PUBLIC NOTICE

STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF FREEBORN
THIRD JUDICIAL DISTRICT
Case Type: Consumer
Credit Contract/
Replevin
21st Mortgage
Corporation,
Plaintiff,
v.
Paw Lah and Say Lah, and John Doe and Mary
Roe, whose true names are to Claimant
unknown Defendant.
Case No.: 24-CV-24-21
AMENDED NOTICE
OF MOTION AND
MOTION FOR SUMMARY
JUDGMENT

TO: All Counsel and Parties of Record and District Court Administrator.

NOTICE OF MOTION

PLEASE TAKE NOTICE that on the 25 th day of April, 2024 at 10:00 a.m., or as soon thereafter as counsel may be heard, Plaintiff, 21 st Mortgage Corporation by and through its undersigned attorneys, will make the following Motion for Summary Judgment before the Honorable Ross Leuning, Freeborn County District Court Judge in the District Court of Freeborn County. This hearing will be held via Zoom and appearance shall be by video or audio.

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Meeting ID: 160 674 1720
Passcode: 207191
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MOTION FOR SUMMARY JUDGMENT

Plaintiff, by and through its undersigned attorneys, hereby moves this Court for an Order granting Summary Judgment with respect to its replevin claim as it is undisputed that Paw Lah and Say Lah remain obligated to Plaintiff for breach of contract and Plaintiff is entitled to the following relief: 1) possession of the collateral; 2) to the extent Plaintiff has not sold the collateral pursuant to the contract and this Court’s prior orders, permission to sell the collateral at public or private sale; and 3) entry of a money judgment to the extent the sale proceeds are not sufficient to satisfy Defendant’s debt in full, but only to the extent permissible by state or federal law.

FOLEY & MANSFIELD PLLP
Dated: March 1, 2024
By: s/ Sean C. Mansfield
Sean C. Mansfield (#0400374)
250 Marquette Avenue, Suite 540 Minneapolis, MN 55401
Telephone: (612) 338-8788
Fax: (612) 338-8690
scmansfield@foleymansfield.com Attorneys for Plaintiff

Albert Lea Tribune:
Mar. 6, 13 and 20, 2024
24-CV-24-21