Posted: September 14th, 2022

ASSIGNMENT

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Professor (Tutor)
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STATE OF MINNESOTA DISTRICT COURT

COUNTY OF ANOKA TENTH JUDICIAL DISTRICT

_________________________________ PERSONAL INJURY

JOHN JOHNSON,
COURT FILE NO._______
Plaintiff,

vs. SUMMONS

SALLY SMITH,

Defendant.
_________________________________

THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANT:

YOU ARE HEREBY SUMMONED and required to serve upon Plaintiff’s attorney an answer to the Complaint, which is herewith served upon you within twenty (20) days after service of this Summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the Complaint.

Dated:_________________________ ____________________________________
Melissa Anderson
Attorney Registration No. 56987
Attorney for Plaintiff
4260 Main Street
Anoka, Minnesota 55303
Tel: (763) 421-1847

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF ANOKA TENTH JUDICIAL DISTRICT

___________________________________WRONGFUL DEATH

JOHN JOHNSON,
COURT FILE NO.____________
Plaintiff,

vs. COMPLAINT

SALLY SMITH,

Defendant.
___________________________________

Plaintiff is the husband of the deceased. He brings this complaint (on behalf of the deceased “decendent”-Mary Johnson) against the defendant above named, states and alleges:

1. That on or about the 27th day of June, 2016, in the City of Minneapolis, County of Hennepin, State of Minnesota, Decendent above named was driving her 2015 Lexus GS400 automobile in a northerly direction on Marquette Avenue near its intersection with Sixth Street. Defendant, Sally Smith, was driving her 2015 BMW Z3 automobile in a westerly direction on Sixth Street in such a careless, negligent, and unlawful manner so as to cause it to collide with said decendent’s vehicle.
2. That as a result of said Defendant’s negligent acts, the said decendent was caused to sustain severe, painful, and personal injuries to her body that led to her eventual death.
3. That as a result of the death of the decendent, the plaintiff suffered the loss of his wife who he had been married to for more than 20 years and experienced severe emotional distress.
4. That as a result of the death of the decendent, the plaintiff’s 3 children suffered the loss of their mother and experienced severe emotional distress.
5. That as a result of the death of the decendent, the plaintiff and his 3 children have been deprived of care, support, love, companionship, affection, financial support and other advantages and pleasures of the family relationship.
6. That as a result of the death of the decendent, the plaintiff has incurred funeral and burial costs, medical and other expenses that relate to healthcare for the injuries that led to the death; the estate of the plaintiff lost revenues, lost profits, and earning capacity. Plaintiffs will incur extra medical and other healthcare related expenses in future mainly in the form of counseling for him and his children.
WHEREFORE, Plaintiff demands a trial by jury against the defendant above named on all issues so triable, and request that the court enter judgment against the defendant for all costs and disbursements incurred herein, and for such further relief as the court finds just and fair.

Dated: ___________________________ ____________________________________
Melissa Anderson
Attorney Registration No. 56987
Attorney for Plaintiff
4260 Main Street
Anoka, Minnesota 55303
Telephone: (763) 421-1847

The plaintiff and the undersigned hereby acknowledge that pursuant to Minnesota Statutes, Section 549.211, Subd. 1, sanctions may be imposed if the court should find that the undersigned acted in bad faith, asserted a claim or defense that is frivolous and that is costly to the other party, asserted an unfounded position solely to delay the ordinary course of the proceedings or to harass, or committed a fraud upon the court.

Dated: ___________________________ ________________________________________
Melissa Anderson
Attorney Registration No. 56987 Attorney for Plaintiff
4260 Main Street
Anoka, Minnesota 55303
Telephone: (763) 421-1847

STATE OF MINNESOTA )
) ss.
COUNTY OF ANOKA )

JOHN JOHNSON, being first duly sworn, on oath says that he is the plaintiff above named; that he has read the foregoing Complaint and knows the contents thereof; and that the same is true of his own knowledge, except as to matters therein stated on information and belief, and as to those matters, he believes them to be true.

____________________________________
John Johnson

Subscribed and sworn to before me
this _____ day of ________, 20 __.

_____________________________
Notary Public

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