STATE OF MINNESOTA
COUNTY OF ANOKA DISTRICT COURT
TENTH JUDICIAL DISTRICT
Case type: Other civil
(Reformation of Instrument)
Court File No.: 02-CV-14-1446
Wells Fargo Bank, N.A. as successor by merger to Wells Fargo Home Mortgage, Inc.,
Mary A. Lane, Lukas Ray Lane, Randall Lee Lane, also the unknown heirs of Gary P. Lane, and all other persons unknown claiming any right, title, estate, interest, or lien in the real estate described in the complaint herein,
THIS SUMMONS IS DIRECTED TO THE ABOVE NAMED DEFENDANT;
1. YOU ARE BEING SUED. The Plaintiffs have 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:
Bradley N. Beisel
John F. Nielsen
Beisel & Dunlevy, P.A.
282 U.S. Trust Center
730 Second Ave. S.
Minneapolis, MN 55402-2444
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 the County of Anoka, commonly known as 6821 227th Avenue NE, Stacy, Minnesota, 55079 and legally described as:
Lot 1 and Lots 33 through 35, Block 2, The Martin Lake Shores, Anoka County.
(referred to as the Subject Property and Correct Legal Description).
The purpose of this action is to obtain an Order for the following relief:
1. Reforming the Quit Claim Deed, document 1865285, nunc pro tunc, to include the Correct Legal Description.
2. Determining that the defendants, other than Defendant Mary A. Lane, have no right, title, or interest in the above-described Subject Property.
3. Reforming the Mortgage, document 1865286, nunc pro tunc, to include the Correct Legal Description.
4. Determining that the Mortgage is valid and enforceable against the entire property described in the Correct Legal Description.
5. For such other and further relief that the Court deems just and equitable.
557.03 NOTICE OF NO PERSONAL CLAIM
Pursuant to Minn. Stat. 557.03 you are hereby served with notice that no personal claim is made against you and that any defendant upon whom this notice is served who unreasonably defends this action shall pay full costs to the plaintiff.
Dated: April 21, 2014
BEISEL & DUNLEVY, P.A.
By: /s/ John F. Nielsen #0392392
Bradley N. Beisel #6191
282 U.S. Trust Building
730 Second Avenue South
Minneapolis, MN 55402-2444
Telephone: (612) 767-4839
Attorneys for Plaintiff
Published in the
Anoka County UnionHerald
April 25, May 2, 9, 2014