STATE OF MINNESOTA COUNTY OF BELTRAMI DISTRICT COURT NINTH JUDICIAL DISTRICT Case type: Other civil (Declaratory Judgment) Barbara D.
STATE OF MINNESOTA
COUNTY OF BELTRAMI
NINTH JUDICIAL DISTRICT
Case type: Other civil
Barbara D. Lambert, individually and as Trustee of the Trust Agreement of Barbara D. Lambert dated January 9, 2014,
Anne K. Naumann, Michael Duncan Lambert, unknown heirs of Richard F. Lambert, and all other persons unknown claiming any right, title, estate, interest, or lien in the real estate described herein,
Court File No. 04-CV-21-2128
THIS SUMMONS IS DIRECTED TO THE ABOVE NAMED DEFENDANTS.
1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiff's Complaint against you is 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 21 DAYS TO PROTECT YOUR RIGHTS. You must give or mail to the person who signed this summons a written response called an Answer within 21 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
Beisel & Dunlevy, P.A.
730 Second Avenue South, Suite 282
Minneapolis, MN 55402-2444
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 21 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. This action involves, affects, or brings into question real property situated in the County of Beltrami, commonly known as commonly known as 23488 Star Island SE, Cass Lake, Minnesota 56633 and legally described as:
The East 75 feet of Lot 1, Section 35, Township 146, Range 31, Beltrami County, Minnesota, according to the US Government Survey thereof.
(referred to as the "Subject Property").
The purpose of this action is to obtain an Order as follows:
1.Reforming the Erroneous Deed, Document No. A000579642, so that the grantee is changed from "Richard F. Lambert and Barbara D. Lambert, as Trustees of the Trust Agreement of Barbara D. Lambert dated January 9, 2014" to "Richard F. Lambert and Barbara D. Lambert, as Trustees of the Trust Agreement of Richard F. Lambert dated January 9, 2014."
2.For such other and further relief as is deemed just by the Court.
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.
BEISEL & DUNLEVY, P.A.
Dated: August 18, 2021
By: /s/ Bradley N. Beisel
Bradley N. Beisel (#6191)
730 Second Avenue South, Suite 282
Minneapolis, MN 55402
Ph: (612) 767-4839
Attorneys for Plaintiff
(Aug. 25; Sept. 1 & 8, 2021) 2901346