STATE OF MINNESOTA COUNTY OF FARIBAULT

IN DISTRICT COURT

FIFTH JUDICIAL DISTRICT

Court File No.: 22-CV-23-477

Judge: Troy G. Timmerman

Case Type: Other Civil

Trish A. Matter, Plaintiff,

vs.

Cory T. Hansen, Defendant.

COMPLAINT

Plaintiff, Trish A. Matter, by and through her attorney, Andrew J. Moeller, who states and alleges as follows:

1. Plaintiff, Trish A. Matter, is a natural person located at 11965 450th Ave, Blue Earth, MN, 56013.

2. Defendant, Cory T Hansen, is a natural person located at 4342 480th Ave., Frost MN 56033.

3. Both parties live and reside in Faribault County, Minnesota. The causes of action arose in Faribault County. The appropriate venue is Faribault County.

4. Plaintiff and Defendant were in a romantic relationship from 2007 to December 2022.

5. Plaintiff and Defendant closed on a home on or about October 31, 2012, and moved into the home around said date.

6. The home has both parties on the title and mortgage of the real property, and the real property is not encumbered by a mortgage.

7. The property in question is 4342 480th Ave., Frost, MN 56033, and legally described as:

Beginning at the Northwest Corner of the Southwest Quarter (SW 1/4) of Section Thirteen (13) in Township One Hundred One (101) North, Range Twenty-six (26) West of the Fifth Principal Meridian in Faribault County, Minnesota thence South along the West section line a distance of 400 feet to the point of beginning, thence continuing along the West section line a distance of 540 feet, thence East parallel with the North Section line, a distance of 425 feet, thence North parallel with the West Section line, a distance of 40 feet, thence West parallel with the South section line a distance of 425 feet to the point of beginning. Said tract contains approximately 5.21 acres.

8. The property has an initial value of $100,900 according to the 2023 Faribault County Property Tax Statement. However, the property likely has a much higher appraisal value due to improvements made to the property and real estate market forces.

9. The parties ended the romantic relationship around December 2022 but Defendant has continued to reside at the property.

10. Both parties contributed equally to the property.

11. Defendant has refused to response to Plaintiff’s July 14, 2023, letter and has continuously refused to cooperate regarding the status of the parties’ home.

12. Plaintiff requests that an appraisal of the property be ordered prior to the house being placed on the market for sale.

13. Plaintiff fears that Defendant will refuse to property maintain the property until he leaves and will refuse to cooperate in selling the home and dividing the proceeds in a just and equitable manner.

14. Plaintiff seeks to obtain her interest in the property.

COUNT I: PARTITION

15. Plaintiff restates and re-alleges paragraphs 1-14.

16. Pursuant to Minn. Stat. § 558.01 et seq., Plaintiff seeks to have the property sold as the real properly is so situated that a partition cannot be had without great prejudice to the owners and therefore the property should be sold at a private sale by a licensed realtor; or, alternatively, at a public auction.

17. Pursuant to Minn. Stat. § 558.14, Plaintiff is seeking to have a Referee appointed.

18. Wherefore, Plaintiff prays for the following:

a. Ordering the sale of the aforesaid real property at a private sale by a license realtor, or in the alternative, at a public auction.

b. Appointing a referee to sell the aforesaid real property.

c. Ordering that an appraisal of the real property be conducted prior to placing the property on the market for private sale by a licensed realtor.

d. Ordering the equal apportionment of all costs of the sale of the real estate to the owners herein.

e. Judgment awarding interest, costs, disbursements, and attorneys fees as allowed by law;

f. Ordering half of the net proceeds to both parties; and

g. any other relief the court deems equitable and just.

ACKNOWLEDGEMENT

The undersigned hereby acknowledges that costs, disbursements, and reasonable attorney fees may be awarded pursuant to Minn. Stat. § 549.211, subd. 2, to the party against whom the allegations in this pleading are asserted.

Dated: August 11, 2023 /s/

Andrew J. Moeller

Andrew J. Moeller (0401872)

amoeller@farrishlaw.com

Farrish Johnson Law Office, Chtd.

1907 Excel Drive

Mankato, MN 56001

Phone: 507.625.2525

Fax: 507.625.4394

Attorneys for Plaintiff

September 11, 18, 25, 2023

____________________________

STATE OF MINNESOTA

COUNTY OF FARIBAULT

IN DISTRICT COURT

FIFTH JUDICIAL DISTRICT

Case Type: Other Civil

Court File No.: 22-CV-23-477

Judge: Troy G. Timmerman

Trish A. Matter, Plaintiff,

vs.

Cory T. Hansen, Defendant.

SUMMONS

THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANT:

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:

Andrew J. Moeller

Farrish Johnson Law Office, Chtd.

1907 Excel Drive

Mankato, MN 56001

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.

Dated: August 11, 2023 /s/ Andrew J. Moeller

Andrew J. Moeller (0401872)

amoeller@farrishlaw.com

Farrish Johnson Law Office, Chtd.

1907 Excel Drive

Mankato, MN 56001

Phone: 507.625.2525

Fax: 507.625.4394

Attorneys for Plaintiff

Trish A. Matter

September 11, 18, 25, 2023

____________________________

OAH 71-0330-39445

STATE OF MINNESOTA

OFFICE OF

ADMINISTRATIVE

HEARINGS

In the Matter of the

Orderly Annexation of

Certain Real Property to the City of Blue Earth from

Blue Earth City Township

(MBAU Docket OA-123-7)

NOTICE OF HEARING

Notice is hereby given that a public hearing will be held on October 5, 2023, beginning at 10:30 a.m. at the Blue Earth Public Safety Center, 120 South Walnut Street, Blue Earth, Minnesota 56013, before Administrative Law Judge Jessica A. Palmer-Denig. The Administrative Law Judge will take comments from members of the public who wish to be heard regarding this matter beginning at 5:30 p.m. in the same location. Other participation by the public shall be governed by Minn. R. 6000.1200 (2023.

The hearing will be held to address City of Blue Earth (City) Resolution 23-08 seeking annexation of certain real property (Property) to the City from Blue Earth City Township (Township). At the hearing, all persons shall be given an opportunity to be heard orally and to submit written data, statements, or arguments concerning this matter. The hearing will be conducted pursuant to the procedures set out in Minn. R. ch. 6000 (2023), as supplemented by Minn. R. 1400.5010-.8400 (2023).

Interested persons may also submit written data, statements, or arguments concerning this matter to the Administrative Law Judge. Submissions may be made either by mail to the Office of Administrative Hearings, Attn: Star Holman, MBAU Administrator, PO Box 64620, St. Paul, Minnesota 55164-0620, or by email to star.holman@state.mn.us. All materials should be submitted so they are received by 4:30 p.m. on September 29, 2023, and such submissions shall include the docket number for this matter: OAH 71-0330-39445.

To date, the only party to this proceeding is the City. The City has requested an order authorizing the annexation of the Property from the Township.

David F. Frundt, Frundt, Lundquist & Gustafson, Ltd., appears on behalf of the City. David Klabunde, Town Board Chair, has participated on behalf of the Township, which may decide to become a party. Any other person, group of persons, or governmental agency residing in, owning property in, or exercising jurisdiction over the subject area, and who has a direct legal interest that will be affected by the outcome of this proceeding, may become a party to this matter by filing a notice of appearance no later than 4:30 p.m. on September 21, 2023. The cost of this proceeding will be apportioned among the parties.

The Property proposed for annexation is described as follows:

All of that part of the South Half of Section Six (6), Township One Hundred Two (102) North, Range Twenty-Seven (27) West, Faribault County, Minnesota, lying East of the Blue Earth River;

AND

All of that portion of the Southwest Quarter of Section Five (5), Township One Hundred Two (102) North, Range Twenty-Seven (27) West, Faribault County, Minnesota, now lying outside of the Corporate limits of the City of Blue Earth;

AND

All that portion of the North Half of Section Seven (7), Township One Hundred Two (102) North, Range Twenty-Seven (27) West, Faribault County, Minnesota, now lying North and East of the Blue Earth River;

AND

All that part of the Northwest Quarter of Section Eight (8), Township One Hundred Two (102) North, Range Twenty-Seven (27) West, Faribault County, Minnesota, lying East of the Blue Earth River and now lying outside of the Corporate limits of the City of Blue Earth.

After the presentation of testimony and other evidence is complete and the record is closed, the Administrative Law Judge will issue findings and an order in accordance with Minn. Stat. ch. 414 (2022).

Any questions concerning the proposed annexation should be directed to Star Holman, MBAU Administrator, at star.holman@state.mn.us or (651) 361-7909.

Any party who needs a reasonable accommodation for a disability or an interpreter in order to participate in the hearing should submit a request in writing to the Office of Administrative Hearings. A person seeking an accommodation for a disability should complete the Office of Administrative Hearings’ Reasonable Accommodation Request Form. A copy of the form can be found at: https://mn.gov/oah/lawyers-and-litigants/title-ii.jsp. Examples of reasonable accommodations include, but are not limited to, wheelchair accessibility, an American Sign Language interpreter, or Braille or large-print materials. Requests for an interpreter should be submitted to Star Holman at star.holman@state.mn.us. If any party requires an interpreter, the Administrative Law Judge must be promptly notified so that appropriate arrangements can be made.

Dated: September 6, 2023

JESSICA A. PALMER-DENIG

Administrative Law Judge

September 18, 25, 2023

____________________________

PUBLIC HEARING NOTICE

The Blue Earth Housing and Redevelopment Authority (HRA) is seeking proposals from qualified contractors for the removal of trees and brush at 926 S Galbraith Street. The HRA expects to select a contractor by October 10, 2023. Proposals must be submitted to City Administrator, Mary Kennedy at City Hall by Friday, September 29, 2023, at 4:00 pm. The full RFP can be found on the city’s website at www.becity.org.

September 18, 25, 2023

____________________________

STATE OF MINNESOTA

COUNTY OF FARIBAULT

FIFTH JUDICIAL DISTRICT

DISTRICT COURT

PROBATE DIVISION

Court File No. 22-PR-23-520

Estate of

ARTHUR WILLIAM ALLIS,

Decedent

NOTICE AND ORDER OF HEARING ON PETITION FOR FORMAL ADJUDICATION OF

INTESTACY, DETERMINATION OF HEIRSHIP,

APPOINTMENT OF PERSONAL REPRESENTATIVE AND NOTICE TO CREDITORS

It is Ordered and Notice is given that on October 17, 2023 at 10:30 a.m., a hearing will be held in this Court at 415 North Main Street, Blue Earth, Minnesota, for the adjudication of intestacy and determination of heirship of the Decedent, and for the appointment of Reed Allis, whose address is 40 Tenth Street SE #4, Wells, MN, 56097 as Personal Representative of the Estate of the Decedent in an UNSUPERVISED administration. Any objections to the petition must be filed with the Court prior to or raised at the hearing. If proper and if no objections are filed or raised, the Personal Representative will be appointed with full power to administer the Estate, including the power to collect all assets, to pay all legal debts, claims, taxes and expenses, to sell real and personal property, and to do all necessary acts for the Estate.

Notice is also given that (subject to Minnesota Statutes section 524.3-801) all creditors having claims against the Estate are required to present the claims to the Personal Representative or to the Court Administrator within four months after the date of this Notice or the claims will be barred.

BY THE COURT

Dated: 09/14/2023

Troy G. Timmerman

Judge of District Court

Kelly Iverson

Court Administrator

Attorney for Petitioner

Abby Leach Schumaker

Leach Law, PLLC

1206 West Front Street,

Unit #5

Albert Lea, MN, 56007

Attorney License No: 0398442

Telephone: (507) 369-5953

Email:

abby@leachlawalbertlea.com

September 25, October 2, 2023

____________________________

STATE OF MINNESOTA

COUNTY OF FARIBAULT

FIFTH JUDICIAL DISTRICT

DISTRICT COURT

PROBATE DIVISION

Court File No. 22-PR-23-525

Estate of

Merlin Gene Larson,

Decedent

NOTICE AND ORDER FOR HEARING ON PETITION FOR DESCENT OF PROPERTY

A Petition for Determination of Descent has been filed with this Court. The Petition represents that the Decedent died more than three years ago, leaving property in Minnesota and requests the probate of Decedent’s

last Will (if any), and the descent of such property be determined and assigned by this Court to the persons entitled to the property.

Any objections to the Petition must be filed with the Court prior to or raised at the hearing. If proper, and no objections are filed or raised, the Petition may be granted.

IT IS ORDERED and Notice is further given, that the Petition will be heard on October 17, 2023, at

10:30 AM, by this Court at 415 N. Main St., Blue Earth, Minnesota.

1. Notice shall be given to all interested persons (MINN. STAT. § 524.1-401) and persons who have filed a demand for notice pursuant to Minnesota Statutes section 524.3-204.

2. Notice shall be given by publishing this Notice and Order as provided by law and by: Mailing a copy of this Notice and Order at least 14 days prior to the hearing date.

BY THE COURT

Dated: 09/18/2023

Troy G. Timmerman

Judge of District Court

Kelly Iverson

Court Administrator

Attorney for Petitioner

David F. Frundt

FRUNDT, LUNDQUIST & GUSTAFSON, LTD.

117 W. 5th St., PO Box 95

Blue Earth, MN, 56013

Attorney License No: 028550X

Telephone: (507) 526-2177

FAX: (507) 526-4477

Email: dfrundt@flglawfirm.com

September 25, October 2, 2023

____________________________

FARIBAULT COUNTY

BOARD OF COMMISSIONERS

SYNOPSIS

SEPTEMBER 5, 2023

1. All members present. The pledge of allegiance was recited.

2. Approved synopsis and official proceedings the August 15, 2023 regular and drainage meetings.

3. Approved the amended agenda of September 5, 2023.

4. Adopted the Meeting Protocol and Rules of Decorum as amended.

5. Approved the Solid Waste Collection and Transportation License for Roll-Pro, LLC for the remainder of 2023.

6. Approved a cell phone stipend for Tyler Stallman.

7. Approved the hire of Broden Thompson as a full-time dispatch/jailer.

8. Approved Resolution 23-CB-76 to adopt and implement the Le Sueur River Watershed Comprehensive Management Plan. All voted yes.

9. Approved the Le Sueur River Watershed Collaboration Joint Powers Agreement.

10. Approved the Policy Advisory Committee Bylaws of the Le Sueur River Watershed Collaboration Joint Powers Agreement.

11. Approved Resolution 23-RB06-75 accepting the 2022 Bridge Project as complete and authorizing payment to Midwest Contracting, LLC. All voted yes.

12. Accepted a Certificate of Substantial Completion from Century Construction and Associated Mechanical for the courthouse HVAC project.

13. Set a tax abatement hearing at 9:45am on October 3, 2023, for parcel 30.591.0220 in the City of Wells.

14. Appointed Joel Sonnek to the EDA board for a term ending 12/31/2027.

15. Approved a Memorandum of Agreement with the International Union of Operating Engineers Local #49.

16. Approved the County Coordinator as a temporary signer for any documents which require the signature of the County Auditor or Treasurer until an Auditor/Treasurer is hired.

17. Approved an SSTS loan in the amount of $8,124.28 and SSTS grants in the amount of $4,062.14 to Milden and Marlene Arndt for parcel 10.008.1500 in Emerald Township.

18. Approved the training request from J. Schmidtke to attend the Mn Assoc of County Veterans Service Officers Annual Fall Training in Nisswa.

19. Approved the training request from B. Bonin to attend a Basic Law Enforcement Sniper training course in Tekamah, NE.

20. Approved payment of the following bills: audit/auxiliary totaling $ 531,167.87.

Discussion was held concerning the following:

1. B. Bruegger spoke regarding windbreak requirements for hog sites during public comment.

2. A. Oeltjenbruns with the Southern Minnesota Initiative Foundation presented an update.

3. A. Geiger of Prairieland met regarding the 2024 Faribault County solid waste budget.

4. P. Krill met regarding the 2024 central services budget.

5. B. Baldwin met to discuss the petition submitted regarding the appointed office of auditor/treasurer.

6. B. Douglas & N. Carr met regarding the Le Sueur River One Watershed One Plan.

7. M. Daly met regarding Public Works.

Complete minutes are on file in the Central Services Office.

The meeting was recessed to September 19th, 2023.

Bruce Anderson, Chair

Sarah Van Moer,

Acting Clerk to the Board

September 25, 2023

____________________________

FARIBAULT COUNTY

BOARD OF COMMISSIONERS

SPECIAL MEETING

SYNOPSIS

SEPTEMBER 12, 2023

1. Commissioners Anderson, Groskreutz, Roper, and Young were present. Commissioner Loveall appeared via interactive technology.

2. The special meeting was called to order.

3. Approved making the County Coordinator position exempt.

4. Approved the hire of Brian Hov as County Coordinator.

5. Approved the draft of the coordinator job description as amended.

6. Approved renaming the Central Services Director position Human Resources Director and the draft of the job description as amended.

Discussion was held concerning the following:

1. The hire of the County Coordinator.

2. The job description of the County Coordinator.

3. The Central Services Director position, including job title and duties.

Complete minutes are on file in the Central Services Office.

The meeting was adjourned.

Bruce Anderson, Chair

Sarah Van Moer,

Acting Clerk to the Board

September 25, 2023

____________________________

NOTICE OF HEARING

FOR CONDITIONAL USE PERMIT REQUEST

#09-23-87

NOTICE IS HEREBY GIVEN that the Faribault County Planning Commission will meet on Tuesday, October 10, 2023, at 7:00 p.m. in the Conference Room of the Blue Earth Ag. Center, Blue Earth, MN.

The meeting agenda will include a Public Hearing on the application of Winnebago Solar & Storage/Ted Nagel for a Conditional Use Permit request.

Applicant is requesting Conditional Use Permit to install a temporary a MET Station for approximately a 12 month period, in A-2 Agriculture District.

The site is located at the following described property: That part of the North Half of the Northeast Quarter of Section 7, Township 103 North, Range 27 West, Faribault County, Minnesota, described as follows:

Commencing at the North Quarter corner of said Section 7; thence on an assumed bearing of North 88 degrees 51 minutes 42 seconds East, along the north line of said section, a distance of 805.85 feet to an iron monument, said iron monument being the point of beginning of the tract to be described; thence South 1 degree 08 minutes 18 seconds East a distance of 522.92 feet to an iron monument; thence North 88 degree 51 minutes 42 seconds East a distance of 910.14 feet to an iron monument; thence North 1 degree 08 minutes 18 seconds West a distance of 522.92 feet to an iron monument located on the north line of said section; thence South 88 degrees 51 minutes 42 seconds West, along said north line, a distance of 910.14 feet to the point of beginning, containing 10.93 acres, subject to easements now of record in said county and state.

All interested parties are encouraged to submit input prior to the Public Hearing in lieu of attending, parties can do so by emailing sara.hauskins@ co.faribault.mn.us, calling 507.526.2388, or sending a letter to Planning & Zoning at 415 South Grove St, Suite 8, Blue Earth, MN 56013.

Sara Hauskins

Faribault County Planning and Zoning Administrator

September 25, 2023

____________________________

NOTICE OF HEARING

FOR CONDITIONAL USE PERMIT REQUEST

#09-23-88

NOTICE IS HEREBY GIVEN that the Faribault County Planning Commission will meet on Tuesday, October 10, 2023, at 7:00 p.m. in the Conference Room of the Blue Earth Ag. Center, Blue Earth, MN.

The meeting agenda will include a Public Hearing on the application of Blue Earth Light & Water / Andrew Linder for a Conditional Use Permit request.

Applicant is requesting Conditional Use Permit to install & operate a 4 Mega Watt Solar Array, in A-2 Agriculture District.

The site is located at the following described property: That part of the Northwest Quarter of the Northwest Quarter of Section 5, Township 102 North, Range 27 West and the Southwest Quarter of the Southwest Quarter of Section 32, Township 103 North, Range 27 West all in Faribault County, Minnesota.

All interested parties are encouraged to submit input prior to the Public Hearing in lieu of attending, parties can do so by emailing sara.hauskins@ co.faribault.mn.us, calling 507.526.2388, or sending a letter to Planning & Zoning at 415 South Grove St, Suite 8, Blue Earth, MN 56013.

Sara Hauskins

Faribault County Planning and Zoning Administrator

September 25, 2023

____________________________

FARIBAULT COUNTY BOARD OF COMMISSIONERS

PUBLIC NOTICE

Notice is hereby given that a public hearing will take place on Tuesday, October 2 at 9:45 AM in the Board of Commissioners Room at the Faribault County Courthouse, 415 North Main Street, Blue Earth, MN 56013. The purpose of the hearing is to consider a property tax abatement for the county portion of tax on Parcel ID: 30.591.0220.

September 25, 2023

____________________________