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73-CV-18-6415
Filed in Seventh Judicial District Court
7/31/2018 10:31 AM
Stearns County, MN
STATE OF MINNESOTA DISTzuCT COURT
COTINTY OF STEARNS SEVENTH JUDICIAL DISTRICT
Case Type: Consumer Credit Contract
Cavalry SPV I, LLC,
Plaintiff,
VS
SUMMONS
Mark W Pawlowski.
Defendant.
TO: THE STATE OF MII.INESOTA TO THE ABOVE-NAMED DEFENDANT
l. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The
Plaintiff s Complaint against you is attached to this Summons. Do not th¡ow these papers away.
They are official papers that affect your rights. You must respond to this lawsuit even though it
may not yet be frled with the Court and there may be no Court file number on this Summons.
2, YOU MUST REPLY WITHIN 20 DAYS TO PROTECT YOUR RIGHTS.
You must give or mail to the person who signed this Summons a written response callecl an
Answer u'ithin 20 days of the date on which you received this Summons. You must send a copy
of your Auswer to the person who signed this Summons located at Gurstel Law Firrn, P.C., 6681
Country Club Drive, Golden Valley, MN 55427.
3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written
response to the Plaintiff s Complaint. In your Answer you must state whether you agree or
disagree with each paragraph of the Complaint. Ifyou believe the Plaintiff should not be given
everything asked for in the Complaint, you rnust say so in your Answer.
4. YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTEN
RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNN,D THIS
SUMMONS. If you do not Answer within 20 days, you wiil lose this case. You will not get to
tell your side of the story, and the Court may decide against you and award the Plaintiff evãr¡hing
askecl for in the Complaint. if you do not want to contest the claims stated in the Complaint, you
do not need to respond. A Default Judgment can then be entered against you for the relief
requested in the Complaint.
5. LEGAL ASSISTANCE. You rnay wish to get legal help from a lawyer. If you
do not have a lawyer, the Court Adrninistrator may have information about places where you can
get legal assistance. Even if you cannot get legal help, you must still provide a written
Answer to protect your rights or you may lose the case,
73-CV-18-6415
Filed in Seventh Judicial District Court
7/31/2018 10:31 AM
Stearns County, MN
6. ALTERNATIVE DISPUTE RESOLUTION. The parries may agree ro or be
ln an ve process 114 the Minnesota
oum your response to even if you
P.C,
(#3364s2) _
Ricci (#397065) _
Schaal (#396690)
M. Toms (#313762)
Shawn J. Anderson (#397944)
Kenneth K. Oh (#398067\ t
Joseph M. Rossman (ß}7A7$-J: _
Our Filc: 989280 Attorneys for Plaintiff
6681 Country Club Drive
Golden Valley, Minnesota 55427
Telephone: (877) 7 7 8-2302
Fax: (763) 267-6777
73-CV-18-6415
Filed in Seventh Judicial District Court
7/31/2018 10:31 AM
Stearns County, MN
STATE OF MINNESO]A DISTzuCT COURT
CÛIJ}ITY OF STEARNS SEVENTH JUDIEIAIÐISTMET
Cavalry SPV i, LLC,
Plaintiff,
vs. COMPLAINT
Mark'W Pawlowski,
Defendant
Plainti{f, as and for its cause of action states and alleges as follows:
COUNT I.
L That plaintiff herein is the owner of certain accounts of Citibank, N.4., including the
account of defendant herein.
2. That defendant obtained credit from Citibank, N.4., with account number ending in
************7960.
3. That defendant is a resident of the State of Minnesota, County of Stearns.
4. Defendant owes plaintiff 82,775.29, for credit extended on or before March 6,2017.
5. That although duly demanded, defendant has failed to pay said amount and therefore is
indebted to the piaintiff in the amount of ß2,775.29.
73-CV-18-6415
Filed in Seventh Judicial District Court
7/31/2018 10:31 AM
Stearns County, MN
COUNT II,
them herein by reference.
7., From time to tirne, plaintifiand/or Citibank, N.A. made and rendered to defendant
accurate invoices and/or statements of account of 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 rnade to any item thereof within a reasonable period of time,
8. A full, just, and true account was rnade and stated between plaintiff and/or Citibank,
N.A. and defendant which showed a balance of 52,775.29, due to plaintiff from defendant over
and above all sums received from defendant and for which defendant is entitled to oedit.
73-CV-18-6415
Filed in Seventh Judicial District Court
7/31/2018 10:31 AM
Stearns County, MN
WHEREFORE, plaintiff.demands judgrnent against defendant as follows :
1. For the amount-of $2,77 5.29 ;
). Eor:plaintiffs sssts and disbursements ineurred herein;and
3. For such further and additional relief as the fair and equitable.
FIRM, P.C-
d#33 s2)
M. Ricci (#397065)
_
D. Schaal (#396690)
M. Toms (#313762)
hawn J. Anderson (#397944)
Kenneth K. Oh (ffi95}67)
Joseph M, Rossman (ffig7w_ K
Attorneys for Plaintiff
6681 Country Club Drive
Golden Valley, Minnesota 55427
Telephone : 877 -7 7 8 -2302
ACKNOWLEDGMENT
Cavalry SPV I, LLC acknowledges that costs, disbursements, reasonable attomey and witness fees
rnay be awarded to Mark W pawlowski, pursuant to 549.211.
I,
s2) _
Ricci (#397065) _
S Schaal (#396690)
Steven M. Toms (#313762)
Shawn J. Anderson (#397944)
Kenneth K. Oh (#398067)
Joseph M. Rossman (ßg7ñA\ Í
Its Attorneys
Preview
73-CV-18-6415 Filed in Seventh Judicial District Court 7/31/2018 10:31 AM Stearns County, MN STATE OF MINNESOTA DISTzuCT COURT COTINTY OF STEARNS SEVENTH JUDICIAL DISTRICT Case Type: Consumer Credit Contract Cavalry SPV I, LLC, Plaintiff, VS SUMMONS Mark W Pawlowski. Defendant. TO: THE STATE OF MII.INESOTA TO THE ABOVE-NAMED DEFENDANT l. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiff s Complaint against you is attached to this Summons. Do not th¡ow these papers away. They are official papers that affect your rights. You must respond to this lawsuit even though it may not yet be frled with the Court and there may be no Court file number on this Summons. 2, YOU MUST REPLY WITHIN 20 DAYS TO PROTECT YOUR RIGHTS. You must give or mail to the person who signed this Summons a written response callecl an Answer u'ithin 20 days of the date on which you received this Summons. You must send a copy of your Auswer to the person who signed this Summons located at Gurstel Law Firrn, P.C., 6681 Country Club Drive, Golden Valley, MN 55427. 3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiff s Complaint. In your Answer you must state whether you agree or disagree with each paragraph of the Complaint. Ifyou believe the Plaintiff should not be given everything asked for in the Complaint, you rnust say so in your Answer. 4. YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTEN RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNN,D THIS SUMMONS. If you do not Answer within 20 days, you wiil lose this case. You will not get to tell your side of the story, and the Court may decide against you and award the Plaintiff evãr¡hing askecl for in the Complaint. if you do not want to contest the claims stated in the Complaint, you do not need to respond. A Default Judgment can then be entered against you for the relief requested in the Complaint. 5. LEGAL ASSISTANCE. You rnay wish to get legal help from a lawyer. If you do not have a lawyer, the Court Adrninistrator may have information about places where you can get legal assistance. Even if you cannot get legal help, you must still provide a written Answer to protect your rights or you may lose the case, 73-CV-18-6415 Filed in Seventh Judicial District Court 7/31/2018 10:31 AM Stearns County, MN 6. ALTERNATIVE DISPUTE RESOLUTION. The parries may agree ro or be ln an ve process 114 the Minnesota oum your response to even if you P.C, (#3364s2) _ Ricci (#397065) _ Schaal (#396690) M. Toms (#313762) Shawn J. Anderson (#397944) Kenneth K. Oh (#398067\ t Joseph M. Rossman (ß}7A7$-J: _ Our Filc: 989280 Attorneys for Plaintiff 6681 Country Club Drive Golden Valley, Minnesota 55427 Telephone: (877) 7 7 8-2302 Fax: (763) 267-6777 73-CV-18-6415 Filed in Seventh Judicial District Court 7/31/2018 10:31 AM Stearns County, MN STATE OF MINNESO]A DISTzuCT COURT CÛIJ}ITY OF STEARNS SEVENTH JUDIEIAIÐISTMET Cavalry SPV i, LLC, Plaintiff, vs. COMPLAINT Mark'W Pawlowski, Defendant Plainti{f, as and for its cause of action states and alleges as follows: COUNT I. L That plaintiff herein is the owner of certain accounts of Citibank, N.4., including the account of defendant herein. 2. That defendant obtained credit from Citibank, N.4., with account number ending in ************7960. 3. That defendant is a resident of the State of Minnesota, County of Stearns. 4. Defendant owes plaintiff 82,775.29, for credit extended on or before March 6,2017. 5. That although duly demanded, defendant has failed to pay said amount and therefore is indebted to the piaintiff in the amount of ß2,775.29. 73-CV-18-6415 Filed in Seventh Judicial District Court 7/31/2018 10:31 AM Stearns County, MN COUNT II, them herein by reference. 7., From time to tirne, plaintifiand/or Citibank, N.A. made and rendered to defendant accurate invoices and/or statements of account of 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 rnade to any item thereof within a reasonable period of time, 8. A full, just, and true account was rnade and stated between plaintiff and/or Citibank, N.A. and defendant which showed a balance of 52,775.29, due to plaintiff from defendant over and above all sums received from defendant and for which defendant is entitled to oedit. 73-CV-18-6415 Filed in Seventh Judicial District Court 7/31/2018 10:31 AM Stearns County, MN WHEREFORE, plaintiff.demands judgrnent against defendant as follows : 1. For the amount-of $2,77 5.29 ; ). Eor:plaintiffs sssts and disbursements ineurred herein;and 3. For such further and additional relief as the fair and equitable. FIRM, P.C- d#33 s2) M. Ricci (#397065) _ D. Schaal (#396690) M. Toms (#313762) hawn J. Anderson (#397944) Kenneth K. Oh (ffi95}67) Joseph M, Rossman (ffig7w_ K Attorneys for Plaintiff 6681 Country Club Drive Golden Valley, Minnesota 55427 Telephone : 877 -7 7 8 -2302 ACKNOWLEDGMENT Cavalry SPV I, LLC acknowledges that costs, disbursements, reasonable attomey and witness fees rnay be awarded to Mark W pawlowski, pursuant to 549.211. I, s2) _ Ricci (#397065) _ S Schaal (#396690) Steven M. Toms (#313762) Shawn J. Anderson (#397944) Kenneth K. Oh (#398067) Joseph M. Rossman (ßg7ñA\ Í Its Attorneys