Shirley A. Bierbaum, as Trustee of the SHIRLEY A BIERBAUM Trust under Agreement dated September 9, 2009,
Plaintiff,
vs.
Keith A. Britton (a/k/a Keith Arthur Britton); Carmen Lynn Britton; Charles Carpenter; Dorothy Carpenter; Phillip B. Smith and Sharyll A. Smith, as Trustees under the Phillip B. and Sharyll A. Smith Family Trust Agreement dated March 1, 2003; Anthony J. Stoffel; Cindy Lou Stoffel; Kathy S. Buckman as Trustee of the Kathy S. Buckman Trust under agreement dated May 20, 2014; Arrowhead Electric Cooperative, Inc., Schroeder Township; a Minnesota Corporation; Mortgage Electronic Registration Systems, Inc.; U.S. Bank National Association N.D.; State of Minnesota and all persons known or unknown claiming any right, title, estate, interest, or lien in the real estate described in the complaint herein,
SUMMONS
THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANT:
You are hereby summoned and required to serve upon plaintiff’s attorney an answer to the Complaint which is on file in the Office of the Court Administrator of the above-named Court within twenty-one (21) days after service of this Summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the Complaint.
This Action involves, affects, or brings in question real property situated in the County of Cook, State of Minnesota, described as follows, to-wit:
SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT A
NOTICE IS FURTHER GIVEN that the object of said action is to obtain a judgment declaring that plaintiff is the owner in fee of the property described above, subject only to the interests of defendants set forth in the complaint, and that the defendants, and each of them, have no right, title, estate, interest, or lien in or upon said real estate, except as set forth in the complaint.
NOTICE IS FURTHER GIVEN that no personal claim is made by plaintiff against the defendants.
Civil cases are subject to Alternative Dispute Resolution processes as provided in Rule 114 of the General Rules of Practice of the District Courts. Alternative Dispute Resolution includes mediation, arbitration, and other processes set forth in the rules. You may contact the Court Administrator for information about these processes and about resources available in your area.
SMITH LAW, PLLC
Dated: February 13, 2025
By: /s/ Richard Furlong
Tyson Smith (# 0395670)
Richard T Furlong III (#0403157)
1710 W. Hwy. 61, P.O. Box 66
Grand Marais, MN 55604
(218) 387-9800
tyson@arrowheadlegal.com
rich@arrowheadlegal.com
Attorneys for Plaintiff
EXHIBIT A
That part of Government Lot 4, Section 31, Township 59 North, Range 4 West, Cook County, Minnesota described as follows:
COMMENCING at the West Quarter Corner of Section 31 as marked by an iron pipe; thence South 00 degrees 47 minutes 46 seconds West, assumed bearing, along west line of Section 34. a distance of 1309.57 feet to the Northwest corner of Government Lot 4 and the POINT OF BEGINNING of the parcel to be herein described; thence South 89 degrees 28 minutes 57 seconds East along the north line of said Government Lot 4, a distance of 203.50 feet; thence South 00 degrees 47 minutes 46 seconds West 54.00 feet; thence South 29 degrees 22 minutes 24 seconds West 22.08 feet; thence South 21 degrees 20 minutes 06 seconds East 28.04 feet; thence South 00 degrees 47 minutes 46 seconds West 142.51; thence South 25 degrees 33 minutes 21 seconds East 202.06 feet; thence South 31 degrees 08 minutes 20 seconds East 112.55 feet to the northerly line of Minnesota Department of Transportation right of Way Plat No. 16-1 as on file and of record as Document No. 83998 in the office of the Cook County Recorder; thence South 60 degrees 43 minutes 34 seconds West along said northerly line 111.69 feet to Minnesota Department of Transportation right of Way Monument B21; thence South 29 degrees 16 minutes 27 seconds East along said northerly line 26.18 feet to Minnesota Department of Transportation Right of Way Monument B20; thence South 57 degrees 29 minutes 45 seconds West along said northerly line 92.65 feet; thence North 31 degrees 03 minutes 21 seconds West 186.47 feet; thence South 58 degrees 51 minutes 39 seconds West 109.98 feet to the west line of said Lot 4; thence North 00 degrees 47 minutes 46 seconds East along said west line, a distance of 546.74 feet to the Northwest corner of Government Lot 4 and the POINT OF BEGINNING.
Subject to a 24.0-foot-wide easement lying 12 feet on either side of the centerline legally described as follows:
A 24.00 foot wide easement located withing Government Lot 4, Section 31, Township 59 North, Range 4 West being 12.00 feet on each side of a centerline which is legally described as follows:
COMMENCING at the West Quarter Corner of Section 31 as marked by an iron pipe; thence South 00 degrees 47 minutes 46 seconds West, assumed bearing, along west line of Section 34, a distance of 1309.57 feet to the Northwest corner of Government Lot 4; thence South 89 degrees 28 minutes 57 seconds East along the north line of said Government Lot 4, a distance of 203.50 feet; thence South 00 degrees 47 minutes 46 seconds West 241.87 feet; thence South 25 degrees 33 minutes 21 seconds East 63.91 feet to the POINT OF BEGINNING of the centerline to be herein described; thence South 58 degrees 34 minutes 14 seconds West 96.44 feet; thence South 54 degrees 17 minutes 56 seconds West 89.65 feet; thence South 63 degrees 31 minutes 44 seconds West 73.00 feet, more or less, to the centerline of Skou Road and there terminating.
Further subject to a 33.0-foot-wide easement in favor of the public lying 16.5 feet on either side of the centerline legally described as follows:
Beginning at the end of Skou Road, (Township Road 2), as it is described and recorded in the office of the Cook County Recorder, as Schroeder Township Road Easement Map No. 1; thence North 00 degrees 00 minutes 30 seconds East on the extension of the Skou Road center line 18 feet more or less to the North line of Government Lot 4 and there terminating. Further subject to and together with an easement for Skou Road as set forth in Document No. 83124, in the Office of the Cook County, Minnesota Recorder, and legally described as follows:
Commencing at the West 1/4 corner of Section 31, Township 59 North, Range 4 West, Cook County, Minnesota; thence South 00 degrees 00 minutes, 00 seconds West, assumed bearing, along the West line of said Section 31 a distance of 1327.1 feet; thence East 4.9 feet to the end of Township Road No. 2 and point of beginning of the centerline to be herein described; thence South 00 degrees 00 minutes 30 seconds West 641.9 feet; thence South 04 degrees 38 minutes 52 seconds East 191.7 feet to the North right of way of Trunk Highway No.61 and there terminating. Located within Gov’t Lot 4, Section 31, T.59 N., R. 4 W. and SE 1/4 – SE 1/4, Section 36, T.59 N., R.5 W.
Further subject to an easement for public utilities in favor of Arrowhead Electric Cooperative, Inc., as set forth in Document Nos. 140211, in the Office of the Cook County, Minnesota Recorder.
