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STATE OF MINNESOTA COUNTY OF OLMSTED DISTRICT COURT THIRD JUDICIAL DISTRICT CIVIL DIVISION Adam David Pettey, Plaintiff, vs.

STATE OF MINNESOTA COUNTY OF OLMSTED
DISTRICT COURT
THIRD JUDICIAL DISTRICT
CIVIL DIVISION
Adam David Pettey,
Plaintiff,
vs.
Safa Abdiranman Mohamed and Ambiyo Isse Mohamed,
Defendants.
Court File No.________
Type of Case: Personal Injury
SUMMONS
THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANTS:
1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiff'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 within 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 Bird, Stevens & Borgen, P.C., 300 Third Avenue SE, Rochester, MN 55904.
3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiff's Complaint. In your Answer, you must state whether you agree or disagree with each paragraph of the Complaint. If you believe 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. 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 Court may decide against you and award the Plaintiff 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 from 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.
Dated: September 11, 2020
BIRD, STEVENS & BORGEN, P.C.
/s/ Jeremy R. Stevens
Jeremy R. Stevens (#305698)
Charles A. Bird (#0008345
300 Third Avenue SE, Suite 305
Rochester, MN 55904
Telephone: (507)282-1503
Fax: (507)282-7736
Email: jeremy@bsbjustice.com
charles@bsbjustice.com
~and~
HANSON LAW FIRM
Jeffrey A. Hanson (#40897)
2420 58th Street N.W.
Rochester, MN 55901
Telephone: (507)282-7770
Attorneys for Plaintiff
STATE OF MINNESOTA
COUNTY OF OLMSTED
DISTRICT COURT/
CIVIL DIVISION
THIRD JUDICIAL DISTRICT
Adam David Pettey
Plaintiffs,
vs.
Safa Abdiranman Mohamed and Ambiyo Isse Mohamed,
Defendants.
Case Type: Personal Injury
Court File No: 55-CV-____
COMPLAINT
Plaintiff for his Complaint against the Defendants states and alleges:
I.
On June 8, 2018, at approximately 10:30 p.m., Defendant Safa Abdiranman Mohamed was operating a 2007 Suzuki XL7 owned by Defendant Ambiyo Isse Mohamed and driving west bound on Civic Center Drive NW, Rochester MN.
II.
At said time and date, Plaintiff Adam David Pettey was crossing 6th Avenue NW at the intersection of Civic Center Drive and 6th Avenue NW in Rochester, MN.
III.
At said time and date, Defendant Safa Abdiranman Mohamed was negligent in operating the above referenced motor vehicle and said negligence directly caused a collision with the Plaintiff Adam David Pettey in the above described intersection.
IV.
Defendant Abiyo Isse Mohamed is vicariously liable for the negligence of Defendant Safa Abdiranman Mohamed pursuant to the Minnesota Safety Responsibility Act.
V.
That Plaintiff Adam David Pettey was negligent and that said negligence was a direct cause of the occurrence referenced herein and further states that Defendant Safa Abdiranman Mohamed's causal negligence equaled or exceeded that of Plaintiff.
VI.
As a proximate result of the above described collision Plaintiff Adam David Pettey sustained serious and permanent injuries, has incurred, and will incur in the future. medical expenses, and will sustain a loss of earning capacity.
WHEREFORE, the Plaintiff seeks judgment against the Defendants, and each of them. in excess of Fifty-Thousand and No/100 Dollars ($50,000.00), together with their costs and disbursements incurred herein and prejudgment interest thereon.
Dated: September 11, 2020
BIRD, STEVENS & BORGEN, P.C.
/s/ Jeremy R. Stevens
Jeremy R. Stevens (#305698)
Charles A. Bird (#0008345
300 Third Avenue SE, Suite 305
Rochester, MN 55904
Telephone: (507)282-1503
Fax: (507)282-7736
Email: jeremy@bsbjustice.com
charles@bsbjustice.com
~and~
Dated: August 8, 2020
HANSON LAW FIRM
/s/ Jeffrey A. Hanson
Jeffrey A. Hanson (#40897)
2420 58th Street N.W.
Rochester, MN 55901
Telephone: (507)282-7770
Attorneys for Plaintiff
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.
/s/ Jeremy R. Stevens
Jeremy R. Stevens
(Oct. 30; Nov. 6 & 13, 2021)2909358