Preview
27-CV-24-4470
Filed in District Court
State of Minnesota
3/26/2024 1:35 AM
File TP121795
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT
CKS PRIME INVESTMENTS LLC, Court File Number:
Case Type: Contract
Plaintiff,
V. SUMMONS
DANIEL KIM,
Defendant(s).
TO: THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANT(S):
1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The
Plaintifi'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 with
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: 13055 Riverdale Dr NW, Suite 500-108
Coon Rapids, MN 55448.
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 think 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
27-CV-24-4470
Filed in District Court
State of Minnesota
3/26/2024 1:35 AM
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 Couit may decide against you and award the Plaintifi 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 fiom 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.
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.
RESURGENCE LEGAL GROUP, PC
By /s/ Svetlana N. Dailv
Svetlana N. Daily, #325478
Attorney for Plaintifi'
13055 Riverdale Dr NW, Suite 500-108
Coon Rapids, MN 55448
(952)545-2174
MNAttomeys@ResurgenceLe gal. com
27-CV-24-4470
Filed in District Court
State of Minnesota
3/26/2024 1:35 AM
File TP12 1 795
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT
CKS PRINIE INVESTMENTS LLC, Contract
Plaintifi',
V. COMPLAINT
DANIEL KINI,
Defendant(s).
CKS PRIME INVESTMENTS LLC, ("PlaintifI"), by and through its Attorneys,
RESURGENCE LEGAL GROUP, PC, for its Complaint, states and alleges as follows:
COUNT I.
1. Plaintiff herein is the owner of certain accounts of INDIGO MASTERCARD ISSUED BY
CELTIC BANK SERVICED BY GENESIS FS CARD SERVICES INC, including Defendant's
account number ending in ************4555.
2. Defendant is a resident ofthe State ofMinnesota, County of HENNEPIN, and resides at 8133
ZENITH AVE S, MINNEAPOLIS MN 55431.
3. Defendant owes Plaintiffthe sum of$1,618.77, for the purchase of goods, wares, and services
by Defendant on or before February 8, 2022 on Defendant's INDIGO MASTERCARD ISSUED BY
CELTIC BANK SERVICED BY GENESIS FS CARD SERVICES INC account ending in
************4555_
4. Although duly demanded, Defendant has failed and refused to pay said amount and therefore
is indebted to Plaintiff in the amount of $1,61 8.77.
27-CV-24-4470
Filed in District Court
State of Minnesota
3/26/2024 1:35 AM
COUNT II.
5. Plaintiff realleges the allegations set forth in Paragraphs l through 5, and incorporates them
herein by reference.
6. Prior to commencement of this action, INDIGO MASTERCARD ISSUED BY CELTIC
BANK SERVICED BY GENESIS FS CARD SERVICES INC mailed to Defendant monthly
statements required by the credit agreement, and Defendant accepted said statements without making
objection thereto.
7. Defendant has failed to pay the amounts set forth in those statements, and there is a balance
of $1,618.77 that is due Plaintifi' from Defendant and above all sums received from Defendant and
for which Defendant was entitled to credit.
8. Although Plaintifl' made demands upon Defendant for the payment of the aforesaid sum,
Defendant has failed and neglected to pay same.
WHEREFORE, Plaintifi' demands judgnent against Defendant(s) as follows:
1. For the sum of $1,618.77;
2. For Plaintifl's costs and disbursements incurred herein; and
3. For such filrther and additional relief as the Court deems just, fair and equitable.
RESURGENCE LEGAL GROUP, PC
By /s/ Svetlana N. Daily
Svetlana N. Daily, #325478
Attorney for Plaintifl'
13055 Riverdale Dr NW, Suite 500- 108
Coon Rapids, MN 55448
(952)545-2174
MNAttorneys@ResurgenceLegal.com
27-CV-24-4470
Filed in District Court
State of Minnesota
3/26/2024 1:35 AM
ACKNOWLEDGMENT
By presenting this form to the court, I celtify that to the best of my lmowledge, information,
and belief, the following statements are true. I understand that if a statement is not true, the court
can order a penalty against me (such as to pay money to the other party, pay court costs, and/or other
penalties).
1. The information I included in this form is based on facts and supported by existing law.
2. I am not presenting this form for any improper purpose. I am not using this form to:
a. Harrass anyone;
b. Cause unnecessary delay in the case; or
c. Needlessly increase the costs of litigation.
3. No judicial oflicer has said I am a fi'ivolous litigant.
4. There is no court order saying I cannot serve or file this form.
5. This form does not contain any "restricted identifiers" or confidential information as
defined in Rule 11 of the General Rules of Practice
(https://Www.revisor.mn.gov/court rules/gp/id/l l) or the Rules of Public Access to
Records of the Judicial Branch (https://www.revisor.mn.gov/court rule/ra-tohl).
6. If I need to file "restricted identifiers," confidential information, or a confidential document,
I will use Form 11.1 and/or Form 11.2, as required by Rule 11.
RESURGEN CE LEGAL GROUP, PC
By /s/ Svetlana N. DailV
Svetlana N. Daily, #325478
Attorney for Plaintiff
13055 Riverdale Dr NW, Suite 500-108
Coon Rapids, MN 55448
(952)545-2174
WAttornevs@ResurgenceLegal.com
Preview
27-CV-24-4470 Filed in District Court State of Minnesota 3/26/2024 1:35 AM File TP121795 STATE OF MINNESOTA DISTRICT COURT COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT CKS PRIME INVESTMENTS LLC, Court File Number: Case Type: Contract Plaintiff, V. SUMMONS DANIEL KIM, Defendant(s). TO: THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANT(S): 1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintifi'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 with 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: 13055 Riverdale Dr NW, Suite 500-108 Coon Rapids, MN 55448. 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 think 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 27-CV-24-4470 Filed in District Court State of Minnesota 3/26/2024 1:35 AM 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 Couit may decide against you and award the Plaintifi 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 fiom 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. 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. RESURGENCE LEGAL GROUP, PC By /s/ Svetlana N. Dailv Svetlana N. Daily, #325478 Attorney for Plaintifi' 13055 Riverdale Dr NW, Suite 500-108 Coon Rapids, MN 55448 (952)545-2174 MNAttomeys@ResurgenceLe gal. com 27-CV-24-4470 Filed in District Court State of Minnesota 3/26/2024 1:35 AM File TP12 1 795 STATE OF MINNESOTA DISTRICT COURT COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT CKS PRINIE INVESTMENTS LLC, Contract Plaintifi', V. COMPLAINT DANIEL KINI, Defendant(s). CKS PRIME INVESTMENTS LLC, ("PlaintifI"), by and through its Attorneys, RESURGENCE LEGAL GROUP, PC, for its Complaint, states and alleges as follows: COUNT I. 1. Plaintiff herein is the owner of certain accounts of INDIGO MASTERCARD ISSUED BY CELTIC BANK SERVICED BY GENESIS FS CARD SERVICES INC, including Defendant's account number ending in ************4555. 2. Defendant is a resident ofthe State ofMinnesota, County of HENNEPIN, and resides at 8133 ZENITH AVE S, MINNEAPOLIS MN 55431. 3. Defendant owes Plaintiffthe sum of$1,618.77, for the purchase of goods, wares, and services by Defendant on or before February 8, 2022 on Defendant's INDIGO MASTERCARD ISSUED BY CELTIC BANK SERVICED BY GENESIS FS CARD SERVICES INC account ending in ************4555_ 4. Although duly demanded, Defendant has failed and refused to pay said amount and therefore is indebted to Plaintiff in the amount of $1,61 8.77. 27-CV-24-4470 Filed in District Court State of Minnesota 3/26/2024 1:35 AM COUNT II. 5. Plaintiff realleges the allegations set forth in Paragraphs l through 5, and incorporates them herein by reference. 6. Prior to commencement of this action, INDIGO MASTERCARD ISSUED BY CELTIC BANK SERVICED BY GENESIS FS CARD SERVICES INC mailed to Defendant monthly statements required by the credit agreement, and Defendant accepted said statements without making objection thereto. 7. Defendant has failed to pay the amounts set forth in those statements, and there is a balance of $1,618.77 that is due Plaintifi' from Defendant and above all sums received from Defendant and for which Defendant was entitled to credit. 8. Although Plaintifl' made demands upon Defendant for the payment of the aforesaid sum, Defendant has failed and neglected to pay same. WHEREFORE, Plaintifi' demands judgnent against Defendant(s) as follows: 1. For the sum of $1,618.77; 2. For Plaintifl's costs and disbursements incurred herein; and 3. For such filrther and additional relief as the Court deems just, fair and equitable. RESURGENCE LEGAL GROUP, PC By /s/ Svetlana N. Daily Svetlana N. Daily, #325478 Attorney for Plaintifl' 13055 Riverdale Dr NW, Suite 500- 108 Coon Rapids, MN 55448 (952)545-2174 MNAttorneys@ResurgenceLegal.com 27-CV-24-4470 Filed in District Court State of Minnesota 3/26/2024 1:35 AM ACKNOWLEDGMENT By presenting this form to the court, I celtify that to the best of my lmowledge, information, and belief, the following statements are true. I understand that if a statement is not true, the court can order a penalty against me (such as to pay money to the other party, pay court costs, and/or other penalties). 1. The information I included in this form is based on facts and supported by existing law. 2. I am not presenting this form for any improper purpose. I am not using this form to: a. Harrass anyone; b. Cause unnecessary delay in the case; or c. Needlessly increase the costs of litigation. 3. No judicial oflicer has said I am a fi'ivolous litigant. 4. There is no court order saying I cannot serve or file this form. 5. This form does not contain any "restricted identifiers" or confidential information as defined in Rule 11 of the General Rules of Practice (https://Www.revisor.mn.gov/court rules/gp/id/l l) or the Rules of Public Access to Records of the Judicial Branch (https://www.revisor.mn.gov/court rule/ra-tohl). 6. If I need to file "restricted identifiers," confidential information, or a confidential document, I will use Form 11.1 and/or Form 11.2, as required by Rule 11. RESURGEN CE LEGAL GROUP, PC By /s/ Svetlana N. DailV Svetlana N. Daily, #325478 Attorney for Plaintiff 13055 Riverdale Dr NW, Suite 500-108 Coon Rapids, MN 55448 (952)545-2174 WAttornevs@ResurgenceLegal.com