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Filing # 192423588 E-Filed 02/21/2024 01:07:08 PM
IN THE COUNTY COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.:
MIAMI PROPERTY 2021 LLC,
a Florida limited liability
company,
Plaintiff,
vs.
MARIA L. SUAZO,
Defendant.
/
COMPLAINT FOR POSSESSION
Plaintiff, MIAMI PROPERTY 2021 LLC, a Florida limited
liability company (the "Landlord"), by undersigned counsel, files
this complaint against MARIA L. SUAZO (hereinafter referred to as
the "Tenant"), and all parties in possession of the premises
described below, and in support thereof states as follows:
1 This is an action to evict a tenant from real property
located in Miami-Dade County, Florida.
2 Plaintiff, which owns the subject property, is a Florida
limited liability company authorized to and conducting business in
Miami-Dade County, Florida.
3 The Landlord owns a single family apartment residence
located at 423 N.W. 9° Street, Apt. # 9, Miami, Florida 33136 (the
"Premises").
4 Defendant, MARIA L. SUAZO, is an adult resident of Miami-
Dade County, Florida and sui juris, in all respects.
5 The Landlord entered into a written lease agreement with
the Defendant, Maria L. Suazo, whereby the Tenant agreed to pay
rent of $1,500.00 per month, payable on the 1°t day of each month.
(Exhibit “A”)
6 The lease expired on February 29, 2023 and was not
renewed as required by Section 12 of the lease. The Tenant is
therefore currently a month-to-month tenant.
7
The Tenant and those currently in possession have failed
to pay rental payments totaling $3,153.50 and are in breach of the
rental agreement between the parties.
8. On or about November 14, 2023, the Landlord served the
Tenant with a written three (3) day notice to pay rent or deliver
possession of the premises pursuant to Florida Statutes Section
83.56(3), but Defendants refused to do either. (Exhibit “B”).
9 Plaintiff believes that there may be others occupying the
Premises.
10. The Tenant and those others in possession of the Premises
have failed to vacate the Premises by midnight November 17, 2023,
have failed to deliver possession of the premises to the Landlord,
are currently residing therein and have refused to vacate the
Premises.
11. The Landlord files this complaint pursuant to Florida's
Summary Procedure Statute Section 51.011.
12. All conditions precedent to the filing of this action
have been fulfilled or have occurred and there are no justiciable
issues of either law or fact which can be raised as a defense to
this action.
13. Pursuant to Section 83.48 of the Florida Statutes, the
Plaintiff is entitled to attorney's fees and costs, if it is the
prevailing party.
14. The Plaintiff has retained the undersigned counsel to
represent them in this action and are obligated to pay a reasonable
fee.
WHEREFORE, Plaintiff, MIAMI PROPERTY 2021 LLC, a Florida
limited liability company, demands judgment for possession of the
Premises against Defendant, Maria L. Suazo, and all parties in
possession of the Premises.
Respectfully submitted,
Luis E. Diaz & Associates, P.A.
Attorney for Plaintiff
1529 S.W. Ist Street
Miami, Florida 33135
Telephone Number: (305) 642-0078
Facsimile Number: (305) 646-2452
By: Ziti Pra
Luis E. Diaz, Es
Florida Bar No.: 0025550
Luisediazlaw@aol.com
EXHIBIT
66 A”
a-
ie Tenant.
ie te this
Maint
1) nts”). Maria
BEY
FEN TEI
THO Ai RE
EN] LER) OT
rE
UTE
OF HE LEAS! NTA
iD 1EXCLUSIVE
SIVE OP)OPTION
vit Ol
fami FL 33136,
threo
A’
fT HS
money.
Is:
hallbe:
ier re!
PIRST {7% of ih
hiers:chesk, wire,
| guarantythe security deposit
Non
mber.
A They flo
Te
make
naib
hal the leased
payment
Jan
je forms:
Initials:
Oy tials:
i
fe portal
with: AppFe
onder,P: nfs must be made: Rat
cash ‘Of BUT TENANTWil {CHARG: CCONVIENCE
‘chet;
3924 Alton REGHO6' 33140.
‘OF
fight to:re\ ofline payments:and tequire Tenants to'via Electronic
Cash
antl fees,-past
wed
sd fo: nant vacates prem ifnotpai
‘font
De
‘tenal
nidiord: i
ment received:
ofthe
moveto
have Tenants
d.
Any late red.del tent,
ll charge
be $76 for any jade'to:
i
x
Ldssee #1:
ORD
Landjord applies: lath
}and:-cou ay Landlord.
d all other fees owed
5) =: Past Rent
urrent
0)
are two: or more: is to the'leased and:one‘dies,
from the lease
surviving Tenant responsible to. complete the lease:as'ag)
rent payments and. ‘person
dies during the term of the
lease, ‘on th ‘of. death. Ten: irs or executer of estate must
‘property clean
Ce, petty days
will be.co ‘will now-belong
Of Bi
ignsthis lease; ble iiividually making
full rent
‘payments. lord can make both one Tenant
fol also yneans that the'Landlord
i
i
Tease
is not:
NOT
ers
quired notice. Ténant will Have the right to: he
challenge the Lend isch
if Tenant bt ‘agreement, has
i
to courtto uulity ‘and all‘othe s
itthis
it
ce #1 Initials: Martas | #2 Initia
ii
ttomey:
to starta kof 5
pay Landlord: Landlord:
it and recover possession of the leased.property:
5} End this leaseagi
will following occurs:
‘0. bills. owed.
before. teinof this: ‘without,
1d co) his lease.
N BY TENAN’ ND
WS
incurred the:
by Landlord:
G renaptor Sg
at ING:SEC! DEPOSIT
post
CilC
rant: Landlord,
end Th
not
Aa
belongings
itafier receiving ‘tove.out. lord's thefinal
be:
Jtemized' and cost,
y hi
“unit,
D, Tenant
will be:respo pexceed the
litials:::
ie
dlord finds the property isfactory condition, T: eourity deposit.
.within
30 days fror ing.of Tenant's have vatated
lord will notin: unit while:
(1 TO. RTY BY RE. FLOOD, NATURAL DISA‘
rm
‘ease
of a fire, fleod,or ster ieee he eee he Ten ‘eontinue fo.
occupy tie livable part ission,
agrees to:stay, rent will the:same: ed upon unless changed by Landlord Any
ged o re, Fent wil retum'to theo ne seed upon ateribe
Land
D. Te ‘willgi and. Landlord's.représentatives, petmission'to-enter
re, by tenantor Tena ‘held fully:
MOWNETS:
Tenant agrees: Tenant's willbe
has. lant was
‘tenant's personal property
‘or mishap:
PAI
Enviro Agency, Landlords property: ult
before:t fogi This ‘children
and Je ‘mayex] lems.
It also
phy 6to hazards,
irettto info sficerning
paint
less: has had
may
willnotbe
Landi
ae
ould the testing
be delayed past’
of the lease, fay of 1/30: amount,
day thatielapses: lls of lead base pal
Lessee st AA BAS OCS se Lessee iia: —
‘the Landlord does -hevor she may immediately: terminate original leased
féement;and retum.
6; ‘Tenant has three choices if sisi in | lead roperty:
1) Tenant may have | removed at his or her cost. Tenaht wil contin toepey par edie
per day While weiting for removal of lead based paint:to be completed. Landlord hat be
- fesponsi for reimbursem
ble ent to Tenan for. t
work performed,
~2)_.-Tenant may inform Landlord in writing that heer she tio longer wishes to rentthe property fom the:
Jandlond:
3) Tenant may:stilt rent ‘property but aarees natto Sle Lao spor ora health or
medical problems‘due tole
lead!
ac based paint ot seul Based painthazards.
21)
iA, Landlotd's'Insui ‘enant's parsonial property.:Landlord will:carry no
‘Insurance that: ‘en property.
Hf there is any logsor: ‘water,
fire, thefl,act of other, tenant,
‘any-andall
ul rat t num:
not: Tet property: fite; flood; or
disaste
Ee Tenantagrees: ‘bri ‘enant
rees that ifthe guest-does bring onal property ito.the leised: property, this propertywill rotbe
Landlord's liability.
Landlord is not responsi oa Sty. yar person or lest won ered
Tenants) ofthe Idased property: ss vay ioe an Cat iments and all
legal issueswil andied in arbitration
nl inhi by-Landlord;shas ht to enter the leased pro ‘notice for any
‘e-or she had fo enter
Notic
forall non-ererger
the property, and
reven:
G.- Tenant gives:Landlor “ForSi ther: sign Landlord
Bi: ff Tenantis ‘Sectién 8 Inspectors. fime; will-be: ited
fo. enter
the Jeased property forany ‘and all reasons.
esse # Initials:
4 ano-<- Lessee # 2 Initials:
23) i
A, Landlord agrees to keep | phimbing (exclu Is) heating, a tioning (if providedin
lease); roofing: services in.go d. working condi
Landlord 4s not responsible for d saused ya repre iene pUSe af items to
‘the leased property.
24),RE
‘A. Tenant agrees that hey.wil iately notify the dlord of any and all dangerolsior defective items.
in the'leased property. T Ht 80 ‘7204 or put servi6e request into portal. If
‘enant falls to.d enant ble for any Injury.due to-defecti
normal-wear
and Teriant-agtees.that willbe resp
1) an Door Knol
isnot wie. paper.
AVG due contin
to ase aid not: aanging: Aiter..
‘Light, Bulbs:
Mini-Blinds
Glass: ‘willl be paidfer by: Tenant. Landlord, net Tenant,will
nant agrees at Is: items
Tei ‘wall:correct
and.
imply; Landlord: ‘at Tenant's.
t: All-repair
costs will Incluc jonth's rent:
8 Benefits
and Landlord Siispects: exce: damage to the leased
ry, excessive
arefound, Landlord:will move: Section 8 Ber
ZEI
Ani iconside) ‘Landlord.will havethe rightto.
‘end this lease i authorized jone ‘the lease,
BeliTe ling Sec sand houses an.unauthorized. ‘move for
‘g:service representative. Landlor move'to, ‘Tenant's.
8 Benefits revoked.
Lessee# 1 Initials: MACOS iitials:
HANG) ATIN SEI
AL Tenant {O:change; remodel, or update anything in they without: permission
ip that will be:signedby . Anything, as minores painting :papering.a
7 Wall;to installing a chi if, Taust “approve e Landlord.
B ‘Anger at Landon opie ctaraeee slp, ov moe fthe-Landlord
yk
be. responsible for lost’keys:or lock-outs
Tenantwil ie of maven ‘strongly suggests that the tenant
ve MoreCO} mat ‘heir expense; and ina:
eked outof property after:hol leased
property. Landlord will not! cfiarges.. “Wlocksmith damages any locks.on
ity, tenant accepts Ii ity and will haw install new.locks, Landlord must
lock:
jut permis Tenant vl few lockset.
with Land ‘of
not repair-or service any-vehicle anywhere on the leased property:This includes
in the:
front-of the property.
leased: property: must have current registration; inspection
stickers:
‘D. No T perty..
ized vel les ondeased ior suche ao, eles:
d to be illegal wi anteievpanss
front, or teatya
lly oe hiclés owned! iy Tear oor quests willbe.
i LAWN CARE
Landlord is:responsi ‘Care unle: therwiserrioted
OF PRGI ERT
‘may atany gi sell the leased:
B,:. lfsalé:of property. cecut fall: ity dep ‘new own ‘enant: New:
‘owner
Is. now: ible for: ityde
‘Lessee: initials: AAAS SSERs itial
provide Tenant with new'owners:
Ww baddress,.
ve tobe informied:of any-sale. nded sale:
sibi ‘obligations: Tenant
call oF conta lord after'sale,
DEP. REFUND
int breake:thi inany: Security deposit is non-refundable.
Tenant agrees to give Laiidl iter fodwarding ress and retum: keys before maviig from,
property. If Keys rela Landlord will keep’ int's security deposit in full.
dlord has 30: Tenant's ne move:ol onerd tye belance ofthe
Security:depi ing address.
lord will Manta: edtlist of any damagawed: es, rent; owed: uit, ote desu
ingly.
nt anyci tarices:.
owed ih thé following order:
1). Additional: rent
and late fees-owed.
3)
of the T the following ¢onditions:
lease has meompleted,
“Un charges
or fees: due:
ly andéall: ‘pald:in full;
jefsorial property from both inside and. e.of d-property.
iver nes dress:
has retumed fo Landlord.
the i
ty Q
‘properly repaired.
The-entire cleaned ‘broom swept
Tenant agrees that’ low. is accordinaly,
41) > Any. anyone oranything is
Tena ns responsibly
waterbed
of ariy kind into the propetty
3) Tenant transfer-of.
4) Tenant agrees that will one else ‘acctipy the leased property wh ‘on the
fae
Lessee# ethetcin Lessee #2 Initials: ee
willhe :wable; ine) install, mountor: y antenna,
theleased all ‘also.not-gi in spemisionh
east vanywherein ‘property,
Tenant agrees leased property: al ‘berth primary: resitence for tenses. and afyone that ison
“the lease.
2 “Tenant will not use! leased property. for ‘any type of business.
8) Teriant agrees riot tol sé the property for any hazardo
9). . Teri és responsible for conduct; Behavior, and noisé.of all people living in or visiting the leased
10) ‘Tenant agrees that phonenut ‘forthe landlor and working phone.humber.
Tenant-agrees if.this number anged, they. will lord with new:
‘number.
14). Megal acth ly erid if Tenant of tenant’s-guests are found to be using,
sell distri jal drugs.
‘2)Any eLaw
43)Te ‘they: any Te orguest licted damagesto
) Te of trashirom: property r ple ratedby
that they, ‘an ember of the hot (old will not become
a nuisance:
‘the neighbors.:
renal ‘more communi plaints
47) Tenai all lord in writing via certified. cretumof.
receipt req nat denn gio oly fern ate ified ina-court
jaaring:as: notice given:
i 18). Any belongings left by the Tenant ‘consid Landlord
will
-dispose
of abandon ad T ‘costof
19) ‘windows
the landlord ‘blind, Said.
‘MO0.dai
in or-on: ie
33)
Ac (tenant ht New Rent in.hol
they immediately forfeit their seourtty deposit to landlord
riod willbe. curtent nit
TERM iN ATIO IN
sing Payments are inated: ast rior rentand s in the.amount
of ofl month's rent twa businie termination. Tage isnot mad Lanilord wl
‘eviction at thisti
:
7A acta:S Lessee
#2 Initials:
Lessee# 1 Initials
So
ing breeds:
“Huskies
Pinschars laskah Malamutes “German:
‘Rhodesian Ridgebacks.
*Femvand Ranch.
“Any
AnyNol
‘nixed breed ‘the.above,.-
‘past history or
B..:Any-other:pets.mi pet addendum and depesit may be required.
intainers
for nor uiAnY ‘hat is. not
in ‘of the:
trash of bel bedding,
ide'the then be ch
JURY
ir
indiérd/tehant relationshi ‘the tei
ii
see#.
i
REQUIRED. INSU! IDENDUM TO LEASE
AGI
This Addendumis: ‘partotth ‘Or the duration
of the Lease: Agreement,. Tenant'is requ to maintain: and provide the following mini required
ins
100, iL Of nt's. for. je tot 'S pr for
Jess than th loss: ion, Backup: of sewer,
r-sump,. Insurance’)
‘Tenant: lence:of Required Insurance priorto. vtpancy ¢ leased
premises: ‘the tim period. fat ahy time Tenant does not have Re ined
Insurance, Ten: the and. Lessor shall: have; i orto any other
fights ment, obligation: to-purcha: insurance.
imburs Tenant ‘costs: and expenses: with-such
i
Tenant: may obtain: Reaiired an: insuran suran iny
choice. I
does: redIrisuranice;
the: insurant ‘schedule th
a
Tenants uni lent.
The coverag ve. AN.
amount equi ‘totalco: ‘enant!by the
Lessor... Some int poi werag! ich Ten jould'unde:
RR ned: Of: Lessoris the:
insured CRI
coverage. i makes-no
arising out
‘Tenant requires any..of these
then jnsural iny.of Tenant's.
inder the LRRL.poliey may be:more: Jnsuran
Tenant
optionsto: red Insuranceul un
insurance:
the Tenant for verage Shall