On June 29, 2022 a
Discovery Plan
was filed
involving a dispute between
and
for Consumer Credit Contract
in the District Court of Jackson County.
Preview
32-CV-22-89
Filed in District Court
State of Minnesota
6/29/2022 3:39 PM
Messerli I Kramer P.A.
MESSERLI I KRAMER ATTORNEYS AT LAW
Telephone Representatives Available:
8 a.m. - 7 p.m. Monday, Tuesday, Thursday
ATTORNEYS AT LAW 3033 Campus Drive
8 a.m. - 5 p.m. Wednesday
Suite 250
8 a.m. - 6 p.m. Friday
Plymouth, Minnesota
55441-2662
main 763-548-7900
fax 763-548-7922 Lobby Hours:
toll free 844-841-0508 8 a.m. - 5 p.m. Monday- Friday
TTY: 711
March 28, 2022
111111111111111111111111111 IIIII IIII IIII
Mercedes Gustafson
Magus Law
3109 W 50th St. # 124
Minneapolis, MN 55410
Our Client: Citibank, N.A.
Consumer: Sonya Daberkow
Account Number: XXXXXXXXXXXX6642
Balance: $8,959.96
Our File Number: 20-161561
Dear Ms. Mercedes Gustafson Esq.:
We represent Citibank, N.A. (MY BEST BUY VISA). This letter is written in compliance with the Minnesota Rules of
Civil Procedure, Rule 26.06 and the Minnesota Rules of General Practice for the District Cou1is, Rule 115.10. As such
this letter is written in an effoti to confer on a discovery plan and also to discuss settlement. Please review the following
information carefully. We have outlined a few options for you to review and respond as you feel appropriate:
1) Contact our firm within the next fourteen days to work out a discovery plan. An attorney can
be reached by calling 844-841-0508; or
2) Send us a letter within the next fourteen days listing your contact information and availability between the
hours of9:00-5:00 Monday through Friday. An attorney will then attempt to reach you to discuss a discovery
plan; or
3) If you do not wish to collaborate on a discovery plan, attached is a proposed plan that we have formulated. If
we do not hear from you within foutieen days we will assume the attached plan is acceptable and will present
it to the Court when, and if, the case is filed.
Very truly yours,
MESSERLI & KRAMER PA
IMPORT ANT NOTICE
This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for
that purpose.
MN_0303 FileNo 20-161561
1
32-CV-22-89
Filed in District Court
State of Minnesota
6/29/2022 3:39 PM
CONSUMER CREDIT CONTRACT
STA TE OF MINNESOTA DISTRICT COURT
COUNTY OF JACKSON FIFTH JUDICIAL DISTRICT
Citibank, N.A. RULE 26.06(c) DISCOVERY PLAN
Plaintiff,
vs.
Comi File No.
Sonya Daberkow
Defendant(s).
TO: Attorney, Ms. Mercedes Gustafson Esq. 3109 W 50th St. #124 Minneapolis, MN 55410
Pursuant to Rule 26.06(c) of the Minnesota Rules of Civil Procedure, the parties submit the following
Discovery Plan:
(1) Plaintiff provided its 26.01 (a) Required Disclosures on March 28, 2022. Plaintiff proposes Defendant
provide his/her 26.0l(a) Required Disclosures as soon as possible.
(2) Discovery will be needed on any denial, dispute, or defense claimed or asserted by Defendant.
Discovery should not be conducted in phases, but should be limited to the issues raised in Plaintiffs Complaint
'
and Defendant's Answer.
(3) Any of Plaintiff's electronically stored information can be reproduced in hardcopy format.
(4) Parties may claim privilege of or protection of trial-preparation materials at the time of production. If
a party disagrees with a designation, the disagreeing party must object to the designation within fourteen days of
receiving the document. If the parties are unable to resolve a designation dispute, the paiiies may petition the
court for a determination.
MN_0303 File No20-161561
2
32-CV-22-89
Filed in District Court
State of Minnesota
6/29/2022 3:39 PM
(5) No changes should be made to the limitations on discovery imposed under the Minnesota Rules of
Civil Procedure or Local Rules. Plaintiff does not propose any other limitations.
(6) The court need not issue any other orders under Rules 26.03, 16.02, and 16.03 at this time.
MESSERLI & KRAMER PA
ISi J~)'(rllV G. P~J =#=0304q43 fv1N
DATE:
eSigned on 3/28/2022 in Hennepin County, MN
3033 Campus Drive, Ste. 250
Plymouth, MN 55441
cc-litigation@messerlikramer.com
Ph#: (763) 548-7900
Fax#: (763) 548-7922
Dated: This_ day of _ _ _ _ _ ,2022
Mercedes Gustafson
DEFENDANT'S ATTORNEY
MN_0303 File No: 20-161561
3
Document Filed Date
June 29, 2022
Case Filing Date
June 29, 2022
Category
Consumer Credit Contract
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32-CV-22-89 Filed in District Court State of Minnesota 6/29/2022 3:39 PM Messerli I Kramer P.A. MESSERLI I KRAMER ATTORNEYS AT LAW Telephone Representatives Available: 8 a.m. - 7 p.m. Monday, Tuesday, Thursday ATTORNEYS AT LAW 3033 Campus Drive 8 a.m. - 5 p.m. Wednesday Suite 250 8 a.m. - 6 p.m. Friday Plymouth, Minnesota 55441-2662 main 763-548-7900 fax 763-548-7922 Lobby Hours: toll free 844-841-0508 8 a.m. - 5 p.m. Monday- Friday TTY: 711 March 28, 2022 111111111111111111111111111 IIIII IIII IIII Mercedes Gustafson Magus Law 3109 W 50th St. # 124 Minneapolis, MN 55410 Our Client: Citibank, N.A. Consumer: Sonya Daberkow Account Number: XXXXXXXXXXXX6642 Balance: $8,959.96 Our File Number: 20-161561 Dear Ms. Mercedes Gustafson Esq.: We represent Citibank, N.A. (MY BEST BUY VISA). This letter is written in compliance with the Minnesota Rules of Civil Procedure, Rule 26.06 and the Minnesota Rules of General Practice for the District Cou1is, Rule 115.10. As such this letter is written in an effoti to confer on a discovery plan and also to discuss settlement. Please review the following information carefully. We have outlined a few options for you to review and respond as you feel appropriate: 1) Contact our firm within the next fourteen days to work out a discovery plan. An attorney can be reached by calling 844-841-0508; or 2) Send us a letter within the next fourteen days listing your contact information and availability between the hours of9:00-5:00 Monday through Friday. An attorney will then attempt to reach you to discuss a discovery plan; or 3) If you do not wish to collaborate on a discovery plan, attached is a proposed plan that we have formulated. If we do not hear from you within foutieen days we will assume the attached plan is acceptable and will present it to the Court when, and if, the case is filed. Very truly yours, MESSERLI & KRAMER PA IMPORT ANT NOTICE This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. MN_0303 FileNo 20-161561 1 32-CV-22-89 Filed in District Court State of Minnesota 6/29/2022 3:39 PM CONSUMER CREDIT CONTRACT STA TE OF MINNESOTA DISTRICT COURT COUNTY OF JACKSON FIFTH JUDICIAL DISTRICT Citibank, N.A. RULE 26.06(c) DISCOVERY PLAN Plaintiff, vs. Comi File No. Sonya Daberkow Defendant(s). TO: Attorney, Ms. Mercedes Gustafson Esq. 3109 W 50th St. #124 Minneapolis, MN 55410 Pursuant to Rule 26.06(c) of the Minnesota Rules of Civil Procedure, the parties submit the following Discovery Plan: (1) Plaintiff provided its 26.01 (a) Required Disclosures on March 28, 2022. Plaintiff proposes Defendant provide his/her 26.0l(a) Required Disclosures as soon as possible. (2) Discovery will be needed on any denial, dispute, or defense claimed or asserted by Defendant. Discovery should not be conducted in phases, but should be limited to the issues raised in Plaintiffs Complaint ' and Defendant's Answer. (3) Any of Plaintiff's electronically stored information can be reproduced in hardcopy format. (4) Parties may claim privilege of or protection of trial-preparation materials at the time of production. If a party disagrees with a designation, the disagreeing party must object to the designation within fourteen days of receiving the document. If the parties are unable to resolve a designation dispute, the paiiies may petition the court for a determination. MN_0303 File No20-161561 2 32-CV-22-89 Filed in District Court State of Minnesota 6/29/2022 3:39 PM (5) No changes should be made to the limitations on discovery imposed under the Minnesota Rules of Civil Procedure or Local Rules. Plaintiff does not propose any other limitations. (6) The court need not issue any other orders under Rules 26.03, 16.02, and 16.03 at this time. MESSERLI & KRAMER PA ISi J~)'(rllV G. P~J =#=0304q43 fv1N DATE: eSigned on 3/28/2022 in Hennepin County, MN 3033 Campus Drive, Ste. 250 Plymouth, MN 55441 cc-litigation@messerlikramer.com Ph#: (763) 548-7900 Fax#: (763) 548-7922 Dated: This_ day of _ _ _ _ _ ,2022 Mercedes Gustafson DEFENDANT'S ATTORNEY MN_0303 File No: 20-161561 3