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19AV-CV-24-1650
Filed in District Court
State of Minnesota
6/23/2024 8:35 PM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF DAKOTA FIRST JUDICIAL DISTRICT
____________________________ Case Type: Eviction
Holiday Acres Apartments, Partnership
Plaintiff
v. EVICTION COMPLAINT
Megan Redmond, John Doe, Mary Roe
Defendant
_____________________________
Donald Perron, attorney for Plaintiff, states and declares as follows:
1. Plaintiff Holiday Acres Apartments, Partnership is a Minnesota Partnership with its
office address at 37 E. Isabel St., St. Paul, MN 55107. Plaintiff is owner of the rental premises
in question.
2. Defendant(s) Megan Redmond is a/ are Minnesota resident(s) who leased, by written
agreement, the premises at 1812 Oakdale Ave. #209 and garage B5, West St. Paul, MN 55118,
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 non-payment of rent. Defendant(s) owe(s) rent of
$1,350.00 per month due on the first day of each month. Defendant(s) owe(s) past due rent and
other monies owed under the lease totaling $1,458.00 through June 2024, plus the costs of this
action including but not limited to the costs and disbursements of this action set forth below,
plus any amounts that become due during the pendency of this action. The Defendant(s) is/are
still in possession of the premises.
19AV-CV-24-1650
Filed in District Court
State of Minnesota
6/23/2024 8:35 PM
5. A detailed itemized accounting is attached hereto and made a part hereof.
6. The written notice required by Minn. Stat. §504B.321 Subd. 1a was timely and properly
delivered and is attached hereto and made a part hereof.
7. 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.
8. 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 6-21-24 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-24-1650
Filed in District Court
State of Minnesota
6/23/2024 8:35 PM
Community Code:fl
MI CONTINENT Mid Continent
Mano ement .
Management Corporation, at the address on this
lease, is an agent
37 East Isdibel Street authorized to accept service of
I St. Paul, MN
55107 process and receive and give receipts for notice
Phone 55 291.0111 I Fax 651.291.1402
and demands'
LEASE AGREEMENT
STUDIO NEW x .12 MONTH LEASE
1 BEDROOM RENEWAL
x 2 BEDROOM
6_ MONTH LEASE
ROOMMATE CHANGE 2 MONTH LEASE (MONTH
3 BEDROOM x -TO-MONTH)
REVISED: Garage Add
OTHER TERM LEASE:
RESIDENTS: (List nam and date of birth for
all persons who will live in the
unit.)
NAME Megan Red and
NAME
DATE OF BIRTH 1/16/1983
Legend RedTIIond
DATE OF BIRTH 1/27/2012
NAME Malachi Redinond
NAME
DATE OF BIRTH 9/4/2013
I
DATE OF BIRTH
NAME
NAME
DATE OF BIRTH
DATE OF BIRTH
PROPERTY ADDRESS AND UNIT # 1812 Oakdale Avenue #209, West St
Paul, MN 55118
LEASE START DATE July 10, 2023 LEASE END DATE 12:00 PM on July_31, 2024
NOTICE PERIOD _
Two 2 II calendar months.
FIRST MONTH S PRORATED RENT
(ifa plicabie) MONTHLY RENT
07/10/2023 . 07/31/2023 03/01/2023 . 07/31/2024
UNIT RENT $ UNIT RENT $ 1300.00
SHORT TERM FEE' 3
SHORT TERM FEE $
GARAGE RENT 1: 3-5 $35.48 GARAGE RENT #B-S $50.00
STORAGE LOCKER s STORAGE LOCKER 3
MONTHLY PET FEE $ .
MoNTHLY PET FEE $
TOTAL $35.43 TOTAL 3 1350.00
PERFORMANCE new IT
3 500.00 (on acct.)
PET DEPOSIT
$ 0.00
PET FEE (NON-REFUN BLE)
$ 0.00
LAST MONTH'S RENT ACCOUNT 39
OTHER:
$
OTHER: I
$
UTILITIES INCLUDED IN ENT
(check all that apply):
N2 ELECTRICI
Ye_s_ HEAT Yes WATER & SEWER
Yes RUBBISH RE OVAL/RECYCLING NO COOKING GAS NO OTHER:
19AV-CV-24-1650
Filed in District Court
State of Minnesota
6/23/2024 8:35 PM
MISCELLANEOUS
30. Agreement is Sub eet to
Mortgage: Management may subject the
agree that the rights of olders of any Property to a mortgage or contract for deed.
present or future mortgage or contract for deed Residenfis)
Agreement. and Reside t(s) agree to will be superior to Resid
sign a statement to that effect upon reque This ent(s) rights under this
mortgage or cancel the ontract deed and terminate st. may permit the holder to foreclose the
Resident(s) Lease Agreement.
31. False or Misleadin Rental
Application: if Management determines that
the Rental Application otherwise are not true or any oral or written statements made
complete in any way, then Resident has violated by Resident(s) in
this Lease and may be evicted.
32. Building Rules an Attachme
nts Are Part of Lease; No Oral
Lease. if a term of any ttachment Agreements: Any attachment to this Lease is a
conflicts with any term of this part of this
Resident Handbook and Lease, the attachment term will be
Community Rules are a part of this Lease and controlling. Management's
at any time by giving R , Management may make reasonable chan
ldent(s) written notice. No oral agree
ments have been made. This Lease and its attac
ges in these rules
written agreements are e entire hments and any other
agreement between Resident and Mana
gement.
33. Move-In Specials: n the event
lease terms are not fulfilled
value of any other rental incentive or by Residenfls), any move-in special, conc
inducement, is due to Manageme in addition ession, or the fair market
attorneys' fees set forth erein. nt to any liquidated
damages, court costs, and
34. Attorney General's otice: Upon request, the
significant legal rights of owners and tenants of rentaAttor ney General's Office will provide you with a state
l dwelling units. For further ment and disclosure of the
State Capital St. Pau MN 55155
information, call or write: Attor
ney General's Office
,
(651) 296-6
196.
35. Notices: Resident
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19AV-CV-24-1650 Filed in District Court State of Minnesota 6/23/2024 8:35 PM STATE OF MINNESOTA DISTRICT COURT COUNTY OF DAKOTA FIRST JUDICIAL DISTRICT ____________________________ Case Type: Eviction Holiday Acres Apartments, Partnership Plaintiff v. EVICTION COMPLAINT Megan Redmond, John Doe, Mary Roe Defendant _____________________________ Donald Perron, attorney for Plaintiff, states and declares as follows: 1. Plaintiff Holiday Acres Apartments, Partnership is a Minnesota Partnership with its office address at 37 E. Isabel St., St. Paul, MN 55107. Plaintiff is owner of the rental premises in question. 2. Defendant(s) Megan Redmond is a/ are Minnesota resident(s) who leased, by written agreement, the premises at 1812 Oakdale Ave. #209 and garage B5, West St. Paul, MN 55118, 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 non-payment of rent. Defendant(s) owe(s) rent of $1,350.00 per month due on the first day of each month. Defendant(s) owe(s) past due rent and other monies owed under the lease totaling $1,458.00 through June 2024, plus the costs of this action including but not limited to the costs and disbursements of this action set forth below, plus any amounts that become due during the pendency of this action. The Defendant(s) is/are still in possession of the premises. 19AV-CV-24-1650 Filed in District Court State of Minnesota 6/23/2024 8:35 PM 5. A detailed itemized accounting is attached hereto and made a part hereof. 6. The written notice required by Minn. Stat. §504B.321 Subd. 1a was timely and properly delivered and is attached hereto and made a part hereof. 7. 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. 8. 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 6-21-24 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-24-1650 Filed in District Court State of Minnesota 6/23/2024 8:35 PM Community Code:fl MI CONTINENT Mid Continent Mano ement . Management Corporation, at the address on this lease, is an agent 37 East Isdibel Street authorized to accept service of I St. Paul, MN 55107 process and receive and give receipts for notice Phone 55 291.0111 I Fax 651.291.1402 and demands' LEASE AGREEMENT STUDIO NEW x .12 MONTH LEASE 1 BEDROOM RENEWAL x 2 BEDROOM 6_ MONTH LEASE ROOMMATE CHANGE 2 MONTH LEASE (MONTH 3 BEDROOM x -TO-MONTH) REVISED: Garage Add OTHER TERM LEASE: RESIDENTS: (List nam and date of birth for all persons who will live in the unit.) NAME Megan Red and NAME DATE OF BIRTH 1/16/1983 Legend RedTIIond DATE OF BIRTH 1/27/2012 NAME Malachi Redinond NAME DATE OF BIRTH 9/4/2013 I DATE OF BIRTH NAME NAME DATE OF BIRTH DATE OF BIRTH PROPERTY ADDRESS AND UNIT # 1812 Oakdale Avenue #209, West St Paul, MN 55118 LEASE START DATE July 10, 2023 LEASE END DATE 12:00 PM on July_31, 2024 NOTICE PERIOD _ Two 2 II calendar months. FIRST MONTH S PRORATED RENT (ifa plicabie) MONTHLY RENT 07/10/2023 . 07/31/2023 03/01/2023 . 07/31/2024 UNIT RENT $ UNIT RENT $ 1300.00 SHORT TERM FEE' 3 SHORT TERM FEE $ GARAGE RENT 1: 3-5 $35.48 GARAGE RENT #B-S $50.00 STORAGE LOCKER s STORAGE LOCKER 3 MONTHLY PET FEE $ . MoNTHLY PET FEE $ TOTAL $35.43 TOTAL 3 1350.00 PERFORMANCE new IT 3 500.00 (on acct.) PET DEPOSIT $ 0.00 PET FEE (NON-REFUN BLE) $ 0.00 LAST MONTH'S RENT ACCOUNT 39 OTHER: $ OTHER: I $ UTILITIES INCLUDED IN ENT (check all that apply): N2 ELECTRICI Ye_s_ HEAT Yes WATER & SEWER Yes RUBBISH RE OVAL/RECYCLING NO COOKING GAS NO OTHER: 19AV-CV-24-1650 Filed in District Court State of Minnesota 6/23/2024 8:35 PM MISCELLANEOUS 30. Agreement is Sub eet to Mortgage: Management may subject the agree that the rights of olders of any Property to a mortgage or contract for deed. present or future mortgage or contract for deed Residenfis) Agreement. and Reside t(s) agree to will be superior to Resid sign a statement to that effect upon reque This ent(s) rights under this mortgage or cancel the ontract deed and terminate st. may permit the holder to foreclose the Resident(s) Lease Agreement. 31. False or Misleadin Rental Application: if Management determines that the Rental Application otherwise are not true or any oral or written statements made complete in any way, then Resident has violated by Resident(s) in this Lease and may be evicted. 32. Building Rules an Attachme nts Are Part of Lease; No Oral Lease. if a term of any ttachment Agreements: Any attachment to this Lease is a conflicts with any term of this part of this Resident Handbook and Lease, the attachment term will be Community Rules are a part of this Lease and controlling. Management's at any time by giving R , Management may make reasonable chan ldent(s) written notice. No oral agree ments have been made. This Lease and its attac ges in these rules written agreements are e entire hments and any other agreement between Resident and Mana gement. 33. Move-In Specials: n the event lease terms are not fulfilled value of any other rental incentive or by Residenfls), any move-in special, conc inducement, is due to Manageme in addition ession, or the fair market attorneys' fees set forth erein. nt to any liquidated damages, court costs, and 34. Attorney General's otice: Upon request, the significant legal rights of owners and tenants of rentaAttor ney General's Office will provide you with a state l dwelling units. For further ment and disclosure of the State Capital St. Pau MN 55155 information, call or write: Attor ney General's Office , (651) 296-6 196. 35. Notices: Resident