Jerald Morse – Plaintiff vs. Hester Morse Doe Rowe – SummonsFree Access

State of Minnesota
County of Jackson
In District Court
Fifth Judicial District
Case Type: Adverse Title Claim
Court File No. 32-CV-21-111

Jerald Morse, Plaintiff,
Barbara Hester, Michele Morse, John Doe, Mary Rowe, and all other person’s unknown claiming any right, title, estate, interest, or lien in the real estate described in the Complaint herein, Defendant(s).



1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiff’s Complaint against you is attached to this Summons. This summons is an official document from the Court that affects 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:

Southern Minnesota Regional Legal Services, Inc.
1567 North McMillan Street, Suite 6
Worthington, MN 56187

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 described as follows: Lot One (1) and a strip of land 20 feet wide and 4 inches wide along the North side of said Lot One (1) Block Nineteen (19) in Griffin’s Addition to the Village (now City) of Lakefield, in Jackson County, Minnesota.

The object of this action is, in part, to obtain a declaratory judgment regarding the validity of a purported quitclaim deed filed with the Jackson County Record’s Office on April 19, 2021.
The undersigned hereby acknowledges that sanctions may be awarded pursuant to Minn. Stat. § 549.211.
Dated this 31st day of
October 2021
Nobles County,
State of Minnesota

Jason G. Jack #0402115
Southern Minnesota Regional Legal Services, Inc.
Attorneys for Plaintiff
1567 North McMillan Street, Suite 6
Worthington, MN 56187
Phone: 507-372-7368
Fax: 507-372-2574
(Jan. 13)

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