Preview
86-CV-24-2902
Filed in District Court
State of Minnesota
6/3/2024 1:55 AM
M ESS E RLI KRAM E R I ygisoeRHL'lEKYrgr/rfirfléev
Telephone Representatives Available:
8 am. -7 pm, Monday. Tuesday. Thursday
ATTORNEYS AT LAW Dnve
am. 5 p.m. Wednesday
2;:ng8 8 -
8 a'm' ' 6 p'm' Fr'day
Plymouth, Minnesota 554412662
main 763-548-7900
fax 7635487922 Lobby HourS:
toll free 844'8410510 8 a-m- -
5 pm Monday -
Friday
TTY: 711
May 07, 2024
lllllllllllllll
Vierma Olson
772 MEADOWLARK LN
HANOVER, MN 55341-4016
Our Client: Capital One, N.A.
Consumer: Vienna Olson
ACCOLint Number: XXXXXXXXXXXX8702
Balance: $4,472.01
Our File Number: 24-1 13693
Dear Vienna Olson:
This letter is writtenin compliance with the Minnesota Rules of Civil Procedure, Rule 26.06 and the Minnesota Rules of
General Practice for' the District Courts, Rule l 15.10. As such this letter is written in an effort to confer' on a
discovery
plan and also to discuss settlement. Please review the following information carefully. We have outlined a few options for
you to review and respond as you feel appropriate:
1) Contact our firm within the next fourteen days to work out a discovery plan. An attorney can
be reached by calling 844-841-0510; or
2) Send us a letter within the next fourteen days listing your contact information and
availability between the
hours of 9:00-5:00 Monday through Friday. An attorney will then attempt to reach you to discuss a
discovery
plan; or
3) 1f you do not wish to collaborate on a discovery plan, attached is a proposed plan that we have formulated. 1f
we do not hear from you within fourteen days we will assume thc attached plan is acceptable and will present
it to the Court when, and if, the case is filed.
Very truly yours,
MESSERLI & KRAMER PA
IMPORTANT NOTICE
This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for
that purpose.
MN_03()3 rile No: 24-1 13693
Page 1 of 5
86-CV-24-2902
Filed in District Court
State of Minnesota
6/3/2024 1:55 AM
CONSUMER CREDIT CONTRACT
STATE OF MINNESOT"A DISTRICT COURT
COUNTY OF WRIGHT TENTII JUDICIAL DISTRICT
Capital One, NA. RULE 26.06(c) DISCOVERY PLAN
Plaintiff,
vs.
Vienna Olson COUl't F1 N0.
Defendant(s).
TO: Vienna Olson, that address is 772 MEADOWLARK LN HANOVER, MN 55341-4016
Pursuant to Rule 26.06(c) ofthe Minnesota Rules ofCivil Procedure, the parties submit the following
Discovery Plan:
(l) Plaintiff provided its 26.0l(a) Required Disclosures on May 07, 2024. Plaintiff proposes Defendant
provide his/her 26.0l(a) Required Disclosures as soon as possible.
(2) Discovery will be needed on any denial, dispute, or defense claimed or asserted by Defendant.
Discovery should not be conducted in phases, but should be limited to the issues raised in Plaintiff's Complaint
and Defendant's Answer.
(3) Any of Plaintiff's electronically stored information can be reproduced in hardcopy format.
(4) Parties may claim privilege of or protection oftrial-preparation materials at the time of production. If
a party disagrees with a designation, the disagreeing party must object to the designation within fourteen days of
receiving the document. If the parties are unable to resolve a designation dispute, the parties may petition the
court for a determination.
MN_O303 File No: 241 13693
Page 2 of 5
86-CV-24-2902
Filed in District Court
State of Minnesota
6/3/2024 1:55 AM
(5) No changes should be made to the limitations on discovery imposed under the Minnesota Rules of
Civil Procedure or Local Rules. Plaintiffdoes not propose any other limitations.
(6) The court need not issue any other orders under Rules 2603, 16.02, and 16.03 at this time.
MESSERLI & KRAMER PA
f, />
'
~
lili'iGZQx'Sti-ii-lte
DATE:
eSiined on 5/8/2024 in Hennepin County, MN
3033 Campus Drive, Ste. 250
Plymouth, MN 5544l
cclitigation@messerlikramereom
Ph#: (763) 5487900
Fax#: (763) 5487922
Dated: This _ day! of ,2024
Vienna Olson
DEFENDANT PRO SE
MN 0303 File No: 241 l3693
Page 3 of 5
86-CV-24-2902
Filed in District Court
State of Minnesota
6/3/2024 1:55 AM
CONSUMER CREDIT CONTRACT
STATE OF MINNESOTA DISTRICT COURT
COUNTY OE WRIGHT TENTH IUDICIAL DISTRICT
Capital One, NA RULE 26.01(a) REQUIRED INITIAL
Plaintiff, DISCLOSURES
VS.
Vienna Olson .
CouIt File NO'
Defendant(s).
TO: Vienna Olson, that address is 772 MEADOWLARK LN HANOVER, MN 55341-4016
Pursuant to Rule 26.0l(a) ofthe Minnesota Rules OfCivil Procedure, Plaintiff makes the following required
disclosures:
INITIAL DISCLOSURES
Disclosure A: The name and, if known, the address and telephone number of each individual likely to have
discoverable information
along with the subjects ofthat information
that the disclosing party may use to support
its claims or defenses, unless the use would be solely for impeachment.
Response:
1. Plaintiff, available through counsel, Messerli & Kramer, P.A., 3033 Campus Drive, Suite 250,
Plymouth, Minnesota 55441, (763) 548 7900.
This entity may have information regarding the facts alleged in Plaintiff's Complaint and
Defendant's Answer.
2. Defendant, address and telephone number known to Defendant.
This individual may have information regarding the facts alleged in Plaintiff's Complaint
and Defendant's Answer.
3. Defendant's financial institutions, addresses and telephone numbers known to Defendant.
These entities may have information regarding the facts alleged in Plaintiff's Complaint
and Defendant's Answer.
4. Various merchants, addresses and telephone numbers unknown.
These entities may have information regarding the facts alleged in Plaintiff's Complaint
and Defendant's Answer.
MN_O303 File N0124-l 13693
Page 4 of 5
86-CV-24-2902
Filed in District Court
State of Minnesota
6/3/2024 1:55 AM
Disclosure B: A copy
or a description by category emd location
of all documents, electronically stored
information, and tangible things that the disclosing party has in its possession, custody, or control and may use to
support its claims or defenses, unless the use would be solely for impeachment.
Response: All documents, electronically stored information, and tangible things in the possession, custody, or
control of Plaintiff, that Plaintiff may use to support its claims or defenses, include:
l. Account documents; and
2. Electronic Data.
Disclosure C: A computation ofeach category of damages claimed by the disclosing party
who must also make
available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless
privileged or protected from disclosure, on which each computation is based, including materials bearing on the
nature and extent of injuries suffered.
Response: The following is a ceinputation of each categor'y of'damages claimed by Plaintiff: The account
balance of $4,472.01 consists ol' the principal balance of $4,417.01 plus incurred costs of $55.00. All documents
or other evidentiary material, to the extent discoverable, are available upon request.
Disclosure D: For inspection and copying as under Rule 34, any insurance agreement under which an insurance
business may be liable to satisfy all or part ofa possiblejudgment in the action or to indemnify or reimburse for
payments made to satisfy the judgment.
Response: No insurance is available
\
for' this claim.
MESSERLI & KRAMER PA
Steam Kar't'déki
DATE:
eSigned on 5/8/2024 in Inlennepin County, MN
3033 Campus Drive, Ste. 250
Plymouth, MN 5544i
cc-litigation@messerlikramercom
Ph#: (763) 5487900
Fax#: (763) 548-7922
MN_0303 File No: 24] 13693
Page 5 of 5
Preview
86-CV-24-2902 Filed in District Court State of Minnesota 6/3/2024 1:55 AM M ESS E RLI KRAM E R I ygisoeRHL'lEKYrgr/rfirfléev Telephone Representatives Available: 8 am. -7 pm, Monday. Tuesday. Thursday ATTORNEYS AT LAW Dnve am. 5 p.m. Wednesday 2;:ng8 8 - 8 a'm' ' 6 p'm' Fr'day Plymouth, Minnesota 554412662 main 763-548-7900 fax 7635487922 Lobby HourS: toll free 844'8410510 8 a-m- - 5 pm Monday - Friday TTY: 711 May 07, 2024 lllllllllllllll Vierma Olson 772 MEADOWLARK LN HANOVER, MN 55341-4016 Our Client: Capital One, N.A. Consumer: Vienna Olson ACCOLint Number: XXXXXXXXXXXX8702 Balance: $4,472.01 Our File Number: 24-1 13693 Dear Vienna Olson: This letter is writtenin compliance with the Minnesota Rules of Civil Procedure, Rule 26.06 and the Minnesota Rules of General Practice for' the District Courts, Rule l 15.10. As such this letter is written in an effort to confer' on a discovery plan and also to discuss settlement. Please review the following information carefully. We have outlined a few options for you to review and respond as you feel appropriate: 1) Contact our firm within the next fourteen days to work out a discovery plan. An attorney can be reached by calling 844-841-0510; or 2) Send us a letter within the next fourteen days listing your contact information and availability between the hours of 9:00-5:00 Monday through Friday. An attorney will then attempt to reach you to discuss a discovery plan; or 3) 1f you do not wish to collaborate on a discovery plan, attached is a proposed plan that we have formulated. 1f we do not hear from you within fourteen days we will assume thc attached plan is acceptable and will present it to the Court when, and if, the case is filed. Very truly yours, MESSERLI & KRAMER PA IMPORTANT NOTICE This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. MN_03()3 rile No: 24-1 13693 Page 1 of 5 86-CV-24-2902 Filed in District Court State of Minnesota 6/3/2024 1:55 AM CONSUMER CREDIT CONTRACT STATE OF MINNESOT"A DISTRICT COURT COUNTY OF WRIGHT TENTII JUDICIAL DISTRICT Capital One, NA. RULE 26.06(c) DISCOVERY PLAN Plaintiff, vs. Vienna Olson COUl't F1 N0. Defendant(s). TO: Vienna Olson, that address is 772 MEADOWLARK LN HANOVER, MN 55341-4016 Pursuant to Rule 26.06(c) ofthe Minnesota Rules ofCivil Procedure, the parties submit the following Discovery Plan: (l) Plaintiff provided its 26.0l(a) Required Disclosures on May 07, 2024. Plaintiff proposes Defendant provide his/her 26.0l(a) Required Disclosures as soon as possible. (2) Discovery will be needed on any denial, dispute, or defense claimed or asserted by Defendant. Discovery should not be conducted in phases, but should be limited to the issues raised in Plaintiff's Complaint and Defendant's Answer. (3) Any of Plaintiff's electronically stored information can be reproduced in hardcopy format. (4) Parties may claim privilege of or protection oftrial-preparation materials at the time of production. If a party disagrees with a designation, the disagreeing party must object to the designation within fourteen days of receiving the document. If the parties are unable to resolve a designation dispute, the parties may petition the court for a determination. MN_O303 File No: 241 13693 Page 2 of 5 86-CV-24-2902 Filed in District Court State of Minnesota 6/3/2024 1:55 AM (5) No changes should be made to the limitations on discovery imposed under the Minnesota Rules of Civil Procedure or Local Rules. Plaintiffdoes not propose any other limitations. (6) The court need not issue any other orders under Rules 2603, 16.02, and 16.03 at this time. MESSERLI & KRAMER PA f, /> ' ~ lili'iGZQx'Sti-ii-lte DATE: eSiined on 5/8/2024 in Hennepin County, MN 3033 Campus Drive, Ste. 250 Plymouth, MN 5544l cclitigation@messerlikramereom Ph#: (763) 5487900 Fax#: (763) 5487922 Dated: This _ day! of ,2024 Vienna Olson DEFENDANT PRO SE MN 0303 File No: 241 l3693 Page 3 of 5 86-CV-24-2902 Filed in District Court State of Minnesota 6/3/2024 1:55 AM CONSUMER CREDIT CONTRACT STATE OF MINNESOTA DISTRICT COURT COUNTY OE WRIGHT TENTH IUDICIAL DISTRICT Capital One, NA RULE 26.01(a) REQUIRED INITIAL Plaintiff, DISCLOSURES VS. Vienna Olson . CouIt File NO' Defendant(s). TO: Vienna Olson, that address is 772 MEADOWLARK LN HANOVER, MN 55341-4016 Pursuant to Rule 26.0l(a) ofthe Minnesota Rules OfCivil Procedure, Plaintiff makes the following required disclosures: INITIAL DISCLOSURES Disclosure A: The name and, if known, the address and telephone number of each individual likely to have discoverable information along with the subjects ofthat information that the disclosing party may use to support its claims or defenses, unless the use would be solely for impeachment. Response: 1. Plaintiff, available through counsel, Messerli & Kramer, P.A., 3033 Campus Drive, Suite 250, Plymouth, Minnesota 55441, (763) 548 7900. This entity may have information regarding the facts alleged in Plaintiff's Complaint and Defendant's Answer. 2. Defendant, address and telephone number known to Defendant. This individual may have information regarding the facts alleged in Plaintiff's Complaint and Defendant's Answer. 3. Defendant's financial institutions, addresses and telephone numbers known to Defendant. These entities may have information regarding the facts alleged in Plaintiff's Complaint and Defendant's Answer. 4. Various merchants, addresses and telephone numbers unknown. These entities may have information regarding the facts alleged in Plaintiff's Complaint and Defendant's Answer. MN_O303 File N0124-l 13693 Page 4 of 5 86-CV-24-2902 Filed in District Court State of Minnesota 6/3/2024 1:55 AM Disclosure B: A copy or a description by category emd location of all documents, electronically stored information, and tangible things that the disclosing party has in its possession, custody, or control and may use to support its claims or defenses, unless the use would be solely for impeachment. Response: All documents, electronically stored information, and tangible things in the possession, custody, or control of Plaintiff, that Plaintiff may use to support its claims or defenses, include: l. Account documents; and 2. Electronic Data. Disclosure C: A computation ofeach category of damages claimed by the disclosing party who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered. Response: The following is a ceinputation of each categor'y of'damages claimed by Plaintiff: The account balance of $4,472.01 consists ol' the principal balance of $4,417.01 plus incurred costs of $55.00. All documents or other evidentiary material, to the extent discoverable, are available upon request. Disclosure D: For inspection and copying as under Rule 34, any insurance agreement under which an insurance business may be liable to satisfy all or part ofa possiblejudgment in the action or to indemnify or reimburse for payments made to satisfy the judgment. Response: No insurance is available \ for' this claim. MESSERLI & KRAMER PA Steam Kar't'déki DATE: eSigned on 5/8/2024 in Inlennepin County, MN 3033 Campus Drive, Ste. 250 Plymouth, MN 5544i cc-litigation@messerlikramercom Ph#: (763) 5487900 Fax#: (763) 548-7922 MN_0303 File No: 24] 13693 Page 5 of 5