STATE OF MINNESOTA DISTRICT COURT
FAMILY COURT DIVISION
COUNTY OF STEARNS SEVENTH JUDICIAL DISTRICT
In re the Matter of:
Jared David Mogensen Court File No.: 73-FA-25-8697
Petitioner, Judicial Officer: Matthew Engelking
and
SUMMONS
Perla Melani Campomanes Yaicate,
Respondent.
TO: PERLA MELANI CAMPOMANES YAICATE, THE ABOVE NAMED RESPONDENT.
THIS SUMMONS IS AN OFFICIAL DOCUMENT THAT AFFECTS YOUR RIGHTS. A
copy of the paperwork regarding this lawsuit is served on you with this summons. Read this summons and the attached Complaint carefully. If you do not understand it, contact an attorney for legal advice.
1. The Petitioner has filed a lawsuit asking the court to decide custody and parenting time for the minor child, Royce Brian Mogensen. A copy of the Complaint to Establish Paternity, Custody, and Parenting Time is attached to this Summons.
2. You must serve upon Petitioner and file with the court a written Answer to the Complaint. If Petitioner is requesting child support, you must file a Financial Affidavit along with your Answer. You must pay the required filing fee. If you cannot afford to pay the filing fee, you may qualify to have the filing fee waived by the court. You must file an In Forma Pauperis application with the court and a judge will decide whether you must pay the fee. All court forms are available from the Court Administrator’s office and on the Court’s website at www.mncourts.gov/forms. You must serve your Answer and Financial Affidavit upon Petitioner within 21 daysof the date you were served with this Summons, not counting the day of service. If you do not serve and file your Answer and Financial Affidavit, the court may grant Petitioner everything he is asking for in the attached Complaint.
3. This case may be settled informally if you contact Petitioner’s attorney, Jean Paul Agustin of Burns & Hansen, PA, 8401 Wayzata Boulevard, Suite 300, Minneapolis, Minnesota 55426, or by calling him or emailing him at 952-564-6257 or jeanpaul@burnshansen.com.
NOTICE OF PARENT EDUCATION PROGRAM REQUIREMENTS
PARENTING EDUCATION MAY BE REQUIRED IN ALL CUSTODY OR PARENTING PROCEEDINGS. YOU MAY CONTACT COURT ADMINISTRATION FOR ADDITIONAL INFORMATION REGARDING THIS REQUIREMENT AND THE AVAILABILITY OF PARENT EDUCATION PROGRAMS.
BURNS & HANSEN, P.A.
Dated: November 19, 2025 /s/ Jean Paul Agustin
Jean Paul Agustin (#0397358)
Mariah Glinski (#0504713)
jeanpaul@burnshansen.com
mariah@burnshansen.com
8401Wayzata Boulevard, Suite 300
Minneapolis, Minnesota 55426
Telephone: (952) 564-6230
Facsimile: (952) 564-6231
Attorneys for Petitioner
ACKNOWLEDGMENT
I hereby acknowledge that, pursuant to Minn. Stat. § 549.211, costs, disbursements and reasonable attorney and witness fees may be awarded to the opposing party in this litigation if the Court should find that Petitioner acted in bad faith, asserted a claim or defense which is frivolous and which is costly to Respondent, asserted an unfounded position solely to delay the ordinary course of proceedings or to harass, or commit a fraud on the Court.
Dated: November 19, 2025 /s/ Jean Paul Agustin
Jean Paul Agustin (#0397358)
STATE OF MINNESOTA DISTRICT COURT
FAMILY COURT DIVISION
COUNTY OF STEARNS SEVENTH JUDICIAL DISTRICT
In re the Matter of:
Jared David Mogensen, Court File No.: 73-FA-25-8697
Petitioner, Judicial Officer: Matthew Engelking
and
COMPLAINT TO ESTABLISH
PATERNITY, CUSTODY,
AND PARENTING TIME
Perla Melani Campomanes Yaicate
Respondent.
For his Complaint, Jared David Mogensen (hereinafter “Petitioner”) states and alleges as follows:
I.
The true and correct names and addresses of the Petitioner and Respondent are as follows:
Petitioner: Jared David Mogensen
321 7th Street North, #23
Sartell, MN 56377
Respondent: Perla Melani Campomanes Yaicate
Unknown
Social Security Numbers are provided in the Confidential Information form.
II.
Petitioner is currently represented by Jean Paul Agustin, Esq. and Mariah Glinski, Esq., Burns & Hansen, P.A., 8401 Wayzata Boulevard, Suite 300, Minneapolis, MN 55426. Upon information and belief, Respondent is self-represented.
III.
Petitioner and Respondent have both attained the age of majority. Petitioner is thirty nine (39) years of age, and his date of birth is February 2, 1986. Respondent is thirty (30) years of age, and her date of birth is September 30, 1995.
IV.
For more than 180 days immediately preceding the commencement of this proceeding, Petitioner and the minor child have been and now are residents of the State of Minnesota and now reside within the County of Stearns.
V.
The Petitioner and Respondent never married. Petitioner and Respondent dated from approximately 2016 until 2025. During the month of December 2019, Petitioner and Respondent engaged in sexual intercourse. By reason of that sexual intercourse, Respondent became pregnant with a child and gave birth out of wedlock on September 29, 2020.
The parties hereto have one (1) minor or dependent child namely:
Royce Brian Mogensen, born September 29, 2020, (age 5).
IV.
The minor child is not subject to any tribal court, juvenile proceeding, or CHIPS case. There is no guardian ad litem appointed for the minor child. Neither party has any non-joint minor children. Respondent is not now pregnant, upon information and belief of Petitioner.
The minor child was born in Lima, Peru and Petitioner is listed as the child’s father on the birth certificate and Consular Report of Birth Abroad. After the child’s birth, Petitioner has received the minor child into his home and openly held out the child as his biological son.
Petitioner is a fit and proper person to have custody of the minor child. The best interests and welfare of the child will be served if the parties are given joint legal custody and sole physical custody is granted to Petitioner, subject to reasonable and liberal parenting time by the Respondent.
VII.
No separate proceedings for custody are pending in a Court in this State or elsewhere. No order for protection is in effect under Minn. Stat. § 518B or any similar law of another state, which governs the parties or the minor child.
VIII.
Neither party is nor was in the military service of the United States at any time which is relevant to this proceeding.
IX.
Minnesota is the proper jurisdiction within the contemplation of the Uniform Child Custody Jurisdiction Act to enter an order regarding the custody, care, and control of the minor child. Stearns County is the proper county for this paternity proceeding.
X.
To the best of Petitioner’s knowledge, neither party nor the minor child receives public assistance.
XI.
That this Complaint is filed in good faith and for the purposes set forth herein.
WHEREFORE, Petitioner requests that the Court grant the following relief:
1. Establishing that Petitioner is the biological father of Royce Brian Mogensen born September 29, 2020.
2. Awarding the parties joint legal custody of the minor child.
3. Awarding Petitioner sole physical custody of the minor child, subject to Respondent’s right to reasonable and liberal parenting time.
4. For such other and further relief as the Court may deem just, fair, and equitable.
BURNS & HANSEN P.A.
Date: November 19 2025.
/s/ Jean Paul Agustin
Jean Paul Agustin (#0397358)
Mariah Glinski (#0504713)
jeanpaul@burnshansen.com
mariah@burnshansen.com
8401Wayzata Boulevard, Suite 300
Minneapolis, Minnesota 55426
Telephone: (952) 564-6230
Facsimile: (952) 564-6231
Attorneys for Petitioner
ACKNOWLEDGMENT
I hereby acknowledge that, pursuant to Minn. Stat. Sec. 549.211, costs, disbursements and reasonable attorney and witness fees may be awarded to the opposing party in this litigation if the Court should find that Petitioner acted in bad faith, asserted a claim or defense which is frivolous and which is costly to Respondent, asserted an unfounded position solely to delay the ordinary course of proceedings or to harass, or commit a fraud on the Court.
Date: November 19, 2025. /s/ Jean Paul Agustin
Jean Paul Agustin (#0397358)
VERIFICATION
STATE OF MINNESOTA )
) SS
COUNTY OF STEARNS )
a. I have read this document. To the best of my knowledge, information and belief the information contained in this document is well grounded in fact and is warranted by existing law.
b. I have not been determined by any Court in Minnesota or in any other State to be a frivolous litigant and I am not the subject of an Order precluding me from serving or filing this document.
c. I am not serving or filing this document for any improper purpose, such as to harass the other party or to cause delay or needless increase in the cost of litigation or to commit a fraud on the Court.
d. I understand that if I am not telling the truth or if I am misleading the Court or if I am serving or filing this document for an improper purpose, the Court can order me to pay money to the other party, including the reasonable expenses incurred by the other party because of the serving or filing this document, Court costs, and reasonable attorney’s fees. I understand that I could also be prosecuted for perjury if I am not telling the truth in my Petition.
I declare under penalty of perjury that everything I have stated in this document is true and correct. Minn. Stat. § 358.116.
Dated: November 18, 2025 /s/ Jared David Mogensen
Jared David Mogensen