Probate & Trust Law Section Conference Manual ... - Minnesota CLE

hereinafter called the “subject property.”
IV.
Plaintiff Sally Doe and her sibling defendants each own an undivided one-fourth (1/4)
interest in the fee of the subject property.
V.
The subject property is improved with a residence homestead.
VI.
The subject property is encumbered by a mortgage with Wells Fargo of approximately
$40,000.
VII.
That the approximate cash value of the subject property is $200,000.
VIII.
The subject property is so situated that partition cannot be had without great prejudice to
the owner.
WHEREFORE, plaintiff prays as follows:
1. That this court order partition of said property.
2. That this court appoint three disinterested and judicious citizens of the County as
referees.
3. That the subject property of the parties be sold and the net equity be divided
equally between the sibling parties.
4. That the court ascertain administrative costs and award such costs and attorney’s
fees to Plaintiff Sally Doe.
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