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
Grace Brann, Case Type: CIVIL-OTHER
Plaintiffs, Court File No.:
vs.
CIVIL COVER SHEET
Lidiamaria Valdivia, and Nassios Services,
LLC, a Minnesota Limited Liability Company,
Defendants.
Date Case Filed: April 10, 2024
This civil cover sheet must be filed by the initial filing lawyer or party, if unrepresented by legal
counsel, unless the court orders all parties or their legal counsel to complete this form. Once the
initial civil cover sheet is filed, opposing lawyers or unrepresented parties who have not already
been ordered to complete this form may submit their own cover sheet within ten days after being
served with the initial cover sheet. See Rule 104 of the General Rules of Practice for the District
Courts.
If information is not known to the filing party at the time of filing, it shall be provided to
the Court Administrator in writing by the filing party within seven (7) days of learning the
information. Any party impleading additional parties shall provide the same information to the
Court Administrator. The Court Administrator shall, upon receipt of the completed certificate,
notify all parties or their lawyers, if represented by counsel, of the date of filing the action and
the file number assigned.
ATTORNEYS FOR PLAINTIFF(S) ATTORNEYS FOR DEFENDANT(S)
Wyatt S. Partridge, ID #0391272 Kristen N. Williams (MN #397350)
Nicklaus A. Johnson, ID #0504617 Aaron D. Sampsel (MN #398521)
8050 West 78th Street Christensen Sampsel PLLC
Edina, MN 55439 305 North Fifth Avenue, Suite 375
Telephone: 952-941-4005 Minneapolis, MN 55401
Facsimile: 952-941-2337 Phone: (612) 473-1200
Email: wpartridge@hjlawfirm.com Kristen@christensensampsel.com
Email: njohnson@hjlawfirm.com Aaron@chhristensensampsel.com
35578.0002-
62-CV-24-2063
Filed in District Court
State of Minnesota
4/10/2024 4:06 PM
(Attach addition sheet for additional attorneys / parties)
Note: If either Plaintiff or Defendant gets an attorney, the attorney’s name, address, telephone
number and attorney ID number must be given in writing to the Court Administrator
immediately.
1. Provide a concise statement of the case including facts and legal basis:
Plaintiffs and Defendant entered into a contract for Plaintiff to loan Defendants $40,000.00 to
perform their remodeling project at 2097 Niles Ave, St. Paul, MN. Plaintiffs allege that
Defendant breached the contract, was unjustly enriched, and was negligent in failing to repay
loan amount of $40,000.00 by the maturity date.
2. Date Complaint was served: March 21, 2024
3. For Expedited Litigation Track (ELT) Pilot Courts only:
a. the parties jointly and voluntarily agree that this case shall be governed by the
Special Rules for ELT Pilot. Date of agreement:
b. The court is requested to consider excluding this case from ELT for the following
reasons:
Note: ELT is mandatory in certain cases, and where mandatory, exclusion may also be
sought by timely motion under the Special Rules for ELT Pilot.
c. Anticipated number of trial witnesses: 5
d. Amount of medical expenses to date:
e. Amount of lost wages to date:
f. Identify any known subrogation interests:
4. Estimated discovery completion within 4 months from the date of this form.
5. Disclosure / discovery of electronically stored information discussed with other party?
No Yes, date of discussion:
If Yes, list agreements, plans, and disputes: Parties shall confer if and when issues arise.
6. Proposed trial start date: February 1, 2025
7. Estimated trial time: 1 day (estimates less than a day must be stated in hours).
8. Jury trial is:
waived by consent of Plaintiffs pursuant to Minn. R. Civ. P. 38.02.
(specify party)
requested by (NOTE: Applicable fee must be enclosed)
2
62-CV-24-2063
Filed in District Court
State of Minnesota
4/10/2024 4:06 PM
(specify party)
9. Physical/mental/blood examination pursuant to Minn. R. Civ. P. 35 is requested:
Yes No
10. Identify any party or witness who will require interpreter services, and describe the
services needed (specifying language, and if known, particular dialect): N/A
11. Issues in dispute: Breach of Contract, Unjust Enrichment, Civil Theft, Promissory
Estoppel
12. Case Type / Category: CIVIL-OTHER (NOTE: select case type from Form
23, Subject Matter Index for Civil Cases, appended to the Minnesota Rules of Civil Procedure).
13. Recommended Alternative Dispute Resolution (ADR) mechanism: Mediation
(See list of ADR processes set forth in Minn. Gen. R. Prac. 114.02(a))
Recommended ADR provider (known as a “neutral”): To be discussed by parties.
Recommended ADR completion date: September 1, 2024
If applicable, reasons why ADR not appropriate for this case:
HELLMUTH & JOHNSON, PLLC
Dated: April 10, 2024 By: /s/ Wyatt S. 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 PLAINTIFFS
ACKNOWLEDGMENT
The undersigned hereby acknowledges that costs, disbursements and reasonable attorney and
witness fees may be awarded pursuant to Minn. Stat. § 549.211 to the party against whom the
allegations in this pleading are asserted.
Dated: April 10, 2024 By: /s/ Wyatt S. Partridge
Wyatt S. Partridge, ID #0391272
3
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 Grace Brann, Case Type: CIVIL-OTHER Plaintiffs, Court File No.: vs. CIVIL COVER SHEET Lidiamaria Valdivia, and Nassios Services, LLC, a Minnesota Limited Liability Company, Defendants. Date Case Filed: April 10, 2024 This civil cover sheet must be filed by the initial filing lawyer or party, if unrepresented by legal counsel, unless the court orders all parties or their legal counsel to complete this form. Once the initial civil cover sheet is filed, opposing lawyers or unrepresented parties who have not already been ordered to complete this form may submit their own cover sheet within ten days after being served with the initial cover sheet. See Rule 104 of the General Rules of Practice for the District Courts. If information is not known to the filing party at the time of filing, it shall be provided to the Court Administrator in writing by the filing party within seven (7) days of learning the information. Any party impleading additional parties shall provide the same information to the Court Administrator. The Court Administrator shall, upon receipt of the completed certificate, notify all parties or their lawyers, if represented by counsel, of the date of filing the action and the file number assigned. ATTORNEYS FOR PLAINTIFF(S) ATTORNEYS FOR DEFENDANT(S) Wyatt S. Partridge, ID #0391272 Kristen N. Williams (MN #397350) Nicklaus A. Johnson, ID #0504617 Aaron D. Sampsel (MN #398521) 8050 West 78th Street Christensen Sampsel PLLC Edina, MN 55439 305 North Fifth Avenue, Suite 375 Telephone: 952-941-4005 Minneapolis, MN 55401 Facsimile: 952-941-2337 Phone: (612) 473-1200 Email: wpartridge@hjlawfirm.com Kristen@christensensampsel.com Email: njohnson@hjlawfirm.com Aaron@chhristensensampsel.com 35578.0002- 62-CV-24-2063 Filed in District Court State of Minnesota 4/10/2024 4:06 PM (Attach addition sheet for additional attorneys / parties) Note: If either Plaintiff or Defendant gets an attorney, the attorney’s name, address, telephone number and attorney ID number must be given in writing to the Court Administrator immediately. 1. Provide a concise statement of the case including facts and legal basis: Plaintiffs and Defendant entered into a contract for Plaintiff to loan Defendants $40,000.00 to perform their remodeling project at 2097 Niles Ave, St. Paul, MN. Plaintiffs allege that Defendant breached the contract, was unjustly enriched, and was negligent in failing to repay loan amount of $40,000.00 by the maturity date. 2. Date Complaint was served: March 21, 2024 3. For Expedited Litigation Track (ELT) Pilot Courts only: a. the parties jointly and voluntarily agree that this case shall be governed by the Special Rules for ELT Pilot. Date of agreement: b. The court is requested to consider excluding this case from ELT for the following reasons: Note: ELT is mandatory in certain cases, and where mandatory, exclusion may also be sought by timely motion under the Special Rules for ELT Pilot. c. Anticipated number of trial witnesses: 5 d. Amount of medical expenses to date: e. Amount of lost wages to date: f. Identify any known subrogation interests: 4. Estimated discovery completion within 4 months from the date of this form. 5. Disclosure / discovery of electronically stored information discussed with other party? No Yes, date of discussion: If Yes, list agreements, plans, and disputes: Parties shall confer if and when issues arise. 6. Proposed trial start date: February 1, 2025 7. Estimated trial time: 1 day (estimates less than a day must be stated in hours). 8. Jury trial is: waived by consent of Plaintiffs pursuant to Minn. R. Civ. P. 38.02. (specify party) requested by (NOTE: Applicable fee must be enclosed) 2 62-CV-24-2063 Filed in District Court State of Minnesota 4/10/2024 4:06 PM (specify party) 9. Physical/mental/blood examination pursuant to Minn. R. Civ. P. 35 is requested: Yes No 10. Identify any party or witness who will require interpreter services, and describe the services needed (specifying language, and if known, particular dialect): N/A 11. Issues in dispute: Breach of Contract, Unjust Enrichment, Civil Theft, Promissory Estoppel 12. Case Type / Category: CIVIL-OTHER (NOTE: select case type from Form 23, Subject Matter Index for Civil Cases, appended to the Minnesota Rules of Civil Procedure). 13. Recommended Alternative Dispute Resolution (ADR) mechanism: Mediation (See list of ADR processes set forth in Minn. Gen. R. Prac. 114.02(a)) Recommended ADR provider (known as a “neutral”): To be discussed by parties. Recommended ADR completion date: September 1, 2024 If applicable, reasons why ADR not appropriate for this case: HELLMUTH & JOHNSON, PLLC Dated: April 10, 2024 By: /s/ Wyatt S. 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 PLAINTIFFS ACKNOWLEDGMENT The undersigned hereby acknowledges that costs, disbursements and reasonable attorney and witness fees may be awarded pursuant to Minn. Stat. § 549.211 to the party against whom the allegations in this pleading are asserted. Dated: April 10, 2024 By: /s/ Wyatt S. Partridge Wyatt S. Partridge, ID #0391272 3