Case type: Other civil
(Quiet Title)
Court File No. 13-CV-14-595
Wells Fargo Bank, N.A. as successor by merger to Wells Fargo Home Mortgage, Inc.,
Garry Wordelman, Kathy Wordelman, Michael D. Deluney, Kenneth R. Deluney, Stephen L. Deluney, Susan M. Deluney, and the unknown heirs of Leo R. Deluney, and any unknown person claiming any right, title, estate, interest or lien upon the property described in the action,
1. YOU ARE BEING SUED. The Plaintiff has 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
Beisel & Dunlevy, P.A.
730 Second Ave. S.
Suite 282
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 Chisago, commonly known as 39052 Mica Avenue, North Branch, MN 55056, and legally described as:
Lot 3, Block 1, Petrowske Estates, Chisago County, Minnesota.
(referred to as the Subject Property).
The purpose of this action is to obtain an Order for the following relief:
1. Reforming the Deed dated June 30, 2004 and recorded on August 8, 2004 as Document No. A434150 nunc pro tunc, to list the grantees as Leo R. Deluney and Marion J. Deluney as Joint Tenants.
2. Determining that Marion J. Deluney became the owner of the Subject Property as the surviving joint tenant by operation of law upon the death of Leo R. Deluney on June 8, 2011.
3. Determining that Marion J. Deluney is the fee owner of the Subject Property, free of any right, title or interest in any of the above named defendants.
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: August 6, 2014
By: /s/ Bradley N. Beisel #6191
730 Second Avenue South
Suite 282
Minneapolis, MN 55402-2444
Telephone: (612) 436-2222
Attorneys for Plaintiff
Published in the
ECM Post Review
August 13, 20, 27, 2014

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