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Summons/CHS (0427)

STATE OF MINNESOTA DISTRICT COURT
COUNTY OF ROSEAU NINTH JUDICIAL DISTRICT CASE TYPE: 14 OTHER CIVILCourt File No. 68-CV-16-176

CHS INC., a Minnesota corporation,

Plaintiff,

vs.                                                                      SUMMONS
Northern Townsite Company, a Minnesota 
Corporation; Minnesota and Great Northern
Railway Company, a Minnesota Corporation;
Minnesota Northern Railroad, Inc., a 
Delaware Corporation; 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: 

NORTHERN TOWNSITE COMPANY, A MINNESOTA CORPORATION; MINNESOTA AND GREAT NORTHERN RAILWAY COMPANY, A MINNESOTA CORPORATION; MINNESOTA NORTHERN RAILROAD, INC., A DELAWARE CORPORATION; ALSO ALL OTHER PERSONS UNKNOWN CLAIMING ANY RIGHT, TITLE, ESTATE, INTEREST OR LIEN IN THE REAL ESTATE DESCRIBED IN THE COMPLAINT.

1.  YOU ARE BEING SUED.  The Plaintiff has started a lawsuit against you. The Plaintiff’s 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 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:

Anderson Law Offices, P.A.
P.O. Box 430
Warroad, MN 56763

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 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 Roseau County, State of Minnesota, legally described as follows:

That portion of the NE¼ NE¼ of Section 10, Township 160 North, Range 43 West of the 5th P.M., Roseau County, Minnesota, being that portion of that certain 250.0 foot wide strip of land described in Warranty Deed from Northern Townsite Company to the Minnesota and Great Northern Railway Company filed for record June 7, 1905, in Book 29, page 475-6 in and for said County, described as follows:
Commencing at the Northeast corner of said Section 10; thence South along the East line of said Section 10, a distance of 115 feet, more or less, to the Northwesterly line of said 250.0 foot wide strip of land; thence Southwesterly, along said Northwesterly line, 925.0 feet to the True Point of Beginning for the parcel herein described, said point being the Westerly corner of that certain parcel of land described in deed dated January 8, 1999 from The Burlington Northern and Santa Fe Railway Company to McFarlane Seeds, Inc.; thence continuing Southwesterly along said Northwesterly line 300.0 feet to the northerly corner of that certain parcel of land described in deed dated April 3, 2000 from The Burlington Northern and Santa Fe Railway Company to Cenex Harvest States Cooperatives; thence Southeasterly, along the Northeasterly line of said parcel described in deed to Cenex Harvest States Cooperatives, 98 feet, more or less, to a line parallel with and distant 9.0 feet Northwesterly, measured at right angles from said BNSF Railway Company’s (now operated by Minnesota Northern Railroad, Inc.) most northerly Elevator Track centerline, as now located and constructed; thence Northeasterly along said parallel line 300.0 feet to the Southerly corner of said parcel of land described in deed to McFarlane Seeds, Inc.; thence Northwesterly, along the Southwesterly line of said parcel of land described in deed to McFarlane Seeds, Inc. to the True Point of Beginning.

The object of this action is an action to determine adverse claims.

ANDERSON LAW OFFICES, P.A.

Dated this 7th day of March, 2016.
By:                  
 /s/
Nora L. Crumpton – #0392570
Attorney for Plaintiff
115 Roberts Ave. NE
P.O. Box 430
Warroad, MN 56763
Telephone: (218) 386-1040

ATTORNEY FOR PLAINTIFF
(April 6, 13 & 20, 2016)

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