Motion for Writ in Freedom Mortgage Corporation vs Julia Dosch, Northwest Minnesota Multi County Housing and Redevelopment Authority, Secretary of Housing and Urban Development| Trellis.Law

On June 24, 2024 a Complaint-Civil Index #1 was filed involving a dispute between Freedom Mortgage Corporation, and Dosch, Julia, Northwest Minnesota Multi County Housing And Redevelopment Authority, Secretary Of Housing And Urban Development, for Civil Other/Misc. in the District Court of Roseau County.

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68-CV-24-405
Filed in District Court
State of Minnesota
6/24/2024 11:03 AM

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF ROSEAU NINTH JUDICIAL DISTRICT

CASE TYPE: CIVIL OTHER/MISC

Freedom Mortgage Corporation,

Plaintiff,
COMPLAINT
vs.
Case No.:
Julia Dosch; Northwest Minnesota Multi County
Housing and Redevelopment Authority; Secretary
of Housing and Urban Development, an agency of
the United States Government; John Doe and
Mary Roe,

Defendants.

Plaintiff Freedom Mortgage Corporation (“Plaintiff” or “Freedom Mortgage Corporation”)

for its Complaint against the above-named Defendants alleges as follows:

1. Plaintiff holds a first-priority, mortgage lien interest in the real property located at

26575 County Rd 15, Roseau, MN 56751 and legally described as:

A parcel of land located in the Southeast Quarter of the Northeast Quarter (SE1/4
NE1/4), of Section Eight (8), Township One Hundred Sixty-one (161) North, Range
Forty (40) West of the Fifth Principal Meridian in Minnesota, according to the United
States Government Survey thereof, described as follows:

Beginning at the Southeast (SE) corner of said section, thence North Two Thousand
Seven Hundred Sixteen (2716) feet to the point of beginning, thence West Six
Hundred (600) feet, thence North Three Hundred Fifty (350) feet, thence East Six
Hundred (600) feet, thence South Three Hundred Fifty (350) feet to the point of
beginning and there terminating.

(the “Subject Property”).

2. Defendant Julia Dosch is the record owner of the Subject Property.

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3. Defendant Northwest Minnesota Multi County Housing and Redevelopment

Authority holds a junior mortgage encumbering the Subject Property, dated December 21, 2018, and

recorded with the Office of the Roseau County Recorder on December 26, 2018 as Document No.

294870.

4. Defendant Secretary of Housing and Urban Development, an agency of the United

States Government holds two, junior mortgages encumbering the Subject Property: the first dated

July 12, 2022, and recorded with the Office of the Roseau County Recorder on December 19, 2022

as Document No. 307691, and the second dated October 31, 2023, and recorded with the Office of

the Roseau County Recorder on November 30, 2023 as Document No. 309980.

5. Defendants John Doe and Mary Roe are any and all individuals, including spouses

(whose existence and identities are unknown to Plaintiff), who may hold an unrecorded interest in the

Subject Property.

6. On December 21, 2018, Julia Dosch executed a promissory note in favor Marketplace

Home Mortgage, L.L.C., in the original principal amount of $123,717.00 (the “Note”). The Note was

indorsed to the order of Pacific Union Financial, LLC and then in blank. Plaintiff, directly or through

an agent, holds the Note. A true and correct copy of the Note is attached to the Complaint as Exhibit

7. To secure repayment of the indebtedness evidenced by the Note, Julia Dosch executed

and delivered to Mortgage Electronic Registration Systems, Inc., as nominee for Marketplace Home

Mortgage, L.L.C., a mortgage encumbering the Subject Property dated December 21, 2018 and

recorded in the Office of the Roseau County Recorder on December 26, 2018 as Document No.

294869 (the “Mortgage”). A true and correct copy of the Mortgage is attached to the Complaint as

Exhibit B.

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68-CV-24-405
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6/24/2024 11:03 AM

8. The Mortgage was assigned to RoundPoint Mortgage Serving Corporation pursuant

to that assignment of mortgage recorded in the Office of the Roseau County Recorder on February

26, 2020 as Document No. 298315. A true and correct copy of the assignment of mortgage is attached

to the Complaint as Exhibit C.

9. The Mortgage was assigned to Plaintiff pursuant to that assignment of mortgage

recorded in the Office of the Roseau County Recorder on October 23, 2020 as Document No. 300516.

A true and correct copy of the assignment of mortgage is attached to the Complaint as Exhibit D.

CAUSE OF ACTION I
BREACH OF CONTRACT

10. Plaintiff incorporates the above paragraphs by reference herein.

11. The Note is in default due to non-payment of the sums due thereunder from January

1, 2024 to date. The unpaid principal balance due and owing on the Note and Mortgage is $113,993.92.

Plaintiff is entitled to collect all interest accruing from and after December 1, 2023, plus applicable

costs, fees, disbursements and attorneys’ fees due and owing under the Note and Mortgage.

12. Plaintiff has declared the entire unpaid principal balance of the Note together with all

accrued and unpaid interest thereon, and any other amounts owing under the Note and Mortgage, to

be due and payable in full.

CAUSE OF ACTION II
FORECLOSURE

13. Plaintiff incorporates the above paragraphs by reference herein.

14. The Mortgage is in default for non-payment of the sums due under the Note.

15. The terms of the Mortgage and Minn. Stat. § 581.03 provide that in the event of a

default under the Mortgage, the mortgaged premises may be sold at a foreclosure sale. The proceeds

of the sale shall be used to pay the amount owing in addition to costs and attorneys’ fees.

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16. No other action or proceeding at law has been instituted to recover the indebtedness

secured by the Note and Mortgage.

17. Plaintiff has complied with all pre-foreclosure notice and acceleration requirements

under the Mortgage.

WHEREFORE, Plaintiff respectfully requests that this Court enter judgment as follows:

1. Granting judgment against Julia Dosch in the amount due under the Note and Mortgage

which is comprised of the unpaid principal balance of $113,993.92, plus all interest accruing from

and after December 1, 2023, applicable costs, fees, disbursements, and attorneys’ fees.

2. Adjudging Plaintiff’s mortgage interest in the Subject Property to be prior, paramount,

and superior to any of Defendants’ liens.

3. Directing the Sheriff of Roseau County to conduct a sale of the Subject Property pursuant

to Minn. Stat. § 581.03 and apply the proceeds thereof to the amount due pursuant to the Note and

Mortgage plus interest, costs, disbursements, and attorneys’ fees.

4. Adjudging that the Subject Property may be redeemed from the sheriff’s sale within six

(6) months from the date of confirmation of sale.

5. For such other and further relief as the Court deems just and equitable.

TROTT LAW, P.C.

Dated: June 24, 2024 By: s/ Samuel R. Coleman
Samuel R. Coleman (#0389839)
Attorney for Plaintiff
25 Dale Street North
St. Paul, MN 55102
Telephone: (651) 209-9785
scoleman@trottlaw.com
(24-0563-LIT02)

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68-CV-24-405
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ACKNOWLEDGMENT

The undersigned acknowledges that costs, disbursements and reasonable attorney and witness

fees may be awarded against a party acting in bad faith pursuant to Minn. Stat. § 549.211.

TROTT LAW, P.C.

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68-CV-24-405
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Exhibit A
68-CV-24-405
Filed in District Court
State of Minnesota

'3,'
6/24/2024 11:03 AM
LOAN #z
MIN: 1002491aooo114493-5

NOTE FHA Case No.
I

December 21 , 2018 Edlna, Minnesota
[Date] [city] Isa-to]
26575 County Road 15, Roseau, MN 56751
[Ptoperty Address]

1. BORROWER'S PROMISE TO PAY
In return for a loan lhal have received, promise to pay U.S. $123,717.00
I I
(thls amount ls called 'Prlnclpal').
plus Interest. to the order of the Lender. The Lender is Marketplace Home Mortgage, L.L.c., a Llmlted Llablllty
Company.

I will make all payments under this Note In the fonn of cash. check or money order
I understand that the Lender
may transfer thls Note. The Lender or anyone who takes thls Note by transfer and who
ts entitled to receive payments under this Note is called the 'Note Holder. '

2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. will pay Interest at a I

yearly rate of 5.125 '/o.
The Interest rate required by this Section 2 ls the rate l will pay both before and alter any delauit described in Section
6(3) of this Note.
3. PAYMENTS
(A) Time and Place of Payments
will pay principal and Interest by making a payment every month.
I

wlIl make my monthly payment on the 1st
I
day oi each month beginning on February 1. 2019.
l will make these payments every month untll I have pald all of the principal and Interest and any other charges described
below that l may owe under this Note. Each monthly payment will be applied as of Its scheduled due date and wIII
be applied to interest and any other Items In the order described In the Security Instrument before Principal. II, on
l sIIII owe amounts under thls Note, l will
January 1, 2049. pay those amounts In full on that date, which Is
called the "Maturity Date."
IwIII make my monthly payments at 7380 France Avenue s. Suite 200
Edina, MN 55435
or at a different place If required by the Note Holder.
(B) Amount of Monthly Payments
My monthly payment will be in the amount of U.S. $673.62.

4. BORROWER'S RIGHT TO PREPAY
Ihave the right to make payments of Principal at any time before they are due. A payment of Principal only Is known
as a 'Prepayment.' When l make a Prepayment. will tell the Note Holder In writing that i am doing so. I may not designate
I

a payment as a Prepayment If l have not made all the monthly payments due under the Note.
I
may make a fuII Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use
my Prepayments to reduce the amount of Principal that I owe under this Note. However. the Note Holder may apply my
Prepayment to the accrued and unpaid Interest on the Prepayment amount. before applying my Prepayment to reduce the
Principal amount of the Note. If make a partial Prepayment, there will be no changes In the due date or In the amount of
I

my monthly payment unless the Note Holder agrees in writing to those changes.

5. LOAN CHARGES
If a law. which applies to this loan and which sets maximum loan charges. is ﬁnally interpreted so that the Interest or
other loan charges collected or to be collected In connection with this loan exceed the permitted limits. then: (a) any such
loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit: and (b) any sums already
collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund
by reducing the Principal owe under this Note or by making a direct payment to me. If a refund reduces Principal, the
I

reduction wllI be treated as a partial Prepayment.

6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
Ifthe Note Holder has not received the fuII amount of any monthly payment by the end of 15 calendar days after
the date it is due. will pay a late charge to the Note Holder. The amount of the charge will be 4.000 "In of my overdue
I

payment of principal and Interest. i will pay this late charge promptly but only once on each late payment.

(B) Default
If I do not pay the full amount of each monthly payment on the dale It Is due. lwlll be In default.
(C) Notice of Default
If I am in default. the Note Holder may send me a written notice telling me that It do not pay the overdue amount by a
I

certain date, the Note Holder may require me to pay Immediately the full amount of Principal which has not been paid and

utums'mre FIXED RATE More -
sangro Funny - Fanni- MuIFr-ddro use unrroau rnsrnuuarrr Form 3200 1m
Mounted tor FHA 9/15 (rev. 2/16)
Elite Mae, rne page 1 or 3 FHAazoonor 0216
FHAazoONo'r (cLS)
1212112015 07:23 AM Psr
68-CV-24-405
Filed in District Court
State of Minnesota
6/24/2024 11:03 AM
LOAN #:
all the inleresl that owe on lhal amounl. That dale must be al Ieasl 30 days aﬂer the date on which the nutim»
I tr; maitmt
lo me or delivered by other means.
(D) No Waiver By Note Holder
Even if. at a time when am in default, lhe Note Holder does not require me to pay immediately in full as described
l

above, the Note Holder will slill have the right to do so if am in default at a later time.
I

(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in lull as described above, the Note Holder will have the right
to be paid back by mo for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable
law. Those expenses include, for example, reasonable atlorneys' fees.

7. GIVING OF NOTICES
Unless applicable law requires a different method. any notice lhal must be given Io me under this Note will be given
by delivering it or by mailing it by ﬁrst class mail to rne at the Property Address above or at a different address if give I

the Note Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by ﬁrst
class mall to the Note Holder at the address stated in Section 3(A) above or at a different address if am given a notice I

of that different address,

8. OBLIGATIONS 0F PERSONS UNDER THIS NOTE
If more than one person signs this Note. each person is fully and personally obligated to keep all of the promises
made in this Note, including the promise lo pay the full amount owed. Any person who ls a guarantor, surety or endorser
of this Note is also obligated to do these things. Any person who takes over these obligations. including the obligations
of a guarantor. surely or endorser of this Note. is also obligated to keep all of the promises made in this Note. The Note
Holder may enforce its rights under this Note against each person individually or against all of us togetherv Thls means
that any one of us may be required to pay all of the amounts owed under this Note.

9. WAIVERS
and any other person who has obligations under this Note waive the rights of Presenlment and Notice of Dishonor.
|

'Presentment' means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor"
means the right to require the Note Holder to give notice to other persons that amounts due have not been paid.

10. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to
the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"). dated the same
date as this Note, protects the Note Holder from possible losses which might result If do not keep the promises which
l I

make in this Note. That Security Instrument describes how and under what conditions may be required to make immediate
l

payment in full of all amounts owe under this Note. Some oi those conditions are described as follows:
l

If all or any part of the Property or any Interest In the Property is sold or transferred (or if Borrower is not a
natural person and a beneﬁcial interest in Borrower is sold or transferred) without Lender's prior written consent.
Lender may require immediate payment in full of all sums secured by this Security instrument. However. this
option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option. Lender shall give Borrower notice of acceleration. The notice shall provide
a period of not less than 30 days from the date the notice is given in accordance with Section M within which
Borrower must pay ail sums secured by this Security instrument. if Borrower fails to pay these sums prior to the
expiration of this period. Lender may invoke any remedies permitted by this Security Instrument without further
notice or demand on Borrower.

WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED.

jﬂaﬂwx
JJ" A DoscH
(Seal)

'r'ﬂy to the or", .3 g6
Without
FM
Resouréel'
N x._
Lender: Marketplace Home Mortgage. L.L.C.
NMLS ID:. 1082
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DeWayne Jensen
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Exeoclanve Vice president ((g'
hﬁfsolgglsgztsosr'zh'd'ew
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[Sign Original Only]
MULTrsrArE FIXED RATE NOTE Single Family Fannie MaeIFreddre Mnc UNIFORM INSTRUMENT
- -
Fonn 3200 1/01
Modiﬁed {or FHA 9/15 (my. 2/16)
Elite Mae, Inc.
page 2 of 3 FHA3200N0T 0216
FHAazoONor (CLS)
1212112018 07:28 AM PST
68-CV-24-405
Filed in District Court
State of Minnesota
LOAN 6/24/2024 11:03 AM

PAY TO THE ORDER OF:
m ,
LLC

WlﬂIout Rocoum

BY:

TITLE:

[Sign Orlglnal Only]

InumsrA'rE FIXED RATE NOTE Single FamIIy - Flnnh MuIFraddh Nae UNIFORM INSTRUMENT
-
Fm 3200 1101
Modiﬁed for FHA 9115(m 2/16)
Ellie Mae. Inc. Page 3 of 3 FHA3200NOT 0216
FHA3200NOT (CLS)
1212112018 07:23 AM PST
68-CV-24-405
Filed in District Court
State of Minnesota
6/24/2024 11:03 AM

ALLONGE TO NOTE

Date of Note: 12/21/2018

Mortgagor(s): Julia Dosch

Property Address: 26575 County Road 15
Roseau, MN 56751

Loan Amount: $123,717.00

Loan Number:
_
PAY T0 THE ORDER OF:

Fimrm'* LLC
Faerie Union

WITHOUT RECOURSE

Marketplace Home Mortgage, L.L.C.,
A Limited Liability Company

wgﬂﬂ
Chris Royal, Ch'réCompliance Ofﬁcer & General Counsel
68-CV-24-405
Filed in District Court
State of Minnesota
6/24/2024 11:03 AM
68-CV-24-405
Filed in District Court

lélgé
State of Minnesota
6/24/2024 11:03 AM

Mr Cooper Loan #:
ALLONGE
V¥4f
Loan Number:

Borrower(s): Julia Dosch

Property Address: 26575 County Road 15, Roseau, MN 56751

Principal Balance: $123,717.00

Note Date: December 21, 2018

PAY TO THE ORDER OF

Without Recourse

Company Name: Nationstar Mortgage, LLC D/ BIA Mr. Cooper

By: 93
Steve Davenport
Manager, Production Ops Team
68-CV-24-405
Filed in District Court
State of Minnesota
6/24/2024 11:03 AM

Exhibit B
68-CV-24-405
Filed in District Court
State of Minnesota
6/24/2024 11:03 AM

Doc No 294869
Certified ﬁled and/or recomd on
12/26/18 10:00 AM
Ofﬁce of the County Recorder
Roseau County. Minnesota
Pamela S. Grand. County Recorder
When recorded, return to:
Marketplace Home Mortgage, L.L.C. Deputy BLM Pkg ID 47009
Attn: Final Document Department Doc Name: "M9899
clo DocProbe
1125 Ocean Avenue Document Recording Fee $46.00
Lakewood, NJ 08701 Document Total $46.00

puddleﬂawyd
4mm County Ti

.0... [Spaco
"'
This Line For Recording 03:}

MORTGAGE FHA C No

L. _ _,

MIN: 1002491 40001144936
MERS PHONE #: 1-888-679-6377
DEFINITIONS
Words used in multiple sections of this document are deﬁned below and other words are deﬁned in Sections 3. 10. 12.
17. 19 and 21. Certain rules regarding the usage of words used in this document are also provided in Section 15.
(A) "Security Instrument" means this document. which is dated December 21. 2018, together with all Riders to
this document.
(B) "Borrower" is JULIA DOSCH, A SINGLE WOMAN.

Borrower is the mortgagor under this Security Instrument.
(C) "MERS" is Mortgage Electronic Registration Systems. Inc. MERS is a separate corporation that is acting solely as a
nominee for Lender and Lender's successors and assigns. MERS is the mortgagee under this Security Instrument.
MERS is organized and existing under the laws of Delaware. and has an address and telephone number of PO. Box
2026. Flint. MI 48501-2026. tel. (888) 679-MERS.
(D) "Lender" ls Marketplace Home Mortgage. L.L.C..

Lender is a Limited Liability Company, organized and existing
under the laWS of Minnesota.
Lender's address is 7380 France Avenue S, Suite 200, Edina. MN 55435

MINNESOTASingle FamilyFannie Muanddlo Mac UNIFORM INSTRUMENT Form 3024'110'1'
Modiﬁed for FHA 9/2014 (HUD Handbook 4000.1)
Ellie Mae. Inc. page 1 of 9 MNEFHMSDE 101s
MNEDEED (CLS)
12/21/2010 07:23 AM PST

14,"
68-CV-24-405
Filed in District Court
State of Minnesota
6/24/2024 11:03 AM

A parcel of land located in the Southeast Quarter of the
Northeast Quarter (SE1/4 NE'A), of Section Eight (8),
Township One Hundred Sixty-one (161) North, Range
Forty (40) West of, the Fiﬁh Principal Meridian in
Minnesota, according to the United States Government
Survey thereof, described as follows:

Beginning at the Southeast (SE) comer of said section,
thence North Two Thousand Seven Hundred Sixteen (2716)
feet to the point of beginning, thence West Six Hundred
(600) feet, thence North Three Hundred Fiﬁy (350) feet,
thence East Six Hundred (600) feet, thence South Three
Hundred Fiﬁy (350) feet to the point of beginning and there
terminating.

to:
2.4,
68-CV-24-405
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LOAN #2
(E) "Note" means the promissory note signed by Borrower and dated December 21. 2018. The Note states
that Borrower owes Lender ONE HUNDRED TWENTY THREE THOUSAND SEVEN HUNDRED SEVENTEEN AND
"0,100.0ﬁi...ttﬁtiittﬁ0O.Ihitﬁlhttiiitttitttitiﬁﬁtl. Dollars (U-S. $123,717.00
plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later
than January 1. 2049.
(F) "Property" means the property that is described below under the heading 'Transfer of Rights in the Property."
(G) "Loan" means the debt evidenced by the Note, plus interest, late charges due under the Note. and all sums due
under this Security Instrument. plus interest.
(H) "Rlders" means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be
executed by Borrower [check box as applicable]:
D Adjustable Rate Rider D Condominium Rider D Planned Unit Development Rider
l2] Other(s) [specify]
Manufactured Home Rider, Manufactured Home Affidavit of Afﬂxatlon

(l) "Applicable Law" means all controlling applicable federal. state and local statutes. regulations. ordinances and
administrative rules and orders (that have the eti'ect of law) as well as all applicable ﬁnal. non-appealable Judicial opinions.
(J) "Community Association Dues, Fees. and Assessments" means all dues. fees. assessments and other charges that
are imposed on Borrower or the Property by a condominium associau'on, homeowners association or similar organization.
(K) "Electronic Funds Transfer" means any transfer of funds. other than a transaction originated by check. draﬂ. or
similar paper instrument. which is initiated through an electronic terminal, telephonic instrument. computer, or magnetic
tape so as to order. instruct. or authorize a ﬁnancial institution to debit or credit an account. Such term includes. but is not
limited to. point-of-sale transfers. automated teller machine transactions. transfers initiated by telephone. wire transfers.
and automated clearinghouse transfers.
(L) "Escrow Items" means those items that are described in Section 3.
(M) "Miscellaneous Proceeds" means any compensation. settlement. award of damages. or proceeds paid by any third
party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to. or destruction
of. the Property; (ii) condemnation or other taking of all or any part of the Property; (iii) conveyance in lieu of condemna-
tion; or (iv) misrepresentations of. or omissions as to, the value and/or condition of the Property.
(N) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on. the Loan.
(O) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the Note. plus
(ii) any amounts under Section 3 of this Security Instrument.
(P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. §2601 et seq.) and its implementing regu-
lation. Regulation X (12 C.F.R. Part 1024). as they might be amended from time to time. or any additional or successor
legislation or regulation that governs the same subject matter. As used in this Security Instrument. "RESPA' refers to all
requirements and restrictions that are imposed in regard to a "federally related mortgage loan" even if the Loan does not
qualify as a "federally related mortgage loan' under RESPA.
(G) "Secretary" means the Secretary of the United States Department of Housing and Urban Development or his designee.
(R) "Successor ln Interest of Borrower" means any party that has taken title to the Property. whether or not that party
has assumed Borrower's obligations under the Note and/or this Security Instrument.

TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: (i) the repayment of the Loan. and all renewals. extensions and modiﬁca-
tions of the Note: and (ii) the performance of Borrower's covenants and agreements under this Security Instrument and
the Note. For this purpose. Borrower does hereby mortgage. grant and convey to MERS (solely as nominee for Lender
and Lender's successors and assigns) and to the successors and assigns of MERS. with power of sale. the following
described property located in the County of Roseau
[Type of Recording Jurisdiction] [Name of Recording Jurisdicﬁon]:
SEE LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF AS "EXHIBIT A".
PIN# 32.0012800

which currently has the address of 26575 County Road 15. Roseau.
[Street] [Cltyl
Minnesota 56751 ('Property Address'):
[Zip Code]

TOGETHER WITH ail the improvements now or hereaﬂer erected on the property. and all easements. appurtenances.
and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security

MINNESOTASingle Family-Fannie Mae/Freddie Mac UNIFORM ms'rRUMENT Form 3024 1/01
Modiﬁed for FHA 9/2014 (Huo Handbook 4000.1)
Ellie Mae. Inc. 2 of 9 MNEFHA1soE 1016
page
, MNEDEED (CLS)
12/21/2018 07:23 AM PST

'
Barb "i
68-CV-24-405
Filed in District Court
State of Minnesota
6/24/2024 11:03 AM
LOAN #2

Instrument. All of the foregoing is referred to in this Security Instrument as the 'Property.' Borrower understands and agrees
that MERS holds only legal title to the interests granted by Borrower in this Security Instrument. but. if necessary to comply
with law or custom. MERS (as nominee for Lender and Lender's successors and assigns) has the right: to exercise any or
all of those interests. including, but not limited to. the right to foreclose and sell the Property; and to take any action required
of Lender including, but not limited to, releasing and canceling this Security Instrument.

BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mort-
gage. grant and convey the Property and that the Property is unencumbered. except for encumbrances of record. Borrower
warrants and will defend generally the title to the Property against all claims and demands. subject to any encumbrances
of record.

THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited
variations by jurisdiction to constitute a uniform security instrument covering real property.

UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment of Principal, Interest, Escrow Items. and Late Charges. Borrower shell pay when due the principal
of. and interest on. the debt evidenced by the Note and late charges due under the Note. Borrower shall also pay funds
for Escrow Items pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in
U.S. currency. However. if any check or other instrument received by Lender as payment under the Note or this Security
Instrument is returned to Lender unpaid. Lender may require that any or all subsequent payments due under the Note
and this Security Instrument be made in one or more of the following forms. as selected by Lender. (a) ash; (b) money
order; (c) certiﬁed check. bank check. treasurer's check or cashier's check. provided any such check is drawn upon an
institution whose deposits are insured by a federal agency. instrumentality. or entity; or (d) Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location designated in the Note or at such other
location as may be designated by Lender in accordance with the notice provisions in Section 14. Lender may return any
payment or partial payment ifthe payment or partial payments are insufﬁcient to bring the Loan current Lender may accept
any payment or partial payment insufﬁcient to bring the Loan current, without waiver of any rights hereunder or prejudice
to its rights to refuse such payment or partial payments in the future. but Lender is not obligated to apply such payments
at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date. then Lender
need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring
the Loan current. If Borrower does not do so within a reasonable period of time. Lender shall either apply such funds or
return them to Borrower. lf not applied eariier, such funds will be applied to the outstanding principal balance under the Note
immediately prior to foreclosure. No oﬂ'set or claim which Borrower might have now or in the future against Lender shall
relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and
agreements secured by this Security Inshument.
2. Application of Payments or Proceeds. Except as othenNise described in this Section 2. all payments accepted
and applied by Lender shall be applied in the following order of priority:
First, to the Mortgage Insurance premiums to be paid by Lender to the Secretary or the monthly charge by the Secretary
instead of the monthly mortgage insurance premiums;
Second. to any taxes. special assessments. leasehold payments or ground rents. and ﬁre, ﬂood and other hazard
insurance premiums. as required:
Third. to interest due under the Note:
Fourth. to amortization of the principal of the Note: and.
Fiﬂh. to late charges due under the Note.
Any application of payments. insurance proceeds. or Miscellaneous Proceeds to principal due under me Note shall not
extend or postpone the due date. or change the amount. of the Periodic Payments.
3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under the Note,
until the Note is pald in full. a sum (the 'Funds') to provide for payment of amounts due for: (a) taxes and assessments and
other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property: (b) leasehold
payments or ground rents on die Property. if any; (c) premiums for any and all insurance required by Lender under Section
5; and (d) Mortgage Insurance premiums to be paid by Lender to the Secretary or the monme charge by the Secretary
instead of the monthly Mortgage Insurance premiums. These items are called "Escrow ltems."At origination or at any time
during the term of the Loan. Lender may require that Community Association Dues. Fees. and Assessments. if any. be
escrowed by Borrower. and such dues. fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to
Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless
Lender waives Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's obligation
to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In die event of such
waiver. Borrower shall pay directly. when and where payable. the amounts due for any Escrow Items for which payment of
Funds has been waived by Lender and. if Lender requires. shall furnish to Lender receipts evidencing such payment within
such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall for all
purposes be deemed to be a covenant and agreement contained in this Security Instrument. as the phrase "covenant and
agreement" is used in Section 9. If Borrower is obligated to pay Escrow Items directly. pursuant to a waiver. and Borrower
fails to pay the amount due for an Escrow Item. Lender may exercise its rights under Section 9 and pay such amount and
Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as
to any or all Escrow Items at

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Dixon, Donna K. Track Judge’s New Case

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Document Filed Date

June 24, 2024

Case Filing Date

June 24, 2024

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Document for Freedom Mortgage Corporation vs Julia Dosch, Northwest Minnesota Multi County Housing and Redevelopment Authority, Secretary of Housing and Urban Development

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