27-CV-24-16192
`
`Filed in District Court
`State of Minnesota
`10/23/2024 5:08 PM
`
`STATE OF MINNESOTA
`
`DISTRICT COURT
`
`FOURTH JUDICIAL DISTRICT
`COUNTY OF HENNEPIN
`______________________________________________________________________________
`
`CASE TYPE: Other Civil (Mortgage
`Foreclosure)
`
`COURT FILE NO:
`
`SUMMONS
`
`Coulee Bank,
`
`Plaintiff,
`
`v.
`
`
`
`Innovative Engineering Services, Inc.,
`The Heritage Hotel, LLC, Twin Cities
`Hospitality, LLC, Mohamed E. Elkhateeb,
`Shannon Foster Sandquist, and Equity Trust
`Company, Custodian FBO the Michael Louis
`Tracy IRA #200-266-859,
`
`Defendants.
`______________________________________________________________________________
`
`THIS SUMMONS IS DIRECTED TO THE FOLLOWING DEFENDANTS:
`
`INNOVATIVE ENGINEERING SERVICES, INC.; THE HERITAGE HOTEL, LLC; TWIN
`CITIES HOSPITALITY, LLC; MOHAMED E. ELKHATEEB; SHANNON FOSTER
`SANDQUIST; AND EQUITY TRUST COMPANY, CUSTODIAN FBO THE MICHAEL
`LOUIS TRACY IRA #200-266-859.
`
`1.
`
`YOU ARE BEING SUED. The Plaintiff, Coulee Bank, 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 from the date on which you received this Summons. You must send a copy of your
`
`Answer to the person who signed this Summons at the following address:
`
`29829659v3
`
`
`
`Filed in District Court
`State of Minnesota
`10/23/2024 5:08 PM
`
`STATE OF MINNESOTA
`
`DISTRICT COURT
`
`FOURTH JUDICIAL DISTRICT
`COUNTY OF HENNEPIN
`______________________________________________________________________________
`
`CASE TYPE: Other Civil (Mortgage
`Foreclosure)
`
`COURT FILE NO:
`
`SUMMONS
`
`Coulee Bank,
`
`Plaintiff,
`
`v.
`
`
`
`Innovative Engineering Services, Inc.,
`The Heritage Hotel, LLC, Twin Cities
`Hospitality, LLC, Mohamed E. Elkhateeb,
`Shannon Foster Sandquist, and Equity Trust
`Company, Custodian FBO the Michael Louis
`Tracy IRA #200-266-859,
`
`Defendants.
`______________________________________________________________________________
`
`THIS SUMMONS IS DIRECTED TO THE FOLLOWING DEFENDANTS:
`
`INNOVATIVE ENGINEERING SERVICES, INC.; THE HERITAGE HOTEL, LLC; TWIN
`CITIES HOSPITALITY, LLC; MOHAMED E. ELKHATEEB; SHANNON FOSTER
`SANDQUIST; AND EQUITY TRUST COMPANY, CUSTODIAN FBO THE MICHAEL
`LOUIS TRACY IRA #200-266-859.
`
`1.
`
`YOU ARE BEING SUED. The Plaintiff, Coulee Bank, 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 from the date on which you received this Summons. You must send a copy of your
`
`Answer to the person who signed this Summons at the following address:
`
`29829659v3
`
`
`
`27-CV-24-16192
`
`Filed in District Court
`State of Minnesota
`10/23/2024 5:08 PM
`
`WINTHROP & WEINSTINE, P.A.
`Attn: Andrew Steil
`225 South Sixth Street, Suite 3500
`Minneapolis, MN 55402
`
`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 AFFECTS OR BRINGS INTO QUESTION TITLE TO
`
`REAL PROPERTY located at 337 Oak Grove Street Minneapolis, MN 55403, tax parcel
`
`29829659v3
`
`-2-
`
`
`
`27-CV-24-16192
`
`Filed in District Court
`State of Minnesota
`10/23/2024 5:08 PM
`
`identification number of 27-029-24-32-0020 (“Innovative Real Property”), legally described as
`
`follows: The Northwesterly 10 feet of Lot 4, measured front and rear, and all of Lot 5, together
`
`with the Northeasterly half of the adjoining vacated alley lying between the extensions across it of
`
`the Southeasterly line of the Northwesterly 10 feet of Lot 4 and of the Northwesterly line of Lot
`
`5, all in Block 1, J.S. Johnson’s Subdivision of Lots P, Q, R, S and T of Johnson’s Addition to
`
`Minneapolis, Hennepin County, Minnesota
`
`The object of this lawsuit includes, among other things, the foreclosure of the following
`
`mortgage held by Plaintiff. A mortgage (“Innovative Mortgage”) dated March 24, 2021, that was
`
`recorded with the Office of the County Recorder in and for Hennepin County, as document
`
`number. 10936435, March 25, 2021. the Innovative Mortgage encumbers the Innovative Real
`
`Property.
`
`Dated: October 23, 2024
`
`WINTHROP & WEINSTINE, P.A.
`
`/s/ Andrew Steil
`Andrew J. Steil (#387048)
` asteil@winthrop.com
`William J. Schumacher (#0397267)
` wschumacher@winthrop.com
`Austyn K. Boothe (#403141)
` aboothe@winthrop.com
`225 South Sixth Street, Suite 3500
`Minneapolis, MN 55402
`Telephone: (612) 604-6400
`
`Attorneys for Plaintiff Coulee Bank
`
`ACKNOWLEDGMENT
`
`The undersigned hereby acknowledges that costs, disbursements, and reasonable attorney
`and witness fees may be awarded pursuant to Minn. Stat. § 549.211, subd. 2 for the party against
`whom the allegations in this pleading are asserted.
`
`29829659v3
`
`/s/ Andrew Steil
`Andrew J. Steil
`
`-3-
`
`
`
`27-CV-24-16192
`
`Filed in District Court
`State of Minnesota
`10/23/2024 5:08 PM
`
`IF PART OF THE PROPERTY TO BE SOLD CONTAINS YOUR HOUSE, YOU MAY DESIGNATE AN
`AREA AS A HOMESTEAD TO BE SOLD AND REDEEMED SEPARATELY.
`
`YOU MAY DESIGNATE THE HOUSE YOU OCCUPY AND ANY AMOUNT OF THE PROPERTY AS A
`HOMESTEAD. THE DESIGNATED HOMESTEAD PROPERTY MUST CONFORM TO THE LOCAL ZONING
`ORDINANCES AND BE COMPACT SO THAT IT DOES NOT UNREASONABLY REDUCE THE VALUE OF
`THE REMAINING PROPERTY.
`
`YOU MUST PROVIDE THE COURT WITH A LEGAL DESCRIPTION OF THE HOMESTEAD YOU
`HAVE DESIGNATED.
`
`29829659v3
`
`-4-
`
`
`
`27-CV-24-16192
`
`Filed in District Court
`State of Minnesota
`10/23/2024 5:08 PM
`
`IF THE PROPERTY TO BE SOLD CONTAINS SEPARATE TRACTS, YOU MAY REQUEST THAT THE
`TRACTS BE SOLD AND REDEEMED SEPARATELY. EACH OF THE SEPARATE TRACTS MUST
`CONFORM TO LOCAL ZONING ORDINANCES.
`
`YOU MUST PROVIDE THE COURT WITH A COPY OF THE LEGAL DESCRIPTIONS OF EACH OF THE
`TRACTS YOU HAVE DESIGNATED TO BE SOLD SEPARATELY
`
`29829191~v2
`
`29829659v3
`
`-5-
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
