STATE OF WISCONSIN
CASE NUMBER: 2019CV000284
CASE TYPE: OTHER – REAL ESTATE
CASE CODE: 30405
Earl Allen Mork, Plaintiff,
Polk County, Involuntary Plaintiff,
The estate of Henry Cooper Oakey,
The heirs of Minnie Oakey,
NOTICE OF MOTION TO CORRECT LEGAL
TO: Polk County,
Malia Theresa Malone,
Polk County Corporation Counsel,
1005 West Main Street, Suite 100,
To: The estate of Henry Cooper Oakey
The heirs of Minnie Oakey
Be notified that the Plaintiff, Earl Allen Mork (“Plaintiff”), by his attorney Rory E. O’Sullivan, shall move the court, the Honorable Jeffery L. Anderson presiding, pursuant to Wis. Stat. § 847.07, at the Polk County Justice Center, 1005 West Main Street, Suite 300, Balsam Lake, WI 54810 on March 6, 2020, at 12:45 p.m., for a judgement in this matter, correcting the legal description of Lot 3 contained in a certified survey map dated July 24th, 1964 and received for recording with the Polk County Register of Deeds in volume 1 of Certified Survey Maps, page 61, as document number 306690 and, consequently, transferring to Plaintiff the following-described parcel of land:
Part of the SW 1/4 of the NE 1/4 of Section 1, T32N, R18W, Town of Osceola, Polk County, Wisconsin, including part of Lot 3 of a Certified Survey Map recorded in Volume 1 Page 61 of said maps as Document no. 306690 more particularly described as follows:
Commencing at the East 1/4 corner of said Section 1; thence along the East-West 1/4 line of Section 1, N 86°35’27”W a distance of 1627.32 feet;
thence N03°24’33”E a distance of 361.07 feet to the southeasterly line of Lot 3 of said Certified Survey Map;
thence along the southeasterly line of said Lot 3, N52°38’15”E a distance of 94.98 feet to the point of beginning;
Thence, N41°14’06”W a distance of 149.11 feet to the south right of way of County Road “K”;
Thence along said right of way, N89°05’48”W a distance of 42.00 feet;
Thence, N04°13’46”E a distance of 66.11 feet to the north right of way of County Road “K” and the beginning of a meander line on the southerly shore of Big Lake;
Thence, the following being along said right of way and said meander line, S89°05’48”E a distance of 43.87 feet;
Thence N86°55’37”E a distance of 72.51 feet;
Thence easterly along the arc of a curve, concave northerly, a distance of 36.76 feet, said curve having a radius of 394.14 feet a chord which bears N84°15’18”E a distance of 36.75 feet;
Thence leaving said right of way and said meander line, S19°43’01”E a distance of 67.11 feet;
Thence, S16°07’29”E a distance of 78.30 feet along the centerline of 180th street;
Thence, S52°38’15”W a distance of 77.78 feet to the point of beginning.
Including all lands lying between the above described meander line and the shore of Big Lake between a line that bears N04°13’46”E from the beginning of said meander line and a line that bears N19°43’01”W from the end of said meander line.
Containing 0.52 Acres, more or less.
Subject to the right of way for County Road “K” and 180th/ Street within the above described property and subject to all easements, restrictions and covenants of record.
The motion and its supporting documentation shall be filed in advance of the hearing and Plaintiff shall rely on those anticipated pleadings and on the arguments and evidence presented at the hearing.
A copy of the motion and the supporting documentation may be obtained either from the court, whose address is Polk County Justice Center, 1005 West Main Street, Suite 300, Balsam Lake, WI 54810 or from Plaintiff’s attorney, whose address is 219 N. Main Street, River Falls, WI 54022.
Dated this 14th day of January 2019.
Rodli, Beskar, Neuhaus, Murray & Pletcher, S.C.,
219 North Main Street,
P.O. Box 138,
/s/ Rory E. O’Sullivan
Rory E. O’Sullivan
Attorneys for Plaintiffs
Wisconsin State Bar No. 1088644
T: (715) 425-7281
F: (715) 425-7586