Preview
19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF DAKOTA FIRST JUDICIAL DISTRICT
____________________________ Case Type: Eviction
Healing Home, LLC
Plaintiff
v. EVICTION COMPLAINT
Timothy McCoy, John Doe, Mary Roe
Defendant(s)
_____________________________
Donald Perron, attorney for Plaintiff, states and declares as follows:
1. Healing Home, LLC is a Limited Liability Company with its registered office address
at 2365 McKnight Rd. N., North St. Paul, Minnesota 55109. Plaintiff is the owner of the rental
premises in question.
2. Defendant(s) Timothy McCoy is a/ are Minnesota resident(s) who leased, by written
agreement, the premises at 200 3rd Ave. S., Unit#1B, South St. Paul, MN 55075, in Dakota
County. A copy of the current lease is attached hereto and made a part hereof.
3. 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.
4. This is an eviction action for holdover after notice to vacate. On April 25, 2024,
Plaintiff gave Defendant a 30 day Notice to Vacate. By the terms of the notice, Defendant was
required to vacate on or before May 31, 2024. Defendant failed to vacate and is still in
possession of the premises. A copy of the Notice is attached hereto and made a part hereof.
19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
5. The tenancy is not affected by a federal or state housing subsidy program through
project based federal assistance payments; the Section 8 program; the low-income housing tax
credit program; or other similar program.
6. The Defendants’ military status is unknown.
WHEREFORE PLAINTIFF PRAYS THE COURT FOR THE FOLLOWING RELIEF:
1. For judgment against Defendant(s) and an Order issuing an immediate Writ of
Recovery returning lawful possession of the premises to the Plaintiff.
2. For Judgment against Defendants for all Plaintiff's costs and disbursements including,
but not limited to, the filing fee of $297, convenience fee of $5.00, and process service fee of
$75.00 for total statutory costs of $377.00 plus attorney fees allowed under the lease and law.
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 6-14-24 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
19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
Residential Lease Agreement
THIS AGREEMENT (hereinafter referred to as the "Minnesota Lease Agreement")
is made and entered into this 7th day of March 2023, by and between HEALING HOME,
LLC. 2365 McKNIGHT ROAD NORTH ST. PAUL, MN 55109 (hereinafter referred to as
"Landlord") and Timothy McCoy 200 3rd Ave. UNIT #1 B, SOUTH ST. PAUL, MN 55075
(hereinafter referred to as "Tenant." For and in consideration of the covenants and
obligations contained herein and other good and valuable consideration, the receipt and
sufficiency of which is hereby acknowledged, the parties hereto hereby agree as follows:
1. PROPERTY. Landlord owns certain real property and improvements located at 200 3rd Ave.
UNIT #1 B, SOUTH ST. PAUL, MN 55075 (hereinafter referred to as the "Property").
Landlord desires to lease the Premises to Tenant upon the terms and conditions contained herein.
Tenant desires to lease the Premises from Landlord on the terms and conditions as contained
herein.
2. TERM. This Minnesota Lease Agreement shall commence on March 71h, 2023 and shall
continue as a lease for term. The termination date shall be on month to month at 11 :59 PM. Upon
termination date, Tenant shall be required to vacate the Premises unless one of the following
circumstances occur:
(i) Landlord and Tenant formally extend this Minnesota Lease Agreement in writing or create
and execute a new, written, and signed Minnesota Lease Agreement; or
(ii) Landlord willingly accepts new Rent from Tenant, which does not constitute past due Rent.
In the event that Landlord accepts new rent from Tenant after the termination date, a month-toÂ
month tenancy shall be created. If at any time either party desires to terminate the month-to-month
tenancy, such party may do so by providing to the other party written notice of intention to terminate
at least 30 days prior to the desired date of termination of the month-to-month tenancy.
Notices to terminate may be given on any calendar day, irrespective of Commencement Date. Rent
shall continue at the rate specified in this Minnesota Lease Agreement, or as allowed by law. All
other terms and conditions as outlined in this Minnesota Lease Agreement shall remain in full force
and effect. Time is of the essence for providing notice of termination (strict compliance with dates
by which notice must be provided is required).
B. Prorated Rent. In the event that the Commencement Date is not the 1st of the calendar
month, Rent payment remitted on the Commencement Date shall be prorated based on a
30-day period.
C. Returned Checks. In the event that any payment by Tenant is returned for insufficient funds
("NSF") or if Tenant stops payment, Tenant will pay $ 50.00 to Landlord for each such
check, plus late charges, as described above, until Landlord has received payment.
Furthermore, Landlord may require in writing that Tenant pay all future Rent payments by
cash, money order, or cashier's check.
D. Order in which funds are applied. Landlord will apply all funds received from Tenant first to
any non-rent obligations of Tenant including late charges, returned check charges, chargeÂ
backs for repairs, brokerage fees, and periodic utilities, then to rent, regardless of any
notations on a check.
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19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
E. Rent Increases. There will be no rent increases through the Termination Date. If this lease
is renewed automatically on a month to month basis, Landlord may increase the rent during
the renewal period by providing written notice to Tenant that becomes effective the month
following the 30'" day after the notice is provided.
RENT. Tenant shall pay to Landlord the sum of $927.00 per month as Rent for the Term of the
Agreement. Due date for Rent payment shall be the ist day of each calendar month and shall be
considered advance payment for that month. Weekends and holidays do not delay or excuse
Tenant's obligation to timely pay rent.
A. Delinguent Rent. lf not paid on the 'l st, Rent shall be considered overdue and delinquent on
the 2nd day of each calendar month. If Tenant fails to timely pay any month's rent, Tenant
will pay Landlord a late charge of $ 50.00 per day until rent is paid in full. If Landlord
receives the monthly rent by the 3rd day of the month, Landlord will waive the late charges
for that month. Any waiver of late charges under this paragraph will not affect or diminish
any other right or remedy Landlord may exercise for Tenant's failure to timely pay rent.
4 SECURITY DEPOSIT. Upon execution of this Minnesota Lease Agreement, Tenant shall deposit
with Landlord the sum of $927.00 (which amount is not in excess of two months periodic rent)
receipt of which is hereby acknowledged by Landlord, as security for any damage caused to the
Premises during the term hereof. Landlord may place the security deposit in an interest bearing
account and any interest earned will be paid to Landlord or Landlord's representative.
A. REFUND. Upon termination of the tenancy, all funds held by the landlord as security
.
deposit may be applied to the payment of accrued rent and the amount of damages that the landlord
has suffered by reason of the tenant's noncompliance with the terms of this Minnesota Lease
Agreement or with any and all laws, ordinances, rules and orders of any and all governmental or
quasi-governmental authorities affecting the cleanliness, use, occupancy and preservation of the
Premises.
B. DEDUCTIONS. Landlord may deduct reasonable charges from the security deposit for:
(1.) Unpaid or accelerated rent;
(2.) Late charges;
(3.) Unpaid utilities;
(4.) Costs of cleaning, deodorizing, and repairing the Property and its contents for
which Tenant is responsible;
(5.) Pet violation charges;
(6.) Replacing unreturned keys, garage door openers, or other security devices;
(7.) The removal of unauthorized locks or fixtures installed by Tenant;
(8.) Insufficient light bulbs;
(9.) Packing, removing, and storing abandoned property;
(10.) Removing abandoned or illegally parked vehicles;
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19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
(11.) Costs of re—renting, if Tenant is in default;
(12.) Attorney fees and costs of court incurred in any proceeding against Tenant;
(13.) Any fee due for early of removal of an authorized keybox;
(14.) Other items Tenant is responsible to pay under this Lease.
if deductions exceed the security deposit, Tenant will pay to Landlord the excess within ten days
after Landlord makes written demand. The security deposit will be applied first to any non—rent
items, including late charges, returned check charges, repairs, brokerage fees, and periodic
utilities, then to any unpaid rent.
5. USE 0F PREMISES. The Premises shall be used and occupied solely by Tenant and Tenant's
immediate family, consisting of Timothy McCoy exclusively, as a private single-family dwelling,
and no part of the Premises shall be used at any time during the term of this Minnesota Lease
Agreement by Tenant for the purpose of carrying on any business, profession, or trade of any kind,
or for any purpose other than as a private single family dwelling. Tenant shall not allow any other
person, other than Tenant's immediate family or transient relatives and friends who are guests of
Tenant, to use or occupy the Premises without first obtaining Landlord's written consent to such
use. Tenant shall comply with any and all laws, ordinances, rules and orders of any and all
governmental or quasi-governmental authorities affecting the cleanliness, use, occupancy and
preservation of the Premises.
6. CONDITION OF PREMISES. Tenant stipulates, represents and warrants that Tenant has
examined the Premises, and that they are at the time of this Lease in good order, repair, and in a
safe, clean and tenantable condition.
7. ASSIGNMENT AND SUB-LETTING. Tenant shall not assign this Minnesota Lease Agreement, or
sub-let or grant any license to use the Premises or any part thereof without the prior written consent
of Landlord. A consent by Landlord to one such assignment, sub-letting or license shall not be
deemed to be a consent to any subsequent assignment, sub-letting or license. An assignment,
sub-letting or license without the prior written consent of Landlord or an assignment or sub-letting
by operation of law shall be absolutely null and void and shall, at Landlord's option, terminate this
Minnesota Lease Agreement.
8. ALTERATIONS AND IMPROVEMENTS. Tenant shall make no alterations to the buildings or
improvements on the Premises or construct any building or make any other improvements on the
Premises without the prior written consent of Landlord. Any and all alterations, changes, and/or
improvements built, constructed or placed on the Premises by Tenant shall, unless otherwise
provided by written agreement between Landlord and Tenant, be and become the property of
Landlord and remain on the Premises at the expiration or earlier termination of this Minnesota
Lease Agreement.
9. NON-DELIVERY 0F POSSESSION. In the event Landlord cannot deliver possession of the
Premises to Tenant upon the commencement of the Lease term, through no fault of Landlord or its
agents, then Landlord or its agents shall have no liability, but the rental herein provided shall abate
until possession is given. Landlord or its agents shall have thirty (30) days in which to give
possession, and if possession is tendered within such time, Tenant agrees to accept the demised
Premises and pay the rental herein provided from that date. In the event possession cannot be
delivered within such time, through no fault of Landlord or its agents, then this Minnesota Lease
Agreement and all rights hereunder shall terminate.
19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
10. HAZARDOUS MATERIALS. Tenant shall not keep on the Premises any item of a dangerous,
flammable or explosive character that might unreasonably increase the danger of fire or explosion
on the Premises or that might be considered hazardous or extra hazardous by any responsible
insurance company.
11. UTILITIES. Tenant shall be responsible for payment of the following utilities: For trash that will not
fit in the barrel provided. Recycle barrels are for paper, cardboard, cans and plastic, (no trash).
12. MAINTENANCE, REPAIR, AND RULES. Tenant will, at its sole expense, keep and maintain the
Premises and appurtenances in good and sanitary condition and repair during the term of this
Minnesota Lease Agreement and any renewal thereof. Without limiting the generality of the
foregoing. Tenant shall:
A. Not obstruct the driveways, sidewalks, courts, entry ways, stairs and/or halls, which shall be
used for the purposes of ingress and egress only;
B= Keep all windows, glass, window coverings, doors, locks and hardware in good, clean order
and repair;
C Not obstruct or cover the windows or doors;
DI
Not leave windows or doors in an open position during any inclement weather;
E Not hang any laundry, clothing, sheets, etc., from any window, rail, porch or balcony nor air or
dry any of same within any yard area or space;
Not cause or permit any locks or hooks to be placed upon any door or window without the prior
written consent of Landlord;
G Keep all air conditioning filters clean and free from dirt;
H Keep all lavatories, sinks, toilets, and all other water and plumbing apparatus in good order
and repair and shall use same only for the purposes for which they were constructed. Tenant
shall not allow any sweepings, rubbish, sand, rags, ashes or other substances to be thrown or
deposited therein. Any damage to any such apparatus and the cost of clearing stopped
plumbing resulting from misuse shall be borne by Tenant;
Tenant's family and guests shall at all times maintain order in the Premises and at all places on
the Premises, and shall not make or permit any loud or improper noises, or otherwise disturb
other residents;
Keep all radios, television sets, stereos, phonographs, etc., turned down to a level of sound
that does not annoy or interfere with other residents;
K Deposit all trash, garbage, rubbish or refuse in the locations provided and shall not allow any
trash, garbage, rubbish or refuse to be deposited or permitted to stand on the exterior of any
building or within the common elements;
L Abide by and be bound by any and all rules and regulations affecting the Premises or the
common area appurtenant thereto which may be adopted or promulgated by the Condominium
or Homeowners' Association having control over them.
19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
13. DAMAGE TO PREMISES. In the event the Premises are destroyed or rendered wholly
uninhabitable by fire, storm, earthquake, or other casualty not caused by the negligence of Tenant,
this Minnesota Lease Agreement shall terminate from such time except for the purpose of enforcing
rights that may have then accrued hereunder. The rental provided for herein shall then be
accounted for by and between Landlord and Tenant up to the time of such injury or destruction of
the Premises, Tenant paying rentals up to such date and Landlord refunding rentals collected
beyond such date. Should a portion of the Premises thereby be rendered uninhabitable, the
Landlord shall have the option of either repairing such injured or damaged portion or terminating
this Lease. In the event that Landlord exercises its right to repair such uninhabitable portion, the
rental shall abate in the proportion that the injured parts bears to the whole Premises. and such
part so injured shall be restored by Landlord as speedily as practicable, after which the full rent
shall recommence and the Minnesota Lease Agreement continue according to its terms.
14. ACCESS BY LANDLORD. Landlord and Landlord's agents shall have the right at all reasonable
times, and by all reasonable means, without notice, during the term of this Minnesota Lease
Agreement and any renewal thereof to enter the Premises for the following purposes:
A. Inspect the Property for condition;
B. Make repairs;
C. Show the Property to prospective tenants, prospective purchasers, inspectors, fire marshals,
lenders, appraisers, or insurance agents;
D. Exercise a contractual or statutory lien;
E. Leave written notice;
F. Seize nonexempt property after default.
Landlord may prominently display a "For Sale" or "For Lease" or similarly worded sign on the
Property during the term of this Lease or any renewal period.
If Tenant fails to permit reasonable access under this Paragraph, Tenant will be in default.
15. SUBORDINATION OF LEASE. This Minnesota Lease Agreement and Tenant's interest hereunder
are and shall be subordinate, junior and inferior to any and all mortgages, liens or encumbrances
now or hereafter placed on the Premises by Landlord, all advances made under any such
mortgages, liens or encumbrances (including, but not limited to, future advances), the interest
payable on such mortgages, liens or encumbrances and any and all renewals, extensions or
modifications of such mortgages, liens or encumbrances.
16. TENANT'S HOLD OVER. If Tenant remains in possession of the Premises with the consent of
Landlord after the natural expiration of this Minnesota Lease Agreement, a new tenancy from
month-to-month shall be created between Landlord and Tenant which shall be subject to all of the
terms and conditions hereof except that rent shall then be due and owing at $1800 per month and
except that such tenancy shall be terminable upon fifteen (15) days written notice served by either
party.
17. SURRENDER OF PREMISES. Upon the expiration of the term hereof, Tenant shall surrender the
Premises in as good a state and condition as they were at the commencement of this Minnesota
Lease Agreement, reasonable use and wear and tear thereof and damages by the elements
excepted.
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19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
18. ANIMALS. THERE WILL BE NO ANIMALS, unless authorized by a separate written Pet Addendum
to this Residential Lease Agreement. Tenant shall not permit any animal, including mammals,
reptiles, birds, fish, rodents, or insects on the property, even temporarily, unless otherwise agreed
by a separate written Pet Agreement. If tenant violates the pet restrictions of this Lease, Tenant
will pay to Landlord a fee of $50.00 per day per animal for each day Tenant violates the animal
restrictions as additional rent for any unauthorized animal. Landlord may remove or cause to be
removed any unauthorized animal and deliver it to appropriate local authorities by providing at least
24-hour written notice to Tenant of Landlord's intention to remove the unauthorized animal.
Landlord will not be liable for any harm, injury, death, or sickness to any unauthorized animal.
Tenant is responsible and liable for any damage or required cleaning to the Property caused by
any unauthorized animal and for all costs Landlord may incur in removing or causing any
unauthorized animal to be removed.
19. WATERBEDS. THERE WILL BE NO WATERBEDS, unless authorized by a separate written
Waterbed Addendum to this Residential Lease Agreement.
20. QUIET ENJOYMENT. Tenant, upon payment of all of the sums referred to herein as being payable
by Tenant and Tenant's performance of all Tenant's agreements contained herein and Tenant's
observance of all rules and regulations, shall and may peacefully and quietly have, hold and enjoy
said Premises for the term hereof.
21. INDEMNIFICATION. Landlord shall not be liable for any damage or injury of or to the Tenant,
Tenant's family, guests, invitees, agents or employees or to any person entering the Premises or
the building of which the Premises are a part or to goods or equipment, or in the structure or
equipment of the structure of which the Premises are a part, and Tenant hereby agrees to
indemnify, defend and hold Landlord harmless from any and all claims or assertions of every kind
and nature.
22. DEFAULT. If Landlord breaches this Lease, Tenant may seek any relief provided by law. lfTenant
fails to comply with any of the material provisions of this Minnesota Lease Agreement, other than
the covenant to pay rent, or of any present rules and regulations or any that may be hereafter
prescribed by Landlord. or materially fails to comply with any duties imposed on Tenant by statute,
within seven (7) days after delivery of written notice by Landlord specifying the non-compliance and
indicating the intention of Landlord to terminate the Lease by reason thereof, Landlord may
terminate this Minnesota Lease Agreement. If Tenant fails to pay rent when due and the default
continues for seven (7) days thereafter, Landlord may, at Landlord's option, declare the entire
balance of rent payable hereunder to be immediately due and payable and may exercise any and
all rights and remedies available to Landlord at law or in equity or may immediately terminate this
Minnesota Lease Agreement.
23. ABANDONMENT. If at any time during the term of this Minnesota Lease Agreement Tenant
abandons the Premises or any part thereof, Landlord may, at Landlord's option, obtain possession
of the Premises in the manner provided by law, and without becoming liable to Tenant for damages
or for any payment of any kind whatever. Landlord may, at Landlord's discretion, as agent for
Tenant, relent the Premises, or any part thereof, for the whole or any part thereof, for the whole or
any part of the then unexpired term, and may receive and collect all rent payable by virtue of such
reletting, and, at Landlord's option, hold Tenant liable for any difference between the rent that would
have been payable under this Minnesota Lease Agreement during the balance of the unexpired
term, if this Minnesota Lease Agreement had continued in force, and the net rent for such period
realized by Landlord by means of such re—renting. If Landlord's right of reentry is exercised
following abandonment of the Premises by Tenant, then Landlord shall consider any personal
property belonging to Tenant and left on the Premises to also have been abandoned, in which case
Landlord may dispose of all such personal property in any manner Landlord shall deem proper and
Landlord is hereby relieved of all liability for doing so.
19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
24. ATTORNEYS' FEES. Should it become necessary for Landlord to employ an attorney to enforce
any of the conditions or covenants hereof. including the collection of rentals or gaining possession
of the Premises, Tenant agrees to pay all expenses so incurred, including a reasonable attorneys'
fee.
25. RECORDING 0F MINNESOTA LEASE AGREEMENT. Tenant shall not record this Minnesota
Lease Agreement on the Public Records of any public office. In the event that Tenant shall record
this Minnesota Lease Agreement, this Minnesota Lease Agreement shall, at Landlord's option,
terminate immediately and Landlord shall be entitled to all rights and remedies that it has at law or
in equity.
26. GOVERNING LAW. This Minnesota Lease Agreement shall be governed, construed and
interpreted by, through and under the Laws of the State of Minnesota.
27. SEVERABILITY. If any provision of this Minnesota Lease Agreement or the application thereof
shall, for any reason and to any extent, be invalid or unenforceable, neither the remainder of this
Minnesota Lease 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.
28. BINDING EFFECT. The covenants, obligations and conditions herein contained shall be binding
on and inure to the benefit of the heirs, legal representatives, and assigns of the parties hereto.
29. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience of
reference only and they are not intended to have any effect whatsoever in determining the rights
or obligations of the Landlord or Tenant.
30. CONSTRUCTION. The pronouns used herein shall include, where appropriate, either gender or
both, singular and plural.
3'1. NON-WAIVER. No delay, indulgence, waiver, non-enforcement, election or non-election by
Landlord under this Minnesota Lease Agreement will be deemed to be a waiver of any other breach
by Tenant, nor shall it affect Tenant's duties, obligations, and liabilities hereunder.
32. MODIFICATION. The parties hereby-agree that this document contains the entire agreement
between the parties and this Minnesota Lease Agreement shall not be modified, changed, altered
or amended in any way except through a written amendment signed by all of the parties hereto.
33. NOTICE. Any notice required or permitted under this Lease or under state law shall be delivered
to Tenant at the Property address, and to Landlord at the following address:
34. LEAD-BASED PAINT DISCLOSURE. lf the premises were constructed prior to 1978, Tenant
acknowledges receipt of the form entitled "LEAD—BASED PAINT DISCLOSURE" which contains
disclosure of information on lead—based paint and/or lead—based paint hazards.
35. RIGHT OF RE-ENTRY. Upon the occurrence of a Default, Landlord may elect to terminate this
Lease, or, without terminating this Lease, terminate Tenants right to possession of the Premises.
Upon any such termination, Tenant shall immediately surrender and vacate the Premises and
deliver possession thereof to Landlord. Tenant grants to Landlord the right to enter and repossess
the Premises and to expel Tenant and any others who may be occupying the Premises and to
remove any and all property therefrom, without being deemed in any manner guilty of trespass and
without relinquishing Landlords rights to Rent or any other right given to Landlord hereunder or by
operation of law.
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19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
Tenant Handbook is available to you at:
https:/lwww.aq.state.mn.us/Consumer/Handbooks/LT/default.asp
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19AV-CV-24-1626
Filed in District Court
State of Minnesota
6/20/2024 3:01 PM
30-Day Notice
Date: April 25th, 2024
Tenant's Name: Timothy McCoy
Address of Rental Unit:
200 3rd Ave. S.
Unit #1B
South St. Paul, MN 55075
| am writing you this notice that your lease dated on March 7th, 2023, by and
between Healing Home LLC will be terminated on the 31st day of May 2024. This
is your 30-day notice, we are not renewing your month to month lease for June. It is
very important that you remove all your personal items by this time, so we have a
chance to clean the apartment before a new tenant moves in.
You are responsible for returning the apartment to the same or better condition than
when you moved in. If you do not, you will be charged for any damages beyond
regular use of the premises. Your itemized security deposit will be returned to you on
or before the 215' of the month following your departure.
The most common charges incurred by departing tenants are:
1) Failure to clean. You should vacuum the carpet, sweep and mop all floors,
clean bathrooms and kitchens.
2) Failure to move everything. Anything you leave behind will be charged
against your security deposit for disposal. This includes vehicles, household
items and garage items.
3) Damages beyond wear and tear.
4) Failure to return keys, etc.
5) Failure to pay all rent, fees, etc.
Please contact me should have any questions.
Thank you.
Hedi/rig;
Healing Home LLC
Owner
Preview
19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM STATE OF MINNESOTA DISTRICT COURT COUNTY OF DAKOTA FIRST JUDICIAL DISTRICT ____________________________ Case Type: Eviction Healing Home, LLC Plaintiff v. EVICTION COMPLAINT Timothy McCoy, John Doe, Mary Roe Defendant(s) _____________________________ Donald Perron, attorney for Plaintiff, states and declares as follows: 1. Healing Home, LLC is a Limited Liability Company with its registered office address at 2365 McKnight Rd. N., North St. Paul, Minnesota 55109. Plaintiff is the owner of the rental premises in question. 2. Defendant(s) Timothy McCoy is a/ are Minnesota resident(s) who leased, by written agreement, the premises at 200 3rd Ave. S., Unit#1B, South St. Paul, MN 55075, in Dakota County. A copy of the current lease is attached hereto and made a part hereof. 3. 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. 4. This is an eviction action for holdover after notice to vacate. On April 25, 2024, Plaintiff gave Defendant a 30 day Notice to Vacate. By the terms of the notice, Defendant was required to vacate on or before May 31, 2024. Defendant failed to vacate and is still in possession of the premises. A copy of the Notice is attached hereto and made a part hereof. 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM 5. The tenancy is not affected by a federal or state housing subsidy program through project based federal assistance payments; the Section 8 program; the low-income housing tax credit program; or other similar program. 6. The Defendants’ military status is unknown. WHEREFORE PLAINTIFF PRAYS THE COURT FOR THE FOLLOWING RELIEF: 1. For judgment against Defendant(s) and an Order issuing an immediate Writ of Recovery returning lawful possession of the premises to the Plaintiff. 2. For Judgment against Defendants for all Plaintiff's costs and disbursements including, but not limited to, the filing fee of $297, convenience fee of $5.00, and process service fee of $75.00 for total statutory costs of $377.00 plus attorney fees allowed under the lease and law. 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 6-14-24 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 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM Residential Lease Agreement THIS AGREEMENT (hereinafter referred to as the "Minnesota Lease Agreement") is made and entered into this 7th day of March 2023, by and between HEALING HOME, LLC. 2365 McKNIGHT ROAD NORTH ST. PAUL, MN 55109 (hereinafter referred to as "Landlord") and Timothy McCoy 200 3rd Ave. UNIT #1 B, SOUTH ST. PAUL, MN 55075 (hereinafter referred to as "Tenant." For and in consideration of the covenants and obligations contained herein and other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties hereto hereby agree as follows: 1. PROPERTY. Landlord owns certain real property and improvements located at 200 3rd Ave. UNIT #1 B, SOUTH ST. PAUL, MN 55075 (hereinafter referred to as the "Property"). Landlord desires to lease the Premises to Tenant upon the terms and conditions contained herein. Tenant desires to lease the Premises from Landlord on the terms and conditions as contained herein. 2. TERM. This Minnesota Lease Agreement shall commence on March 71h, 2023 and shall continue as a lease for term. The termination date shall be on month to month at 11 :59 PM. Upon termination date, Tenant shall be required to vacate the Premises unless one of the following circumstances occur: (i) Landlord and Tenant formally extend this Minnesota Lease Agreement in writing or create and execute a new, written, and signed Minnesota Lease Agreement; or (ii) Landlord willingly accepts new Rent from Tenant, which does not constitute past due Rent. In the event that Landlord accepts new rent from Tenant after the termination date, a month-to month tenancy shall be created. If at any time either party desires to terminate the month-to-month tenancy, such party may do so by providing to the other party written notice of intention to terminate at least 30 days prior to the desired date of termination of the month-to-month tenancy. Notices to terminate may be given on any calendar day, irrespective of Commencement Date. Rent shall continue at the rate specified in this Minnesota Lease Agreement, or as allowed by law. All other terms and conditions as outlined in this Minnesota Lease Agreement shall remain in full force and effect. Time is of the essence for providing notice of termination (strict compliance with dates by which notice must be provided is required). B. Prorated Rent. In the event that the Commencement Date is not the 1st of the calendar month, Rent payment remitted on the Commencement Date shall be prorated based on a 30-day period. C. Returned Checks. In the event that any payment by Tenant is returned for insufficient funds ("NSF") or if Tenant stops payment, Tenant will pay $ 50.00 to Landlord for each such check, plus late charges, as described above, until Landlord has received payment. Furthermore, Landlord may require in writing that Tenant pay all future Rent payments by cash, money order, or cashier's check. D. Order in which funds are applied. Landlord will apply all funds received from Tenant first to any non-rent obligations of Tenant including late charges, returned check charges, charge backs for repairs, brokerage fees, and periodic utilities, then to rent, regardless of any notations on a check. 1 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM E. Rent Increases. There will be no rent increases through the Termination Date. If this lease is renewed automatically on a month to month basis, Landlord may increase the rent during the renewal period by providing written notice to Tenant that becomes effective the month following the 30'" day after the notice is provided. RENT. Tenant shall pay to Landlord the sum of $927.00 per month as Rent for the Term of the Agreement. Due date for Rent payment shall be the ist day of each calendar month and shall be considered advance payment for that month. Weekends and holidays do not delay or excuse Tenant's obligation to timely pay rent. A. Delinguent Rent. lf not paid on the 'l st, Rent shall be considered overdue and delinquent on the 2nd day of each calendar month. If Tenant fails to timely pay any month's rent, Tenant will pay Landlord a late charge of $ 50.00 per day until rent is paid in full. If Landlord receives the monthly rent by the 3rd day of the month, Landlord will waive the late charges for that month. Any waiver of late charges under this paragraph will not affect or diminish any other right or remedy Landlord may exercise for Tenant's failure to timely pay rent. 4 SECURITY DEPOSIT. Upon execution of this Minnesota Lease Agreement, Tenant shall deposit with Landlord the sum of $927.00 (which amount is not in excess of two months periodic rent) receipt of which is hereby acknowledged by Landlord, as security for any damage caused to the Premises during the term hereof. Landlord may place the security deposit in an interest bearing account and any interest earned will be paid to Landlord or Landlord's representative. A. REFUND. Upon termination of the tenancy, all funds held by the landlord as security . deposit may be applied to the payment of accrued rent and the amount of damages that the landlord has suffered by reason of the tenant's noncompliance with the terms of this Minnesota Lease Agreement or with any and all laws, ordinances, rules and orders of any and all governmental or quasi-governmental authorities affecting the cleanliness, use, occupancy and preservation of the Premises. B. DEDUCTIONS. Landlord may deduct reasonable charges from the security deposit for: (1.) Unpaid or accelerated rent; (2.) Late charges; (3.) Unpaid utilities; (4.) Costs of cleaning, deodorizing, and repairing the Property and its contents for which Tenant is responsible; (5.) Pet violation charges; (6.) Replacing unreturned keys, garage door openers, or other security devices; (7.) The removal of unauthorized locks or fixtures installed by Tenant; (8.) Insufficient light bulbs; (9.) Packing, removing, and storing abandoned property; (10.) Removing abandoned or illegally parked vehicles; 2 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM (11.) Costs of re—renting, if Tenant is in default; (12.) Attorney fees and costs of court incurred in any proceeding against Tenant; (13.) Any fee due for early of removal of an authorized keybox; (14.) Other items Tenant is responsible to pay under this Lease. if deductions exceed the security deposit, Tenant will pay to Landlord the excess within ten days after Landlord makes written demand. The security deposit will be applied first to any non—rent items, including late charges, returned check charges, repairs, brokerage fees, and periodic utilities, then to any unpaid rent. 5. USE 0F PREMISES. The Premises shall be used and occupied solely by Tenant and Tenant's immediate family, consisting of Timothy McCoy exclusively, as a private single-family dwelling, and no part of the Premises shall be used at any time during the term of this Minnesota Lease Agreement by Tenant for the purpose of carrying on any business, profession, or trade of any kind, or for any purpose other than as a private single family dwelling. Tenant shall not allow any other person, other than Tenant's immediate family or transient relatives and friends who are guests of Tenant, to use or occupy the Premises without first obtaining Landlord's written consent to such use. Tenant shall comply with any and all laws, ordinances, rules and orders of any and all governmental or quasi-governmental authorities affecting the cleanliness, use, occupancy and preservation of the Premises. 6. CONDITION OF PREMISES. Tenant stipulates, represents and warrants that Tenant has examined the Premises, and that they are at the time of this Lease in good order, repair, and in a safe, clean and tenantable condition. 7. ASSIGNMENT AND SUB-LETTING. Tenant shall not assign this Minnesota Lease Agreement, or sub-let or grant any license to use the Premises or any part thereof without the prior written consent of Landlord. A consent by Landlord to one such assignment, sub-letting or license shall not be deemed to be a consent to any subsequent assignment, sub-letting or license. An assignment, sub-letting or license without the prior written consent of Landlord or an assignment or sub-letting by operation of law shall be absolutely null and void and shall, at Landlord's option, terminate this Minnesota Lease Agreement. 8. ALTERATIONS AND IMPROVEMENTS. Tenant shall make no alterations to the buildings or improvements on the Premises or construct any building or make any other improvements on the Premises without the prior written consent of Landlord. Any and all alterations, changes, and/or improvements built, constructed or placed on the Premises by Tenant shall, unless otherwise provided by written agreement between Landlord and Tenant, be and become the property of Landlord and remain on the Premises at the expiration or earlier termination of this Minnesota Lease Agreement. 9. NON-DELIVERY 0F POSSESSION. In the event Landlord cannot deliver possession of the Premises to Tenant upon the commencement of the Lease term, through no fault of Landlord or its agents, then Landlord or its agents shall have no liability, but the rental herein provided shall abate until possession is given. Landlord or its agents shall have thirty (30) days in which to give possession, and if possession is tendered within such time, Tenant agrees to accept the demised Premises and pay the rental herein provided from that date. In the event possession cannot be delivered within such time, through no fault of Landlord or its agents, then this Minnesota Lease Agreement and all rights hereunder shall terminate. 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM 10. HAZARDOUS MATERIALS. Tenant shall not keep on the Premises any item of a dangerous, flammable or explosive character that might unreasonably increase the danger of fire or explosion on the Premises or that might be considered hazardous or extra hazardous by any responsible insurance company. 11. UTILITIES. Tenant shall be responsible for payment of the following utilities: For trash that will not fit in the barrel provided. Recycle barrels are for paper, cardboard, cans and plastic, (no trash). 12. MAINTENANCE, REPAIR, AND RULES. Tenant will, at its sole expense, keep and maintain the Premises and appurtenances in good and sanitary condition and repair during the term of this Minnesota Lease Agreement and any renewal thereof. Without limiting the generality of the foregoing. Tenant shall: A. Not obstruct the driveways, sidewalks, courts, entry ways, stairs and/or halls, which shall be used for the purposes of ingress and egress only; B= Keep all windows, glass, window coverings, doors, locks and hardware in good, clean order and repair; C Not obstruct or cover the windows or doors; DI Not leave windows or doors in an open position during any inclement weather; E Not hang any laundry, clothing, sheets, etc., from any window, rail, porch or balcony nor air or dry any of same within any yard area or space; Not cause or permit any locks or hooks to be placed upon any door or window without the prior written consent of Landlord; G Keep all air conditioning filters clean and free from dirt; H Keep all lavatories, sinks, toilets, and all other water and plumbing apparatus in good order and repair and shall use same only for the purposes for which they were constructed. Tenant shall not allow any sweepings, rubbish, sand, rags, ashes or other substances to be thrown or deposited therein. Any damage to any such apparatus and the cost of clearing stopped plumbing resulting from misuse shall be borne by Tenant; Tenant's family and guests shall at all times maintain order in the Premises and at all places on the Premises, and shall not make or permit any loud or improper noises, or otherwise disturb other residents; Keep all radios, television sets, stereos, phonographs, etc., turned down to a level of sound that does not annoy or interfere with other residents; K Deposit all trash, garbage, rubbish or refuse in the locations provided and shall not allow any trash, garbage, rubbish or refuse to be deposited or permitted to stand on the exterior of any building or within the common elements; L Abide by and be bound by any and all rules and regulations affecting the Premises or the common area appurtenant thereto which may be adopted or promulgated by the Condominium or Homeowners' Association having control over them. 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM 13. DAMAGE TO PREMISES. In the event the Premises are destroyed or rendered wholly uninhabitable by fire, storm, earthquake, or other casualty not caused by the negligence of Tenant, this Minnesota Lease Agreement shall terminate from such time except for the purpose of enforcing rights that may have then accrued hereunder. The rental provided for herein shall then be accounted for by and between Landlord and Tenant up to the time of such injury or destruction of the Premises, Tenant paying rentals up to such date and Landlord refunding rentals collected beyond such date. Should a portion of the Premises thereby be rendered uninhabitable, the Landlord shall have the option of either repairing such injured or damaged portion or terminating this Lease. In the event that Landlord exercises its right to repair such uninhabitable portion, the rental shall abate in the proportion that the injured parts bears to the whole Premises. and such part so injured shall be restored by Landlord as speedily as practicable, after which the full rent shall recommence and the Minnesota Lease Agreement continue according to its terms. 14. ACCESS BY LANDLORD. Landlord and Landlord's agents shall have the right at all reasonable times, and by all reasonable means, without notice, during the term of this Minnesota Lease Agreement and any renewal thereof to enter the Premises for the following purposes: A. Inspect the Property for condition; B. Make repairs; C. Show the Property to prospective tenants, prospective purchasers, inspectors, fire marshals, lenders, appraisers, or insurance agents; D. Exercise a contractual or statutory lien; E. Leave written notice; F. Seize nonexempt property after default. Landlord may prominently display a "For Sale" or "For Lease" or similarly worded sign on the Property during the term of this Lease or any renewal period. If Tenant fails to permit reasonable access under this Paragraph, Tenant will be in default. 15. SUBORDINATION OF LEASE. This Minnesota Lease Agreement and Tenant's interest hereunder are and shall be subordinate, junior and inferior to any and all mortgages, liens or encumbrances now or hereafter placed on the Premises by Landlord, all advances made under any such mortgages, liens or encumbrances (including, but not limited to, future advances), the interest payable on such mortgages, liens or encumbrances and any and all renewals, extensions or modifications of such mortgages, liens or encumbrances. 16. TENANT'S HOLD OVER. If Tenant remains in possession of the Premises with the consent of Landlord after the natural expiration of this Minnesota Lease Agreement, a new tenancy from month-to-month shall be created between Landlord and Tenant which shall be subject to all of the terms and conditions hereof except that rent shall then be due and owing at $1800 per month and except that such tenancy shall be terminable upon fifteen (15) days written notice served by either party. 17. SURRENDER OF PREMISES. Upon the expiration of the term hereof, Tenant shall surrender the Premises in as good a state and condition as they were at the commencement of this Minnesota Lease Agreement, reasonable use and wear and tear thereof and damages by the elements excepted. 5 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM 18. ANIMALS. THERE WILL BE NO ANIMALS, unless authorized by a separate written Pet Addendum to this Residential Lease Agreement. Tenant shall not permit any animal, including mammals, reptiles, birds, fish, rodents, or insects on the property, even temporarily, unless otherwise agreed by a separate written Pet Agreement. If tenant violates the pet restrictions of this Lease, Tenant will pay to Landlord a fee of $50.00 per day per animal for each day Tenant violates the animal restrictions as additional rent for any unauthorized animal. Landlord may remove or cause to be removed any unauthorized animal and deliver it to appropriate local authorities by providing at least 24-hour written notice to Tenant of Landlord's intention to remove the unauthorized animal. Landlord will not be liable for any harm, injury, death, or sickness to any unauthorized animal. Tenant is responsible and liable for any damage or required cleaning to the Property caused by any unauthorized animal and for all costs Landlord may incur in removing or causing any unauthorized animal to be removed. 19. WATERBEDS. THERE WILL BE NO WATERBEDS, unless authorized by a separate written Waterbed Addendum to this Residential Lease Agreement. 20. QUIET ENJOYMENT. Tenant, upon payment of all of the sums referred to herein as being payable by Tenant and Tenant's performance of all Tenant's agreements contained herein and Tenant's observance of all rules and regulations, shall and may peacefully and quietly have, hold and enjoy said Premises for the term hereof. 21. INDEMNIFICATION. Landlord shall not be liable for any damage or injury of or to the Tenant, Tenant's family, guests, invitees, agents or employees or to any person entering the Premises or the building of which the Premises are a part or to goods or equipment, or in the structure or equipment of the structure of which the Premises are a part, and Tenant hereby agrees to indemnify, defend and hold Landlord harmless from any and all claims or assertions of every kind and nature. 22. DEFAULT. If Landlord breaches this Lease, Tenant may seek any relief provided by law. lfTenant fails to comply with any of the material provisions of this Minnesota Lease Agreement, other than the covenant to pay rent, or of any present rules and regulations or any that may be hereafter prescribed by Landlord. or materially fails to comply with any duties imposed on Tenant by statute, within seven (7) days after delivery of written notice by Landlord specifying the non-compliance and indicating the intention of Landlord to terminate the Lease by reason thereof, Landlord may terminate this Minnesota Lease Agreement. If Tenant fails to pay rent when due and the default continues for seven (7) days thereafter, Landlord may, at Landlord's option, declare the entire balance of rent payable hereunder to be immediately due and payable and may exercise any and all rights and remedies available to Landlord at law or in equity or may immediately terminate this Minnesota Lease Agreement. 23. ABANDONMENT. If at any time during the term of this Minnesota Lease Agreement Tenant abandons the Premises or any part thereof, Landlord may, at Landlord's option, obtain possession of the Premises in the manner provided by law, and without becoming liable to Tenant for damages or for any payment of any kind whatever. Landlord may, at Landlord's discretion, as agent for Tenant, relent the Premises, or any part thereof, for the whole or any part thereof, for the whole or any part of the then unexpired term, and may receive and collect all rent payable by virtue of such reletting, and, at Landlord's option, hold Tenant liable for any difference between the rent that would have been payable under this Minnesota Lease Agreement during the balance of the unexpired term, if this Minnesota Lease Agreement had continued in force, and the net rent for such period realized by Landlord by means of such re—renting. If Landlord's right of reentry is exercised following abandonment of the Premises by Tenant, then Landlord shall consider any personal property belonging to Tenant and left on the Premises to also have been abandoned, in which case Landlord may dispose of all such personal property in any manner Landlord shall deem proper and Landlord is hereby relieved of all liability for doing so. 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM 24. ATTORNEYS' FEES. Should it become necessary for Landlord to employ an attorney to enforce any of the conditions or covenants hereof. including the collection of rentals or gaining possession of the Premises, Tenant agrees to pay all expenses so incurred, including a reasonable attorneys' fee. 25. RECORDING 0F MINNESOTA LEASE AGREEMENT. Tenant shall not record this Minnesota Lease Agreement on the Public Records of any public office. In the event that Tenant shall record this Minnesota Lease Agreement, this Minnesota Lease Agreement shall, at Landlord's option, terminate immediately and Landlord shall be entitled to all rights and remedies that it has at law or in equity. 26. GOVERNING LAW. This Minnesota Lease Agreement shall be governed, construed and interpreted by, through and under the Laws of the State of Minnesota. 27. SEVERABILITY. If any provision of this Minnesota Lease Agreement or the application thereof shall, for any reason and to any extent, be invalid or unenforceable, neither the remainder of this Minnesota Lease 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. 28. BINDING EFFECT. The covenants, obligations and conditions herein contained shall be binding on and inure to the benefit of the heirs, legal representatives, and assigns of the parties hereto. 29. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience of reference only and they are not intended to have any effect whatsoever in determining the rights or obligations of the Landlord or Tenant. 30. CONSTRUCTION. The pronouns used herein shall include, where appropriate, either gender or both, singular and plural. 3'1. NON-WAIVER. No delay, indulgence, waiver, non-enforcement, election or non-election by Landlord under this Minnesota Lease Agreement will be deemed to be a waiver of any other breach by Tenant, nor shall it affect Tenant's duties, obligations, and liabilities hereunder. 32. MODIFICATION. The parties hereby-agree that this document contains the entire agreement between the parties and this Minnesota Lease Agreement shall not be modified, changed, altered or amended in any way except through a written amendment signed by all of the parties hereto. 33. NOTICE. Any notice required or permitted under this Lease or under state law shall be delivered to Tenant at the Property address, and to Landlord at the following address: 34. LEAD-BASED PAINT DISCLOSURE. lf the premises were constructed prior to 1978, Tenant acknowledges receipt of the form entitled "LEAD—BASED PAINT DISCLOSURE" which contains disclosure of information on lead—based paint and/or lead—based paint hazards. 35. RIGHT OF RE-ENTRY. Upon the occurrence of a Default, Landlord may elect to terminate this Lease, or, without terminating this Lease, terminate Tenants right to possession of the Premises. Upon any such termination, Tenant shall immediately surrender and vacate the Premises and deliver possession thereof to Landlord. Tenant grants to Landlord the right to enter and repossess the Premises and to expel Tenant and any others who may be occupying the Premises and to remove any and all property therefrom, without being deemed in any manner guilty of trespass and without relinquishing Landlords rights to Rent or any other right given to Landlord hereunder or by operation of law. 7 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM Tenant Handbook is available to you at: https:/lwww.aq.state.mn.us/Consumer/Handbooks/LT/default.asp As to Landlord this 77 day of M of 'ALA , 20 Q3. LANDLORDr/'fl:/ :7 / ' /, ' Sign: "/ Print: HEALING HOME LLC 651—760-3236 Date: '9' '2 Z As to Tenant, this day of , 20 TENANT: Sigmi/Z/iyCZP/ 2%":2 Print: //Wo/A /? fl CCm/I/ Date: I "Mfg/7 / 20 fl 3 TENANT: Sign: Print: Date: 8: 19AV-CV-24-1626 Filed in District Court State of Minnesota 6/20/2024 3:01 PM 30-Day Notice Date: April 25th, 2024 Tenant's Name: Timothy McCoy Address of Rental Unit: 200 3rd Ave. S. Unit #1B South St. Paul, MN 55075 | am writing you this notice that your lease dated on March 7th, 2023, by and between Healing Home LLC will be terminated on the 31st day of May 2024. This is your 30-day notice, we are not renewing your month to month lease for June. It is very important that you remove all your personal items by this time, so we have a chance to clean the apartment before a new tenant moves in. You are responsible for returning the apartment to the same or better condition than when you moved in. If you do not, you will be charged for any damages beyond regular use of the premises. Your itemized security deposit will be returned to you on or before the 215' of the month following your departure. The most common charges incurred by departing tenants are: 1) Failure to clean. You should vacuum the carpet, sweep and mop all floors, clean bathrooms and kitchens. 2) Failure to move everything. Anything you leave behind will be charged against your security deposit for disposal. This includes vehicles, household items and garage items. 3) Damages beyond wear and tear. 4) Failure to return keys, etc. 5) Failure to pay all rent, fees, etc. Please contact me should have any questions. Thank you. Hedi/rig; Healing Home LLC Owner