AMENDED SUMMONS
STATE OF MINNESOTA
COUNTY OF CARLTON
DISTRICT COURT
SIXTH JUDICIAL DISTRICT
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Aaron J.R. Nelson, a minor,
by Roy T. Nelson his father and
natural guardian,
Plaintiff,
vs.
Ruth M. Cunningham,
Defendant.
THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANT:
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You are hereby summoned and required to answer the Complaint of the Plaintiff in the above-entitled action, a copy of which Complaint is hereto attached and herewith served upon you, and to serve a copy of your Answer to said Complaint upon the subscriber at his office, 200 Alworth Building, 306 West Superior Street, Duluth, MN 55802-1973 within twenty (20) days after the service of this Summons and said Complaint upon you, exclusive of the day of such service; and if you fail to answer the said Complaint within the time aforesaid, the Plaintiff in the above matter will apply to the Court for the relief demanded in Plaintiff's Complaint herein.
PARTIES ARE REQUIRED TO ATTEMPT ALTERNATIVE DISPUTE RESOLUTION UNDER MINNESOTA LAW. ALTERNATIVE DISPUTE RESOLUTION INCLUDES MEDIATION, ARBITRATION, AND OTHER PROCESSES AS SET FORTH IN THE DISTRICT COURT RULES. YOU MAY CONTACT THE COURT ADMINISTRATOR ABOUT RESOURCES IN YOUR AREA.
Dated: October 1, 2007
THE DOWNS LAW FIRM
/s/ Jeremy Downs
Jeremy M. Downs, #315266
Attorney for Plaintiff
306 West Superior St., #200
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Duluth, MN 55802
(218) 727-7221
AMENDED COMPLAINT
STATE OF MINNESOTA
COUNTY OF CARLTON DISTRICT COURT
SIXTH JUDICIAL DISTRICT
Aaron J.R. Nelson, a minor,
by Roy T. Nelson his father and
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natural guardian.
Plaintiffs,
vs.
Ruth M. Cunningham,
Defendant.
Come now Plaintiff, Aaron J.R. Nelson, by Roy T. Nelson his father and natural guardian, for his cause of action against the Defendant, states and alleges as follows:
1. On August 4th, 2006 near the Moose Lake Campground Park 4th Street entrance in the City of Moose Lake, County of Carlton, State of Minnesota, Plaintiff Aaron J.R. Nelson, while walking with his bicycle in the Park, was severely and permanently injured after a motor vehicle driven by Ruth M. Cunningham ran into Plaintiff.
2. As a direct result of the negligence of Defendant, Plaintiff received grievous bodily injury and damages. The damages and injuries received by Plaintiff include the following:
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a. Permanent bodily injury;
b. Past, present and future pain, suffering and emotional distress and trauma;
c. Past and future medical expenses;
d. Lost income.
WHEREFORE, Plaintiff prays for judgment against Defendant for damages in excess of $50,000.00, together with her costs and disbursements herein.
Dated: October 1, 2007.
The Downs Law Firm
/s/ Jeremy Downs
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Jeremy M. Downs #0315266
Attorney for Plaintiff
306 W. Superior St., 200
Duluth, MN 55802
(218) 727-7221
PLAINTIFF DEMAND TRIAL
BY JURY
ACKNOWLEDGMENT
The undersigned hereby acknowledges that costs, disbursements, and reasonable attorney and witness fees may be awarded pursuant to Minn. Stat. § 549.21, subd. 2, to the party against whom the allegations in this pleading are asserted.
Dated: October 1, 2007.
The Downs Law Firm
/s/ Jeremy Downs
Jeremy M. Downs # 0315266
Attorney for Plaintiff
306 W. Superior St., 200
Duluth, MN 55802
(218) 727-7221
Published in the Pine Journal on October 4, 2007 X3