18-CV-20-468
`
`Filed in District Court
`State of Minnesota
`2/3/2020 4:11 PM
`
`STATE OF MINNESOTA
`
`COUNTY OF CROW WING
`
`Second Round Sub, LLC,
`
`VS-
`Tanya R Pierson,
`
`Plaintiff,
`
`'
`
`Defendant.
`
`DISTRICT COURT
`
`NINTH JUDICIAL DISTRICT
`
`Case Type: Consumer Credit Contract
`
`SUMMONs
`
`THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANT:
`YOU ARE BEING SUED. The Plaintiff has statted a lawsuit against you. The
`1.
`Plaintiff‘s Complaint against you is attached to this Summons. Do not throw these papers away.
`They are ofcial
`papers that affect your rights. You must respond to this lawsuit even though it
`may not yet be led with the Court and there may be no Court le
`number on this Summons.-
`YOU MUST REPLY WITHIN 20 DAYS TO PROTECT YOUR RIGHTS.
`2.
`You must give or mail to the person who signed this Summons a written response called an
`Answer within 20 days ofthe date on which you received this Summons. You must send a copy
`ofyour Answer to the person who signed this Summons located at Gurstel Law Firm, P.C., 6681
`Country Club Drive, Golden Valley, MN 55427.
`YOU MUST RESPOND TO EACH CLAIM. The Answer is your written
`3.
`response to the Plaintiff‘s Complaint.
`In your Answer you must state whether you agree or
`disagree with each paragraph of the Complaint. If you believe the Plaintiff should not be given
`everything asked for in the Complaint, you must say so in your Answer.
`YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTEN
`4.
`RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THIS
`SUMMONS. Ifyou do not Answer within 20 days, you will lose this case. You will not get to
`tell your side ofthe story, and the Court may decide against you and award the Plaintiff
`everything asked for in the Complaint. Ifyou do not want to contest the claims stated in the
`Complaint, you do not need to respond. A Detatiltggrnentpanthenbe
`entered against you for
`the relief—FéQuested in the Complaint.
`LEGAL ASSISTANCE. You may wish to get legal help from a lawyer.
`5.
`lfyou
`do not have a lawyer, the Court Administrator may have information about places where you can
`get legal assistance. Even ifyou cannot get legal help, you must still provide a written
`Answer to protect your rights 0r you may lose the case.
`
`
`
`18-CV-20-468
`
`Filed in District Court
`State of Minnesota
`2/3/2020 4:11 PM
`
`ALTERNATIVE DISPUTE RESOLUTION. The parties may agree to or be
`6.
`ordered to participate in an alternative dispute resolution process under Rule 114 ofthe
`Minnesota General Rules ofPractice. You must still send your written response to the Complaint
`even ifyou expect to use alternative means of resolving this dispute.
`
`I
`
`OurFiie; 1239686
`
`GURSTEL LAW FIRM, P.C.
`
`'
`
`Amy M. Goltz (#336452)
`Nikolas D. Schaal (#396690)
`Steven M. Toms (#31 3762)
`Kali A. Russen (#399695)
`Kelly K. Heenan (#400103)
`Thersia' Walsh (#321497)
`Evan D. Stein (#399494)
`Attorneys for Plaintiff
`6681 Country Club Drive
`Golden Valley, Minnesota 55427
`Telephone: (877) 344-4002
`Fax; (763) 267-6777
`
`E
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`18-CV-20-468
`
`Filed in District Court
`State of Minnesota
`2/3/2020 4:11 PM
`
`STATE OF MINNESOTA
`
`COUNTY OF CROW WING
`
`Second Round Sub, LLC,
`
`VS-
`Tanya R Pierson,
`
`Plaintiff,
`
`Defendant
`
`DISTRICT COURT
`
`NINTH JUDICIAL DISTRICT
`
`Case Type: Consumer Credit Contract
`
`COMPLAINT
`
`Plaintiff, as and for its cause of action states and alleges as follows:
`
`mu
`
`1. That plaintiffherein is the owner ofcertain accounts ofComenity Bank, including the
`account of defendant herein.
`
`2. That defendant obtained credit from Comenity Bank, with account number ending in
`**************2940'
`
`3. That defendant is a resident ofthe State ofMinnesota, County of Crow Wing.
`
`4. Defendant owes plaintiff$1,670.18, for credit extended on or before July 30, 2019.
`
`5. That although duly demanded, defendant has failed to pay said amount and therefore is
`indebted to the plaintiffin the amount of$l ,670.] 8.
`
`
`
`18-CV-20-468
`
`Filed in District Court
`State of Minnesota
`2/3/2020 4:11 PM
`
`-' OU-NT Ii.
`ACCOUNT STATED
`
`6. Plaintiff realleges the allegations set forth in paragraphs 1 through 5, and incorporates
`them herein by reference.
`
`7. From time to time , plaintiff and/0r Comenity Bank made and rendered to defendant
`accurate invoices and/or statements of account ofthe transactions between said parties. Said
`invoices and/or statements of account were received by defendant, accepted and retained by said
`defendant without objection being made to any item thereofwithin a reasonable period oftime.
`8. A full, just, and true account was made and stated between plaintiff and/or Comenity
`Bank and defendant which showed a balance of $1,670.] 8, due to plaintiff from defendant over
`and above all sums received from defendant and for which defendant is entitled to credit.
`
`
`
`18-CV-20-468
`
`Filed in District Court
`State of Minnesota
`2/3/2020 4:11 PM
`
`WHEREFORE, plaintiff demands judgment against defendant as follows:
`
`]. For the amount of$1,6’70,'l 8;
`
`2. For plaintiff‘s costs and disbursem*nts incurred herein; and
`
`3. For such further and additional relief as the Court deems just, fair and equitable.
`
`GURSTEL LAW FIRM, P.C.
`
`$2.
`
`by
`Amy M. Goltz (#336452)
`Nikolas D. Schaal (#396690)
`Steven M. Toms (#313762)
`Kali A. Russen (#399695)
`Kelly K. Heenan (#400103)
`Thersia Walsh (#321497)
`Evan D. Stein (#399494)
`Attorneys for Plaintiff
`6681 Country Club Drive
`Golden Valley, Minnesota 55427
`Telephone: 877-344—4002
`
`>1
`
`ACKNOWLEDGMENT
`Second Round Sub, LLC acknowledges that costs, disbursem*nts, reasonable attorney and witness
`fees may be awarded to Tanya R Pierson, pursuant to Minnesota Statute § 549.21 1.
`Second Round Sub, LLC
`SQ,
`Amy M. Goltz (#336452)__
`
`b1
`
`Nikolas D. Schaal (#396690)
`Steven M. Toms (#313762)
`Kali A. Russen (#399695)
`Kelly K. Heenan (#400103)
`Thersia Wal_sl_i_(#32149_]_}_
`Evan D.Stein(#399494) 3g
`Its Attorneys
`
`,
`
`_
`
`,
`
`u‘____
`
`__.
`
`
