Michael P. Talia
Hanna Warhank
JACKSON, MURDO, & GRANT, PC
203 N. Ewing St.
Helena, MT 59601
Phone: (406) 442-1300
Emails: mtalia@jmgattorneys.com
hwarhank@jmgattorneys.com
Attorneys for Trustee Linda C. Baker
IN THE MONTANA TWENTY-FIRST JUDICIAL DISTRICT COURT, RAVALLI COUNTY
LINDA C. BAKER, in her capacity as Trustee of the MARGARET E. DUNBAR REVOCABLE LIVING TRUST,
Plaintiff,
v.
JACOB L. DUNBAR, MONICA DUNBAR, ANA L. DUNBAR in her capacity as PERSONAL REPRESENTATIVE OF THE ESTATE OF THOMAS H. DUNBAR, SALENA DUNBAR, THE HEIRS AND DEVISEES OF DAVID W. POPHAM, THE HEIRS AND DEVISEES OF THOMAS E. POPHAM, THE HEIRS AND DEVISEES OF ED WETHERILL, and ALL PERSONS, KNOWN OR UNKNOWN, CLAIMING OR WHO MIGHT CLAIM ANY RIGHT, TITLE, ESTATE, OR INTEREST IN OR LIEN OR ENCUMBRANCE UPON THE PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF’S OWNERSHIP OR ANY CLOUD UPON PLAINTIFF’S TITLE, WHETHER THE CLAIM OR POSSIBLE CLAIM BE PRESENT OR CONTINGENT,
Defendants.
Cause No. DV-41-2026-0000291-QT
Judge: Howard F. Recht
SUMMONS
THE STATE OF MONTANA sends greetings to the above-named Defendant:
ALL PERSONS, KNOWN OR UNKNOWN, CLAIMING OR WHO MIGHT CLAIM ANY RIGHT, TITLE, ESTATE, OR INTEREST IN OR LIEN OR ENCUMBRANCE UPON THE REAL PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF’S OWNERSHIP OR ANY CLOUD UPON PLAINTIFF’S TITLE, WHETHER THE CLAIM OR POSSIBLE CLAIM BE PRESENT OR CONTINGENT
This action is brought, among other things, to quiet title to land located in Ravalli County, Montana:
See Exhibit “A”, attached hereto.
The objection of this action is to quiet title in the name of the Plaintiff, as fee simple owner, free of all liens and encumbrances.
If you claim any interest, lien, or encumbrance upon that real property, YOU ARE HEREBY SUMMONED to answer Plaintiff’s Complaint to Quiet Title in this action which is filed in the Office of the Clerk of this Court, a copy of which is herewith served upon you, and to file your answer and serve a copy thereof upon Plaintiff’s attorney within twenty-one (21) days after the service of this Summons, exclusive of the day of service; and in case of your failure to appear or answer, judgment may be taken against you by default for the relief demanded in Plaintiff’s Complaint.
WITNESS my hand the Seal of said Court this 26th day of August, 2026.
Paige Trautwein, Clerk of Court
/s/Michelle Goldman
Exhibit A
Legal Description
Parcel 1
The SE1/4SE1/4 of Section 36, Township 7 North, Range 21 West, P.M.M., Ravalli County, Montana.
Deed Reference: Book 78 of Deeds, page 378 and Instrument No. 600459.
EXCEPTING THEREFROM Lots 1 and 12, Block 1, West Woodside, Ravalli County, Montana, according to the official recorded plat thereof.
Deed Reference: Book 55 of Deeds, page 454.
ALSO EXCEPTING THEREFROM Lots 5 and 6, Block 6, West Woodside, Ravalli County, Montana, according to the official recorded plat thereof.
Deed Reference: Book 53 of Deeds, page 332 and Book 53 of Deeds, page 440.
ALSO EXCEPTING THEREFROM a tract of land, described as follows: Beginning at the southeast comer of said SE1/4SE1/4, thence west 512.5 feet, thence north 310 feet, thence east 100 feet, thence north 218 feet, thence east 412.5 feet to the east line of said SE1⁄41⁄4SE1⁄4, thence south to the place of beginning.
Deed Reference: Book 220 of Deeds, pages 407 and 408.
EXCEPTING THEREFROM Highway right-of-way, formerly Northern Pacific Railroad right-of-way.
Deed Reference: Book 163 of Deeds, page 973.
EXCEPTING THEREFROM that portion deed to the State of Montana as recorded in Instrument No. 570103.
EXCEPTING THEREFROM A tract of land located in the SE1⁄4SE1⁄4 of Section 36, Township 7 North, Range 21 West, and being more particularly described as follows: Beginning at a point twenty-five (25) rods west, and three hundred and ten (310) feet north of the southeast corner of section thirty-six (36), township seven (7) north, range twenty-one (21) west, Montana Meridian, and running thence due north two hundred and eighteen (218); thence west one hundred (100) feet; thence south two hundred and eighteen (218); thence east one hundred (100) feet to the place of beginning. Recording Reference Instrument No. 806151.
Parcel 2
A tract of land located in the SE1⁄4SE1⁄4 of Section 36, Township 7 North, Range 21 West, and being more particularly described as follows:
Beginning at a point twenty-five (25) rods west, and three hundred and ten (310) feet north of the southeast corner of section thirty-six (36), township seven (7) north, range twenty-one (21) west, Montana Meridian, and running thence due north two hundred and eighteen (218) feet; thence west one hundred (100) feet; thence south two hundred and eighteen (218); thence east one hundred (100) feet to the place of beginning.
Recording Reference Instrument No. 806151.
Parcel 3
A tract of land located in the SE1⁄4SE1⁄4SE1⁄4 of Section 36, Township 7 North, Range 21 West, and being more particularly described as follows:
Beginning at a point 25 rods West of the Southeast corner of Section 36, Township 7 North, Range 21 West, and running thence North 310 feet; thence West 100 feet; thence South 310 feet; thence due East 100 feet to the place of beginning.
Recording Reference Instrument No. 806152.
Parcel 4
Lot 1 and Lot 12 of Block 1, West Woodside, Ravalli County, Montana, according to the official recorded plat thereof.
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