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  • MIAMI PROPERTY 2021 LLC VS MARIA L. SUAZO Evictions - Residential document preview
  • MIAMI PROPERTY 2021 LLC VS MARIA L. SUAZO Evictions - Residential document preview
  • MIAMI PROPERTY 2021 LLC VS MARIA L. SUAZO Evictions - Residential document preview
  • MIAMI PROPERTY 2021 LLC VS MARIA L. SUAZO Evictions - Residential document preview
  • MIAMI PROPERTY 2021 LLC VS MARIA L. SUAZO Evictions - Residential document preview
  • MIAMI PROPERTY 2021 LLC VS MARIA L. SUAZO Evictions - Residential document preview
  • MIAMI PROPERTY 2021 LLC VS MARIA L. SUAZO Evictions - Residential document preview
  • MIAMI PROPERTY 2021 LLC VS MARIA L. SUAZO Evictions - Residential document preview
						
                                

Preview

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