Preview
19AV-CV-24-1701
Filed in District Court
State of Minnesota
6/26/2024 2:13 PM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF DAKOTA FIRST JUDICIAL DISTRICT
CASE TYPE: HOUSING
RRE Woods Holdings, LLC,
Plaintiff, COMPLAINT
vs.
Robert Hampton III (dob 9/17/1987),
John Doe, Jane Doe,
Defendant.
Parties
1. Plaintiff is RRE Woods Holdings, LLC. Plaintiff is a Landlord as that term is defined
in Minn. Stat. § 504B.001, Subd. 7.
2. Defendant is Robert Hampton III. Defendant is a Residential Tenant as that term is
defined in Minn. Stat. § 504B.001, Subd. 12.
The Lease
3. There is a written lease between the parties and it is attached to the Complaint as
Exhibit A.
4. The address of the property in the Lease is 14645 Portland Avenue South #211 and
Garage #C33, in the City of Burnsville, County of Dakota, State of Minnesota, Zip
Code 55306.
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 LIHTC program
or any other similar program.
Conditions Precedent
6. All necessary conditions precedent have been performed or have occurred.
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19AV-CV-24-1701
Filed in District Court
State of Minnesota
6/26/2024 2:13 PM
7. Plaintiff has complied with Minn. Stat. § 504B.181 by:
a. disclosing to tenant either in the rental agreement or otherwise in writing prior
to the beginning of the tenancy the name and address of: 1) the person authorized
to manage premises; and 2) an owner or agent authorized by owner to accept
service of process and receive and give receipts for notice and demands, AND
b. posting in a conspicuous place on the property a printed or typewritten notice
containing the above information in the lease, OR
c. the above information is known by or has been disclosed to the tenant not less
than 30 days before the filing of this action because of communications from
landlord.
Count 1: Eviction – Non-payment
8. A detailed, itemized accounting or statement listing the amounts owing is attached to
this Complaint as Exhibit B.
9. The written notice required by Minn. Stat. § 504B.321, Subd. 1a was properly
delivered. That notice is attached to this Complaint as Exhibit C.
10. In addition to the arrearages identified in the immediately preceding paragraphs,
pursuant to Minn. Stat. § 504B.291, prior to redeeming the tenancy and being restored
to possession, Defendant(s) may be required to pay to the landlord or bring to court
the amount of the rent that is in arrears, with interest, costs of the action, and an
attorney’s fee not to exceed $5, and by performing any other covenants of the lease –
including amounts that become due during the pendency of this action.
11. The total amount required to redeem the tenancy is $1,872.09 + $377.00 (costs of the
action – filing fee and service fee) for a total of $2,249.09, plus any additional
amounts, or other covenants of the lease which may become due during the pendency
of this action. The amount pled may not include all money owing under the lease.
12. Defendants’ military status is unknown.
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19AV-CV-24-1701
Filed in District Court
State of Minnesota
6/26/2024 2:13 PM
Request for Relief
1. Plaintiff seeks judgment against Defendant and an Order for possession of the property
and the issuance of an immediate Writ of Recovery.
2. Plaintiff seeks all allowable costs and disbursements of the action.
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.
Dated: June 26, 2024 HANBERY & TURNER, P.A.
/s/ Douglass E. Turner
Douglass E. Turner, #0279948
33 South 6th St. Suite 4160
Minneapolis, MN 55402
Tele: (612) 353-4388
EM: hnc@hnclaw.com
Attorney for Plaintiff
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19AV-CV-24-1701
Filed in District Court
State of Minnesota
6/26/2024 2:13 PM
APARTMENT LEASE CONTRACT NAA
mm wag," Sammy
Date of Lease Contract: A_ugust 30 , 2023
(when the Lease Contract is filled out) This is a binding document. Read carefully before signing.
Moving In
General lnformatidn' 1'
1. PARTIES. This Lease Contract [sometimes referred to as the 3. LEASE TERM. The Initial term of the Lease Contract begins on the
'lease") is between you, the
"
{5) (list all r
r
signing the ,' 22nd day of September 2023 and ends at
Lease Contract): 11:59 pm the let day 2024
Robert: H ton III This Lease Contract will automatically renew month-to-month
unless either party gives at leasti days written notice of
termination or intent to move-out as required by paragraph 51
(Move-Out Notice). lfthe number of days isn't filled in. at least 30
days notice is required. Atleast 15 days before this lease automatically
renews, we will send you notice ofautomatic renewal as required
by statute.
4. RENT AND CHARGES. Unless the parties agree in writing
otherwise, you will pays 1518 per month for rent.
payable in advance and without demand:
Cl at the on-site ma nager's office, or
a at our online payment site, or
a a: Wall: in Damn: flgfl
(name of apartment community or title holder). You've agreed to rent Prorated rent ofS for the remainder ofIcheck
Apartment No. at 45211 14645
Portland Avenue one]: lst month or D 2nd month, on Sebtembe 1
S . #211 2023 Any additional expenses attributable to the online
.
(street address) in payment of rent will be disclosed to you by us.
Burnsvil 1e (cig'),
Minnesota, 55306 {zip code) (the "apartment" or the Otherwise, you must pay your rent on or before the Ist day of each
"premises") for use as a private residence only. The terms "you" and month (due date) with no grace period. Cash Is unacceptable without
"your" refer to all residents listed above. The terms "we." "us," and our prior written permission. You must not withhold or offset
"our" refer to the owner listed above (or any ofowner's successors' rent unless authorized by statute. We may. at our option, and upon
in interest or assigns). Written or electronic notice to or from our advance notice to you, require at any time that you pay all rent and
managers constitutes notice to or from us. if anyone else has other sums in cash, certified or cashier's check, money orden or one
guaranteed performance of this Lease Contract, a separate Lease monthly check rather than multiple checks. At our discretion, we
Contract Guaranty for each guarantor is attached. may convertany and all checks via the Automated Clearing House
The person authorized to manage the apartment is: (ACH) system for the purposes of collecting payment. Rent is not
considered accepted if the payment/ACH is rejected, does not clear,
an Management services, LLC or is stopped for any reason. If you don't pay all rent on or before
Name the 3rd day of the month, you'll pay a late charge. Your late
400 gust St. Ste. 790 charge will be (check one): C] a flat rate of S _l&l..44_ or
m % of yourtotal rent due. The total amount of your late
Street Add ress charges shall not exceed eight percent (8%) of your monthly rent
payment. You'll also pay a charge of S 0
I
for each
Des Moines, IA 50309 returned check or rejected electronic payment. plus a late charge.
City, State. Zip Code if you don't pay rent on time. you'll be delinquent and all remedies
The owner or agent authorized to accept service of process and under this Lease Contractwill be authorized. All payment obligations
receive and give receipts for notices is: under this Lease Contract shall constitute rent under this Lease
Contract.
Coggoratzion Service among
Name . SECURITY DEPOSIT. Unless the parties otherwise agree in a
2345 Rice street, Ste 230 separate addendum document, the total security deposit at the time
of execution ofthis Lease Contract for all residents In the apartment
Street Address is $ 500 -00 due on or before the date this Lease Contract
is signed.
Roseville' W 55113
City, State, Zip Code in compliance with Minnesota law, your security deposit will
bear simple Interest. Interest will be included as part of the
. OCCUPANTS. The apartment will be occupied only by you and security deposit. Within 21 daysafter termination of your residency
(list all other occupants notsignllrg the Lease Contract): and receipt of your mailing address or written delivery instructions,
Robert: "Eton we will return the deposit to you, with interest, or furnish to
you a
written statement specifying the reasons for the withholding of the
deposit or any portion thereof. You may not withhold payment of
any portion of any rent on the grounds that the security deposit
should serve as payment of the rent.
6. KEYS. You will be provided 2 apartment key(s), 2
mailbox key(s], FOB[s), and/or other access
device[s) for access to the building and amenities at no additional
cost at move-in. if the key, FOB, or other access device is lost or
becomes damaged during your tenancy or is not returned or is
returned damaged when you move out, you will be responsible for
the costs for the replacement and/or repair of the same.
No one else may occupy the apartment. Persons not listed above
must not stay in the apartment for more than 3 consecutive
. UTILITIES. We'll pay forthe following items,ifchecked:
days without our prior written consent, and no more than twice Cl water Cl gas D electricity 0 masterantenna
that many days in any one month. If the previous
space isn't filled Cl wastewater D trash CI cable TV
in, two days per month is the limit. El other
You'll pay for all other utilities, related deposits, and any cha
rges,
fees, or services on such utilities. You must not allow utilities to be
o 2023, National Apartment Association. Inc. -
4 023. Minnesota
Pageloffl
EXHIBIT A
Blue Moon eSi nature Services Document ID: 394957690
19AV-CV-24-1701
Filed in District Court
State of Minnesota
6/26/2024 2:13 PM
disconnectedincluding disconnection for not paying your bills Additionally, you are (check one] a required to purchase personal
until the lease term or renewal period ends. Cable channels that are liability insurance D not required to purchase personal liability
provided may be changed during the lease term if the change applies Insurance. lfno box is checked, personal liability insurance ls not
to all residents. Utilities may be used only for normal household required. li' required, failure to maintaiil personal liability insurance
purposes and must not be wasted. lf your electricity is ever throughout your tenancy. including any renewal periods and/or
interrupted. you must use only battery-operated lighting. lfany lease extensions, is an incurable breach of this Lease Contract and
utilities are submetered for the apartment, or prorated by an may result in the termination of tenancy and eviction and/or any
allocation formula, we will attach an addendum to this Lease Contract other remedies as provided by this Lease Contract or state law.
in compliance with state agency rules or city ordinance. Pursuant
to Minnesota Statute 5043.215 Subd. 2a. upon your request. we 9 LOCKS AND LATCHES. Keyed lock(s) will be rekeyed after the
shall provide a copy ofthe actual utility bill for the community along prior resident moves out. The rekeylng will be done before you move
with each apportioned utility bill. into your apartment.
You may at any time ask us to change or rekey locks or latches during
INSURANCE. We do not maintain insurance to cover your personal
the Lease Term. We must comply with those requests, but you must
property or personal injury. We are not responsible to any resident.
pay for them, unless otherwise provided by law.
guest, or occupant for damage or loss of personal property or
personal iniury from (including but not limited to) fire. smoke, rain. Payment for Rekeylng, Repairs, Etc. You must pay for all repairs
flood, water and pipe leaks. hail, ice, snow, lightning, wind, explosions. or replacements to devices arising from the willful, malicious, or
earthquake, interruption of utilities, theft, hurricane, negligence of irresponsible conduct by you or your occupants, or guests during
other residents. occupants, or invited/uninvited guests or vandalism your occupancy. You may be required to pay in advance lfwe notify
unless otherwise required by law. you within a reasonable time after your request that you are more
than 30 days delinquent in reimbursing us for repairing or replacing
ln addition. we urge all residents, and particularly those residing
a device which was misused or damaged by you, your guest or an
in coastal areas, areas near rivers. and areas prone to flooding, to
obtain flood insurance. Renter's insurance may not cover damage occupant; or if you have requested that we repair or change or rekey
the same device during the 30 days preceding your request and we
to your property due to flooding. A flood insurance resource which
have complied with your request. Otherwise, you must pay
may be available includes the National Flood Insurance Program
immediately after the work is completed.
managed by the Federal Emergency Management Agency (FEMA).
We D require m do not require you to get your own insurance
for losses to your personal property or injuries due to theft, fire.
water damage, pipe leaks and the like. If no box is checked. renter's
insurance is not required.
Special Provisions and "What If" Clauses
10.SPECIAI. PROVISIONS. The following special provisions and any owns or uses) if you are judicially evicted or if you surrender or
addenda or written rules fu rnished to you at or before signing will abandon the apartment (see definitions in paragraph 56 (Deposit
become a part of this Lease Contract and will supersede any Return.Surrender, and Abandonment». We will store and care for
conflicting provisions of this printed lease form. property removed under this section. We may sell or otherwise
dispose of the property 28 days after you have abandoned the
apartment, and we may apply the proceeds of such sale to the
removal, care and storage costs and expenses according to state
statute. You will be notified ofthe sale at least 14 days prior to the
sale by personal service or written notice sent to your last known
address by certified mail.
See any additional special provisions.
14.FAII.ING T0 PAY FIRS'I' MONTH'S RENT. ifyou don't paythe first
11. EARLY MOVE-OUT. You'll be liable to us fora reletting month's rent when or before the Lease Contract begins, and subject
charge of
s 1518 . 00 (not to exceed 100% of the babe." monthbl rent to our duty to mitigate our damages, we may end your right of
during the lease term) if you: occupancy and recover damages, future rent, reletting charges,
attorney's fees. court costs. and other lawful charges. Our rights
(1) fail to give written move-out notice as required in paragraph and remedies under paragraphs 11 [ Ea rly Move-Out) and 34 Default
51 [Move-Out Notice); or [
by Resident) apply to acceleration under this paragraph.
(2) move out without paying rent in full for the entire lease term
or renewal period; or 15.RENT INCREASES AND LEASE CONTRACT CHANGES. No rent
(3) move out at our demand because of your default. increases or Lease Contract changes are allowed before the initial
The reletting charge is not a cancellation fiae and does not release Lease Contract term ends, except for changes allowed by any special
you
from your obligations under this Lease Contract. provisions in paragraph 10 (Special Provisions). by a written
addendum or amendment signed by you and us. or by reasonable
Not a Release. The reletting charge is nota lease cancellation fee
or buyout fee. it is an agreed-to liquidated amount changes of apartment rules allowed under paragraph 19 [Community
covering only part Policies or Rules). if. at least 5 days before the advance notice deadline
of our damages; that is. our time, effort, and expense in
finding and referred to in paragraph 3 (Lease Term), we give you written notice
processing a replacement. These damages are uncertain and difficult ol' rent increases or lease changes effective when the lease term or
to ascertainparticularly those relating to inconvenience,
paperwork, renewal period ends, this Lease Contract will automatically continue
advertising, showing apartments, utilities for showing. checking month-to-month with the increased rent or lease changes. The new
prospects, office overhead. marketing costs. and locator-service fees. modified Lease Contract will begin on the date stated in the notice
You agree that the reletting charge is a reasonable estimate of such
(without necessity of your signature) unless you give us written
damages and that the charge is due whether or not our reletting move- out notice under paragraph 51 [Move-Out Notice).
attempts succeed. If no amount is stipulated. you must pay ouractual
reletting costs so far as they can be determined.'l'he reletting charge 16.DELAY 0F OCCUPANCY. if occupancy is or will be delayed for
does not release you from continued liability for: future or past-due
construction, repairs, cleaning, or a previous resident's holding
rent; charges for cleaning. repairing, repainting, or unretu rned keys; we're not
ovei', responsible for the delay. The Lease Contract will
or other sums due. remain in force subject to: [1) abatement of rent on a daily basis
12.REIMBURSEMENT. We agree to make the premisesand all common during delay; and (2) your right to terminate as set forth below.
Termination notice must be In writing. After termination, you are
areas fit for the use intended by the parties and to
keep the premises entitled only to refund of deposit(s) and any rent paid. Rent abatement
in a reasonable repair during the term of this Lease Contract.
However, or lease termination does not apply if delay is for
you must promptly reimburse us for repairs due to the willful. cleaning or repairs
that don't prevent you from occupying the apartment.
malicious, or Irresponsible conduct by you or yourguests or occupants.
We may require payment at any time, Ifthere is a delay and we haven't given notice of delay as set forth
including advance payment of
repairs forwhich you're liable. Delay in demanding sums you owe is immediately below, you may terminate up to the date when the
not a waiver. apartment is ready for occupancy, but not later.
13.?ROPERTY LEI-'l' IN APARTMEN'I'. Under Minnesota law. we may (1) if we give written notice to any of you when or after the initial
term as set forth in Paragraph 3 (Lease Term)and the notice
remove and /or store all property remaining in the
apartment or in states that occupancy has been delayed because of construction
common areas (lncludingany vehicles you orany occupant or
guest or a previous resident's holding over, and that the apartment
0 2023. National Apartment Association. inc. -
4 023 Minnesota
Page 2 of a
Iii Blue Moon eSignature Services Document ID: 394957690
I
19AV-CV-24-1701
Filed in District Court
State of Minnesota
6/26/2024 2:13 PM
wlllbe ready on a specific dateyou may terminate your wearecharged a fee, charge, or tax, based upon youruse oroccupancy
tenancy within 3 days of your receiving the notice. but not later. ofthe apartment, we may add this charge as Additional Rent, during
the term ofthe Lease Contract. with thirty (30) days advance written
(2) if we give written notice to any of you before the initial term
as set forth in Paragraph 3 (Lease Term) and the notice states notice to you. Afterthis written notice [the amount or approximate
that construction delay is expected and that the apartmentwill amount of the charge. will be included). you agree to pay, as Additional
be ready for you to occupy on a specific date. you may terminate Rent. the amount of the charge. tax or fee imposed upon us, as a
result ofyour occupancy. As examples. these charges can include.
your tenancy within 7 days after any of you receives written
butare not limited to: any charges we receive for any zoning violation,
notice, but not later. The readiness date is considered the new
initial term as set forth in Paragraph 3 [Lease Term) for all sound. noise or litter charge; any charge under any nuisance or
chronic nuisance type statute, 911 or other life safety. per person,
purposes. This new date may not be moved to an earlier date
unless we and you agree. or per unit charge or tax and any utility bill unpaid by you, which
is then assessed to us for payment.
17.AD VALOREM TAXES/FEES AND CHARGES ADDITIONAL RENT.
-
Unless otherwise prohibited by law. if. during the term of this 18.DISCI.OSURE RIGHTS. If someone requests information on you
or your rental history for law-enforcement, governmental, or
Agreement, any locality. city. state, or Federal Government imposes
business purposes, we may provide it.
upon Us. any fee, charge, or tax, which is related to or charged by
the number of occupants, or by the apartment unit itself, such that
While You're Living in the Apartment .
19.COMMUNITY POLICIES 0R RULES. You and all guests and 22.PARKING. We may regulate the time, manner, and place of parking
occupants must comply with any written apartment rules and cars, trucks, motorcycles, bicycles, boats. trailers, and recreational
community policies. including instructions for care of our property. vehicles byanyone. We may have unauthorized or illegally parked
To the extent they are not inconsistent with this Lease Contract or vehicles towed underan appropriate statute. A vehicle is unauthorized
Minnesota law, our rules are considered partof this Lease Contract. or illegally parked in the apartment community ifit:
Upon advance notice and compliance with Minnesota law, we may
make reasonable changes to the said written rules. (1) has a flat tire or other condition rendering it inoperable; or
(2) is on jacks, blocks or has wheei(s) missing; or
20.LlMlTATlONS 0N CONDUCT. The apartment and other areas (3) has no current license plate or no current registration and/or
reserved for your private use must be kept clean and free of trash, inspection sticker; or
garbage,and other debris. Trash must be disposed ofat least weekly (4) takes up more than one parking space; or
in appropriate receptacles in accordance with local ordinances. (5] belongs to a resident or occupant who has surrendered or
Passageways may be used only for entry or exit. You agree to keep abandoned the apartment; or
all passageways and common areas free of obstructions such as [6) is parked in a marked handicap space without the legally
trash. storage items, and all forms of personal property. No person required handicap insignia; or
shall ride or allow bikes. skateboards, or other similar objects in (7) is parked in space marked for manager, staff, or guest at the
the passageways.Any swimming pools, saunas, spas, office; or
tanning beds,
exercise rooms. storerooms. laundry rooms. and similarareas must [8) blocks another vehicle from exiting; or
be used with care in accordance with apartment rules and posted (9) is parked in a fire lane or designated "no parking"area: or
signs. Glass containers are prohibited in all common areas. You, (10] is parked in a space marked for other resident(s) or unit(s]; or
your occupants. or guests may not anywhere in the apartment (11) is parked on the grass, sidewalk. or patio; or
community: use candles or use kerosene lamps or kerosene heaters [12)blocks garbage trucks from access to a du mpster; or
without our prior written approval; cook on balconies or outside; (13) belongs to a resident and is parked in a visitoror retail parking
orsolicit business or contributions. Conducting any kind of business space.
(including child care services) in yourapartment or in the apartment
23.!"iLISASEOI-'RI-151DEN'I'. Unless you're entitled to terminate your
community is prohibitedexcept that any lawful business conducted
"at home" by computer, mail, or telephone is permissible if customers. tenancy under paragraphs 10 (Special Provisions], 16 (Delay of
clients, patients, or other business associates do not come to your Occupancy), 32 (Responsibilities of Owner], 44 (Right of Victims of
DomesticAbuse to Terminate Tenancy], or 52 (Move-Out P rocedures);
apartment for business purposes. We may regulate: [l] the use of
or unless. upon your death. your personal representative gives
patios, balconies,and porches; (2] the conduct of furniture movers
and delivery persons; and (3) recreational activities in common statutory notice pursuant to paragraph 43 (Termination of Lease
areas. You'll be liable to us for damage caused by you or any Upon Death of Resident], you or your heirs won't be released from
guests this Lease Contract for any reason including. but not limited to,
or occupants.
voluntary or involuntary school withdrawal or transfer; voluntary
We may exclude from the apartment community guests or others or involuntary iob transfer. marriage, separation, divorce,
who. in our judgment. have been violating the law, violating this reconciliation, loss of co-residents, loss ofemployment or bad health.
Lease Contract or any apartment rules, or distu rbing other residents,
neighbors, visitors, or owner representatives. We may also exclude 24.MILI'I'ARY PERSONNEL CLAUSE. All parties to this Lease Contract
from any outside area or common area a person who refuses to agree to comply with any federal law, including, but not limited to
show photo identification or refuses to identify himself or herself the Service Member's Civil Relief Act, or any applicable state
law(s),
as a resident. occupant. or guest of a specific resident in the ifyou are seeking to terminate this Lease Contract and/or subsequent
community. renewals and/or Lease Contract extensions u nder the rights granted
You agree to notify us if you or any occupants are convicted of by such laws.
any
felony, or misdemeanor involving a controlled substance, violence
to another person or destruction of property. You also 25.RESIDENTSAFETYAND PROPERTY LOSS. You and all occupants
agree to and guests must exercise due care for your own and others'
notify us if you or any occupant registers as a sex offender in any safety
and security,especially in the use ofsmoke detectors, carbon monoxide
state. informing us of criminal convictions or sex offender
registry detectors, keyed deadbolt locks, keyless bolting devices, window
does not waive our right to evlct you.
latches, and access control devices.
21.PROI-IIBI1'ED CONDUCT. You, your occupants or guests, or the Smoke Detectors/Carbon Monoxide Detectors. We'll furnish
guests of any occupants, may not engage in the following activities: smoke detectors and carbon monoxide detectors only
ifrequired by
behaving in a loud or obnoxious manner; disturbing or threatening statute,and we'll test them and provide working batteries when you
the rights. comfort, health, safety, or convenience ofothers first take possession. After that, you must test the smoke detectors
(including
our agents and employees) in or near the apartment and the carbon monoxide detectors on a regular basis, and
community: pay for
disrupting our business operations; manufacturing, delivering, and replace batteries as needed. unless the law provides otherwise.
possesing with intent to deliver, or otherwise possessing a controlled We may replace dead or missing batteries at your expense, without
substance or d rug paraphernalia; engaging in or prior notice to you. You must immediately report smoke-detector
threatening
v' ' e- r sing a .. .. prohibited by state law; discharging malfunctions to us. Neither you nor others may disable neither the
a firearm in the apartment smoke detectors nor the carbon monoxide detectors. if you
community; displaying or possessing a damage
gun, knife, or other weapon in the common area in a way that may or disable the smoke detector or carbon monoxide detector, or remove
alarm others; storing anything in closets having gas a battery without replacing it with a
appliances; working battery, you may be
tamperingwith utilities or telecommunications; bringing hazardous liable to us under state statute forSlOO plus one month's rent, actual
materials into the apartment community; or injuring our damages, and attorney's fees. if you disable or damage the smoke
reputation
by making bad faith allegations against us to others. detector or carbon monoxide detector, or fail to replace a dead
battery
or report malfunctions to us, you will be liable to us and others for
o 2023, National Apartment Association. Inc. -4 any loss. damage. or fines from fire, smoke, or water.
023. Minnesota
Page 3 ofB
Blue Moon eSI nature Services Document ID: 394957690
19AV-CV-24-1701
Filed in District Court
State of Minnesota
6/26/2024 2:13 PM
Casualty Loss. We're notliable to any resident. guest. oroccupant utility costs. We may turn off equipment and interrupt utilities as
for personal lnlury or damage orloss of personal property from any needed to avoid property damage or to perform work. lfutilities
cause. including but not limited to: fire, smoke, rain, flood, water malfunction or are damaged by fire. water. or similar cause, you
and pipe leaks, hail, ice.snow. lightning, wind. explosions, earthquake, must notify our representative immediately. Air condi