On March 03, 2023 a
Complaint,Petition
was filed
involving a dispute between
Discover Bank,
and
Josephson, Jolene,
for Default Judgment
in the District Court of Chisago County.
Preview
13-CV-23-169
Filed in District Court
State of Minnesota
3/3/2023 9:17 AM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF CHISAGO TENTH JUDICIAL DISTRICT
DISCOVER BANK
Plaintiff,
v. SUMMONS
JOLENE IOSEPHSON Court File No.
Defendant(s). Case Type: Consumer Credit Contract (3A)
THE STATE 0F MINNESOTA TO THE ABOVE-NAMED DEFENDANT(S).
1. YOU ARE BEING SUED. The Plaintiff has staned a lawsuit against you. The
Plaintiff's 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 21 DAYS T0 PROTECT YOUR RIGHTS. You must give
or mail to the person who signed this Summons a written response called an Answer within 21 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 to the following address 7300 147m Street West, Suite 307, Apple Valley, MN 55124.
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. If you believe the Plaintiff should not be given everything asked for in the Complaint, you must 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 SIGNED THIS SUMMONS. Ifyou do not Answer within 21
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 Plaintiff everything asked 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 may wish to get legal help from a lawyer. Ifyou 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 provide a written Answer to protect your rights or you may lose
the case.
4664830
13-CV-23-169
Filed in District Court
State of Minnesota
3/3/2023 9:17 AM
6. ALTERNATIVE DISPUTE RESOLUTION. The parties may agec to or be ordered to
participate in an alternative dispute resolution process under Rule 114 of the Minnesota General Rules of
Practice. You must still send your written response to the Complaint even if you expect to use alternative means
of resolving this dispute.
RAUSCH STURM LLP
ATTORNEYS IN THE PRACTICE 0F DEBT COLLECHON
By; r's/Mchaei .I RopeHa
Michael J. RopeIla, #0397665
Joel R. Boon, #0388723
Jason A. Adams, #275657
7300 147'" Street West, Suite 307
Apple Valley, MN 55124
Office Phone No.2 (833) 917-4025 'I'I'Y: 711
Attorney Direct Phone No. (877) 334-1598
Fax: (877) 492-5187
LawfirmMN@rauschsturm.com
ATTORNEY FOR PLAINTIFF
pmnscs.wpdl0ur File No. 4664830
13-CV-23-169
Filed in District Court
State of Minnesota
3/3/2023 9:17 AM
STATE OF MINNESOTA DISTRICT COURT
COUNTY 0F CHISAGO TENTH JUDICIAL DISTRICT
DISCOVER BANK
Plaintiff,
v.
COMPLAINT
JOLENE JOSEPHSON
Court File No.
Defendant(s). Case Type: Consumer Credit Contract (3A)
Plaintiff, by RAUSCH STURM LLP, attorneys and debt collectors, for its claim against Defendant(s),
states and alleges as follows:
1. Upon information and belief, Defendant is an individual residing in CHISAGO County.
2. On or about June 15', 2018, Defendant(s) entered into a Contract for the purchase of goods and/or
services. A copy of the contract is attached hereto as Exhibit "A".
3 That Defendant(s) has/have breached the terms of the Contract, and subsequent
amendments thereto, by failing and refusing to make payment on the Contract, and there
is now due, owing and unpaid the sum of $6,070.33.
4 Pursuant to the Contract and amendments thereto, the Defendant(s) agreed to pay all
costs of collection in the event of default.
5 That although demand has been made upon Defendant(s), neither the said sums or any portion
thereof has been paid, and that there is now due, owing and unpaid despite Plaintiff's demand,
the sum of $6,070.33.
WHEREFORE, Plaintiff prays for judgment against Defendant(s) as for the sum of $6,070.33
plus statutory post judgment interest, plus Plaintiff's costs and disbursements; and for such other and
13-CV-23-169
Filed in District Court
State of Minnesota
3/3/2023 9:17 AM
further relief as the Court deems just.
ACKNOWLEDGMENT
The undersigned hereby acknowledges that sanctions may be awarded pursuant to Minn. Stat. § 549.211.
RAUSCI-l STURM LLP
ATTORNEYS IN THE PRACTICE OF DEBT COLLECI'ION
By: ##Mchmil Ropefla
Michael J. Ropella. #0397665
Joe] R. Boon, #0388723
Jason A. Adams. #275657
7300 I47" Street West, Suite 307
Apple Valley, MN 55124
Office Phone No.: (833) 917-4025 TTY: 711
Attorney Direct Phone No. (877 ) 334-1598
Fax: (877) 492-5187
LawfirmMN@rauschstunn.com
ATTORNEY FOR PLAINTIFF
mmwpd/Our File No. 4664830
Document Filed Date
March 03, 2023
Case Filing Date
March 03, 2023
Category
Default Judgment
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Preview
13-CV-23-169 Filed in District Court State of Minnesota 3/3/2023 9:17 AM STATE OF MINNESOTA DISTRICT COURT COUNTY OF CHISAGO TENTH JUDICIAL DISTRICT DISCOVER BANK Plaintiff, v. SUMMONS JOLENE IOSEPHSON Court File No. Defendant(s). Case Type: Consumer Credit Contract (3A) THE STATE 0F MINNESOTA TO THE ABOVE-NAMED DEFENDANT(S). 1. YOU ARE BEING SUED. The Plaintiff has staned a lawsuit against you. The Plaintiff's 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 21 DAYS T0 PROTECT YOUR RIGHTS. You must give or mail to the person who signed this Summons a written response called an Answer within 21 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 to the following address 7300 147m Street West, Suite 307, Apple Valley, MN 55124. 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. If you believe the Plaintiff should not be given everything asked for in the Complaint, you must 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 SIGNED THIS SUMMONS. Ifyou do not Answer within 21 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 Plaintiff everything asked 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 may wish to get legal help from a lawyer. Ifyou 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 provide a written Answer to protect your rights or you may lose the case. 4664830 13-CV-23-169 Filed in District Court State of Minnesota 3/3/2023 9:17 AM 6. ALTERNATIVE DISPUTE RESOLUTION. The parties may agec to or be ordered to participate in an alternative dispute resolution process under Rule 114 of the Minnesota General Rules of Practice. You must still send your written response to the Complaint even if you expect to use alternative means of resolving this dispute. RAUSCH STURM LLP ATTORNEYS IN THE PRACTICE 0F DEBT COLLECHON By; r's/Mchaei .I RopeHa Michael J. RopeIla, #0397665 Joel R. Boon, #0388723 Jason A. Adams, #275657 7300 147'" Street West, Suite 307 Apple Valley, MN 55124 Office Phone No.2 (833) 917-4025 'I'I'Y: 711 Attorney Direct Phone No. (877) 334-1598 Fax: (877) 492-5187 LawfirmMN@rauschsturm.com ATTORNEY FOR PLAINTIFF pmnscs.wpdl0ur File No. 4664830 13-CV-23-169 Filed in District Court State of Minnesota 3/3/2023 9:17 AM STATE OF MINNESOTA DISTRICT COURT COUNTY 0F CHISAGO TENTH JUDICIAL DISTRICT DISCOVER BANK Plaintiff, v. COMPLAINT JOLENE JOSEPHSON Court File No. Defendant(s). Case Type: Consumer Credit Contract (3A) Plaintiff, by RAUSCH STURM LLP, attorneys and debt collectors, for its claim against Defendant(s), states and alleges as follows: 1. Upon information and belief, Defendant is an individual residing in CHISAGO County. 2. On or about June 15', 2018, Defendant(s) entered into a Contract for the purchase of goods and/or services. A copy of the contract is attached hereto as Exhibit "A". 3 That Defendant(s) has/have breached the terms of the Contract, and subsequent amendments thereto, by failing and refusing to make payment on the Contract, and there is now due, owing and unpaid the sum of $6,070.33. 4 Pursuant to the Contract and amendments thereto, the Defendant(s) agreed to pay all costs of collection in the event of default. 5 That although demand has been made upon Defendant(s), neither the said sums or any portion thereof has been paid, and that there is now due, owing and unpaid despite Plaintiff's demand, the sum of $6,070.33. WHEREFORE, Plaintiff prays for judgment against Defendant(s) as for the sum of $6,070.33 plus statutory post judgment interest, plus Plaintiff's costs and disbursements; and for such other and 13-CV-23-169 Filed in District Court State of Minnesota 3/3/2023 9:17 AM further relief as the Court deems just. ACKNOWLEDGMENT The undersigned hereby acknowledges that sanctions may be awarded pursuant to Minn. Stat. § 549.211. RAUSCI-l STURM LLP ATTORNEYS IN THE PRACTICE OF DEBT COLLECI'ION By: ##Mchmil Ropefla Michael J. Ropella. #0397665 Joe] R. Boon, #0388723 Jason A. Adams. #275657 7300 I47" Street West, Suite 307 Apple Valley, MN 55124 Office Phone No.: (833) 917-4025 TTY: 711 Attorney Direct Phone No. (877 ) 334-1598 Fax: (877) 492-5187 LawfirmMN@rauschstunn.com ATTORNEY FOR PLAINTIFF mmwpd/Our File No. 4664830