On April 10, 2024 a
Motion,Ex Parte
was filed
involving a dispute between
Brann, Grace,
and
Nassios Services, Llc, A Minnesota Limited Liability Company,
Valdivia, Lidiamaria,
for Contract
in the District Court of Ramsey County.
Preview
62-CV-24-2063
Filed in District Court
State of Minnesota
4/10/2024 4:06 PM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT
CASE TYPE: CIVIL/OTHER
Grace Brann, Court File No.: __________
Plaintiff,
vs. DEFENDANTS’ NOTICE OF MOTION
AND MOTION TO DISMISS
Lidiamaria Valdivia, and Nassios Services,
LLC, a Minnesota limited liability
company,
Defendants.
TO: PLAINTIFF, BY AND THROUGH HER ATTORNEYS OF RECORD, KRISTEN
N. WILLIAMS AND AARON D. SAMPSEL, CHRISTENSEN SAMPSEL PLLC,
305 NORTH FIFTH AVENUE, SUITE 375, MINNEAPOLIS, MN 55401.
NOTICE OF MOTION AND MOTION
PLEASE TAKE NOTICE, that on a date and time to be determined, or as soon
thereafter as counsel may be heard, Defendants Lidiamaria Valdivia, and Nassios
Services, LLC (“Defendants”) will bring a Motion to Dismiss Plaintiff Grace Brann’s
Complaint on all Counts as to Defendant Lidiamaria Valdivia and as to both Defendants
on Count IV. Said motion shall be based on Rule 12.02(e) of the Minnesota Rules of Civil
Procedure, applicable law, and the files, records, and proceedings herein, including
35578.0002-#8958435v1
62-CV-24-2063
Filed in District Court
State of Minnesota
4/10/2024 4:06 PM
Defendants’ Memorandum of Law and documents filed in support of their motion, to be
filed in accordance with the Minnesota General Rules of Practice.
HELLMUTH & JOHNSON, PLLC
Dated: April 10, 2024 By: /s/ Wyatt Partridge
Wyatt S. Partridge, ID #0391272
Nicklaus A. Johnson, ID #0504617
8050 West 78th Street
Edina, MN 55439
Telephone: 952-941-4005
Facsimile: 952-941-2337
Email: wpartridge@hjlawfirm.com
Email: njohnson@hjlawfirm.com
ATTORNEYS FOR DEFENDANTS
ACKNOWLEDGMENT
The undersigned hereby acknowledges that costs, disbursements, and reasonable
attorney and witness fees may be awarded pursuant to Minnesota Statutes § 549.211, to
the party against whom the allegations in this pleading are asserted.
Dated: April 10, 2024 By: /s/ Wyatt Partridge
Wyatt S. Partridge, ID #0391272
2
Document Filed Date
April 10, 2024
Case Filing Date
April 10, 2024
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62-CV-24-2063 Filed in District Court State of Minnesota 4/10/2024 4:06 PM STATE OF MINNESOTA DISTRICT COURT COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT CASE TYPE: CIVIL/OTHER Grace Brann, Court File No.: __________ Plaintiff, vs. DEFENDANTS’ NOTICE OF MOTION AND MOTION TO DISMISS Lidiamaria Valdivia, and Nassios Services, LLC, a Minnesota limited liability company, Defendants. TO: PLAINTIFF, BY AND THROUGH HER ATTORNEYS OF RECORD, KRISTEN N. WILLIAMS AND AARON D. SAMPSEL, CHRISTENSEN SAMPSEL PLLC, 305 NORTH FIFTH AVENUE, SUITE 375, MINNEAPOLIS, MN 55401. NOTICE OF MOTION AND MOTION PLEASE TAKE NOTICE, that on a date and time to be determined, or as soon thereafter as counsel may be heard, Defendants Lidiamaria Valdivia, and Nassios Services, LLC (“Defendants”) will bring a Motion to Dismiss Plaintiff Grace Brann’s Complaint on all Counts as to Defendant Lidiamaria Valdivia and as to both Defendants on Count IV. Said motion shall be based on Rule 12.02(e) of the Minnesota Rules of Civil Procedure, applicable law, and the files, records, and proceedings herein, including 35578.0002-#8958435v1 62-CV-24-2063 Filed in District Court State of Minnesota 4/10/2024 4:06 PM Defendants’ Memorandum of Law and documents filed in support of their motion, to be filed in accordance with the Minnesota General Rules of Practice. HELLMUTH & JOHNSON, PLLC Dated: April 10, 2024 By: /s/ Wyatt Partridge Wyatt S. Partridge, ID #0391272 Nicklaus A. Johnson, ID #0504617 8050 West 78th Street Edina, MN 55439 Telephone: 952-941-4005 Facsimile: 952-941-2337 Email: wpartridge@hjlawfirm.com Email: njohnson@hjlawfirm.com ATTORNEYS FOR DEFENDANTS ACKNOWLEDGMENT The undersigned hereby acknowledges that costs, disbursements, and reasonable attorney and witness fees may be awarded pursuant to Minnesota Statutes § 549.211, to the party against whom the allegations in this pleading are asserted. Dated: April 10, 2024 By: /s/ Wyatt Partridge Wyatt S. Partridge, ID #0391272 2