Document for CCF2, LLC vs Kendra Hodges, John Doe, Mary Roe

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                                62-HG-CV-22-1116
                                                                                                   Filed in District Court
                                                                                                     State of Minnesota
                                                                                                     5/23/2022 8:12 AM




STATE OF MINNESOTA                                            DISTRICT COURT

COUNTY OF RAMSEY                                             SECOND JUDICIAL DISTRICT
____________________________                                   Case Type: Eviction

CCF2, LLC

              Plaintiff
v.                                                               EVICTION COMPLAINT

Kendra Hodges, John Doe, Mary Roe


         Defendant
_____________________________

Donald Perron, attorney for Plaintiff, states and declares as follows:

1.     CCF2, LLC is a Minnesota Limited Liability Corporation with its registered office
address at 508 Main St. S., Sauk Centre, Minnesota 56378. Plaintiff is the owner of the rental
premises in question.

2.      Defendant Kendra Hodges is a Minnesota resident who leased, by written agreement,
the premises at 651 Wells St., #2, St. Paul, MN 55106, in Ramsey County. The lease currently
runs from 8-1-21 to 8-31-22.

3.      This is an eviction action for non-payment of rent.

4.     Plaintiff/Owner having present right of possession of said property, has complied with
Minn. Stat. §504B.181 by:

     a. disclosing to the tenant either in the rental agreement or otherwise in writing prior to
        beginning of the tenancy the name and address of:

        i. the person authorized to manage the property AND
        ii. an owner or agent authorized by the owner to accept service of process and receive
            and give receipt for notices and demands, AND

     b. posting in a conspicuous place on the property a printed or typewritten notice
        containing the above information, OR

     c. the above information was known by the tenant not less than 30 days before the filing
        of this action because of communications from the landlord and in the lease.

5.      Defendant owes rent of $950.00 per month due on the first day of each month.
                                         62-HG-CV-22-1116
                                                                                                 Filed in District Court
                                                                                                   State of Minnesota
                                                                                                   5/23/2022 8:12 AM




6.        Defendant owes past due rent, utilities and other monies owed under the lease totaling
$2,589.60 for partial March through May 2022 and costs and disbursements set out below, and
is still in possession of the premises.

7.      The Eviction Moratorium Phaseout legislation no longer applies to eviction actions
except to prohibit eviction actions for non-payment of rent where the tenant has a “pending”
Covid-19 emergency rental assistance application.

8.    Upon information and belief, the Defendant does NOT have a pending Covid-19
emergency rental assistance application.


WHEREFORE PLAINTIFF PRAYS THE COURT FOR THE FOLLOWING RELIEF:

1.      For judgment against Defendants and an Order issuing an immediate Writ of Recovery
returning lawful possession of the premises to the Plaintiff.

2.     For Judgment against Defendants for Plaintiff's costs and disbursements totaling $435.

           VERIFICATION AND AFFIDAVIT OF NON-MILITARY STATUS

Donald Perron states that I am the attorney for the Plaintiff, that I have read the Complaint and
that it is true to the best of my own knowledge, and that Defendant(s) are not now in the
military or naval service of the United States, to the best of Plaintiff’s information and belief.

I declare under penalty of perjury that everything I have stated in this document is true and
correct to the best of my knowledge and belief. Minn. Stat. §358.116.

                                              Perron Law Firm, LLC

Dated 5-20-22                                 By: /s/ Donald A. Perron
                                              Donald Perron, Attorney ID #272358
                                              4707 Hwy 61, #242
                                              White Bear Lake, MN 55110
                                              (651) 484-1191 / perronlaw@hotmail.com


CFPB NOTICE: Because of the Global Covid-19 pandemic. You may be eligible for
temporary protection from eviction under the laws of your state, territory, locality, or
tribal area, or under federal law.

Learn the steps you should take now:

     ▪ Visit www.cfpb.gov/eviction
     ▪ Or call a housing counselor at 800-569-4287