Wynn v. Moment in Time – Summons and Complaint (January 28, 2026)

Accessible document transcript

[Page 1]
STATE OF MINNESOTA DISTRICT COURT
COU
NTY OF WADENA SEVENTH JUDICIAL DISTRICT
PER
SONAL INJURY
_____________________________________________________________________________
Macy Wynn,
Pla
intiff,
v.
Mome
nt in Time Dance Company, LLC,
Defendant.
Summ
ons
_____________________________________________________________________________
THI
S SUMMONS IS DIRECTED TO DEFENDANTS, ABOVE-NAMED:
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
Tyroler Injury Law, 434 Hale Avenue N, Suite 130, Oakdale, Minnesota 55128.
3. YOU M
UST 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 W
ILL 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
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entered against you for the relief requested in the Complaint.
5. LEGAL A
SSISTANCE. 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. ALTE
RNATIVE 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.
Tyrol
er Leonard Injury Law
Dated: December 30, 2025       By: _______________________
Co
lin Peterson (0392414)
Isaac Tyroler (0390296)
Attorneys for Plaintiff
434 Hale Avenue N., Suite 130
Oakdale, MN 55128
Phone: 612-429-3155
Fax:      651-401-6028
80-CV-26-78 Filed in District Court
State of Minnesota
1/28/2026 10:22 AM

[Page 3]
STATE OF MINNESOTA DISTRICT COURT
COU
NTY OF WADENA SEVENTH JUDICIAL DISTRICT
PER
SONAL INJURY
_____________________________________________________________________________
Macy Wynn,
Pla
intiff,
v.
Mome
nt in Time Dance Company, LLC,
Defendant.
Com
plaint
_____________________________________________________________________________
Pla
intiff for her cause of action against the above-named Defendant states and
alleges that:
Nature of the Action
1. This is a civil action for monetary damages arising out of an incident in a
dance studio where a young dancer was told to perform a dangerous maneuver
without appropriate instruction, supervision, or safety precautions. While performing
the maneuver, the dancer fell to the floor, suffering serious and permanent injuries to
her head and neck.
Parties
2. Plaintiff Macy Wynn is a resident of Wadena County, Minnesota.
3. Defendant Moment in Time Dance Company, LLC is a limited liability
company doing business in the State of Minnesota with the principal office address
located in Wadena County, Minnesota.
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4. At all relevant times, Defendant Moment in Time Dance Company, LLC
owned and operated a dance studio located in Wadena County, Minnesota.
5. At all relevant times, Defendant Moment in Time Dance Company, LLC
employed coaches, instructors, and other staff members.
6. At all relevant times, Defendant Moment in Time Dance Company, LLC
was vicariously and/or contractually liable for the actions and inactions of its agents
and employees.
Jurisdiction
7. The Court has jurisdiction over Defendant and venue is proper in Wadena
County under Minn. Stat. § 542.09.
Facts
8. On or about December 12, 2024, Plaintiff Macy Wynn was participating in
a scheduled dance practice at Defendant Moment in Time Dance Company, LLC’s
dance studio.
9. At said time and place, Plaintiff Macy Wynn was preparing for an
upcoming recital and upon the direction of Defendant was attempting an unfamiliar
dance maneuver where she was thrown into the air.
10. Upon information and belief, Plaintiff and the other dancers on her team
had not been appropriately trained by Defendant to perform the maneuver safely.
11. While performing the maneuver, Plaintiff was dropped, landing forcefully
on her head and neck.
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12. Plaintiff experienced immediate pain, weakness, dizziness, and
lightheadedness.
13. Defendant failed to appropriately and timely respond to Plaintiff’s
medical emergency.
14. Eventually, Plaintiff was taken to a local emergency department where it
was determined she needed more advanced trauma care than was available at that
emergency department.
15. Plaintiff was transferred by helicopter to Children’s Hospital and Clinics
in Minneapolis, Minnesota
16. Consultations with specialists were ordered, and Plaintiff received an MRI
of her spine the following morning which revealed a compression injury.
17. As a result of the fall at the dance studio, Plaintiff has suffered serious and
permanent injuries.
Negligence
18. Plaintiff re-alleges all paragraphs above.
19. Defendant Moment in Time Dance Company, LLC either knew or should
have known that the dance maneuver posed an unreasonable risk of injury to
participants, especially in the absence of appropriate instruction, supervision, and
safety precautions.
20. Defendant Moment in Time Dance Company, LLC, was negligent in
failing to provide appropriate instruction, supervision, and safety precautions for their
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dancers.
21. Defendant Moment in Time Dance Company, LLC, was negligent in
failing to appropriately respond to Plaintiff’s medical emergency.
22. Defendant Moment in Time Dance Company, LLC was in other ways
negligent in connection with the December 12, 2024 incident at the dance studio.
23. As a direct and proximate result of the Defendant Moment in Time Dance
Company, LLC’s negligence, Plaintiff sustained significant and permanent injuries.
Economic Damages
24. As a direct and proximate result of the Defendant Moment in Time Dance
Company, LLC’s negligence, Plaintiff has incurred and will continue to incur medical
and rehabilitative expenses all to her damages in the sum presently estimated to be in
excess of $50,000.
25. As a direct and proximate result of the Defendant Moment in Time Dance
Company, LLC’s negligence, Plaintiff has incurred a loss of earnings and a reduction of
earning capacity all to her damages in the sum presently estimated to be in excess of
$50,000.
Non-Economic Damages
26. As a direct and proximate result of the Defendant Moment in Time Dance
Company, LLC’s negligence, Plaintiff has suffered and will continue to suffer bodily
and mental damages including but not limited to pain, discomfort, emotional distress,
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loss of quality of life, and loss of enjoyment of life, all to her economic damage in a sum
presently estimated to be in excess of $50,000.
Prayer for Relief
WHEREFORE, Plaintiff Macy Wynn prays for a judgment against the Defendant
for a reasonable amount in excess $50,000, together with costs, disbursements, and
statutory prejudgment interest herein.
Tyr
oler Leonard Injury Law
Dated: December 30, 2025       By: _______________________
C
olin Peterson (0392414)
Isaac Tyroler (0390296)
Attorneys for Plaintiff
434 Hale Avenue N., Suite 130
Oakdale, MN 55128
Phone: 612-429-3155
Fax:      651-401-6028
80-CV-26-78 Filed in District Court
State of Minnesota
1/28/2026 10:22 AM

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Acknowledgement Required by Minn. Stat. § 549.211, subd. 2
I hereby acknowledge that, pursuant to Minn. Stat. § 549.211(2), costs
disbursements and reasonable attorney and witness fees may be awarded to the
opposing party or parties in this litigation if this Court should find I 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.
Tyr
oler Leonard Injury Law
Dated: December 30, 2025       By: _______________________
Colin
 Peterson (0392414)
Isaac Tyroler (0390296)
Attorneys for Plaintiff
434 Hale Avenue N., Suite 130
Oakdale, MN 55128
Phone: 612-429-3155
Fax:      651-401-6028
80-CV-26-78 Filed in District Court
State of Minnesota
1/28/2026 10:22 AM