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AMENDED SUMMONS Publish September 5,12, and 19, 2019 STATE OF MINNESOTA DISTRICT COURT COUNTY OF OTTER TAIL SEVENTH JUDICIAL DISTRICT Case type: Other civil (Reformation of Instrument) Court File No: 56-CV-19-1703 Wells Fargo Bank, N.

AMENDED SUMMONS
Publish September 5,12, and 19, 2019
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF OTTER TAIL SEVENTH JUDICIAL DISTRICT
Case type: Other civil (Reformation of Instrument)
Court File No: 56-CV-19-1703
Wells Fargo Bank, N.A.,
Plaintiff,
v.
Michael A. Parta, Janet M Parta,
Abigail Parta and the unknown heirs of June
Ardath Parta,
Defendants.
THIS AMENDED SUMMONS IS DIRECTED TO THE ABOVE NAMED DEFENDANTS;
1.  YOU ARE BEING SUED.  The Plaintiff has started a lawsuit against you.
The Plaintiff's Amended 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 Amended Summons.
2.  YOU MUST REPLY WITHIN 20 DAYS TO PROTECT YOUR RIGHTS.  You must give or mail to the person who signed this Amended Summons a written response called an Answer within 20 days of the date on which you received this Amended Summons. You must send a copy of your Answer to the person who signed this Amended Summons located at:
Bradley N. Beisel
Beisel & Dunlevy, P.A.
730 Second Avenue S., Suite 282
Minneapolis, MN 55402-2444
3.  YOU MUST RESPOND TO EACH CLAIM.  The Answer is your written response to the Plaintiff's Amended Complaint. In your Answer you must state whether you agree or disagree with each paragraph of the Amended Complaint. If you believe the Plaintiff should not be given everything asked for in the Amended Complaint, you must say so in your Answer.
4.  YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTEN RESPONSE TO THE AMENDED COMPLAINT TO THE PERSON WHO SIGNED THIS AMENDED 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 Amended Complaint. If you do not want to contest the claims stated in the Amended Complaint, you do not need to respond. A default judgment can then be entered against you for the relief requested in the Amended 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 Amended 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 situated in the County of Otter Tail, commonly known as 49436 Big Lake, Perham, Minnesota 56573, as:
Parcel 1: That part of Lot 5 and that part of Lot 6 of Big Pine Point, said plat is on file and of record in the office of the Recorder of Otter Tail County, Minnesota, and that part of Government Lot 3 of Section 15, Township 136 North, Range 38 West of the Fifth Principal Meridian in said County described as follows:
Commencing at an iron monument which designates the most northerly corner of said Lot 5; thence South 53 degrees 26 minutes 44 seconds West 57.29 feet on an assumed bearing along the northwesterly line of said Lot 5 to an iron monument, said point is the point of beginning; thence continuing South 53 degrees 26 minutes 44 seconds West 107.20 feet along the northwesterly lines of said Lot 5 and Lot 6 to an iron monument; thence South 37 degrees 18 minutes 42 seconds East 149.10 feet to an iron monument; thence continuing South 37 degrees 18 minutes 42 seconds East 22 feet, more or less, to the water’s edge of Big Pine Lake; thence northeasterly along the water’s edge of said Big Pine Lake to the intersection with a line which bears South 34 degrees 30 minutes 48 seconds East from the point of beginning; thence North 34 degrees 30 minutes 48 seconds West 17.40 feet, more or less, to an iron monument; thence continuing North 34 degrees 30 minutes 48 seconds West 144.96 feet to the point of beginning. (“Parcel 1”) Tax ID: 52000990259000
AND
Parcel 2: That part of Lot Six (6) of Big Pine Point, said plat being on file and of record in the office of the County Recorder of Otter Tail County, Minnesota, and that part of Government Lot Three (3) of Section Fifteen (15), Township One Hundred Thirty-six (136) North, Range Thirty-eight (38) West of the Fifth Principal Meridian in said County, described as follows:
Commencing at an iron monument which designates the most northerly corner of Lot 5 of said Big Pine Point, thence South 53 degrees 26 minutes 44 seconds West 57.29 feet on an assumed bearing along the northwesterly line of said Lot 5 to an iron monument; thence continuing South 53 degrees 26 minutes 44 seconds West 107.20 feet along the northwesterly lines of said Lot 5 and said Lot 6 to an iron monument; thence continuing South 53 degrees 26 minutes 44 seconds East 49.92 feet along the northwesterly line of said Lot 6 to the most westerly corner of said Lot 6, which is the point of beginning of the parcel to be described; thence North 53 degrees 26 minutes 44 seconds East 49.92 feet to an iron monument; thence South 37 degrees 18 minutes 42 seconds East 149.10 feet to an iron monument; thence continuing South 37 degrees18 minutes 42 seconds East 22 feet, more or less, to the water’s edge of Big Pine Lake; thence southwesterly along the water’s edge of said Big Pine Lake to the point of intersection with the southwesterly lines of said Lot 6, extended southerly, thence northwesterly along the southwesterly line of said Lot 6, and the extension thereof, to the point of beginning. (“Parcel 2”)
Tax ID: 52000990259000
Parcel 3: That part of Government Lot 3 of Section 15, Township 136 North, Range 38 West of the Fifth Principal Meridian in Otter Tail County, Minnesota, described as follows:
Commencing at the northwesterly corner of Lot 12 of Big Pine Point, said plat is on file and of record in the office of the County Recorder of said county from which the westerly line of said Lot 12 bears South 23º 58’ 18” West on an assumed bearing; thence North 23º 58’ 18” East 241.57 feet to an iron monument; thence North 83º 29’ 05” East 86.51 feet to an iron monument; thence South 71º 30’ 55” East 355.22 feet to an iron monument; thence North 00º 31’ 30” West 43.35 feet to the point of beginning; thence South 00º 31’ 30” East 43.35 feet to an iron monument; thence continuing South 00º 31’ 30” East 114.45 feet to an iron monument ; thence continuing South 00º 31’ 30” East 176.21 feet to an iron monument on the northerly line of a Public Road according to said Big Pine Point; thence North 53º 26’ 44” East 107.30 feet along the northerly line of said Public Road to an iron monument; thence North 00º 31’ 30” West 125.27 feet to an iron monument; thence North59º 32’ 35” East 176.27 feet to an iron monument; thence North 00º 31’ 30” West 230.00 feet to an iron monument; thence continuing North 00º 31’ 30” West 40.00 feet to an iron monument; thence continuing North 00º 31’ 30” West 250 feet, more or less, to the north line of said Government Lot 3; thence westerly along the north line of said Government Lot 3 to the intersection with a line which bears North 00º 31’ 30” West from the point of beginning; thence South 00º 31’ 30” East 460 feet, more or less, to the point of beginning.
SUBJECT TO, AND TOGETHER WITH a 20.00 foot wide easement for road purposes over and under and across part of above described tract and over, under and across part of said Government Lot 3. The centerline of said 20.00 foot wide road easement is described as follows: Beginning at the aforementioned point of beginning; thence North 53º 37’ 55” East 132.49 feet; thence North 47º 31’ 39” East 161.27 feet; thence northeasterly on a curve concave to the southeast, having a central angle of 27º 50’ 57” and a radius of 260 feet, for a distance of 126.38 feet (chord bearing North 61º 27’ 07” East); thence North 75º 22’ 36” East 165 feet; thence North 69º 15’30” East 92 feet, more or less to the east line of said Government Lot 3 and said centerline there terminates. At the point of beginning of said centerline the sidelines of said easement shall be prolonged or shortened to terminate on a line which bears N 00º 31’ 30” West and South 00º 31’ 30” East from said point of beginning. At the point of termination of said centerline and the sidelines of said easement shall be prolonged or shortened to terminate on the east line of said Government Lot 3. (“Parcel 3”)
Tax ID: 52000150102000
(referred to as the “Subject Property”) The Subject Property is depicted in Exhibit A attached to the Amended Complaint.
The purpose of this action is to obtain an Order for the following relief:
1. Reforming the Wells Fargo Mortgage, Document No. 1092930, nunc pro tunc, so that the legal description of the property conveyed is changed from the incomplete legal description set forth in the Mortgage to the complete legal description set forth above.
2. Determining that the Wells Fargo Mortgage, as reformed herein, is in all respects prior and superior to the Junior Mortgage, Document No. 1220312.
3. For such other and further relief as the Court may deem just and equitable.
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 27, 2019 By /s/ Bradley N. Beisel
Bradley N. Beisel (#6191)
730 Second Avenue South, Suite 282
Minneapolis, MN 55402
Ph: (612) 436-2222
bradb@bdmnlaw.com
Attorneys for Plaintiff
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