Fill and Sign the Original Petition Regarding Open Account Minnesota Form

PLAINTIFF'S ORIGINAL PETITION FOR OPEN ACCOUNT TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES Plaintiff, Name_____ , and files this Plaintiff's Original Petition complaining of Defendant(s(, Name(s)_____ . Defendant, Name_____ ______ , may be served with citation at Address . Defendant, Name_____ , may be served with citation at Address . For cause of action Plaintiff would show: I . Plaintiff's action is founded upon the account made Exhibit "A" hereto, incorporated herein by reference. Defendants ordered and received from Plaintiff the items and services therein described at the agreed prices charged or at the reasonable market value . Defendants promised to pay Plaintiff for the account, but the account remains unpaid, damaging Plaintiff in at least the sum of $ with interest at law or as agreed and attorneys' fees. That after this account was presented to Defendants, Defendants acknowledged the amount demanded as justly due and owing. II . Plaintiff presented the account in writing to Defendants, demanding payment, but thirty (30) days thereafter have expired and payment for the just amount owing has not been tendered. Pursuant to Minn. Stat.  481.13 (Lien for Attorney's Fees: "An attorney has a lien for compensation, whether the agreement therefore be expressed or implied. . . "), Plaintiff is entitled to recover reasonable attorneys' fees; since Plaintiff was required to employ the undersigned attorneys for a reasonable fee, Plaintiff should recover attorneys' fees of at least $ which is the usual and customary fee in such cases. Plaintiff respectfully requests the Court to take judicial knowledge of the usual and customary fees in such matters and of the contents of the case file. Plaintiff fully performed all conditions precedent for recovery on said account and for recovery of said attorneys' fees, or all conditions precedent occurred . - 1 - WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendants be cited to appear and answer herein, and that Plaintiff have judgment against Defendants, jointly and severally, in the amount of at least $ , with interest thereon at the rate of 6% per annum from the thirtieth (30th) day from and after the time when the sum is due and payable, or otherwise as agreed by the parties hereto, up to date of judgment, and thereafter in accordance with Minnesota Statutes Annotated  549.09 (Interest on Verdicts and Judgments ), costs of court, reasonable attorneys' fees as hereinabove alleged, and for such further relief, to which Plaintiff may be entitled. - 2 -