STATE OF MINNESOTA COUNTY OF ST. LOUIS DISTRICT COURT SIXTH JUDICIAL DISTRICT CASE TYPE: OTHER CIVIL (Declaratory Judgment; Quiet Title) MidFirst Bank, Plaintiff, v. Chad A. Hinnenkamp; The Estate of Hilding Hakonsen, deceased; The Estate of Edel Hakonsen, deceased; and all heirs and devisees of any of the above-named persons who are deceased; and all other persons who are deceased; and all other persons or entities claiming any right, title, estate, lien or interest in the real estate described in the Summons and Complaint herein and all other persons unknown claiming any right, title, interest, estate in or lien upon the real estate hereinafter described, Defendants. Court File No.: 69DU-CV-22-243 SUMMONS THIS SUMMONS IS DIRECTED TO THE ABOVE NAMED DEFENDANTS. 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: Heley, Duncan & Melander, PLLP 8500 Normandale Lake Blvd., Suite 2110 Minneapolis, MN 55437 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. To be included only if this lawsuit affects title to real property: THIS LAWSUIT MAY AFFECT OR BRING INTO QUESTION TITLE TO REAL PROPERTY located in St. Louis County, Minnesota, legally described as follows: Lot 395 Block 170 Duluth Proper Second Division Except the West 23.05 feet thereof. (the “Torrens Property”) -And- West Twenty Three and One-Half feet (W 23.05’) of Lot Three Hundred Ninety Five (395) and East Two feet (E 2’) of Lot Three Hundred Ninety Seven (397), Block One Hundred Seventy (170), Duluth Proper Second Division. (the “Correct Abstract Property”) (Collectively, the “Property”). The object of this action is to obtain a court order and declaratory judgment as follows: 1. An order and declaratory judgment of this Court declaring Chad A. Hinnenkamp to be the fee owner of the Correct Abstract Property, free and clear of any interests of the Defendants. 2. An order and declaratory judgment of this Court determining all right, title, and interest in the Correct Abstract Property, if necessary. 3. An order of this Court reforming the mortgage encumbering the Property dated August 13, 2010, from Chad A. Hinnenkamp, a single man, as mortgagor, in favor or W.J. Bradley Mortgage Capital Corp., as lender, which mortgage was recorded with the Office of the St. Louis Registrar of Titles on December 8, 2010, as Document No. 893536, and with the Office of the St. Louis County Recorder on December 8, 2010, as Document No. 01150194 (“Mortgage”), and any assignments of the Mortgage, nunc pro tunc, so that it includes the legal description of the Correct Abstract Property. 4. For such other and further relief as this Court deems just and equitable. HELEY, DUNCAN & MELANDER, PLLP Dated: February 7, 2022 By /s/ Jeffrey A. Scott Jeffrey A. Scott (#0339416) 8500 Normandale Lake Boulevard Suite 2110 Minneapolis, Minnesota 55437 (952) 841-0001 Jscott@heleyduncan.com Attorneys for Plaintiff MidFirst Bank ACKNOWLEDGEMENT The undersigned hereby acknowledges that pursuant to Minn. Stat. § 549.211, subd. 2, costs, disbursements, and reasonable attorney and witness fees may be awarded to the opposing party or parties in this litigation if the court should find that the undersigned acted in bad faith, asserting a claim or defense that is frivolous and that is costly to the other party, asserted an unfounded position solely to delay the ordinary course of the proceedings or to harass, or committed a fraud upon the court. /s/ Jeffrey A. Scott Jeffrey A. Scott (Feb. 26; March 5 & 12, 2022) 36778