Legal Document: Velocity Investments, LLC vs TYSHON RYAN

On December 05, 2023 a Summons and Complaint Index #2 was filed involving a dispute between Velocity Investments, Llc, and Ryan, Tyshon, for Default Judgment in the District Court of Hennepin County.

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27-CV-23-18452
Filed in District Court
State of Minnesota
12/5/2023 4:29 AM

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT

Case Type: Consumer Credit Contract
Velocity Investments, LLC,
Plaintiff,
vs. SUMMONS
Tyshon Ryan,
Defendant.

THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANT:

1. 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 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 TO 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 located at Gurstel Law Firm, 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. 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. If you 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. 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 provide a written
Answer to protect your rights or you may lose the case.
27-CV-23-18452
Filed in District Court
State of Minnesota
12/5/2023 4:29 AM

6. ALTERNATIVE DISPUTE RESOLUTION. The parties may agree 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.

GURSTEL LAW FIRM, P.C.

by
Amy M. Goltz (#336452) _____
x
Nikolas D. Schaal (#396690) _____
Kelly K. Heenan (#400103) _____
Jordan D. Lippert (#0402733) _____
Lori Kambourian (#0402361) _____
Attorneys for Plaintiff
6681 Country Club Drive
Our File: 1582021 Golden Valley, Minnesota 55427
Telephone: (877) 344-4002
Fax: (763) 267-6777
27-CV-23-18452
Filed in District Court
State of Minnesota
12/5/2023 4:29 AM

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT

Case Type: Consumer Credit Contract
Velocity Investments, LLC,
Plaintiff,
vs. COMPLAINT
Tyshon Ryan,
Defendant

Plaintiff, as and for its cause of action states and alleges as follows:

COUNT I.

1. That plaintiff herein is the owner of certain accounts of FinWise Bank including the account

of defendant herein.

2. That defendant is a resident of the County of Hennepin, State of Minnesota.

3. That on or about June 25, 2021, defendant executed and delivered to FinWise Bank a

Promissory Note ("Note") for which an account number ending in **** 0735 was assigned.

4. That on or about June 25, 2021, defendant borrowed from FinWise Bank the amount of

$920.00.

5. That defendant shall be in default under the Note if he/she failed to pay all amounts

required under the Note.

6. That defendant has failed to make payments according to the terms of the Note and is in

default under the Note.

7. That defendant owes a remaining balance on the Note in the amount of $1,043.08.

8. Therefore, defendant owes plaintiff the sum of $1,043.08.
27-CV-23-18452
Filed in District Court
State of Minnesota
12/5/2023 4:29 AM

COUNT II.
ACCOUNT STATED

9. Plaintiff realleges the allegations set forth in paragraphs 1 through 8 and incorporates them

in this Count by reference.

10. From time to time, plaintiff and/or FinWise Bank 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 made to any item thereof within a reasonable period of time.

11. A full, just, and true account was made and stated between plaintiff and/or FinWise Bank

and defendant which showed a balance of $1,043.08, due and owing to plaintiff from defendant over

and above all sums received from defendant and for which defendant is entitled to credit.
27-CV-23-18452
Filed in District Court
State of Minnesota
12/5/2023 4:29 AM

WHEREFORE, plaintiff demands judgment against defendant as follows:

1. For the amount of $1,043.08;

2. For plaintiff's costs and disbursements incurred herein; and

3. For such other and further relief as the Court deems just and equitable in the circumstances.

GURSTEL LAW FIRM, P.C.

ACKNOWLEDGMENT
Velocity Investments, LLC acknowledges that costs, disbursements, reasonable attorney and

witness fees may be awarded to Tyshon Ryan, pursuant to Minnesota Statute § 549.211.

Velocity Investments, LLC

by
Amy M. Goltz (#336452) _____
x
Nikolas D. Schaal (#396690) _____
Kelly K. Heenan (#400103) _____
Jordan D. Lippert (#0402733) _____
Lori Kambourian (#0402361) _____
Its Attorneys

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