Preview
14-CV-24-2144
Filed in District Court
State of Minnesota
6/18/2024 8:44 PM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF CLAY SEVENTH JUDICIAL DISTRICT
Edison Squared Investments, LLC,
Plaintiff,
Court File No. ________________
v.
COMPLAINT IN UNLAWFUL
Chelsea Koons, John Doe, and Jane Roe DETAINER
individuals whose true names are unknown
occupying 2616 County Club Blvd. #3,
Moorhead, MN 56560,
Defendants.
Plaintiff for its Complaint against Defendants states and alleges as follows:
1. On or about June 1, 2023, Plaintiff rented to Defendant(s), by written lease the
above-described premises from June 1, 2023 to May 31, 2024. Thereafter, the lease converted to
a month-to-month. The monthly rent obligation was $835.00 for the premises. Attached as
Exhibit A is a true and accurate copy of said lease “Lease”.
2. John Doe and Jane Roe are individuals unknown to Plaintiff that may be in
possession of the above-described premises.
3. Defendant(s) is/are in default of the lease by failing to pay the currently monthly
rent obligation of $800.00 in full, from February 1, 2024 to present date totaling $2,032.72.
Attached as Exhibit B is a true and accurate copy of Defendant’s statement balance.
4. Attached as Exhibit C is a true and correct copy of the 14-Day Notice of Intent to
File an Eviction Action on Defendant(s) that was sent to Defendant(s) on May 4, 2024.
14-CV-24-2144
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5. Plaintiff 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. a landlord or agent authorized by the landlord to accept service of
process and receive and give receipt for notices and demands, AND/or
b. posting in a conspicuous place on the property a printed or typewritten
notice containing the above information
c. The information required by Minn.Stat. §504B.181 section is known by or
has been disclosed to the tenant at least 30 days prior to the initiation of
such action.
6. Plaintiff seeks to have the Defendants evicted for the following reasons:
a. The Defendants are still in possession of the above premises and have failed
to pay the total rent and late fees due.
7. The tenancy is not affected by a federal or state housing subsidy program through
project-based federal assistance payments; the Section 8 program, as defined in section 469.002,
subdivision 24; the low-income housing tax credit program; or any other similar program.
8. Plaintiff seeks judgment against the above Defendants for restitution of said
premises plus costs and disbursements herein.
9. As a matter of law, Plaintiff is entitled to title and occupancy of the subject
premises and Defendants remain in possession thereof and unlawfully detain possession from
Plaintiff.
14-CV-24-2144
Filed in District Court
State of Minnesota
6/18/2024 8:44 PM
WHEREFORE, Plaintiff demands judgment against Defendants Chelsea Koons, John
Doe, and Jane Roe, individuals whose true names are unknown to Plaintiff who are occupants of
and are residing at 2616 Country Club Blvd. #3, Moorhead, MN 56560, for the restitution of the
subject premises and their costs and disbursements herein.
GRIFFITTS LAW OFFICES, PLLC
Dated: June 18, 2024 By: /s/ K. Griffitts
Kelly Vince Griffitts, ID #232695
Attorneys for Plaintiff
8530 Eagle Point Blvd., Suite 100
Lake Elmo, MN 55042
(612) 269-4353
14-CV-24-2144
Filed in District Court
State of Minnesota
6/18/2024 8:44 PM
ACKNOWLEDGMENT
I hereby acknowledge that sanctions may be imposed pursuant to Minn. Stat. § 549.211.
/s/ K. Griffitts
Kelly Vince Griffitts
VERIFICATION
Kelly Vince Griffitts, being first duly sworn on oath says that he is the attorney for the
Plaintiff in the above-entitled action; that he has read the foregoing Complaint and knows the
contents thereof, and that the same is true of his own knowledge, except as to those matters
stated therein on information and belief, and as to those matters he believes it to be true; that
Defendants are not now in the military or naval service of the United States, to the best of his
information and belief.
I declare under penalty of perjury that everything I have stated in this document is true and
correct. Minn.Stat. §358.116.
/s/ K. Griffitts
Kelly Vince Griffitts
14-CV-24-2144
Filed in District Court
State of Minnesota
6/18/2024 8:44 PM
EXHIBIT A
14-CV-24-2144
Filed in District Court
State of Minnesota
6/18/2024 8:44 PM
STANDARD LEASE AGREEMENT
This Agreement, dated May 16, 2023, by and between a business entity known as Edison Squared
Investments, LLC. of 1011 14th St N Suite Ofiice, Fargo, North Dakota, 58102, hereinafter known as
the "Landlord",
AND
One individual lmown as Chelsea Koons, hereinafier known as the "Tenant(s)", agree to the
following:
OCCUPANT(S): The Premises is to be occupied strictly as a residential dwelling with only the
Tenant(s) mentioned above as the Occupant(s).
OCCUPANT Contact information:
Occupant Name Email Phone number
Chelsea Koons chelseakoons10@outlook.com (701) 651 -31 69 L x
Minor Child
OFFER T0 RENT: The Landlord hereby rents to the Tenant(s), subject to the following terms and
conditions of this Agreement, an apartment with the address of 2616 Country Club BLVD APPT #3,
Moorhead, Minnesota, 56560 consisting of l bathroom(s) and 2 bedroom(s) hereinafter known as the
"Premises". The Landlord may also use the address for notices sent to the Tenant(s).
PURPOSE: The Tenant(s) and any Occupant(s) may only use the Premises as a residential dwelling. It
may not be used for storage, manufacturing of any type of food or product, professional service(s), or
for any commercial use unless otherwise stated in this Agreement.
FURNISHINGS: The Premises is not fiJrnished.
APPLIANCES: The Landlord shall provide the following appliances:
Dryer (for Laundry), Hot Water Heater, Oven(s), Refiigerator, Stove(s), Washer (for Laundry), Dish
washer, and all other appliances to be provided by the Tenant(s). Any damage to the Landlord's
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appliances shall be the liability of the Tenant(s), reasonable wear-and-tear excepted, to be billed
directly or less the Security Deposit.
LEASE TERM: This Agreement shall be a fixed-period arrangement beginning on June 1, 2023 and
ending on May 31, 2024 :fease will continue on as a month to month Basis Until Either party
(landlord or tenant) gives a full 60 day notice, if a new Lease Agreement is not authorized. A month to
month lease will incur an added monthly rent of $7 5.00. Hereinafter known as the "Lease Term". Early
access will be granted to the tenant as soon as the repair work is completed
RENT: Tenant(s) shall pay the Landlord in equal monthly installments of $800.00 (U S Dollars)
hereinafter known as the "Rent". The Rent will be due on the First (1st) of every month and be paid by
sending payment to the Landlord's address or thru Innago, the landlords online payment center.
NON-SUFFICIENT FUNDS (N SF CHECKS): If the Tenant(s) attempts to pay the rent with a check
that is not honored or an electronic transaction (ACH) due to insuflicient funds (NSF) there shall be a
fee of $35.00 (US Dollars).
LATE FEE: If rent is not paid on the due date, there shall be a late fee assessed by the Landlord in the
amount of:
8% of overdue Rent changed on a monthly Basis, a 3 day grace period is given
FIRST (IST) MONTH'S RENT: N/A
PREPAYMENT: The Landlord shall require the tenant to pay in advanced the last months rent due to
the tenants credit.
PRORATION PERIOD: The Tenant(s) will not move into the Premises before the start of the Lease
Term.
SECURITY DEPOSIT: A Security Deposit in the amount of $800.00 (US Dollars) paid in original
lease w/ intrest. The Security Deposit is to be returned to the Tenant(s) within 30 days afier this
Agreement has terminated, less any damage charges and without interest. This Security Deposit shall
not be credited towards rent unless the Landlord gives their written consent. A separate Pet deposit will
be required- amount to be set at time of signing of lease- see below.
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POSSESSION: Tenant(s) has examined the condition of the Premises and by taking possession
acknowledges that they have accepted the Premises in good order and in its current condition except as
herein otherwise stated. Failure of the Landlord to deliver possession of the Premises at the start of the
Lease Term to the Tenant(s) shall terminate this Agreement at the option of the Tenant(s). Furthermore,
under such failure to deliver possession by the Landlord, and if the Tenant(s) cancels this Agreement,
the Security Deposit (if any) shall be returned to the Tenant(s) along with any other prepaid rent, fees,
including if the Tenant(s) paid a fee during the application process before the execution of this
Agreement.
ACCESS: Upon the beginning of the Proration Period or the start of the Lease Term, Whichever is
earlier, the Landlord agrees to give access to the Tenant(s) in the forIn of keys, fobs, cards, or any type
of keyless security entry as needed to enter the common areas and the Premises. Duplicate copies of the
access provided may only be authorized under the consent of the Landlord and, if any replacements are
needed, the Landlord may provide them for a fee. At the end of this Agreement all access provided to
the Tenant(s) shall be returned to the Landlord or a fee will be charged to the Tenant(s) or the fee will
be subtracted fiom the Security Deposit.
. . . ctr/m 504/
MOVE-IN INSPECTION: Pictures W111 be taken Wlthfiharmon'of the current condition of the
property. These will be given to the tenant on a thumb drive for their use.
SUBLETTING: The Tenant(s) shall not have the right to sub-let the Premises or any part thereof
without the prior written consent of the Landlord. If consent is granted by the Landlord, the Tenant(s)
will be responsible for all actions and liabilities of the Sublessee including but not limited to: damage
to the Premises, non-payment of rent, and any eviction process (In the event of an eviction the
Tenant(s) shall be responsible for all court filing fee(s), representation, and any other fee(s) associated
with removing the Sublessee). The consent by the Landlord to one sub-let shall not be deemed to be
consent to any subsequent subletting.
ABANDONMENT: If the Tenant(s) vacates or abandons the property for a time-period that is the
minimum set by State law or seven (7) days, whichever is less, the Landlord shall have the right to
terminate this Agreement immediately and remove all belongings including any personal property off
of the Premises. If the Tenant(s) vacates or abandons the property, the Landlord shall immediately have
the right to terminate this Agreement.
ASSIGNMENT: Tenant(s) shall not assign this Lease without the prior written consent of the
Landlord. The consent by the Landlord to one assignment shall not be deemed to be consent to any
subsequent assignment.
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PARKING: The Landlord shall provide the Tenant(s) 1 parking garage #3 as well as access to the
shared parking lot.
RIGHT OF ENTRY: The Landlord shall have the right to enter the Premises during normal working
hours by providing notice in accordance with the minimum State requirement in order for inspection,
make necessary repairs, alterations or improvements, to supply services as agreed or for any reasonable
purpose. The Landlord may exhibit the Premises to prospective purchasers, mortgagees, or lessees
upon reasonable notice.
SALE OF PROPERTY: If the Premises is sold, the Tenant(s) is to be notified of the new Owner, and
if there is a new Manager, their contact details for repairs and maintenance shall be forwarded. If the
Premises is conveyed to another party, the new owner shall not have the right to terminate this
Agreement and it shall continue under the terms and conditions agreed upon by the Landlord and
Tenant(s).
UTILITIES: The Landlord agrees to pay for the following utilities and services:
Lawn Care, Snow Removal, Trash Removal, Water, with all other utilities and services to be the
responsibility of the Tenant(s).
Tenant will need to set up an account with oorhead Public servic o pay for the electrical of the
property, this needs to be done on or prior to the ease s .
MAINTENANCE, REPAIRS, OR ALTERATIONS: The Tenant(s) shall, at their own expense and at
all times, maintain premises in a clean and sanitary manner, and shall surrender the same at termination
hereof, in as good condition as received, normal wear and tear excepted. (Note that the carpets were
professionally cleaned prior to tenant move in and the same is required of the tenant) The Tenant(s)
may not make any alterations to the leased premises without the consent in writing of the Landlord.
The Landlord shall be responsible for repairs to the interior and exterior of the building. If the Premises
includes a washer, dryer, fieezer, dehumidifier unit and/or air conditioning unit, the Landlord makes no
warranty as to the repair or replacement of units if one or all shall fail to operate. The Landlord will
place fresh batteries in all battery-operated smoke detectors when the Tenant(s) moves into the
premises. Alter the initial placement of the flesh batteries it is the responsibility of the Tenant(s) to
replace batteries when needed. A monthly "cursory" inspection may be required for all fire
extinguishers to make sure they are fully charged.
EARLY TERMINATION: The Tenant(s) may not be able to cancel this Agreement unless the Tenant
is a victim of Domestic Violence, in such case, the Tenant may be able to cancel in accordance with any
local, state, or federal laws. There will be a re-rental fee equal to 1/2 of the monthly rent if lease is
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cancelled, if Resident moves out without giving Proper 60 day written notice, if Resident moves out
before full term of lease has expired, or if Resident is evicted. However, Resident is still liable for rent
for the full term of lease, or until unit is rented.
PETS: The Tenant(s) shall be allowed to have 1 pet a dog
approximately 50 pounds. The tenant shall
pay addition to their rent Pet rent of $35.00 per month. The pet deposit shall be $400.00 (50%
in
refundable and %50 non refundable)
The tenant is responsible for any and all damage caused to the property by this animal. At all times the
animal shall be on a leash while on the property or in the common spaces. All cleanup of animal waste
shall be the responsibility of the tenant, if the tenant dose not clean up afier the animal there will be a
cleaning fee applied of $35.00 per occurrence.
-Pet is required to have up to date immunizations
-Pet is required to have up to date pet registration required by the city of Moorhead
-Landlord reserves the write to require DNA testing if seen fit
NOISE/WASTE: The Tenant(s) agrees not to commit waste on the premises, maintain, or permit to be
maintained, a nuisance thereon, or use, or permit the premises to be used, in an unlawful manner. The
Tenant(s) further agrees to abide by any and all local, county, and State noise ordinances.
GUESTS: There shall be no other persons living on the Premises other than the Tenant(s) and any
Occupant(s). Guests of the Tenant(s) are allowed for periods not lasting for more than Ninety-six hours
unless otherwise approved by the Landlord.
SMOKING POLICY: Smoking on the Premises is prohibited on the entire property, including
individual units, common areas, every building and adjoining properties.
COMPLIANCE WITH LAW: The Tenant(s) agrees that during the term of the Agreement, to
promptly comply with any present and future laws, ordinances, orders, rules, regulations, and
requirements of the Federal, State, County, City, and Municipal government or any of their
departments, bureaus, boards, commissions and oficials thereof with respect to the premises, or the use
or occupancy thereof, Whether said compliance shall be ordered or directed to or against the Tenant(s),
the Landlord, or both.
DEFAULT: If the Tenant(s) fails to comply with any of the financial or material provisions of this
Agreement, or of any present rules and regulations or any that may be hereafter prescribed by the
Landlord, or materially fails to comply with any duties imposed on the Tenant(s) by statute or State
laws, within the time period alter delivery of written notice by the Landlord specifying the non-
compliance and indicating the intention of the Landlord to terminate the Agreement by reason thereof,
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the Landlord may terminate this Agreement. If the
Tenant(s) fails to pay rent when due and the default
continues for the time-period specified in the written notice thereafier, the Landlord
may, at their
option, declare the entire balance (compiling all months applicable to this Agreement) of rent payable
hereunder to be immediately due and payable and may exercise
any and all rights and remedies
available to the Landlord at law or in equity and may immediately terminate this
Agreement.
The Tenant(s) will be in default if: (a) Tenant(s) does not pay rent or other amounts that are owed in
accordance with respective State laws; (b) Tenant(s), their guests, or the
Occupant(s) violate this
Agreement, rules, or fire, safety, health, or criminal laws, regardless of whether arrest or conviction
occurs; (c) Tenant(s) abandons the Premises; (d) Tenant(s) gives incorrect or false information in the
rental application; (e) Tenant(s), or any Occupant(s) is arrested, convicted, or
given deferred
adjudication for a criminal ofi'ense involving actual or potential physical harrn to a person, or involving
possession, manufacture, or delivery of a controlled substance, marijuana, or drug paraphernalia under
state statute; (f) any illegal drugs or paraphernalia are found in the Premises or on the
person of the
Tenant(s), guests, or Occupant(s) while on the Premises and/or; (g) as otherwise allowed by law.
MULTIPLE TENANT(S) OR OCCUPANT (S): Each individual that is considered a Tenant(s) is
jointly and individually liable for all of this Agreement's obligations, including but not limited to rent
monies. If any Tenant(s), guest, or Occupant(s) violates this Agreement, the Tenant(s) is considered to
have violated this Agreement. Landlord's requests and notices to the Tenant(s) or any of the
Occupant(s) of legal age constitutes notice to the Tenant(s). Notices and requests fiom the Tenant(s) or
any one of the Occupant(s) (including repair requests and entry permissions) constitutes notice fiom the
Tenant(s). In eviction suits, the Tenant(s) is considered the agent of the Premise for the service of
process.
DISPUTES: If a dispute arises during or after the term of this Agreement between the Landlord and
"
Tenant(s), they shall agree to hold negotiations amongst themselves, in good faith", before any
litigation.
SEVERABILITY: If any provision of this Agreement or the application thereof shall, for any reason
and to any extent, be invalid or unenforceable, neither the remainder of this Agreement nor the
application of the provision to other persons, entities or circumstances shall be affected thereby, but
instead shall be enforced to the maximum extent permitted by law.
SURRENDER OF PREMISES: The Tenant(s) has surrendered the Premises when (a) the move-out
date has passed and no one is living in the Premise within the Landlord's reasonable judgment; or (b)
Access to the Premise have been turned in to Landlord whichever comes first. Upon the expiration of
the term hereof, the Tenant(s) shall surrender the Premise in better or equal condition as it were at the
commencement of this Agreement, reasonable use, wear and tear thereof, and damages by the elements
excepted.
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RETALIATION: The Landlord is prohibited fiom making any type of retaliatory acts against the
Tenant(s) including but not limited to restricting access to the Premises, decreasing or cancelling
services or utilities, failure to repair appliances or fixtures, or any other type of act that could be
considered unjustified.
WAIVER: A Waiver by the Landlord for a breach of any covenant or duty by the Tenant(s), under this
Agreement is not a waiver for a breach of any other covenant or duty by the Tenant(s), or of any
subsequent breach of the same covenant or duty. No provision of this Agreement shall be considered
waived unless such a waiver shall be expressed in writing as a formal amendment to this Agreement
and executed by the Tenant(s) and Landlord.
EQUAL HOUSING: If the Tenant(s) possess(es) any mental or physical impairment, the Landlord
shall provide reasonable modifications to the Premises unless the modifications would be too difiicult
or expensive for the Landlord to provide. Any impairment of the Tenant(s) is/are encouraged to be
provided and presented to the Landlord in writing in order to seek the most appropriate route for
providing the modifications to the Premises.
HAZARDOUS MATERIALS: The Tenant(s) agrees to not possess any type of personal property that
could be considered a fire hazard such as a substance having flammable or explosive characteristics on
the Premises. Items that are prohibited to be brought into the Premises, other than for everyday cooking
or the need of an appliance, includes but is not limited to gas (compressed), gasoline, fuel, propane,
kerosene, motor oil, fireworks, or any other related content in the form of a liquid, solid, or gas.
WATERBEDS: The Tenant(s) is not permitted to furnish the Premises with waterbeds.
GRILLING: The Tenant(s) shall not be permitted to use any type of propane or charcoal grill on the
balcony, instead any grilling shall be done rear their garage or in the courtyard.
INDEMNIFICATION: The Landlord shall not be liable for any damage or injury to the Tenant(s), or
any other person, or to any property, occurring on the Premises, or any part thereof, or in common areas
thereof, and the Tenant(s) agrees to hold the Landlord harmless fiom any claims or damages unless
caused solely by the Landlord's negligence. It is recommended that renter's insurance be purchased at
the Tenant(s)'s expense.
COVENANTS: The covenants and conditions herein contained shall apply to and bind the heirs, legal
representatives, and assigns of the parties hereto, and all covenants are to be construed as conditions of
this Agreement.
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NOTICES: In accordance with Minnesota state law all notices shall be done via email, unless
specifically requested in writing otherwise.
Landlord's/Agent's Mailing Address
Edison Squared Investments, LLC., ATTN. Jeff Edison
1011 14th Street N, Suite Ofice, Fargo, North Dakota, 58102
Tenant(s)'s Mailing Address
2616 Country Club BLVD, APPT #3, Moorhead, Minnesota, 56560
AGENT/MANAGER: The Landlord does not have an Agent or Manager and all contact in regards to
any repair, maintenance, or complaint must go through the Landlord through the following contact
information:
Landlord's Phone Number: (701) 3711950 Email: jefiey.b.edison@gmail.com.
PREMISES DEEMED UNINHABITABLE: If the Property is deemed uninhabitable due to damage
beyond reasonable repair the Tenant(s) will be able to terminate this Agreement by written notice to the
Landlord. If said damage was due to the negligence of the Tenant(s), the Tenant(s) shall be liable to the
Landlord for all repairs and for the loss of income due to restoring the Premises back to a livable
condition in addition to any other losses that can be proved by the Landlord.
SERVICEMEMBERS CIVIL RELIEF ACT: In the event the Tenant(s) is or hereafter becomes, a
member of the United States Armed Forces on extended active duty and hereafter the Tenant(s)
receives permanent change of station (PCS) orders to depart ficom the area where the Premises are
located, or is relieved fiom active duty, retires or separates fiom the military, is ordered into military
housing, or receives deployment orders, then in any of these events, the Tenant may terminate this lease
upon giving thirty (30) days written notice to the Landlord. The Tenant shall also provide to the
Landlord a copy of the official orders or a letter signed by the Tenant's commanding ofiicer, reflecting
the change which warrants termination under this clause. The Tenant will pay prorated rent for any
days which he/she occupies the dwelling past the beginning of the rental period.
The damage/security deposit will be promptly returned to Tenant, provided there are no
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damages to the Premises.
LEAD PAINT: The Premises was constructed before 1978 and therefore the Lead-Based Paint
Disclosure that is attached to this Agreement must be authorizeé.
GOVERNING LAW: This Agreement is to be governed under the laws located in the State of North
Dakota.
ADDITIONAL TERMS AND CONDITIONS: There are no further terms or conditions that will be
added to this Agreement other than any attachments or addendums attached.
ENTIRE AGREEMENT: This Agreement contains all the terms agreed to by the parties relating to its
subject matter including any attachments or addendums. This Agreement replaces all previous
discussions, understandings, and oral agreements. The Landlord and Tenant(s) agree to the terms and
conditions and shall be bound until the end of the Lease Tenn.
The parties have agreed and executed this agreement on
20 2
M" y
/ // ,
LANDLORD(S) SIGNATURE
Landlord's Signature ///
Jefi' Edison as Manger/Member of Edison Squared Investments, LLC.
TENANT(S) SIGNATURE
Tenant's
SignaturL/W
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AMOUNT ($) DUE AT SIGNING
Security Deposit: 800
Pet deposit: 400
Rent (first months): 835
Rent (last months): 835
Total Due: 870.00
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EXHIBIT B
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Property Name Unit Lease DateTenants Invoice Id Due Date Last PaymeRent
2616 Country Club 3 06/01/202 Chelsea Ko 6393261 6/1/2024 - $910.00
2616 Country Club 3 06/01/202 Chelsea Ko 3810892 2/1/2024 3/4/2024 $835.00
2616 Country Club 3 06/01/202 Chelsea Ko 3810893 3/1/2024 4/9/2024 $835.00
2616 Country Club 3 06/01/202 Chelsea Ko 3810894 4/1/2024 4/9/2024 $835.00
2616 Country Club 3 06/01/202 Chelsea Ko 3810895 5/1/2024 - $835.00
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Late Fee C NSF Fee Pet Fee Security DeTotal Invoi Total Amo Total Amou Outstanding A Notes
$72.80 - - - $982.80 $0.00 $0.00 $982.80 -
$66.80 - - - $901.80 $0.00 $901.80 $0.00 -
- - - - $835.00 $0.00 $835.00 $0.00 -
$66.80 - - - $901.80 $0.00 $820.48 $81.32 -
$133.60 - - - $968.60 $0.00 $0.00 $968.60 -
$2,032.72
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EXHIBIT C
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Chelsea Koons
2616 Country Club Parkway
Apartment #3
Moorhead, MN 56560
Re: 14 DAY NOTICE OF INTENT TO FILE AN EVICTION ACTION
Dear All Occupants of the above Property Address:
Please be advised that I am or that I represent your landlord (“Landlord”) regarding your
continued possession of the above-described property. As you are aware, you are in default on
your lease agreement with your Landlord for your failure to make lease payments and late fees
totaling $2,030.72as of the date of this letter (See Attached Ledger). Monthly rent and late fees
will continue to accrue.
You should be aware:
1. The total amount of past due rent is currently $2,030.72 .(See Attached Ledger);
2. The name and address of the person authorized to receive rent and fees on behalf of the
landlord is: Click or tap here to enter text.
3. You have the right to seek legal help. If you can't afford a lawyer, free legal help may be
available. Contact Legal Aid or visit www.LawHelpMN.org to know your rights and find
your local Legal Aid office.
4. To apply for financial help, contact your local county or Tribal social services office,
apply online at MNBenefits.mn.gov or call the United Way toll-free information line by
dialing 2-1-1 or 800-543-7709; and
5. Your landlord can file an eviction case if you do not pay the total amount due or move
out within 14 days from the date of this notice. Some local governments may have an
eviction notice period longer than 14 days.
If you fail to pay or vacate the premises within 14 days, I have been authorized to commence an
eviction action against you in Housing Court to have you forcibly removed by the County
Sheriff. The filing of an eviction action may severely affect your ability to obtain rental housing
in the future.
We look forward to working with you in this matter and ask that if you have any questions,
please contact me.
Sincerely,
Jeff Edison
Edison Squared Investments, LLC.
14-CV-24-2144
Filed in District Court
State of Minnesota
6/18/2024 8:44 PM
FDCPA Notice: This communication is with a debt collector. Any information obtained
will be used for that purpose.
Unless you, within thirty days after receipt of the notice, dispute the validity of the debt, or
any portion thereof, I will assume the to be valid;
If you notify me in writing within the thirty-day period that the debt, or any portion
thereof, is disputed, I will obtain verification of the debt or a copy of a judgment against
you and I will cause a copy of such verification or judgment to be mailed to you; and
Upon your written request within the thirty-day period, I will provide you with the name
and address of the original creditor, if different from the current creditor.
Preview
14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM STATE OF MINNESOTA DISTRICT COURT COUNTY OF CLAY SEVENTH JUDICIAL DISTRICT Edison Squared Investments, LLC, Plaintiff, Court File No. ________________ v. COMPLAINT IN UNLAWFUL Chelsea Koons, John Doe, and Jane Roe DETAINER individuals whose true names are unknown occupying 2616 County Club Blvd. #3, Moorhead, MN 56560, Defendants. Plaintiff for its Complaint against Defendants states and alleges as follows: 1. On or about June 1, 2023, Plaintiff rented to Defendant(s), by written lease the above-described premises from June 1, 2023 to May 31, 2024. Thereafter, the lease converted to a month-to-month. The monthly rent obligation was $835.00 for the premises. Attached as Exhibit A is a true and accurate copy of said lease “Lease”. 2. John Doe and Jane Roe are individuals unknown to Plaintiff that may be in possession of the above-described premises. 3. Defendant(s) is/are in default of the lease by failing to pay the currently monthly rent obligation of $800.00 in full, from February 1, 2024 to present date totaling $2,032.72. Attached as Exhibit B is a true and accurate copy of Defendant’s statement balance. 4. Attached as Exhibit C is a true and correct copy of the 14-Day Notice of Intent to File an Eviction Action on Defendant(s) that was sent to Defendant(s) on May 4, 2024. 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM 5. Plaintiff 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. a landlord or agent authorized by the landlord to accept service of process and receive and give receipt for notices and demands, AND/or b. posting in a conspicuous place on the property a printed or typewritten notice containing the above information c. The information required by Minn.Stat. §504B.181 section is known by or has been disclosed to the tenant at least 30 days prior to the initiation of such action. 6. Plaintiff seeks to have the Defendants evicted for the following reasons: a. The Defendants are still in possession of the above premises and have failed to pay the total rent and late fees due. 7. The tenancy is not affected by a federal or state housing subsidy program through project-based federal assistance payments; the Section 8 program, as defined in section 469.002, subdivision 24; the low-income housing tax credit program; or any other similar program. 8. Plaintiff seeks judgment against the above Defendants for restitution of said premises plus costs and disbursements herein. 9. As a matter of law, Plaintiff is entitled to title and occupancy of the subject premises and Defendants remain in possession thereof and unlawfully detain possession from Plaintiff. 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM WHEREFORE, Plaintiff demands judgment against Defendants Chelsea Koons, John Doe, and Jane Roe, individuals whose true names are unknown to Plaintiff who are occupants of and are residing at 2616 Country Club Blvd. #3, Moorhead, MN 56560, for the restitution of the subject premises and their costs and disbursements herein. GRIFFITTS LAW OFFICES, PLLC Dated: June 18, 2024 By: /s/ K. Griffitts Kelly Vince Griffitts, ID #232695 Attorneys for Plaintiff 8530 Eagle Point Blvd., Suite 100 Lake Elmo, MN 55042 (612) 269-4353 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM ACKNOWLEDGMENT I hereby acknowledge that sanctions may be imposed pursuant to Minn. Stat. § 549.211. /s/ K. Griffitts Kelly Vince Griffitts VERIFICATION Kelly Vince Griffitts, being first duly sworn on oath says that he is the attorney for the Plaintiff in the above-entitled action; that he has read the foregoing Complaint and knows the contents thereof, and that the same is true of his own knowledge, except as to those matters stated therein on information and belief, and as to those matters he believes it to be true; that Defendants are not now in the military or naval service of the United States, to the best of his information and belief. I declare under penalty of perjury that everything I have stated in this document is true and correct. Minn.Stat. §358.116. /s/ K. Griffitts Kelly Vince Griffitts 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM EXHIBIT A 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM STANDARD LEASE AGREEMENT This Agreement, dated May 16, 2023, by and between a business entity known as Edison Squared Investments, LLC. of 1011 14th St N Suite Ofiice, Fargo, North Dakota, 58102, hereinafter known as the "Landlord", AND One individual lmown as Chelsea Koons, hereinafier known as the "Tenant(s)", agree to the following: OCCUPANT(S): The Premises is to be occupied strictly as a residential dwelling with only the Tenant(s) mentioned above as the Occupant(s). OCCUPANT Contact information: Occupant Name Email Phone number Chelsea Koons chelseakoons10@outlook.com (701) 651 -31 69 L x Minor Child OFFER T0 RENT: The Landlord hereby rents to the Tenant(s), subject to the following terms and conditions of this Agreement, an apartment with the address of 2616 Country Club BLVD APPT #3, Moorhead, Minnesota, 56560 consisting of l bathroom(s) and 2 bedroom(s) hereinafter known as the "Premises". The Landlord may also use the address for notices sent to the Tenant(s). PURPOSE: The Tenant(s) and any Occupant(s) may only use the Premises as a residential dwelling. It may not be used for storage, manufacturing of any type of food or product, professional service(s), or for any commercial use unless otherwise stated in this Agreement. FURNISHINGS: The Premises is not fiJrnished. APPLIANCES: The Landlord shall provide the following appliances: Dryer (for Laundry), Hot Water Heater, Oven(s), Refiigerator, Stove(s), Washer (for Laundry), Dish washer, and all other appliances to be provided by the Tenant(s). Any damage to the Landlord's Page l 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM appliances shall be the liability of the Tenant(s), reasonable wear-and-tear excepted, to be billed directly or less the Security Deposit. LEASE TERM: This Agreement shall be a fixed-period arrangement beginning on June 1, 2023 and ending on May 31, 2024 :fease will continue on as a month to month Basis Until Either party (landlord or tenant) gives a full 60 day notice, if a new Lease Agreement is not authorized. A month to month lease will incur an added monthly rent of $7 5.00. Hereinafter known as the "Lease Term". Early access will be granted to the tenant as soon as the repair work is completed RENT: Tenant(s) shall pay the Landlord in equal monthly installments of $800.00 (U S Dollars) hereinafter known as the "Rent". The Rent will be due on the First (1st) of every month and be paid by sending payment to the Landlord's address or thru Innago, the landlords online payment center. NON-SUFFICIENT FUNDS (N SF CHECKS): If the Tenant(s) attempts to pay the rent with a check that is not honored or an electronic transaction (ACH) due to insuflicient funds (NSF) there shall be a fee of $35.00 (US Dollars). LATE FEE: If rent is not paid on the due date, there shall be a late fee assessed by the Landlord in the amount of: 8% of overdue Rent changed on a monthly Basis, a 3 day grace period is given FIRST (IST) MONTH'S RENT: N/A PREPAYMENT: The Landlord shall require the tenant to pay in advanced the last months rent due to the tenants credit. PRORATION PERIOD: The Tenant(s) will not move into the Premises before the start of the Lease Term. SECURITY DEPOSIT: A Security Deposit in the amount of $800.00 (US Dollars) paid in original lease w/ intrest. The Security Deposit is to be returned to the Tenant(s) within 30 days afier this Agreement has terminated, less any damage charges and without interest. This Security Deposit shall not be credited towards rent unless the Landlord gives their written consent. A separate Pet deposit will be required- amount to be set at time of signing of lease- see below. Page 2 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM POSSESSION: Tenant(s) has examined the condition of the Premises and by taking possession acknowledges that they have accepted the Premises in good order and in its current condition except as herein otherwise stated. Failure of the Landlord to deliver possession of the Premises at the start of the Lease Term to the Tenant(s) shall terminate this Agreement at the option of the Tenant(s). Furthermore, under such failure to deliver possession by the Landlord, and if the Tenant(s) cancels this Agreement, the Security Deposit (if any) shall be returned to the Tenant(s) along with any other prepaid rent, fees, including if the Tenant(s) paid a fee during the application process before the execution of this Agreement. ACCESS: Upon the beginning of the Proration Period or the start of the Lease Term, Whichever is earlier, the Landlord agrees to give access to the Tenant(s) in the forIn of keys, fobs, cards, or any type of keyless security entry as needed to enter the common areas and the Premises. Duplicate copies of the access provided may only be authorized under the consent of the Landlord and, if any replacements are needed, the Landlord may provide them for a fee. At the end of this Agreement all access provided to the Tenant(s) shall be returned to the Landlord or a fee will be charged to the Tenant(s) or the fee will be subtracted fiom the Security Deposit. . . . ctr/m 504/ MOVE-IN INSPECTION: Pictures W111 be taken Wlthfiharmon'of the current condition of the property. These will be given to the tenant on a thumb drive for their use. SUBLETTING: The Tenant(s) shall not have the right to sub-let the Premises or any part thereof without the prior written consent of the Landlord. If consent is granted by the Landlord, the Tenant(s) will be responsible for all actions and liabilities of the Sublessee including but not limited to: damage to the Premises, non-payment of rent, and any eviction process (In the event of an eviction the Tenant(s) shall be responsible for all court filing fee(s), representation, and any other fee(s) associated with removing the Sublessee). The consent by the Landlord to one sub-let shall not be deemed to be consent to any subsequent subletting. ABANDONMENT: If the Tenant(s) vacates or abandons the property for a time-period that is the minimum set by State law or seven (7) days, whichever is less, the Landlord shall have the right to terminate this Agreement immediately and remove all belongings including any personal property off of the Premises. If the Tenant(s) vacates or abandons the property, the Landlord shall immediately have the right to terminate this Agreement. ASSIGNMENT: Tenant(s) shall not assign this Lease without the prior written consent of the Landlord. The consent by the Landlord to one assignment shall not be deemed to be consent to any subsequent assignment. Page 3 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM PARKING: The Landlord shall provide the Tenant(s) 1 parking garage #3 as well as access to the shared parking lot. RIGHT OF ENTRY: The Landlord shall have the right to enter the Premises during normal working hours by providing notice in accordance with the minimum State requirement in order for inspection, make necessary repairs, alterations or improvements, to supply services as agreed or for any reasonable purpose. The Landlord may exhibit the Premises to prospective purchasers, mortgagees, or lessees upon reasonable notice. SALE OF PROPERTY: If the Premises is sold, the Tenant(s) is to be notified of the new Owner, and if there is a new Manager, their contact details for repairs and maintenance shall be forwarded. If the Premises is conveyed to another party, the new owner shall not have the right to terminate this Agreement and it shall continue under the terms and conditions agreed upon by the Landlord and Tenant(s). UTILITIES: The Landlord agrees to pay for the following utilities and services: Lawn Care, Snow Removal, Trash Removal, Water, with all other utilities and services to be the responsibility of the Tenant(s). Tenant will need to set up an account with oorhead Public servic o pay for the electrical of the property, this needs to be done on or prior to the ease s . MAINTENANCE, REPAIRS, OR ALTERATIONS: The Tenant(s) shall, at their own expense and at all times, maintain premises in a clean and sanitary manner, and shall surrender the same at termination hereof, in as good condition as received, normal wear and tear excepted. (Note that the carpets were professionally cleaned prior to tenant move in and the same is required of the tenant) The Tenant(s) may not make any alterations to the leased premises without the consent in writing of the Landlord. The Landlord shall be responsible for repairs to the interior and exterior of the building. If the Premises includes a washer, dryer, fieezer, dehumidifier unit and/or air conditioning unit, the Landlord makes no warranty as to the repair or replacement of units if one or all shall fail to operate. The Landlord will place fresh batteries in all battery-operated smoke detectors when the Tenant(s) moves into the premises. Alter the initial placement of the flesh batteries it is the responsibility of the Tenant(s) to replace batteries when needed. A monthly "cursory" inspection may be required for all fire extinguishers to make sure they are fully charged. EARLY TERMINATION: The Tenant(s) may not be able to cancel this Agreement unless the Tenant is a victim of Domestic Violence, in such case, the Tenant may be able to cancel in accordance with any local, state, or federal laws. There will be a re-rental fee equal to 1/2 of the monthly rent if lease is Page 4 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM cancelled, if Resident moves out without giving Proper 60 day written notice, if Resident moves out before full term of lease has expired, or if Resident is evicted. However, Resident is still liable for rent for the full term of lease, or until unit is rented. PETS: The Tenant(s) shall be allowed to have 1 pet a dog approximately 50 pounds. The tenant shall pay addition to their rent Pet rent of $35.00 per month. The pet deposit shall be $400.00 (50% in refundable and %50 non refundable) The tenant is responsible for any and all damage caused to the property by this animal. At all times the animal shall be on a leash while on the property or in the common spaces. All cleanup of animal waste shall be the responsibility of the tenant, if the tenant dose not clean up afier the animal there will be a cleaning fee applied of $35.00 per occurrence. -Pet is required to have up to date immunizations -Pet is required to have up to date pet registration required by the city of Moorhead -Landlord reserves the write to require DNA testing if seen fit NOISE/WASTE: The Tenant(s) agrees not to commit waste on the premises, maintain, or permit to be maintained, a nuisance thereon, or use, or permit the premises to be used, in an unlawful manner. The Tenant(s) further agrees to abide by any and all local, county, and State noise ordinances. GUESTS: There shall be no other persons living on the Premises other than the Tenant(s) and any Occupant(s). Guests of the Tenant(s) are allowed for periods not lasting for more than Ninety-six hours unless otherwise approved by the Landlord. SMOKING POLICY: Smoking on the Premises is prohibited on the entire property, including individual units, common areas, every building and adjoining properties. COMPLIANCE WITH LAW: The Tenant(s) agrees that during the term of the Agreement, to promptly comply with any present and future laws, ordinances, orders, rules, regulations, and requirements of the Federal, State, County, City, and Municipal government or any of their departments, bureaus, boards, commissions and oficials thereof with respect to the premises, or the use or occupancy thereof, Whether said compliance shall be ordered or directed to or against the Tenant(s), the Landlord, or both. DEFAULT: If the Tenant(s) fails to comply with any of the financial or material provisions of this Agreement, or of any present rules and regulations or any that may be hereafter prescribed by the Landlord, or materially fails to comply with any duties imposed on the Tenant(s) by statute or State laws, within the time period alter delivery of written notice by the Landlord specifying the non- compliance and indicating the intention of the Landlord to terminate the Agreement by reason thereof, Page 5 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM the Landlord may terminate this Agreement. If the Tenant(s) fails to pay rent when due and the default continues for the time-period specified in the written notice thereafier, the Landlord may, at their option, declare the entire balance (compiling all months applicable to this Agreement) of rent payable hereunder to be immediately due and payable and may exercise any and all rights and remedies available to the Landlord at law or in equity and may immediately terminate this Agreement. The Tenant(s) will be in default if: (a) Tenant(s) does not pay rent or other amounts that are owed in accordance with respective State laws; (b) Tenant(s), their guests, or the Occupant(s) violate this Agreement, rules, or fire, safety, health, or criminal laws, regardless of whether arrest or conviction occurs; (c) Tenant(s) abandons the Premises; (d) Tenant(s) gives incorrect or false information in the rental application; (e) Tenant(s), or any Occupant(s) is arrested, convicted, or given deferred adjudication for a criminal ofi'ense involving actual or potential physical harrn to a person, or involving possession, manufacture, or delivery of a controlled substance, marijuana, or drug paraphernalia under state statute; (f) any illegal drugs or paraphernalia are found in the Premises or on the person of the Tenant(s), guests, or Occupant(s) while on the Premises and/or; (g) as otherwise allowed by law. MULTIPLE TENANT(S) OR OCCUPANT (S): Each individual that is considered a Tenant(s) is jointly and individually liable for all of this Agreement's obligations, including but not limited to rent monies. If any Tenant(s), guest, or Occupant(s) violates this Agreement, the Tenant(s) is considered to have violated this Agreement. Landlord's requests and notices to the Tenant(s) or any of the Occupant(s) of legal age constitutes notice to the Tenant(s). Notices and requests fiom the Tenant(s) or any one of the Occupant(s) (including repair requests and entry permissions) constitutes notice fiom the Tenant(s). In eviction suits, the Tenant(s) is considered the agent of the Premise for the service of process. DISPUTES: If a dispute arises during or after the term of this Agreement between the Landlord and " Tenant(s), they shall agree to hold negotiations amongst themselves, in good faith", before any litigation. SEVERABILITY: If any provision of this Agreement or the application thereof shall, for any reason and to any extent, be invalid or unenforceable, neither the remainder of this Agreement nor the application of the provision to other persons, entities or circumstances shall be affected thereby, but instead shall be enforced to the maximum extent permitted by law. SURRENDER OF PREMISES: The Tenant(s) has surrendered the Premises when (a) the move-out date has passed and no one is living in the Premise within the Landlord's reasonable judgment; or (b) Access to the Premise have been turned in to Landlord whichever comes first. Upon the expiration of the term hereof, the Tenant(s) shall surrender the Premise in better or equal condition as it were at the commencement of this Agreement, reasonable use, wear and tear thereof, and damages by the elements excepted. Page 6 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM RETALIATION: The Landlord is prohibited fiom making any type of retaliatory acts against the Tenant(s) including but not limited to restricting access to the Premises, decreasing or cancelling services or utilities, failure to repair appliances or fixtures, or any other type of act that could be considered unjustified. WAIVER: A Waiver by the Landlord for a breach of any covenant or duty by the Tenant(s), under this Agreement is not a waiver for a breach of any other covenant or duty by the Tenant(s), or of any subsequent breach of the same covenant or duty. No provision of this Agreement shall be considered waived unless such a waiver shall be expressed in writing as a formal amendment to this Agreement and executed by the Tenant(s) and Landlord. EQUAL HOUSING: If the Tenant(s) possess(es) any mental or physical impairment, the Landlord shall provide reasonable modifications to the Premises unless the modifications would be too difiicult or expensive for the Landlord to provide. Any impairment of the Tenant(s) is/are encouraged to be provided and presented to the Landlord in writing in order to seek the most appropriate route for providing the modifications to the Premises. HAZARDOUS MATERIALS: The Tenant(s) agrees to not possess any type of personal property that could be considered a fire hazard such as a substance having flammable or explosive characteristics on the Premises. Items that are prohibited to be brought into the Premises, other than for everyday cooking or the need of an appliance, includes but is not limited to gas (compressed), gasoline, fuel, propane, kerosene, motor oil, fireworks, or any other related content in the form of a liquid, solid, or gas. WATERBEDS: The Tenant(s) is not permitted to furnish the Premises with waterbeds. GRILLING: The Tenant(s) shall not be permitted to use any type of propane or charcoal grill on the balcony, instead any grilling shall be done rear their garage or in the courtyard. INDEMNIFICATION: The Landlord shall not be liable for any damage or injury to the Tenant(s), or any other person, or to any property, occurring on the Premises, or any part thereof, or in common areas thereof, and the Tenant(s) agrees to hold the Landlord harmless fiom any claims or damages unless caused solely by the Landlord's negligence. It is recommended that renter's insurance be purchased at the Tenant(s)'s expense. COVENANTS: The covenants and conditions herein contained shall apply to and bind the heirs, legal representatives, and assigns of the parties hereto, and all covenants are to be construed as conditions of this Agreement. Page 7 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM NOTICES: In accordance with Minnesota state law all notices shall be done via email, unless specifically requested in writing otherwise. Landlord's/Agent's Mailing Address Edison Squared Investments, LLC., ATTN. Jeff Edison 1011 14th Street N, Suite Ofice, Fargo, North Dakota, 58102 Tenant(s)'s Mailing Address 2616 Country Club BLVD, APPT #3, Moorhead, Minnesota, 56560 AGENT/MANAGER: The Landlord does not have an Agent or Manager and all contact in regards to any repair, maintenance, or complaint must go through the Landlord through the following contact information: Landlord's Phone Number: (701) 3711950 Email: jefiey.b.edison@gmail.com. PREMISES DEEMED UNINHABITABLE: If the Property is deemed uninhabitable due to damage beyond reasonable repair the Tenant(s) will be able to terminate this Agreement by written notice to the Landlord. If said damage was due to the negligence of the Tenant(s), the Tenant(s) shall be liable to the Landlord for all repairs and for the loss of income due to restoring the Premises back to a livable condition in addition to any other losses that can be proved by the Landlord. SERVICEMEMBERS CIVIL RELIEF ACT: In the event the Tenant(s) is or hereafter becomes, a member of the United States Armed Forces on extended active duty and hereafter the Tenant(s) receives permanent change of station (PCS) orders to depart ficom the area where the Premises are located, or is relieved fiom active duty, retires or separates fiom the military, is ordered into military housing, or receives deployment orders, then in any of these events, the Tenant may terminate this lease upon giving thirty (30) days written notice to the Landlord. The Tenant shall also provide to the Landlord a copy of the official orders or a letter signed by the Tenant's commanding ofiicer, reflecting the change which warrants termination under this clause. The Tenant will pay prorated rent for any days which he/she occupies the dwelling past the beginning of the rental period. The damage/security deposit will be promptly returned to Tenant, provided there are no Page 8 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM damages to the Premises. LEAD PAINT: The Premises was constructed before 1978 and therefore the Lead-Based Paint Disclosure that is attached to this Agreement must be authorizeé. GOVERNING LAW: This Agreement is to be governed under the laws located in the State of North Dakota. ADDITIONAL TERMS AND CONDITIONS: There are no further terms or conditions that will be added to this Agreement other than any attachments or addendums attached. ENTIRE AGREEMENT: This Agreement contains all the terms agreed to by the parties relating to its subject matter including any attachments or addendums. This Agreement replaces all previous discussions, understandings, and oral agreements. The Landlord and Tenant(s) agree to the terms and conditions and shall be bound until the end of the Lease Tenn. The parties have agreed and executed this agreement on 20 2 M" y / // , LANDLORD(S) SIGNATURE Landlord's Signature /// Jefi' Edison as Manger/Member of Edison Squared Investments, LLC. TENANT(S) SIGNATURE Tenant's SignaturL/W Page 9 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM AMOUNT ($) DUE AT SIGNING Security Deposit: 800 Pet deposit: 400 Rent (first months): 835 Rent (last months): 835 Total Due: 870.00 Page 10 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM EXHIBIT B 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM Property Name Unit Lease DateTenants Invoice Id Due Date Last PaymeRent 2616 Country Club 3 06/01/202 Chelsea Ko 6393261 6/1/2024 - $910.00 2616 Country Club 3 06/01/202 Chelsea Ko 3810892 2/1/2024 3/4/2024 $835.00 2616 Country Club 3 06/01/202 Chelsea Ko 3810893 3/1/2024 4/9/2024 $835.00 2616 Country Club 3 06/01/202 Chelsea Ko 3810894 4/1/2024 4/9/2024 $835.00 2616 Country Club 3 06/01/202 Chelsea Ko 3810895 5/1/2024 - $835.00 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM Late Fee C NSF Fee Pet Fee Security DeTotal Invoi Total Amo Total Amou Outstanding A Notes $72.80 - - - $982.80 $0.00 $0.00 $982.80 - $66.80 - - - $901.80 $0.00 $901.80 $0.00 - - - - - $835.00 $0.00 $835.00 $0.00 - $66.80 - - - $901.80 $0.00 $820.48 $81.32 - $133.60 - - - $968.60 $0.00 $0.00 $968.60 - $2,032.72 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM EXHIBIT C 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM Chelsea Koons 2616 Country Club Parkway Apartment #3 Moorhead, MN 56560 Re: 14 DAY NOTICE OF INTENT TO FILE AN EVICTION ACTION Dear All Occupants of the above Property Address: Please be advised that I am or that I represent your landlord (“Landlord”) regarding your continued possession of the above-described property. As you are aware, you are in default on your lease agreement with your Landlord for your failure to make lease payments and late fees totaling $2,030.72as of the date of this letter (See Attached Ledger). Monthly rent and late fees will continue to accrue. You should be aware: 1. The total amount of past due rent is currently $2,030.72 .(See Attached Ledger); 2. The name and address of the person authorized to receive rent and fees on behalf of the landlord is: Click or tap here to enter text. 3. You have the right to seek legal help. If you can't afford a lawyer, free legal help may be available. Contact Legal Aid or visit www.LawHelpMN.org to know your rights and find your local Legal Aid office. 4. To apply for financial help, contact your local county or Tribal social services office, apply online at MNBenefits.mn.gov or call the United Way toll-free information line by dialing 2-1-1 or 800-543-7709; and 5. Your landlord can file an eviction case if you do not pay the total amount due or move out within 14 days from the date of this notice. Some local governments may have an eviction notice period longer than 14 days. If you fail to pay or vacate the premises within 14 days, I have been authorized to commence an eviction action against you in Housing Court to have you forcibly removed by the County Sheriff. The filing of an eviction action may severely affect your ability to obtain rental housing in the future. We look forward to working with you in this matter and ask that if you have any questions, please contact me. Sincerely, Jeff Edison Edison Squared Investments, LLC. 14-CV-24-2144 Filed in District Court State of Minnesota 6/18/2024 8:44 PM FDCPA Notice: This communication is with a debt collector. Any information obtained will be used for that purpose. Unless you, within thirty days after receipt of the notice, dispute the validity of the debt, or any portion thereof, I will assume the to be valid; If you notify me in writing within the thirty-day period that the debt, or any portion thereof, is disputed, I will obtain verification of the debt or a copy of a judgment against you and I will cause a copy of such verification or judgment to be mailed to you; and Upon your written request within the thirty-day period, I will provide you with the name and address of the original creditor, if different from the current creditor.