19HA-CV-19-5569
`
`Filed in District Court
`State of Minnesota
`11/26/2019 3:52 PM
`
`STATE OF MINNESOTA
`COUNTY OF DAKOTA
`
`Crown Asset Management, LLC,
`Plaintiff,
`
`VS-
`Vicky K Williamson,
`
`DISTRICT COURT
`FIRST JUDICIAL DISTRICT
`
`Case Type: Consumer Credit Contract
`
`SUMMONS
`
`1.
`
`Defendant.
`THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANT:
`YOU ARE BEING SUED. The Plaintiffhas staned a lawsuit against you. The
`Plaintiff’s Complaint against you is attached t0 this Summons. D0 not throw these papers away.
`They are official papers that affect your rights. You must respond t0 this lawsuit even though it
`may not yet be filed with the Court and there may be n0 Court file 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
`Answerwithin 20 days 0f the date on Which you received this Summons. You must send a copy
`ofyour Answer t0 the person who signed this Summons located at Gurstel Law Firm, P.C., 6681
`Country Club Drive, Golden Valley, MN 5542?.
`YOU MUST RESPOND TO EACH CLAIM. The Answer is your written
`3.
`response to the Plaintiff’s Complaint. 1n your Answer you must state whether you agree 01‘
`disagree with each paragraph 0fthe Complaint. Ifyou believe the Plaintiffshould 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
`RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THIS
`SUMMONS. Ifyou d0 not Answer within 20 days, you will lose this case. You will not get t0
`tell your side 0fthe story, and the Court may decide against you and award the Plaintiff
`everything asked for in the Complaint. Ifyou do not want t0 contest the claims stated in the
`Complaint, you d0 not need to respond. A Default Judgment can then be entered against you for
`the reliefrequested in the Complaint.
`LEGAL ASSISTANCE. You may wish to get legal help from a lawyer. Ifyou
`5.
`d0 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 or you may lose the case.
`
`4.
`
`
`
`19HA-CV-19-5569
`
`Filed in District Court
`State of Minnesota
`11/26/2019 3:52 PM
`
`ALTERNATIVE DISPUTE RESOLUTION. The parties may agree t0 0r be
`6.
`ordered t0 participate in an alternative dispute resolution process under Rule 1 14 ofthe
`Minnesota General Rules ofPractice. You must still send your written response to the Complaint
`even ifyou expect t0 use alternative means ofresolving this dispute.
`GURSTEL LAW FIRM, P.C.
`by
`
`QAmy M. Goltz (#336452)
`
`Our File: 1245152
`
`Nikolas D. Schaal (#396690)
`Steven M. Toms (#3 1 3762)
`Kali A. Russen (#399695)
`Kelly K. Heenan (#4001 03)
`Thersia Walsh (#321497)
`Evan D. Stein (#399494)
`Attorneys for Plaintiff
`668] Country Club Drive
`Golden Valley, Minnesota 55427
`Telephone: (877) 344-4002
`Fax: (763) 267-6777
`
`l/
`
`
`
`19HA-CV-19-5569
`
`Filed in District Court
`State of Minnesota
`11/26/2019 3:52 PM
`
`STATE OF MINNESOTA
`COUNTY OF DAKOTA
`
`Crown Asset Management, LLC,
`Plaintiff,
`
`vs.
`Vicky K Williamson,
`
`Defendant
`
`DISTRICT COURT
`FIRST JUDICIAL DISTRICT
`
`Case Type: Consumer Credit Contract
`
`COMPLAINT
`
`Plaintiff, as and for its cause ofaction states and alleges as follows:
`COUNT I.
`1. That plaintiff herein is the owner of certain accounts of Comenity Bank, including the
`
`account 0f defendant herein.
`
`2. That defendant obtained credit from Comenity Bank, with account number ending in
`
`************]455.
`
`3. That defendant is a resident ofthe State ofMinnesota, County ofDakota.
`
`4. Defendant owes plaintiff $4,693.03, for credit extended 0n 01' before August 16, 2019.
`
`5. That although duly demanded, defendant has failed to pay said amount and therefore is
`
`indebted to the plaintiffin the amount 0f$4,693.03.
`
`
`
`Filed in District Court
`State of Minnesota
`11/26/2019 3:52 PM
`
`19HA-CV-19-5569
`
`wACCOUNT STATED
`
`6.
`
`Plaintiffrealleges the allegations set forth in paragraphs l through 5, and incorporates
`
`them herein by reference.
`7. From time to time , plaintiffand/or Comenity Bank made and rendered to defendant
`
`accurate invoices and/or statements 0f account 0f the 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$4,693.03, due to plaintiff fi'om defendant over
`
`and above all sums received from defendant and for which defendant is entitled to credit.
`
`
`
`19HA-CV-19-5569
`
`Filed in District Court
`State of Minnesota
`11/26/2019 3:52 PM
`
`WHEREFORE, plaintiffdemands judgment against defendant as follows:
`l. For the amount of$4,693.03;
`
`2. For plaintiff‘s costs and disbursements incurred herein; and
`3. For such further and additional relief as the Coufl deemsjust, fair and equitable.
`GURSTEL LAW FIRM, P.C.
`
`g
`
`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
`668] Country Club Drive
`Golden Valley, Minnesota 55427
`Telephone: 877-344-4002
`ACKNOWLEDGMENT
`Crown Asset Management, LLC acknowledges that costs, disbursements, reasonable attorney and
`witness fees may be awarded t0 Vicky K Williamson, pursuant to Minnesota Statute § 549.2] l.
`Crown Asset Management, LLC
`
`by aAmy M. Goltz (#336452)
`
`Nikolas D. Schaal (#396690)
`Steven M. Toms (#313762)
`Kali A. Russen (#399695)
`Kelly K. Heenan (#4001 03)
`Thersia Walsh (#321497)
`Evan D. Stein (#399494) \/
`Its Attorneys
`
`
