On November 14, 2023 a
Miscellaneous
was filed
involving a dispute between
Falcon Leasing,
and
Navarro Farm Labor Services Inc.,
Navarro-Pimentel, Raul,
for Contract
in the District Court of Stearns County.
Preview
73-CV-23-8959
Filed in District Court
State of Minnesota
11/14/2023 2:41 PM
State of Minnesota District Court
County Judicial District: Seventh
Stearns Court File Number:
Case Type: Contract
Falcon Leasing, a division of Falcon
National Bank,
Plaintiff,
Civil Cover Sheet
v. (Non-Family Case Type)
Minn. R. Gen. Prac. 104
Navarro Farm labor Services inc. and
Raul Navarro-Pinentel,
Defendants.
Date Case Filed:
This civil cover sheet must be filed by the initial filing lawyer or party, if unrepresented by legal
counsel, unless the court orders all parties or their legal counsel to complete this form. Once the
initial civil cover sheet is filed, opposing lawyers or unrepresented parties who have not already
been ordered to complete this form may submit their own cover sheet within ten days after being
served with the initial cover sheet. See Rule 104 of the General Rules of Practice for the District
Courts.
If information is not known to the filing party at the time of filing, it shall be provided to the
Court Administrator in writing by the filing party within seven (7) days of learning the
information. Any party impleading additional parties shall provide the same information to the
Court Administrator. The Court Administrator shall, upon receipt of the completed certificate,
notify all parties or their lawyers, if represented by counsel, of the date of filing the action and the
file number assigned.
ATTORNEY FOR PLAINTIFF ATTORNEY FOR DEFENDANTS
Benjamin M. Podobinski
Attorney Attorney Name
225 South Sixth Street, Suite 3500
Postal Address Postal Address
Minneapolis, MN 55402
City State Zip Code City State Zip Code
(612) 604-6400
Telephone Number Telephone Number
CIV117 State ENG 05/13 www.mncourts.gov/forms Page 1 of 4
73-CV-23-8959
Filed in District Court
State of Minnesota
11/14/2023 2:41 PM
bpodobinski@winthrop.com
E-mail address E-mail address
401054
Minnesota Attorney License No. Minnesota Attorney License No.
PLAINTIFF DEFENDANTS
Falcon Leasing Navarro Farm Labor Services Inc.
Name Name
183 Cedar Drive 10101 Main Street
Postal Address Postal Address
Foley, MN 56329 Lamont, CA 93241
City State Zip Code City State Zip Code
Raul Navarro-Pimentel
8909 Bonita Road
Lamont, CA 93241
1. Provide a concise statement of the case including facts and legal basis: Falcon Leasing and
Navarro Farm Labor Services Inc. entered into an equipment finance agreement in which Falcon
Leasing agreed to provide Navarro Farm Labor Services Inc. with the financing to purchase a 2014
Peterbilt 389, VIN 1XPXD49X3ED215851. Raul Navarro-Pimentel personally guaranteed
Navarro Farm Labor Services Inc.’s obligations under the agreement. Navarro Farm Labor
Services Inc. has defaulted under its obligations under the financing agreement and Raul-Navarro-
Pimentel has defaulted under his obligations under the guaranty. Falcon Leasing seeks a monetary
judgment against both Navarro Farm Labor Services Inc. and Raul Navarro-Pimentel.
2. Date Complaint was served: Defendants were served on
3. For Expedited Litigation Track (ELT) Pilot Courts only: N/A
a. □ The parties jointly and voluntarily agree that this case shall be governed by the
Special Rules for ELT Pilot. Date of agreement:
b. □ The court is requested to consider excluding this case from ELT for the following
reasons:
Note: ELT is mandatory in certain cases, and where mandatory, exclusion may also be
sought by timely motion under the Special Rules for ELT Pilot.
c. Anticipated number of trial witnesses: three
CIV117 State ENG 05/13 www.mncourts.gov/forms Page 2 of 4
73-CV-23-8959
Filed in District Court
State of Minnesota
11/14/2023 2:41 PM
d. Amount of medical expenses to date: N/A
e. Amount of lost wages to date: N/A
f. Identify any known subrogation interests: N/A
4. Estimated discovery completion: January 2, 2024
5. Disclosure / discovery of electronically stored information discussed with other party?
X No □ Yes, date of discussion:
If Yes, list agreements, plans, and disputes:
6. Proposed trial start date: March 1, 2024
7. Estimated trial time: four hours
8. Jury trial is: waived by plaintiff
□ waived by consent of pursuant to Minn. R. Civ. P. 38.02.
(specify party)
□ requested by (NOTE: Applicable fee must be enclosed)
(specify party)
9. Physical/mental/blood examination pursuant to Minn. R. Civ. P. 35 is requested:
□ Yes X No
10. Identify any party or witness who will require interpreter services, and describe the services
needed (specifying language, and if known, particular dialect): N/A
11. Issues in dispute: there are no known issues in dispute at this time
12. Case Type / Category: Contract (Money Judgment) (NOTE: select case type from Form 23,
Subject Matter Index for Civil Cases, appended to the Minnesota Rules of Civil Procedure).
13. Recommended Alternative Dispute Resolution (ADR) mechanism: N/A
(See list of ADR processes set forth in Minn. Gen. R. Prac. 114.02(a))
Recommended ADR provider (known as a “neutral”): N/A
Recommended ADR completion date: N/A
If applicable, reasons why ADR not appropriate for this case: N/A
CIV117 State ENG 05/13 www.mncourts.gov/forms Page 3 of 4
73-CV-23-8959
Filed in District Court
State of Minnesota
11/14/2023 2:41 PM
By signing below, the attorney or party submitting this form certifies that to the best of his
knowledge the above information is true and correct.
Submitted by: /s/ Benjamin M. Podobinski
Attorney License Number 387048
Firm: Winthrop & Weinstine, P.A.
Address: 225 South Sixth Street, Suite 3500
Minneapolis, MN 55402
Telephone: (612) 604-6400
Date: November 14, 2023
27358289v1
CIV117 State ENG 05/13 www.mncourts.gov/forms Page 4 of 4
Document Filed Date
November 14, 2023
Case Filing Date
November 14, 2023
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73-CV-23-8959 Filed in District Court State of Minnesota 11/14/2023 2:41 PM State of Minnesota District Court County Judicial District: Seventh Stearns Court File Number: Case Type: Contract Falcon Leasing, a division of Falcon National Bank, Plaintiff, Civil Cover Sheet v. (Non-Family Case Type) Minn. R. Gen. Prac. 104 Navarro Farm labor Services inc. and Raul Navarro-Pinentel, Defendants. Date Case Filed: This civil cover sheet must be filed by the initial filing lawyer or party, if unrepresented by legal counsel, unless the court orders all parties or their legal counsel to complete this form. Once the initial civil cover sheet is filed, opposing lawyers or unrepresented parties who have not already been ordered to complete this form may submit their own cover sheet within ten days after being served with the initial cover sheet. See Rule 104 of the General Rules of Practice for the District Courts. If information is not known to the filing party at the time of filing, it shall be provided to the Court Administrator in writing by the filing party within seven (7) days of learning the information. Any party impleading additional parties shall provide the same information to the Court Administrator. The Court Administrator shall, upon receipt of the completed certificate, notify all parties or their lawyers, if represented by counsel, of the date of filing the action and the file number assigned. ATTORNEY FOR PLAINTIFF ATTORNEY FOR DEFENDANTS Benjamin M. Podobinski Attorney Attorney Name 225 South Sixth Street, Suite 3500 Postal Address Postal Address Minneapolis, MN 55402 City State Zip Code City State Zip Code (612) 604-6400 Telephone Number Telephone Number CIV117 State ENG 05/13 www.mncourts.gov/forms Page 1 of 4 73-CV-23-8959 Filed in District Court State of Minnesota 11/14/2023 2:41 PM bpodobinski@winthrop.com E-mail address E-mail address 401054 Minnesota Attorney License No. Minnesota Attorney License No. PLAINTIFF DEFENDANTS Falcon Leasing Navarro Farm Labor Services Inc. Name Name 183 Cedar Drive 10101 Main Street Postal Address Postal Address Foley, MN 56329 Lamont, CA 93241 City State Zip Code City State Zip Code Raul Navarro-Pimentel 8909 Bonita Road Lamont, CA 93241 1. Provide a concise statement of the case including facts and legal basis: Falcon Leasing and Navarro Farm Labor Services Inc. entered into an equipment finance agreement in which Falcon Leasing agreed to provide Navarro Farm Labor Services Inc. with the financing to purchase a 2014 Peterbilt 389, VIN 1XPXD49X3ED215851. Raul Navarro-Pimentel personally guaranteed Navarro Farm Labor Services Inc.’s obligations under the agreement. Navarro Farm Labor Services Inc. has defaulted under its obligations under the financing agreement and Raul-Navarro- Pimentel has defaulted under his obligations under the guaranty. Falcon Leasing seeks a monetary judgment against both Navarro Farm Labor Services Inc. and Raul Navarro-Pimentel. 2. Date Complaint was served: Defendants were served on 3. For Expedited Litigation Track (ELT) Pilot Courts only: N/A a. □ The parties jointly and voluntarily agree that this case shall be governed by the Special Rules for ELT Pilot. Date of agreement: b. □ The court is requested to consider excluding this case from ELT for the following reasons: Note: ELT is mandatory in certain cases, and where mandatory, exclusion may also be sought by timely motion under the Special Rules for ELT Pilot. c. Anticipated number of trial witnesses: three CIV117 State ENG 05/13 www.mncourts.gov/forms Page 2 of 4 73-CV-23-8959 Filed in District Court State of Minnesota 11/14/2023 2:41 PM d. Amount of medical expenses to date: N/A e. Amount of lost wages to date: N/A f. Identify any known subrogation interests: N/A 4. Estimated discovery completion: January 2, 2024 5. Disclosure / discovery of electronically stored information discussed with other party? X No □ Yes, date of discussion: If Yes, list agreements, plans, and disputes: 6. Proposed trial start date: March 1, 2024 7. Estimated trial time: four hours 8. Jury trial is: waived by plaintiff □ waived by consent of pursuant to Minn. R. Civ. P. 38.02. (specify party) □ requested by (NOTE: Applicable fee must be enclosed) (specify party) 9. Physical/mental/blood examination pursuant to Minn. R. Civ. P. 35 is requested: □ Yes X No 10. Identify any party or witness who will require interpreter services, and describe the services needed (specifying language, and if known, particular dialect): N/A 11. Issues in dispute: there are no known issues in dispute at this time 12. Case Type / Category: Contract (Money Judgment) (NOTE: select case type from Form 23, Subject Matter Index for Civil Cases, appended to the Minnesota Rules of Civil Procedure). 13. Recommended Alternative Dispute Resolution (ADR) mechanism: N/A (See list of ADR processes set forth in Minn. Gen. R. Prac. 114.02(a)) Recommended ADR provider (known as a “neutral”): N/A Recommended ADR completion date: N/A If applicable, reasons why ADR not appropriate for this case: N/A CIV117 State ENG 05/13 www.mncourts.gov/forms Page 3 of 4 73-CV-23-8959 Filed in District Court State of Minnesota 11/14/2023 2:41 PM By signing below, the attorney or party submitting this form certifies that to the best of his knowledge the above information is true and correct. Submitted by: /s/ Benjamin M. Podobinski Attorney License Number 387048 Firm: Winthrop & Weinstine, P.A. Address: 225 South Sixth Street, Suite 3500 Minneapolis, MN 55402 Telephone: (612) 604-6400 Date: November 14, 2023 27358289v1 CIV117 State ENG 05/13 www.mncourts.gov/forms Page 4 of 4