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STATE OF MINNESOTA COUNTY OF OTTER TAIL IN DISTRICT COURT SEVENTH JUDICIAL DISTRICT CIVIL DIVISION
February 20, 2025
Court File No. 56-CV-25-203
Theodore Leucuta,
Plaintiff,
vs
Robert Skow, aka Robert C. Skow; LaVonne Gitter-Skow; William C. Petry; Fern G. Petry; Lloyd A. Mackey; Joyce A. Mackey; 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. The Plaintiff has started a lawsuit against you. The 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 Mill Street
Fergus Falls, MN 56537
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 Otter Tail County, State of Minnesota, legally described as follows:
See attached Exhibit A
The object of this action is to correct gaps in the chain of title caused by errors in past deeded transfers.
EXHIBIT A
Sub Lot "A" of Government Lot 1 of Section 14, Township 136, Range 43, Otter Tail County, Minnesota, EXCEPT tract platted as Subrosa Beach AND EXCEPT TRACT deeded to O.I. Sethre, filed for record in Book 146 of Deeds, page 202, described as follows: That part of Sub Lot "A" of Government Lot 1 of Section 14, Township 136, Range 43, described as follows: Beginning at a point 16 1/2 feet Southeast of stake in southwest corner of Lot 8, Subrosa Beach, directly across the Road in rear of said Subrosa Beach and in line with line between Lots 8 and 9 of said Subrosa Beach, thence running in a Southwesterly direction along Southeast side of said road 15 rods to a point where said road touches the south line of said Sublot "A" of Government Lot 1, thence running due East along south line of said Sublot "A" of Government Lot 1, 15 rods, thence in a northerly direction 8 rods and 15 feet to place of beginning.
AND
Tract B
That part of Government Lot 7 of Section 11, Township 136, Range 43, Otter Tail County, Minnesota, described by metes and bounds as follows, to wit: The point of commencement is ascertained by going from the Southeast corner of Lot 4 of Subrosa Beach according to the plat thereof on file and of record in the office of the County Recorder of Otter Tail County, Minnesota; thence Northeasterly on and along the Southerly line of Subrosa Beach 149.5 feet; thence due South 146 feet. Thence from this point of beginning due South 13 feet more or less to the Section line between Sections 11 and 14, said Township and Range; thence due West to the Southerly line of Subrosa Beach; thence in a Northeasterly direction on and along the Southerly line of Subrosa Beach to the Southeast corner of Lot 4 of said Subrosa Beach; thence Southeasterly in a straight line to the point of commencement, excepting therefrom portions thereof designated as public road in the plat of Subrosa Beach.
Together with a permanent easement for residential and recreational purposes across that part of Lot 7 of Subrosa Beach according to the plat thereof on file and of record with the Otter Tail County Recorder: Commencing at the southernmost corner of said Lot 7; thence in a northwesterly direction along the common boundary between Lot 7 and Lot 8 of Subrosa Beach a distance of 100 feet; thence northeasterly and parallel to the southeasterly line of said Lot 7 a distance of 40 feet; thence southeasterly and parallel to the common boundary between said Lot 7 and said Lot 8 a distance of 100 feet to the southeasterly line of said Lot 7; thence southwesterly on the southeasterly line of said Lot 7 a distance of 40 feet to the point of beginning.
Said easement does not include any lakeshore access, and no buildings may be placed on easement property without the prior written consent of the Grantors or future owners of
said Lot 7. This easement shall be a permanent easement that is appurtenant to the property being sold and shall run with said property.
DATED: January 24, 2025 KREKELBERG LAW FIRM
BY: Chad D. Miller
Attorney for Plaintiff
213 S. Mill Street
Fergus Falls, MN, 56537
(218) 739-4623
Attorney Reg. No. 386902
2-27-3-c
Theodore Leucuta,
Plaintiff,
vs
Robert Skow, aka Robert C. Skow; LaVonne Gitter-Skow; William C. Petry; Fern G. Petry; Lloyd A. Mackey; Joyce A. Mackey; 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. The Plaintiff has started a lawsuit against you. The 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 Mill Street
Fergus Falls, MN 56537
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 Otter Tail County, State of Minnesota, legally described as follows:
See attached Exhibit A
The object of this action is to correct gaps in the chain of title caused by errors in past deeded transfers.
EXHIBIT A
Sub Lot "A" of Government Lot 1 of Section 14, Township 136, Range 43, Otter Tail County, Minnesota, EXCEPT tract platted as Subrosa Beach AND EXCEPT TRACT deeded to O.I. Sethre, filed for record in Book 146 of Deeds, page 202, described as follows: That part of Sub Lot "A" of Government Lot 1 of Section 14, Township 136, Range 43, described as follows: Beginning at a point 16 1/2 feet Southeast of stake in southwest corner of Lot 8, Subrosa Beach, directly across the Road in rear of said Subrosa Beach and in line with line between Lots 8 and 9 of said Subrosa Beach, thence running in a Southwesterly direction along Southeast side of said road 15 rods to a point where said road touches the south line of said Sublot "A" of Government Lot 1, thence running due East along south line of said Sublot "A" of Government Lot 1, 15 rods, thence in a northerly direction 8 rods and 15 feet to place of beginning.
AND
Tract B
That part of Government Lot 7 of Section 11, Township 136, Range 43, Otter Tail County, Minnesota, described by metes and bounds as follows, to wit: The point of commencement is ascertained by going from the Southeast corner of Lot 4 of Subrosa Beach according to the plat thereof on file and of record in the office of the County Recorder of Otter Tail County, Minnesota; thence Northeasterly on and along the Southerly line of Subrosa Beach 149.5 feet; thence due South 146 feet. Thence from this point of beginning due South 13 feet more or less to the Section line between Sections 11 and 14, said Township and Range; thence due West to the Southerly line of Subrosa Beach; thence in a Northeasterly direction on and along the Southerly line of Subrosa Beach to the Southeast corner of Lot 4 of said Subrosa Beach; thence Southeasterly in a straight line to the point of commencement, excepting therefrom portions thereof designated as public road in the plat of Subrosa Beach.
Together with a permanent easement for residential and recreational purposes across that part of Lot 7 of Subrosa Beach according to the plat thereof on file and of record with the Otter Tail County Recorder: Commencing at the southernmost corner of said Lot 7; thence in a northwesterly direction along the common boundary between Lot 7 and Lot 8 of Subrosa Beach a distance of 100 feet; thence northeasterly and parallel to the southeasterly line of said Lot 7 a distance of 40 feet; thence southeasterly and parallel to the common boundary between said Lot 7 and said Lot 8 a distance of 100 feet to the southeasterly line of said Lot 7; thence southwesterly on the southeasterly line of said Lot 7 a distance of 40 feet to the point of beginning.
Said easement does not include any lakeshore access, and no buildings may be placed on easement property without the prior written consent of the Grantors or future owners of
said Lot 7. This easement shall be a permanent easement that is appurtenant to the property being sold and shall run with said property.
DATED: January 24, 2025 KREKELBERG LAW FIRM
BY: Chad D. Miller
Attorney for Plaintiff
213 S. Mill Street
Fergus Falls, MN, 56537
(218) 739-4623
Attorney Reg. No. 386902
2-27-3-c
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