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27-CV-23-18215
Filed in District Court
State of Minnesota
11/30/2023 11:13 AM
STATE 0F MINNESOTA DISTRICT COURT
COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT
Case Type: Minor Settlement
In the Matter of:
Jordyn Poteau, a minor,
by Miatta Bryant, as parent
and natural guardian,
Plaintiff, PETITION FOR MINOR
SETTLEMENT
v.
Jack Delebo,
Defendant.
T0: DISTRICT COURT IN AND FOR HENNEPIN COUNTY, STATE OF MINNESOTA
Your petitioner, Miatta Bryant, as natural guardian for Jordyn Poteau, respectfully
represents to the Court as follows:
I.
She is the mother of natural guardian of Jordyn Poteau, a minor, and lives in Minnesota.
II.
Said minor was born September 7, 2007, and is presently Sixteen (16) years of age.
III.
The present address of the petitioner and the minor is 5801 North Xerxes Avenue, Unit
220, Minneapolis, Minnesota, 55430.
IV.
On September 27, 2022, the minor, Jordyn Poteau, was the passenger in her mother's
vehicle driving on Interstate 94, when Defendant Delebo merged into their vehicle, pushing them
27-CV-23-18215
Filed in District Court
State of Minnesota
11/30/2023 11:13 AM
to the shoulder of the highway.
V.
Your petitioner commenced a claim against defendant: Jack Delebo and his insurance
in the September
company, Farmers Insurance, as a result of the injuries Jordyn Poteau suffered
27, 2022, motor vehicle accident.
VI.
Petitioner has been offered a lump sum of Fifieen Thousand Five Hundred and 00/100
Dollars ($15,500.00) from Farmers Insurance for complete settlement of the minor's claim
against defendant set forth herein. These sums are distributed by Farmers Insurance on behalf
of
defendant, Jack Delebo.
VII.
Petitioner, Miatta Bryant, believes that under the circumstances, said offer of settlement
is fair and reasonable and that it is in the best interest of the minor, Jordyn Poteau, that the same
be approved.
VIII.
That petitioner retained attorney Michael Joyce to represent the minor's interest with
regard to the September 27, 2022, motor vehicle accident and has agreed to pay Mr. Joyce
twenty-five percent of all sums received, either by suit or by settlement, and to reimburse Mr.
Joyce for all costs necessarily incurred in pursuit of this claim. Mr. Joyce has incurred costs in
pursuit of this claim as follows:
a. Filing fees $377.00
b. Medical Records/Reports $132.46
TOTAL EXPENSES $509.46
2
27-CV-23-18215
Filed in District Court
State of Minnesota
11/30/2023 11:13 AM
IX.
Four Hundred Ninety Five and 35/100 Dollars ($495.35) will be paid to Hennepin Health
for outstanding subrogation fees. This fee was reduced through negotiation and will be accepted
as full and final payment.
X.
Three Thousand Three Hundred Forty-Six and 67/100 Dollars ($3,346.67) will be paid to
Legacy Chiropractic for outstanding medical bills. This fee was reduced through negotiation and
will be accepted as full and final payment.
X.
There remains, after payment of attorneys fees and costs, the balance of Seven Thousand
Two Hundred Seventy Three and 52/100 Dollars ($7,273.52), which will be deposited with
Associated Bank, Bloomington, Minnesota until September 7, 2025, on which date Jordyn Poteau
shall obtain eighteen (l8) years of age. The Financial Institution shall forthwith acknowledge to
the Court receipt of the order approving settlement and the sum, and that no disbursement of the
funds will occur unless the Court so orders, using the fonn substantially equivalent to Form 145.1
(attached as Exhibit A).
WHEREFORE, your petitioner prays for an Order of this Court approving the minor
settlement and authorizing petitioner to sign a general release as power of attorney guardian of
Jordyn Poteau, of which said release will discharge any liability on behalf of the defendants set
forth above.
3
27-CV-23-18215
Filed in District Court
State of Minnesota
11/30/2023 11:13 AM
I declare under penalty ofperjury that everything that I have stated in this document is true and
correct. Minn. Stat. § 358.116.
Dated: 11/30/2023 I
Wm% n]
Miatta Bryan
STATE OF MINNESOTA )
)SS.
COUNTY OF HENNEPIN )
Miatta Bryant, being first duly sworn upon oath says:
That she is the person who made and signed the foregoing Petition for Minor Settlement; that,
she has read said Petition and knows the contents thereof; that, said Petition is true of her own
knowledge except as to those matters therein stated on information and belief, and as to those
matters, she believes it to be true.
I declare under penaltj) ofperjury that everything that I have stated in this document is true and
correct. Minn. Stat. § 358. I I 6.
Miatta Bryant
27-CV-23-18215
Filed in District Court
State of Minnesota
11/30/2023 11:13 AM
EXHIBIT A
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT
Case Type: Minor Settlement
Court File No.:
In the Matter of:
Jordyn Poteau, a minor,
by Miatta Bryant, as parent and natural
guardian,
RECEIPT OF MINOR
SETTLEMENT ORDER AND
FUNDS
Plaintiff}
v.
Jack Delebo,
Defendant.
1. Associated Bank, Bloomington, Minnesota ("Financial Institution")
acknowledges receipt of the sum of Seven Thousand Two Hundred Seventy Three
and 52/100 Dollars ($7,273.52), on behalf of Jordyn Poteau in this action.
2. Financial Institution acknowledged receipt of Order Approving Settlement dated
in this action, and that the funds delivered
remain subject to that order in the account specified below:
Name of Depository:
Branch Name:
Branch Address:
Account Number:
5
27-CV-23-18215
Filed in District Court
State of Minnesota
11/30/2023 11:13 AM
Date Account Opened:
Current Balance:
3. This account is a federally insured, restricted account, and no withdrawal of either
principal or interest shall be allowed by Financial Institution without a signed
order in this case.
Dated:
Type or Print Name
Title
6
.
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27-CV-23-18215 Filed in District Court State of Minnesota 11/30/2023 11:13 AM STATE 0F MINNESOTA DISTRICT COURT COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT Case Type: Minor Settlement In the Matter of: Jordyn Poteau, a minor, by Miatta Bryant, as parent and natural guardian, Plaintiff, PETITION FOR MINOR SETTLEMENT v. Jack Delebo, Defendant. T0: DISTRICT COURT IN AND FOR HENNEPIN COUNTY, STATE OF MINNESOTA Your petitioner, Miatta Bryant, as natural guardian for Jordyn Poteau, respectfully represents to the Court as follows: I. She is the mother of natural guardian of Jordyn Poteau, a minor, and lives in Minnesota. II. Said minor was born September 7, 2007, and is presently Sixteen (16) years of age. III. The present address of the petitioner and the minor is 5801 North Xerxes Avenue, Unit 220, Minneapolis, Minnesota, 55430. IV. On September 27, 2022, the minor, Jordyn Poteau, was the passenger in her mother's vehicle driving on Interstate 94, when Defendant Delebo merged into their vehicle, pushing them 27-CV-23-18215 Filed in District Court State of Minnesota 11/30/2023 11:13 AM to the shoulder of the highway. V. Your petitioner commenced a claim against defendant: Jack Delebo and his insurance in the September company, Farmers Insurance, as a result of the injuries Jordyn Poteau suffered 27, 2022, motor vehicle accident. VI. Petitioner has been offered a lump sum of Fifieen Thousand Five Hundred and 00/100 Dollars ($15,500.00) from Farmers Insurance for complete settlement of the minor's claim against defendant set forth herein. These sums are distributed by Farmers Insurance on behalf of defendant, Jack Delebo. VII. Petitioner, Miatta Bryant, believes that under the circumstances, said offer of settlement is fair and reasonable and that it is in the best interest of the minor, Jordyn Poteau, that the same be approved. VIII. That petitioner retained attorney Michael Joyce to represent the minor's interest with regard to the September 27, 2022, motor vehicle accident and has agreed to pay Mr. Joyce twenty-five percent of all sums received, either by suit or by settlement, and to reimburse Mr. Joyce for all costs necessarily incurred in pursuit of this claim. Mr. Joyce has incurred costs in pursuit of this claim as follows: a. Filing fees $377.00 b. Medical Records/Reports $132.46 TOTAL EXPENSES $509.46 2 27-CV-23-18215 Filed in District Court State of Minnesota 11/30/2023 11:13 AM IX. Four Hundred Ninety Five and 35/100 Dollars ($495.35) will be paid to Hennepin Health for outstanding subrogation fees. This fee was reduced through negotiation and will be accepted as full and final payment. X. Three Thousand Three Hundred Forty-Six and 67/100 Dollars ($3,346.67) will be paid to Legacy Chiropractic for outstanding medical bills. This fee was reduced through negotiation and will be accepted as full and final payment. X. There remains, after payment of attorneys fees and costs, the balance of Seven Thousand Two Hundred Seventy Three and 52/100 Dollars ($7,273.52), which will be deposited with Associated Bank, Bloomington, Minnesota until September 7, 2025, on which date Jordyn Poteau shall obtain eighteen (l8) years of age. The Financial Institution shall forthwith acknowledge to the Court receipt of the order approving settlement and the sum, and that no disbursement of the funds will occur unless the Court so orders, using the fonn substantially equivalent to Form 145.1 (attached as Exhibit A). WHEREFORE, your petitioner prays for an Order of this Court approving the minor settlement and authorizing petitioner to sign a general release as power of attorney guardian of Jordyn Poteau, of which said release will discharge any liability on behalf of the defendants set forth above. 3 27-CV-23-18215 Filed in District Court State of Minnesota 11/30/2023 11:13 AM I declare under penalty ofperjury that everything that I have stated in this document is true and correct. Minn. Stat. § 358.116. Dated: 11/30/2023 I Wm% n] Miatta Bryan STATE OF MINNESOTA ) )SS. COUNTY OF HENNEPIN ) Miatta Bryant, being first duly sworn upon oath says: That she is the person who made and signed the foregoing Petition for Minor Settlement; that, she has read said Petition and knows the contents thereof; that, said Petition is true of her own knowledge except as to those matters therein stated on information and belief, and as to those matters, she believes it to be true. I declare under penaltj) ofperjury that everything that I have stated in this document is true and correct. Minn. Stat. § 358. I I 6. Miatta Bryant 27-CV-23-18215 Filed in District Court State of Minnesota 11/30/2023 11:13 AM EXHIBIT A STATE OF MINNESOTA DISTRICT COURT COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT Case Type: Minor Settlement Court File No.: In the Matter of: Jordyn Poteau, a minor, by Miatta Bryant, as parent and natural guardian, RECEIPT OF MINOR SETTLEMENT ORDER AND FUNDS Plaintiff} v. Jack Delebo, Defendant. 1. Associated Bank, Bloomington, Minnesota ("Financial Institution") acknowledges receipt of the sum of Seven Thousand Two Hundred Seventy Three and 52/100 Dollars ($7,273.52), on behalf of Jordyn Poteau in this action. 2. Financial Institution acknowledged receipt of Order Approving Settlement dated in this action, and that the funds delivered remain subject to that order in the account specified below: Name of Depository: Branch Name: Branch Address: Account Number: 5 27-CV-23-18215 Filed in District Court State of Minnesota 11/30/2023 11:13 AM Date Account Opened: Current Balance: 3. This account is a federally insured, restricted account, and no withdrawal of either principal or interest shall be allowed by Financial Institution without a signed order in this case. Dated: Type or Print Name Title 6 .