditors,         )
personal representatives,    )
or otherwise,         )
(Quiet Title)
    YOU ARE BEING SUED.  The Plaintiff has started a lawsuit against you. The Plaintiff’s Complaint 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.
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 at Plaintiff’s attorney’s address indicated at the end of this Summons.
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.
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.
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.
 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.
THIS LAWSUIT MAY AFFECT OR BRING INTO QUESTION TITLE TO REAL PROPERTY located in Kittson County, State of Minnesota, legally described as follows:
The Northeast Quarter of the Northeast Quarter (NE¼NE¼) of Section 35, Township 164 North, Range 51 West, Kittson County, Minnesota.
The object of this action is to obtain the judgment of said Court determining the Plaintiff’s title and all adverse claims to the above-described tract of land, adjudging that the Plaintiff is the owner in fee simple absolute and entitled to possession of said tract of land and the whole thereof, adjudging that the Defendants in said action, and each of them, have no right, title, claim, interest or estate in or to said tract of land or lien thereon, and adjudging such other relief as the Court shall deem proper.
YOU ARE FURTHER NOTIFIED that no personal claim is made against any of the Defendants and that this action is brought only for the purpose of determining adverse claims to real estate and vesting title in the Plaintiff thereby.
Dated:  May 3, 2017.
/s/ Andrew D. Cook
Andrew D. Cook
Attorney for Plaintiff
MN ID #0391946
201 Front Street South, Office #5
P.O. Box 718
Barnesville, MN 56514-0718
TEL (218) 354-7011
FAX (218) 354-7012
901 – 13th Avenue East
P.O. Box 458
West Fargo, ND 58078-0458
TEL (701) 282-3249
FAX (701) 282-0825
The undersigned and the party I represent hereby acknowledge that sanctions may be imposed pursuant to Section 549.211 of the Minnesota Statutes Annotated to the party against whom the allegations in this pleading are asserted.
/s/ Andrew D. Cook
Andrew D. Cook
Attorney for Plaintiff
MN ID #0391946
(May 24, 31, June 7, 2017)

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