Mortgage Foreclosure

STATE OF MINNESOTA
COUNTY OF STEELE
    
DISTRICT COURT
THIRD JUDICIAL 
DISTRICT
Case Type: 
Consumer Credit/Replevin
Case No. 19HA-CV-25-948

21st Mortgage Corporation,    
            Plaintiff,    

vs.                       NOTICE OF MOTION AND MOTION FOR 
SUMMARY JUDGEMENT

Marissa J. Vanesch,     
            Defendants.

NOTICE OF MOTION AND MOTION FOR 
SUMMARY JUDGMENT

TO: DEFENDANT MARISSA J. VANESCH, 2570 18TH STREET NORTHWEST, OWATONNA, 
MINNESOTA 55060.

NOTICE OF MOTION

PLEASE TAKE NOTICE that on the 4th day of June, 2025 at 3:30 p.m., or as soon thereafter as counsel may be heard, Plaintiff, 21st Mortgage 
Corporation, by and through its undersigned 
attorneys, will make the following Motion for 
Summary Judgment before a Judge at Dakota County District Court. This hearing will be held via Zoom and appearances shall be by video or audio.  

Judge Karen Duncan’s virtual courtroom:

To join by internet:  
1. Type https://zoomgov.com.join in your browser’s address bar.
2. Enter the Meeting ID and Meeting Passcode (if asked):
Meeting ID:  161 536 7155
Passcode:  702026

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 Defendants 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 Plaintiff’s debt in full, but only to the extent permissible by state or federal law; and 4) costs and disbursements, including attorneys’ fees, in bringing this action, as allowed for by the Contract between the parties.
        
Date  April 21, 2025. 

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

ATTORNEYS FOR PLAINTIFF 
21ST MORTGAGE CORPORATION

4.30-5.148.11