Motion for Writ in Citi-Minneapolis Partners V, LP vs Alice Kpogba, Allen Kpogba, John Doe, Mary Roe| Trellis.Law

On June 24, 2024 a Complaint-Civil Party: Attorney PERRON, DONALD ANDREW Index #1 was filed involving a dispute between Citi-Minneapolis Partners V, Lp, and Kpogba, Alice, Kpogba, Allen, for Eviction (UD) in the District Court of Anoka County.

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02-CV-24-3555
Filed in District Court
State of Minnesota
6/24/2024 10:43 AM

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF ANOKA TENTH JUDICIAL DISTRICT

____________________________ Case Type: Eviction

Citi-Minneapolis Partners V, LP

Plaintiff

v. EVICTION COMPLAINT

Alice Kpogba, Allen Kpogba,
John Doe, Mary Roe

Defendant
_____________________________

Donald Perron, attorney for Plaintiff, states and declares as follows:

1. Plaintiff Citi-Minneapolis Partners V, LP is a Limited Liability Company, with its registered
agent address at 1010 N. Dale St., St. Paul, MN 55117. Plaintiff is owner of the premises in
question.

2. Defendant(s) Alice Kpogba and Allen Kpogba is a/are Minnesota resident(s) who leased, by
written agreement, the premises at 9800 Redwood St. N.W., Unit #305, Coon Rapids, Minnesota
55433, Anoka 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 $1,319.00
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 $824.52 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
02-CV-24-3555
Filed in District Court
State of Minnesota
6/24/2024 10:43 AM

become due during the pendency of this action. The Defendant(s) is/are still in possession of the
premises.

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 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 $298, convenience fee of $5.00, and process service fee of $75.00 for
total statutory costs of $378.00 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 6-24-24 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
02-CV-24-3555
Filed in District Court
State of Minnesota
6/24/2024 10:43 AM
APARTMENT LEASE CONTRACT

Date of Lease Contract: January 16, 2024
(when the Lease Contract is filled out) This is a binding document. Read carefully before signing.

Moving In — General Information
1. PARTIES. This Lease Contract (sometimes referred to as the 3. LEASE TERM. The initial term of the Lease Contract begins on
“lease”) is between you, the resident(s) (list all people signing the the
1st day of ,
February 2024 , and ends
Lease Contract): at 11:59 pm the
31st day of ,
January 2025 .
This Lease Contract will automatically renew month-to-month
Alice Kpogba, Allen Kpogba
unless either party gives at least
60 days written notice of

termination or intent to move-out as required by paragraph 51

(Move-Out Notice). If the number of days isn’t filled in, at least

30 days notice is required. At least 15 days before this lease

automatically renews, we will send you notice of automatic

renewal as required by statute.

4. RENT AND CHARGES. Unless the parties agree in writing
otherwise, you will pay $
1319.00 per month for rent,
payable in advance and without demand:

 at the on-site manager’s office, or
and us the owner: Citi-Minneapolis Partners V X at our online payment site, or

 at
X Electronic Money Order Location

(name of apartment community or title holder). You’ve agreed to Disclosure is also made that you will be responsible for payment
rent Apartment No. at ,
305 9800 of the following non-optional fees:
Redwood St NW # 305
(street address) in
Coon Rapids (city),
Minnesota,
55433 (zip code) (the “apartment”
or the “premises”) for use as a private residence only. The terms As such, the Total Monthly Payment will be $ .
“you” and “your” refer to all residents listed above. The terms
“we,” “us,” and “our” refer to the owner listed above (or any of Prorated rent of $ is due for the remainder of [check
owner’s successors’ in interest or assigns). Written or electronic one]: 
X 1st month or  2nd month, on ,
notice to or from our managers constitutes notice to or from us. If . Any additional expenses attributable to the online
anyone else has guaranteed performance of this Lease Contract, a payment of rent will be disclosed to you by us.
separate Lease Contract Guaranty for each guarantor is attached. If the lease term ends on a date before the last day of the final
The person authorized to manage the apartment is: month, the amount of rent to be paid for the final month owed will
be prorated at the average daily rate for that month.
American Mgmt Services Central
Name Prorated rent of $ is due for the remainder of last
month, if applicable, on , .
9787 Palm St NW
Otherwise, you must pay your rent on or before the 1st day of
Street Address each month (due date) with no grace period. Cash is unacceptable
without our prior written permission. Unless authorized
Coon Rapids, MN 55433 by Minnesota law, you agree that rent will not be offset or
City, State, Zip Code withheld. We may, at our option, and upon advance notice to
The owner or agent authorized to accept service of process and you, require at any time that you pay all rent and other sums in
receive and give receipts for notices is: cash, certified or cashier’s check, money order, or one monthly
check rather than multiple checks. At our discretion, we may
Wellington Ridge convert any and all checks via the Automated Clearing House
Name
(ACH) system for the purposes of collecting payment. Rent is
9787 Palm St NW not considered accepted if the payment/ACH is rejected, does
not clear, or is stopped for any reason. If you don’t pay all rent
Street Address on or before the
4th day of the month, you’ll pay a late
charge. Your late charge will be (check one):  a flat rate of
Coon Rapids, MN 55433
$
102.00 or  X %
8 of your total rent due. The
City, State, Zip Code
total amount of your late charges shall not exceed eight percent
2. OCCUPANTS. The apartment will be occupied only by you and (8%) of your monthly rent payment. You’ll also pay a charge of
(list all other occupants not signing the Lease Contract): $
35.00 for each returned check or rejected electronic
payment, plus a late charge. If you don’t pay rent on time, you’ll
be delinquent and all remedies under this Lease Contract will be
authorized. All payment obligations under this Lease Contract
shall constitute rent under this Lease Contract.

5. SECURITY DEPOSIT. Unless the parties otherwise agree in a
separate addendum document, the total security deposit at the
time of execution of this Lease Contract for all residents in the
apartment is $ ,
300.00 due on or before the date this
Lease Contract is signed.

In compliance with Minnesota law, your security deposit

will bear simple interest. Interest will be included as part of

the security deposit. Within 21 days after termination of your
No one else may occupy the apartment. Persons not listed above residency and receipt of your mailing address or written delivery
must not stay in the apartment for more than 3 instructions, we will return the deposit to you, with interest, or
consecutive days without our prior written consent, and no more furnish to you a written statement specifying the reasons for the
than twice that many days in any one month. If the previous space withholding of the deposit or any portion thereof. You may not
isn’t filled in, two days per month is the limit. withhold payment of any portion of any rent on the grounds that
the security deposit should serve as payment of the rent.

Document digitally signed using RentCafe eSignature services. Document ID: 40276176
02-CV-24-3555
Filed in District Court
State of Minnesota
6. KEYS. You will be provided 2 apartment key(s), 1 In addition, we urge all residents, and particularly those residing
6/24/2024 10:43 AM
mailbox key(s), FOB(s), and/or 2 other access in coastal areas, areas near rivers, and areas prone to flooding, to
device(s) for access to the building and amenities at no additional obtain flood insurance. Renter’s insurance may not cover damage
cost at move-in. If the key, FOB, or other access device is lost or to your property due to flooding. A flood insurance resource which
becomes damaged during your tenancy or is not returned or is may be available includes the National Flood Insurance Program
returned damaged when you move out, you will be responsible for managed by the Federal Emergency Management Agency (FEMA).
the costs for the replacement and/or repair of the same. We  require  X do not require you to get your own insurance
7. UTILITIES. We’ll pay for the following items, if checked: for losses to your personal property or injuries due to theft, fire,
 water  X gas  electricity  masterantenna water damage, pipe leaks and the like. If no box is checked, renter’s
 wastewater  X trash  cable TV insurance is not required.
 other Additionally, you are [check one]  X required to purchase
personal liability insurance  not required to purchase
You’ll pay for all other utilities, related deposits, and any charges,
personal liability insurance. If no box is checked, personal
fees, or services on such utilities. You must not allow utilities to be
liability insurance is not required. If required, failure to maintain
disconnected—including disconnection for not paying your bills—
until the lease term or renewal period ends. Cable channels that personal liability insurance throughout your tenancy, including
any renewal periods and/or lease extensions, is an incurable
are provided may be changed during the lease term if the change
breach of this Lease Contract and may result in the termination
applies to all residents. Utilities may be used only for normal
of tenancy and eviction and/or any other remedies as provided by
household purposes and must not be wasted. If your electricity
is ever interrupted, you must use only battery-operated lighting. this Lease Contract or state law.
If any utilities are submetered for the apartment, or prorated by 9. LOCKS AND LATCHES. Keyed lock(s) will be rekeyed after the
an allocation formula, we will attach an addendum to this Lease prior resident moves out. The rekeying will be done before you
Contract in compliance with state agency rules or city ordinance. move into your apartment.
Pursuant to Minnesota Statute 504B.215 Subd. 2a. upon your
request, we shall provide a copy of the actual utility bill for the You may at any time ask us to change or rekey locks or latches
community along with each apportioned utility bill. during the Lease Term. We must comply with those requests, but
you must pay for them, unless otherwise provided by law.
8. INSURANCE. We do not maintain insurance to cover your Payment for Rekeying, Repairs, Etc. You must pay for all repairs
personal property or personal injury. We are not responsible to or replacements to devices arising from the willful, malicious, or
any resident, guest, or occupant for damage or loss of personal irresponsible conduct by you or your occupants, or guests during
property or personal injury from (including but not limited your occupancy. You may be required to pay in advance if we
to) fire, smoke, rain, flood, water and pipe leaks, hail, ice, snow, notify you within a reasonable time after your request that you
lightning, wind, explosions, earthquake, interruption of utilities, are more than 30 days delinquent in reimbursing us for repairing
theft, hurricane, negligence of other residents, occupants, or or replacing a device which was misused or damaged by you, your
invited/uninvited guests or vandalism unless otherwise required guest or an occupant; or if you have requested that we repair or
by law. change or rekey the same device during the 30 days preceding
your request and we have complied with your request. Otherwise,
you must pay immediately after the work is completed.

Special Provisions and “What If” Clauses
10. SPECIAL PROVISIONS. The following special provisions and any due to the willful, malicious, or irresponsible conduct by you or
addenda or written rules furnished to you at or before signing your guests or occupants. We may require payment at any time,
will become a part of this Lease Contract and will supersede any including advance payment of repairs for which you’re liable.
conflicting provisions of this printed lease form. Delay in demanding sums you owe is not a waiver.
See Additional Special Provisions 13. PROPERTY LEFT IN APARTMENT. Under Minnesota law,

we may remove and/or store all property remaining in the
apartment or in common areas (including any vehicles you or
any occupant or guest owns or uses) if you are judicially evicted
or if you surrender or abandon the apartment (see definitions in
paragraph 56 (Deposit Return,Surrender, and Abandonment)).
See any additional special provisions.
We will store and care for property removed under this section.
11. EARLY MOVE-OUT. You’ll be liable to us for a reletting charge of We may sell or otherwise dispose of the property 28 days after you
have abandoned the apartment, and we may apply the proceeds
$
1319.00 (not to exceed 100% of the highest monthly rent
during the lease term) if you: of such sale to the removal, care and storage costs and expenses
according to state statute. You will be notified of the sale at least
(1) fail to give written move-out notice as required in paragraph 14 days prior to the sale by personal service or written notice sent
51 (Move-Out Notice); or to your last known address by certified mail.
(2) move out without paying rent in full for the entire lease term
or renewal period; or 14. FAILING TO PAY FIRST MONTH’S RENT. If you don’t pay the
(3) move out at our demand because of your default. first month’s rent when or before the Lease Contract begins, and
The reletting charge is not a cancellation fee and does not release subject to our duty to mitigate our damages, we may end your
you from your obligations under this Lease Contract. right of occupancy and recover damages, future rent, reletting
charges, attorney’s fees, court costs, and other lawful charges.
Not a Release. The reletting charge is not a lease cancellation fee Our rights and remedies under paragraphs 11 (Early Move-Out)
or buyout fee. It is an agreed-to liquidated amount covering only and 34 (Default by Resident) apply to acceleration under this
part of our damages; that is, our time, effort, and expense in finding paragraph.
and processing a replacement. These damages are uncertain and
difficult to ascertain—particularly those relating to inconvenience, 15. RENT INCREASES AND LEASE CONTRACT CHANGES. No rent
paperwork, advertising, showing apartments, utilities for showing, increases or Lease Contract changes are allowed before the
checking prospects, office overhead, marketing costs, and locator- initial Lease Contract term ends, except for changes allowed by
service fees. You agree that the reletting charge is a reasonable any special provisions in paragraph 10 (Special Provisions), by
estimate of such damages and that the charge is due whether or not a written addendum or amendment signed by you and us, or by
our reletting attempts succeed. If no amount is stipulated, you must reasonable changes of apartment rules allowed under paragraph
pay our actual reletting costs so far as they can be determined. The 19 (Community Policies or Rules). If, at least 5 days before the
reletting charge does not release you from continued liability for: advance notice deadline referred to in paragraph 3 (Lease Term),
future or past-due rent; charges for cleaning, repairing, repainting, we give you written notice of rent increases or lease changes
or unreturned keys; or other sums due. effective when the lease term or renewal period ends, this Lease
Contract will automatically continue month-to-month with the
12. REIMBURSEMENT. We agree to make the premises and all increased rent or lease changes. The new modified Lease Contract
common areas fit for the use intended by the parties and to keep will begin on the date stated in the notice (without necessity of
the premises in a reasonable repair during the term of this Lease your signature) unless you give us written move- out notice under
Contract. However, you must promptly reimburse us for repairs paragraph 51 (Move-Out Notice).

Document digitally signed using RentCafe eSignature services. Document ID: 40276176
02-CV-24-3555
Filed in District Court
State of Minnesota
16. DELAY OF OCCUPANCY. If occupancy is or will be delayed for receives written notice, but not later. The readiness date10:43
6/24/2024 is AM
construction, repairs, cleaning, or a previous resident’s holding considered the new initial term as set forth in Paragraph
over, we’re not responsible for the delay. The Lease Contract 3 (Lease Term) for all purposes. This new date may not be
will remain in force subject to: (1) abatement of rent on a daily moved to an earlier date unless we and you agree.
basis during delay; and (2) your right to terminate as set forth
below. Termination notice must be in writing. After termination, 17. AD VALOREM TAXES/FEES AND CHARGES - ADDITIONAL
you are entitled only to refund of deposit(s) and any rent paid. RENT. Unless otherwise prohibited by law, if, during the term of
Rent abatement or lease termination does not apply if delay is this Agreement, any locality, city, state, or Federal Government
for cleaning or repairs that don’t prevent you from occupying the imposes upon Us, any fee, charge, or tax, which is related to or
apartment. charged by the number of occupants, or by the apartment unit
itself, such that we are charged a fee, charge, or tax, based upon
If there is a delay and we haven’t given notice of delay as set forth
your use or occupancy of the apartment, we may add this charge
immediately below, you may terminate up to the date when the as Additional Rent, during the term of the Lease Contract, with
apartment is ready for occupancy, but not later. thirty (30) days advance written notice to you. After this written
(1) If we give written notice to any of you when or after the notice (the amount or approximate amount of the charge, will be
initial term as set forth in Paragraph 3 (Lease Term)—and included), you agree to pay, as Additional Rent, the amount of the
the notice states that occupancy has been delayed because charge, tax or fee imposed upon us, as a result of your occupancy.
of construction or a previous resident’s holding over, and As examples, these charges can include, but are not limited to: any
that the apartment will be ready on a specific date—you may charges we receive for any zoning violation, sound, noise or litter
terminate your tenancy within 3 days of your receiving the charge; any charge under any nuisance or chronic nuisance type
notice, but not later. statute, 911 or other life safety, per person, or per unit charge or
(2) If we give written notice to any of you before the initial term tax and any utility bill unpaid by you, which is then assessed to us
for payment.
as set forth in Paragraph 3 (Lease Term) and the notice states
that construction delay is expected and that the apartment 18. DISCLOSURE RIGHTS. We will only disclose information
will be ready for you to occupy on a specific date, you may concerning you or your rental history if authorized by applicable
terminate your tenancy within 7 days after any of you law.

While You’re Living in the Apartment
19. COMMUNITY POLICIES OR RULES. You and all guests and of the landlord (including our agents and employees) or other
occupants must comply with any written apartment rules tenants and their guests in or near the apartment community;
and community policies, including instructions for care of our disrupting our business operations; manufacturing, delivering,
property. To the extent they are not inconsistent with this Lease possessing with intent to deliver, or otherwise possessing a
Contract or Minnesota law, our rules are considered part of controlled substance or drug paraphernalia; engaging in or
this Lease Contract. Upon advance notice and compliance with threatening violence; possessing a weapon prohibited by state law;
Minnesota law, we may make reasonable changes to the said discharging a firearm in the apartment community; displaying or
written rules. possessing a gun, knife, or other weapon in the common area in
a way that may alarm others; storing anything in closets having
20. LIMITATIONS ON CONDUCT. The apartment and other areas gas appliances; tampering with utilities or telecommunications;
reserved for your private use must be kept clean and free of bringing hazardous materials into the apartment community; or
trash, garbage, and other debris. Trash must be disposed of at injuring our reputation by making bad faith allegations against
least weekly in appropriate receptacles in accordance with local us to others.
ordinances. Passageways may be used only for entry or exit.
You agree to keep all passageways and common areas free of 22. PARKING. We may regulate the time, manner, and place of
obstructions such as trash, storage items, and all forms of personal parking cars, trucks, motorcycles, bicycles, boats, trailers, and
property. No person shall ride or allow bikes, skateboards, or recreational vehicles by anyone. We may have unauthorized or
other similar objects in the passageways. Any swimming pools, illegally parked vehicles towed under an appropriate statute.
saunas, spas, tanning beds, exercise rooms, storerooms, laundry A vehicle is unauthorized or illegally parked in the apartment
rooms, and similar areas must be used with care in accordance community if it:
with apartment rules and posted signs. Glass containers are (1) has a flat tire or other condition rendering it inoperable; or
prohibited in all common areas. You, your occupants, or guests (2) is on jacks, blocks or has wheel(s) missing; or
may not anywhere in the apartment community: use candles or (3) has no current license plate or no current registration and/or
use kerosene lamps or kerosene heaters without our prior written inspection sticker; or
approval; cook on balconies or outside; or solicit business or (4) takes up more than one parking space; or
contributions. Conducting any kind of business (including child (5) belongs to a resident or occupant who has surrendered or
care services) in your apartment or in the apartment community abandoned the apartment; or
is prohibited—except that any lawful business conducted “at (6) is parked in a marked handicap space without the legally
home” by computer, mail, or telephone is permissible if customers, required handicap insignia; or
clients, patients, or other business associates do not come to your (7) is parked in space marked for manager, staff, or guest at the
apartment for business purposes. We may regulate: (1) the use office; or
of patios, balconies, and porches; (2) the conduct of furniture (8) blocks another vehicle from exiting; or
movers and delivery persons; and (3) recreational activities in (9) is parked in a fire lane or designated “no parking” area; or
common areas. You’ll be liable to us for damage caused by you or (10) is parked in a space marked for other resident(s) or unit(s); or
any guests or occupants. (11) is parked on the grass, sidewalk, or patio; or
We may exclude from the apartment community guests or others (12) blocks garbage trucks from access to a dumpster; or
who, in our judgment, have been violating the law, violating (13) belongs to a resident and is parked in a visitor or retail
this Lease Contract or any apartment rules, or disturbing other parking space.
residents, neighbors, visitors, or owner representatives. We may
also exclude from any outside area or common area a person who 23. RELEASE OF RESIDENT. Unless you’re entitled to terminate
refuses to show photo identification or refuses to identify himself your tenancy under paragraphs 10 (Special Provisions), 16
or herself as a resident, occupant, or guest of a specific resident in (Delay of Occupancy), 32 (Responsibilities of Owner), 44 (Right of
the community. Victims of Domestic Abuse to Terminate Tenancy), or 52 (Move-
Out Procedures); or unless, upon your death, your personal
You agree to notify us if you or any occupants are convicted of any
representative gives statutory notice pursuant to paragraph
felony, or misdemeanor involving a controlled substance, violence 43 (Termination of Lease Upon Death of Resident), you or your
to another person or destruction of property. You also agree to heirs won’t be released from this Lease Contract for any reason
notify us if you or any occupant registers as a sex offender in including, but not limited to, voluntary or involuntary school
any state. Informing us of criminal convictions or sex offender
withdrawal or transfer, voluntary or involuntary job transfer,
registry does not waive our right to evict you. marriage, separation, divorce, reconciliation, loss of co-residents,
loss of employment or bad health.
21. PROHIBITED CONDUCT. You, your occupants or guests, or
the guests of any occupants, may not engage in the following
activities: behaving in a loud or obnoxious manner; disturbing
or threatening the rights, comfort, health, safety, or convenience

Document digitally signed using RentCafe eSignature services. Document ID: 40276176
02-CV-24-3555
Filed in District Court
State of Minnesota
24. MILITARY PERSONNEL CLAUSE. All parties to this Lease phone or TV-cable outlets, alarm systems, or lock changes,
6/24/2024 10:43 AM
Contract agree to comply with any federal law, including, but not additions, or rekeying is permitted unless statutorily allowed
limited to the Service Member’s Civil Relief Act, or any applicable or we’ve consented in writing. You may install a satellite dish
state law(s), if you are seeking to terminate this Lease Contract or antenna provided you sign our satellite dish or antenna lease
and/or subsequent renewals and/or Lease Contract extensions addendum which complies with reasonable restrictions allowed
under the rights granted by such laws. by federal law. You agree not to alter, damage, or remove our
property, including alarm systems, smoke detectors, furniture,
25. RESIDENT SAFETY AND PROPERTY LOSS. You and all occupants telephone and cable TV wiring, screens, locks, and access control
and guests must exercise due care for your own and others’ safety devices. When you move in, we’ll supply light bulbs for fixtures
and security, especially in the use of smoke detectors, carbon we furnish, including exterior fixtures operated from inside the
monoxide detectors, keyed deadbolt locks, keyless bolting devices, apartment; after that, you’ll replace them at your expense with
window latches, and access control devices. bulbs of the same type and wattage. Your improvements to the
Smoke Detectors/Carbon Monoxide Detectors. We’ll furnish apartment (whether or not we consent) become ours unless we
smoke detectors and carbon monoxide detectors only if required agree otherwise in writing.
by statute, and we’ll test them and provide working batteries
27. REQUESTS, REPAIRS, AND MALFUNCTIONS. IF YOU OR
when you first take possession. After that, you must test the
ANY OCCUPANT NEEDS TO SEND A NOTICE OR REQUEST—
smoke detectors and the carbon monoxide detectors on a regular
FOR EXAMPLE, FOR REPAIRS, INSTALLATIONS, SERVICES, OR
basis, and pay for and replace batteries as needed, unless the law
SECURITY RELATED MATTERS—IT MUST BE SUBMITTED
provides otherwise. We may replace dead or missing batteries at
your expense, without prior notice to you. You must immediately THROUGH EITHER THE ONLINE RESIDENT/MAINTENANCE
PORTAL, OR SIGNED AND IN WRITING AND DELIVERED TO OUR
report smoke-detector malfunctions to us. Neither you nor others
DESIGNATED REPRESENTATIVE (except in case of fire, smoke,
may disable neither the smoke detectors nor the carbon monoxide
gas, explosion, overflowing sewage, uncontrollable running
detectors. If you damage or disable the smoke detector or carbon
water, electrical shorts, or crime in progress). Our written notes
monoxide detector, or remove a battery without replacing it with
on your oral request do not constitute a written request from you.
a working battery, you may be liable to us under state statute for
$100 plus one month’s rent, actual damages, and attorney’s fees. Our complying with or responding to any oral request regarding
If you disable or damage the smoke detector or carbon monoxide security or non-security matters doesn’t waive the strict
detector, or fail to replace a dead battery or report malfunctions to requirement for written notices under this Lease Contract. You
us, you will be liable to us and others for any loss, damage, or fines must promptly notify us in writing of: water leaks; electrical
from fire, smoke, or water. problems; malfunctioning lights; broken or missing locks or
Casualty Loss. We’re not liable to any resident, guest, or occupant latches; and other conditions that pose a hazard to property,
health, or safety. We may change or install utility lines or
for personal injury or damage or loss of personal property from
equipment serving the apartment if the work is done reasonably
any cause, including but not limited to: fire, smoke, rain, flood,
water and pipe leaks, hail, ice, snow, lightning, wind, explosions, without substantially increasing your utility costs. We may
turn off equipment and interrupt utilities as needed to avoid
earthquake, interruption of utilities, theft, or vandalism unless
property damage or to perform work. If utilities malfunction or
otherwise required by law. We have no duty to remove any ice,
are damaged by fire, water, or similar cause, you must notify our
sleet, or snow but may remove any amount with or without notice.
representative immediately. Air conditioning problems are not
During freezing weather, you must ensure that the temperature

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Document for Citi-Minneapolis Partners V, LP vs Alice Kpogba, Allen Kpogba, John Doe, Mary Roe

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