Preview
25-CV-18-3291
Filed in District Court
State of Minnesota
12/31/2018 12:58 PM
Case TVpe: Personal Injury
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF GOODHUE FIRST JUDICIAL DISTRICT
Dylan Michael Krg, a minor, by his
mother and natural guardian Carrie
Krg, and Carrie King, individually,
SUMMONS
Plaintiffs,
v
Dennis Furlong,
Defendant.
THIS SUMMONS IS DIRECTED TO DEFENDANT DENNIS FURLONG
1. YOU ARE BEING SUED. The Plaintiffs have started a lawsuit against you.
The Plaintiffs'Complaint against you is attached to this Summons. Do not
throw these papers away. They are official papers that affect your rights.
You must respond to this lawsuit even though it may not yet be filed 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 called an Answer within 20 days of the date on which you received
this Summons. You must send a copy of your Answer to the person who
signed this Summons located at:
Schwebel Goetz & Sieben
5120 IDS Center
80 S. 8th Street
Minneapolis, MN 55402
3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written
response to the Plaintiffs'Complaint. In your Answer you must state
whether you agree or disagree with each paragraph of the Complaint. If you
believe the Plaintiffs should not be given everything asked for in the
Complaint, you must say so in your Answer.
4, YOU UIILL LOSE YOUR CAST IF YOU DO NOT SEND A WRITTEN
RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THIS
SUMMONS. If you do not Answer within 20 days, you will lose this case.
You will not get to tell your side of the story, and the Court may decide
against you and award the Plaintiffs everything asked for in the Complaint.
25-CV-18-3291
Filed in District Court
State of Minnesota
12/31/2018 12:58 PM
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 may wish to get legal help from a lawyer. If you
do not have a lawyer, the Court Administrator may have information about
places where you can get legal assistance. Even if you cannot get legal
help, you must still provlde a written Answer to protect your rights or
you may lose the case.
6. ALTERNATryE DISPUTE RESOLUTION. The parties may agree to or be
ordered to participate in an alternative dispute resolution process under
Rule 1L4 of the Minnesota General Rules of Practice. You must stillsend
your written response to the Complaint even if you expect to use alternative
means of resolving this dispute.
I hereby acknowledge that sanctions may be awarded
pursuant to Minn. Stat. $ 549.2LL.
SCHWEBEL GOETZ & SIEBEN, P.A.
Dated: October <\, 2018
William
u;
R. Sieben (#100808)
James S. Ballentine (#2097391
ATTORNEYS FOR THE PLAINTIFFS
5120 IDS Center
80 South Eighth Street
Minneapolis, Minnesota 55402-2246
Telephone : 6L2-377 -7777
Fax: 612-333-631 1
Email: bsieben@schwebel.com
Email : j ballentine@schwebel. com
25-CV-18-3291
Filed in District Court
State of Minnesota
12/31/2018 12:58 PM
Case Tlpe: Personal Injury
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF GOODHUE FIRST JUDICIAL DISTRICT
Dylan Michael K.g, a minor, by his
mother and natural guardian Carrie
Krg, and Carrie King, individually, COMPLAINT
Plaintiffs,
v
Dennis Furlong,
Defendant.
Plaintiffs Dylan Michael King, a minor, by his mother and natural guardian
Carrie King and Carrie King, individually, for their claims for relief, state and allege
that:
I
Carrie King is the mother of Dylan Michael Krg, who was born on December
20,2OO 1 and is presently 16 years of age. Dylan Michael Krg, lives with Carrie King
and Carrie King is responsible for his medical care and attention and is entitled to his
services during his minority.
n
On August27,2OI3 at approximately 3:45 p.m., minor plaintiff Dylan Michael
Krg, was lawfully present on premises owned by defendant Dennis Furlong located at
16865 Highway 61 Boulevard, Welch, Minnesota. At said time and place, minor
plaintiff Dylan Michael King was helping defendant Dennis Furlong on Furlong's
family farm doing pond renovations to improve deer habitat. Minor plaintiff Dylan
Michael king was holding a l2-inch plastic PCV pipe vertical when defendant Dennis
25-CV-18-3291
Filed in District Court
State of Minnesota
12/31/2018 12:58 PM
Furlong lost control of his skid loader and slammed into minor plaintiff pinning him
with the skid loader's bucket.
UI
At that time and place, minor plaintiff Dylan Michael Ktg, sustained severe
and permanent injuries as a result of the carelessness and negligence of the defendant
his in failure to maintain a proper lookout, in his failure to keep his skid loader under
control and as a result of other careless and negligent acts and omissions on the part
of the defendant.
IV
As a result of this accident, minor plaintiff Dylan Michael Ktg, sustained
severe and permanent injuries; upon attaining his majority he will incur medical and
hospital expenses for the treatment of these injuries; he has sustained a permanent
impairment of his earning capacity and, upon attaining his majority, will suffer a
consequent loss of earnings; he has in the past and will in the future suffer physical
and mental pain. Therefore, minor plaintiff Dylan Michael Ktg, a minor has been
damaged and injured in an amount greater than Fifty Thousand and no/ 100
($5O,OOO1 Dollars.
V
As a result of the injuries sustained by minor plaintiff Dylan Michael King, his
mother, plaintiff Carrie King has in the past and will in the future, during the minority
of Dylan Michael Krg, incur medical and hospital expenses for the treatment of his
injuries. Plaintiff Carrie King has in the past and will in the future, during the
minority of Dylan Michael King, be deprived of his services and companionship.
Therefore, plaintiff Carrie King has been damaged and injured in an amount greater
than Fifty Thousand and no/ 100 ($50,000) Dollars.
-2-
25-CV-18-3291
Filed in District Court
State of Minnesota
12/31/2018 12:58 PM
WHEREFORE, plaintiffs pray Judgment against defendant in an amount
greater than Fifty Thousand and no/ 100 ($50,000) Dollars on behalf of minor plaintiff
Dylan Michael Krg, and in an amount greater than Fifty Thousand and no/ 100
($50,000) Dollars on behalf of plaintiff Carrie Krg, together with interest, costs and
disbursements incurred herein.
I hereby acknowledge that sanctions may be awarded
pursuant to Minn. Stat. $ 549.2LL.
SCHWEBEL GOETZ & SIEBEN, P.A.
Dated: October 2018
William R. Sieben (#100808)
James S. Ballentine (#2097391
ATTORNEYS FOR THE PLAINTIFFS
5I2O IDS Center
80 South Eighth Street
Minneapolis, Minnesota 55402-2246
Telephone: 612-377 -7777
Fax: 612-333-6311
Email: bsieben@schwebel.com
Email: j ballentine@schwebel.com
-3-
Preview
25-CV-18-3291 Filed in District Court State of Minnesota 12/31/2018 12:58 PM Case TVpe: Personal Injury STATE OF MINNESOTA DISTRICT COURT COUNTY OF GOODHUE FIRST JUDICIAL DISTRICT Dylan Michael Krg, a minor, by his mother and natural guardian Carrie Krg, and Carrie King, individually, SUMMONS Plaintiffs, v Dennis Furlong, Defendant. THIS SUMMONS IS DIRECTED TO DEFENDANT DENNIS FURLONG 1. YOU ARE BEING SUED. The Plaintiffs have started a lawsuit against you. The Plaintiffs'Complaint against you is attached to this Summons. Do not throw these papers away. They are official papers that affect your rights. You must respond to this lawsuit even though it may not yet be filed 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 called an Answer within 20 days of the date on which you received this Summons. You must send a copy of your Answer to the person who signed this Summons located at: Schwebel Goetz & Sieben 5120 IDS Center 80 S. 8th Street Minneapolis, MN 55402 3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiffs'Complaint. In your Answer you must state whether you agree or disagree with each paragraph of the Complaint. If you believe the Plaintiffs should not be given everything asked for in the Complaint, you must say so in your Answer. 4, YOU UIILL LOSE YOUR CAST IF YOU DO NOT SEND A WRITTEN RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THIS SUMMONS. If you do not Answer within 20 days, you will lose this case. You will not get to tell your side of the story, and the Court may decide against you and award the Plaintiffs everything asked for in the Complaint. 25-CV-18-3291 Filed in District Court State of Minnesota 12/31/2018 12:58 PM 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 may wish to get legal help from a lawyer. If you do not have a lawyer, the Court Administrator may have information about places where you can get legal assistance. Even if you cannot get legal help, you must still provlde a written Answer to protect your rights or you may lose the case. 6. ALTERNATryE DISPUTE RESOLUTION. The parties may agree to or be ordered to participate in an alternative dispute resolution process under Rule 1L4 of the Minnesota General Rules of Practice. You must stillsend your written response to the Complaint even if you expect to use alternative means of resolving this dispute. I hereby acknowledge that sanctions may be awarded pursuant to Minn. Stat. $ 549.2LL. SCHWEBEL GOETZ & SIEBEN, P.A. Dated: October <\, 2018 William u; R. Sieben (#100808) James S. Ballentine (#2097391 ATTORNEYS FOR THE PLAINTIFFS 5120 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402-2246 Telephone : 6L2-377 -7777 Fax: 612-333-631 1 Email: bsieben@schwebel.com Email : j ballentine@schwebel. com 25-CV-18-3291 Filed in District Court State of Minnesota 12/31/2018 12:58 PM Case Tlpe: Personal Injury STATE OF MINNESOTA DISTRICT COURT COUNTY OF GOODHUE FIRST JUDICIAL DISTRICT Dylan Michael K.g, a minor, by his mother and natural guardian Carrie Krg, and Carrie King, individually, COMPLAINT Plaintiffs, v Dennis Furlong, Defendant. Plaintiffs Dylan Michael King, a minor, by his mother and natural guardian Carrie King and Carrie King, individually, for their claims for relief, state and allege that: I Carrie King is the mother of Dylan Michael Krg, who was born on December 20,2OO 1 and is presently 16 years of age. Dylan Michael Krg, lives with Carrie King and Carrie King is responsible for his medical care and attention and is entitled to his services during his minority. n On August27,2OI3 at approximately 3:45 p.m., minor plaintiff Dylan Michael Krg, was lawfully present on premises owned by defendant Dennis Furlong located at 16865 Highway 61 Boulevard, Welch, Minnesota. At said time and place, minor plaintiff Dylan Michael King was helping defendant Dennis Furlong on Furlong's family farm doing pond renovations to improve deer habitat. Minor plaintiff Dylan Michael king was holding a l2-inch plastic PCV pipe vertical when defendant Dennis 25-CV-18-3291 Filed in District Court State of Minnesota 12/31/2018 12:58 PM Furlong lost control of his skid loader and slammed into minor plaintiff pinning him with the skid loader's bucket. UI At that time and place, minor plaintiff Dylan Michael Ktg, sustained severe and permanent injuries as a result of the carelessness and negligence of the defendant his in failure to maintain a proper lookout, in his failure to keep his skid loader under control and as a result of other careless and negligent acts and omissions on the part of the defendant. IV As a result of this accident, minor plaintiff Dylan Michael Ktg, sustained severe and permanent injuries; upon attaining his majority he will incur medical and hospital expenses for the treatment of these injuries; he has sustained a permanent impairment of his earning capacity and, upon attaining his majority, will suffer a consequent loss of earnings; he has in the past and will in the future suffer physical and mental pain. Therefore, minor plaintiff Dylan Michael Ktg, a minor has been damaged and injured in an amount greater than Fifty Thousand and no/ 100 ($5O,OOO1 Dollars. V As a result of the injuries sustained by minor plaintiff Dylan Michael King, his mother, plaintiff Carrie King has in the past and will in the future, during the minority of Dylan Michael Krg, incur medical and hospital expenses for the treatment of his injuries. Plaintiff Carrie King has in the past and will in the future, during the minority of Dylan Michael King, be deprived of his services and companionship. Therefore, plaintiff Carrie King has been damaged and injured in an amount greater than Fifty Thousand and no/ 100 ($50,000) Dollars. -2- 25-CV-18-3291 Filed in District Court State of Minnesota 12/31/2018 12:58 PM WHEREFORE, plaintiffs pray Judgment against defendant in an amount greater than Fifty Thousand and no/ 100 ($50,000) Dollars on behalf of minor plaintiff Dylan Michael Krg, and in an amount greater than Fifty Thousand and no/ 100 ($50,000) Dollars on behalf of plaintiff Carrie Krg, together with interest, costs and disbursements incurred herein. I hereby acknowledge that sanctions may be awarded pursuant to Minn. Stat. $ 549.2LL. SCHWEBEL GOETZ & SIEBEN, P.A. Dated: October 2018 William R. Sieben (#100808) James S. Ballentine (#2097391 ATTORNEYS FOR THE PLAINTIFFS 5I2O IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402-2246 Telephone: 612-377 -7777 Fax: 612-333-6311 Email: bsieben@schwebel.com Email: j ballentine@schwebel.com -3-