STATE OF MINNESOTA COUNTY OF OTTER TAIL IN DISTRICT COURT SEVENTH JUDICIAL DISTRICT CIVIL DIVISION

Other Civil
Court File No. 56-CV-24-2789

Paul Drayton, aka Paul D. Drayton,

Plaintiff,   
V.

Doris Drayton aka Doris D. Drayton; the estate of Doris Drayton aka Doris D. Drayton, deceased; Northern National Bank, formerly known as Pelican Valley State
Bank; Karen Susag and John E. Scheldberg, attorneys-in-fact for George E. Hanson; Chris L. Hill; Sandra D. Hill; Todd E. Nord; the estate of Todd E. Nord, deceased;
Community First Mortgage LLC; Wells Fargo Home Mortgage, Inc. fka Norwest Mortgage Inc.; Minnesota Housing Finance
Agency; Bell Bank; U. S. Bank Home Mortgage; Spencer Paulson; Amanda Paulson; Arnulfo Martinez; Yolanda Martinez; Julian Urbano; West Central Turkeys; and the unknown heirs, successors
or assigns of any of the above and all other parties unknown claiming any right, title, estate, interest, or lien in the real estate
described in the Complaint,

Defendants.

SUMMONS

THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED 
DEFENDANTS, and the unknown heirs of any of the above named persons now deceased, also all other persons or parties unknown claiming any right, title, estate, interest or lien in the real estate described in the Complaint herein.

1. YOU ARE BEING SUED:  Plaintiff has started a lawsuit against you.  Plaintiff’s Complaint against you is attached to this Summons and 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:

Krekelberg Law Firm  
213 S. Mill Street
Fergus Falls, MN 56537

3. YOU MUST RESPOND TO EACH CLAIM.  The Answer is your written response to Plaintiff’s Complaint.  In your Answer you must state whether you agree or disagree with each paragraph of the Complaint.  If you believe 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 your case.  You will not get to tell your side of the story, and the Court may decide against you and award 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  AND ACTION INVOLVES, AFFECTS, AND/OR BRINGS INTO QUESTION REAL PROPERTY located in Otter Tail County, Minnesota, legally described as follows:

See attached Exhibit A
The object of this action is to definitively establish the ownership and clear any claims or disputes regarding said property.

EXHIBIT A AMENDED ABSTRACT OF TITLE TO:
That part of the East Half of the Southwest Quarter, Section 22, Township 136 North, Range 43 West, Otter
Tail County, Minnesota, described as follows: Commencing at the southwest corner of Lot 9 Block 1, HARRIS'S ADDITION, said plat on file of record
in the office of said county (the west line of said Block 1 bears North 00 degrees 51 minutes 58 seconds East from said point of commencement); thence North 89 degrees 09 minutes 17 seconds West, a distance of 66.00 feet to an iron monument, also being the point of beginning; thence continuing North 89 degrees 09
minutes 17 seconds West, a
distance of 100.00 feet to an
iron monument; thence North 00 degrees 51 minutes 58 seconds East, a distance of 150.00 feet to the south line of Block 4, plat of WEST CENTRAL, said plat is on file and of record in said office; thence South
89 degrees 09 minutes 17 seconds East along said south line of Block 4, a distance of 100.00 feet; thence South 00 degrees 51 minutes 58 seconds West, a
distance of 150.00 feet to said point of beginning. SUBJECT TO easements, reservations, or restrictions of record, if any.

DATED: 12/03/2024
KREKELBERG LAW FIRM
BY: CHAD D. MILLER
Attorney for Plaintiff
213 S. Mill Street
Fergus Falls, MN 56537
(218) 739-4623
 Atty. Reg, No. 386902
12-26-3-c