STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF PENNINGTON
NINTH JUDICIAL DISTRICT
Court File No. 57-CV-25-768
Case Type: Other/Quiet Title Action
SUMMONS
RoxAnne Moen,
Plaintiff,
vs.
Patricia Erickson, also known as Patricia Kathleen Erickson, and the unknown heirs, and assigns of the above-named defendant(s) if deceased, and all other persons unknown claiming any right, title, estate, interest, encumbrance, or lien in the real estate described in the Complaint herein,
Defendants
THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANTS AND ALL OTHER PERSONS UNKNOWN CLAIMING ANY RIGHT, TITLE, ESTATE, INTEREST, OR LIEN IN THE REAL ESTATE DESCRIBED IN THE COMPLAINT.
1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiff’s Complaint against you is attached to this summons. 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: Stephen D. Larson, Harbott, Knutson, Larson & Holten, P.L.L.P., 201 North Broadway, Ste. 2, P.O. Box 457, Crookston, MN 56716.
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 questions title to real property located in Pennington County, State of Minnesota, legally described as follows:
—West Half of the Southeast Quarter (W1/2SE1/4), Section Nine (9), Township One Hundred Fifty-four (154) North, Range Forty-four (44) West of the Fifth Principal Meridian.
And
South Half of the Southeast Quarter (S1/2SE1/4), Section Thirty-three (33), Township One Hundred Fifty-three (153) North, Range Forty-four (44) West of the Fifth Principal Meridian.
And
A parcel of land which is part of Southeast Quarter (SE1/4) of Section Thirty-three (33), Township One Hundred Fifty-three (153) North of Range Forty-four (44) West of the Fifth Principal Meridian bounded as follows: Beginning at a point on the East line of said Section 33 lying 1,320’ North of the Southeast corner of said Section 33; thence westerly at right angles to said East line a distance of 608’; thence Northerly along a line parallel with the said East line of Section 33 a distance of 300’; thence Easterly along a line perpendicular to the said East line a distance of 608’; thence Southerly along the said East line of Section 33 a distance of 300’ to the point of beginning; containing 4.19 acres, more or less. Mineral rights are not included in this parcel. The land includes a perpetual right of way and easement to the use of the road presently laid out over and across the Southeast Quarter of Section Thirty-three and the Southwest Quarter of Section 44 in said Township.—
The object of this action is to determine the Plaintiff’s title and all their adverse claims to the above-described real property; adjudging that the Plaintiff owns said real property subject to no other interest; adjudging that Plaintiff is entitled to exclusive possession of said real property; and adjudging that each of the Defendants in said action have no right, title, estate, interest, or lien in the real property. The Plaintiff asserts no personal claims.
Dated: November 11, 2025.
HARBOTT, KNUTSON, LARSON
& HOLTEN P.L.L.P.
By /s/ Stephen D. Larson
Stephen D. Larson
Attorneys for Plaintiff
Bremer Bank Building
201 North Broadway, Ste. 2
PO Box 457
Crookston, MN 56716
(218) 281-4168
MN Atty. ID No. 0392782
slarson@nwmnlaw.com