Motion for Writ in Victoria Townhomes vs Ominee Stallworth, John Doe, Jane Doe| Trellis.Law

On June 28, 2024 a Complaint-Civil Party: Plaintiff Victoria Townhomes Index #1 was filed involving a dispute between Victoria Townhomes, and Stallworth, Ominee, for Eviction (UD) in the District Court of Hennepin County.

Preview
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
6/28/2024 1:31 PM

STATE OF MINNESOTA DISTRICT lIIZOURT

COUNTY OF HENNEPH'l FOURTH JUDICIAL DISTRICT

HOUSING lCOURT

Victoria Townhouses Limited Partnership
6313 Grimes Place North
Brooklyn Center. Minnesota 55429
EVICTION ACTION OOi'leLAlNT
Plaintiff.
vs.
Court File No.
Ominee Stallworth; John Doe; Jane Doe
1535? Grimes Place
Brooklyn Center. MN 55429

Defendant{s}.

My true and correct name is Kathleen Tiaden, I am the Attorney for the Plaintiff in the
above-captioned proceeding, and I state under oath that the information contained in this
Complaint is true and correct to the best of my knowledge:

1. Property Information:
a. 685? Grimes Place
Brooklyn Center. Minnesota 55429
b. The lease does not include a garage or storage unit.

2. About the Parties:
a. Plaintiff i Landlord t: Victoria Townhouses Limited Partnership
b. Defendanttst: Ominee Stallwortlt

3. Lease Information:
a. Lease Start Date October 1. 2&2}
-

b. Lease End Date September 3G, EDIE-4
-

c. Monthly Obligation $1,6Tﬂ.ﬂfl. due on the ﬁrst day of the month.
-

4. Statutory Compliance: Plaintiff, having present right of possession of said property. has
complied with Minn. Stat. § 5MB.181: Disclosing to the Defendantts} either in the rental
agreement or otherwise in writing prior to beginning of the tenancy the name and address of
the person authorized to manage the property, and a landlord or agent authorized by the
landlord to accept service of process and receive and give receipt for notices and demands.
and the required information was posted in a conspicuous location. namely the management
office.

5. Subsidies: Upon information and belief. this tenancy is not affected by a federal or state
housing subsidy program through project-based federal assistance payments; the Section E
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
6/28/2024 1:31 PM

program, as defined in section 469.1302. subdivision 24; the low-income housing tar-t credit
program; or any other similar program.

ti. Reason for Eviction: Non-Payment of Rent (5043.291)
Defendant{s] failed to pay rent in full, and as of June 23, ESE, Defendantljs} are in arrears
353295.311], calculated as follows:
Rent andtor Late Fees for January through June = $3,295.8ﬂ

In addition, pursuant to Minn. Stat. § 5343.291, Defendant(s) are required to pay any
additional rent then in arrears, plus costs and expenses of $4ﬂ'l.ﬂl] {includes the court ﬁling
fee of $3ﬂ2.ﬂﬂ, legal process and service fees of $1ﬂﬂ.ﬂtl, and $5.ﬂil in attorney fees}, and
perform any other covenants of the lease, prior to Defendantts} redeeming and being restored
to possession. Plaintiff does not waive the right to seek collection, payment, or other legal
action for any amount{s} not pied above.

A pro-eviction notice, attached, was delivered to Defendantts} pursuant to Minnesota Statute
section Sud-H.32l, subd. la, and applicable city ordinance.

T. Pursuant to Minnesota Statutes section 5MB.345, subd. 1(a), Plaintiff seeks immediate
judgment against the above Defendantts} for restitution of said premises, and immediate writ
of recovery of said premises, plus costs and disbursements herein.

Veriﬁcation and Affidattit of Non Mﬂitary Status

1, Kathleen Tiaden, being swornfafﬁrmed, state that] am the Plaintist Attorney in this
action, that I have read the complaint and that it is true to the best of my knowledge; that
Defendanﬂs} ist'are not now in the military service of the United States, to the best of my
information and belief. I acknowledge that costs, disbursements, and reasonable attorney and
witness fees may be awarded pursuant to Minnesota Statutes § 549.211, Subd. {2}, to the party
against whom the allegations in these pleadings are asserted. I declare under penalty of perjury
that everything [have stated in this document is true and correct. Minn. Stat. § 358.1 115.

Landlord Resource Nettvork, LLC

Dated: Jane 28, 2024 frﬂt'nthiean Tiaden
Kathleen Tiaden {#ﬂ39T21 "1"]
STATE DF MINNESOTA } ss. 225 S. nth Street, Suite 39m}
CUUNTY OF HENNEPIN } Minneapolis, MIST 554{12
Phone: 6123 Ill-31??
kathleenﬁf'landlordresource.net
Attomey for Plaintiff
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
6/28/2024 1:31 PM
NOTICE OF DCEUPANCY RIGHTS UNDER LLS. Department of Housing and Urban Development.
THE VIOLENCE AGAINST WDMEN ACT 0MB Approval No. ESTT{llﬂﬁ
Expires Uﬁﬂﬂtlﬂl?

Victoria Townhouses Limited Partnership

Notice of {Tlccupancjr Rights under the Violence Against Women ActI

To all Tenants and Applicants

The Violence Against Women Act {VAWA} provides protections for victims of dome stic violence,
dating violence, sexual assault, or stalking. VAWA protections are not only available to women,
but are available equally to all individuals regardless of sex, gender identity, or sexual orientation.1
The [1.5. Department of Housing and Urban Development {HUD} is the Federal agency that
oversees that Victoria Townhouses Limited Partnership is in compliance with VAWA. This notice
explains your rights under VAWA. A HUD-approved certification form is attached to this notice.
You can fill out this form to show that you are or have been a victim of domestic violence, dating
violence, sexual assault, or stalking, and diat you wish to use your rights under VAWA."

Protections for Applicants

If you otherwise qualify for assistance under the programs at Victoria Townhouses Limited
Partnership, you cannot be denied admission or denied assistance because you are or have been a
victim of domestic violence, dating violence, sexual assault, or stalking.

Protections for Tenants

If you are receiving assistance under the programs at Victoria Townhouses Limited Partnership,
you may not be denied assistance, terminated from participation, or be evicted from your rental
housing because you are or have been a victim of domestic violence, dating violence, sexual
assault, or stalking.
Also, if you or an affiliated individual of yours is or has been the victim of domestic violence,
dating violence, sexual assault, or stalking by a member of your household or any guest, you may
not be denied rental assistance or occupancy rights under the programs at Victoria Townhouses
Limited Partnership, solely on the basis of criminal activity directly relating to that domestic
violence, dating violence, sexual assault, or stalking.

Afﬁliated individual means your spouse, parent, brother, sister, or child, or a person to whom you
stand in the place of a parent or guardian {for example, the affiliated individual is in your care,
custody, or control]; or any individual, tenant, or lawful occupant living in your household.
Removing the Abuser or Perpetrator front the Household

Victoria Townhouses Limited Partnership may divide [bifurcate] your lease in order to evict the
individual or terminate the assistance of the individual who has engaged in criminal activity (the

Despite the name of this law. VAWA protection is available regardless of sex, gender identity, or sexual orientation.
1

'-
l-lousing providers cannot discriminate on the basis of any protected characteristic, including race. color. national
origin. religion, sex, familial status, disability, or age. HUD-assisted and l-lLtDvinsured housing must be made
available to all otherwise eligible individuals regardless of actual or perceived sexual orientation, gender identity. or
marital status.
Form HUD-533i}
{lZﬂﬂlftJ
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
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abuser nr perpetratar) directly relating In} domestic violence, dating violence, sexual assauitﬁ or
stalking.

If Victoria Townhouses Limited Partnership chooses to remove the abuser or perpetrators Victoria
Townhouses Limited Partnership may not take aw ﬁll" the rights of eligible tenants to the unit or
otherwise punish the remaining tenants. If the evicted abuser or perpetrator was the sole tenant to
have established eligibility for assistance under the program. Victoria Townhouses Limited
Parmership must allow the tenant who is or has been a victim and other household members to
remain in the unit for a period of timel in order to establish eligibility under the program or under
another HUD housing program covered by VAWA, or. find alternative housing.

In removing the abuser or perpetrator from the householdl Victoria Townhouses Limited
Partnership must follow Federal, State. and local eviction procedures. In order to divide a lease.
Victoria Townhouses Limited Partnership may. but is not required to. ask you for documentation
or certiﬁcation of the incidences of domestic violence. dating violence. sexual assault. or stalking.

Moving to Another Unit

Upon your request. Victoria Townhouses Limited Partnership may permit you to move to another
unit. subject to the availability of other units. and still keep your assistance. In order to approve a
request. Victoria Townhouses Limited Partnership may ask you to provide documentation that you
are requesting to move because of an incidence of domestic violence. dating violence, sexual
assault. or stalking. If the request is a request for emergency transfer, the housing provider may
ask you to submit a written request or fill out a forrn where you certify that you meet the criteria
for an emergency transfer under VAWA. The criteria are:

[1} You are a victim of domestic violence, dating violence, sexual assault, or
stalking. If your housing provider does not already have documentation that you
are a victim of domestic violence, dating violence. sexual assault, or stalking, your
housing provider may ask you for such documentation, as described in the
documentation section below.

[2} You expressly request the emergency transfer. Your housing provider may
choose to require that you submit a form, or may accept another written or oral
request.

[3) You reasonably believe you are threatened with imminent harm from
further violence if you remain in your current unit. This means you have a
reason to fear that if you do not receive a transfer you would suffer violence in the
very near future.

{JR
You are a victirn of sexual assault and the assault occurred on the premises
during the 9lI-calendar-day period before you request a transfer. [f you are a
victim of sexual assault, then in addition to qualifying for an emergency transfer
because you reasonably believe you are threatened with imminent hartn from

Form HUD-533i}
f 12f2lll ft}
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
6/28/2024 1:31 PM

further violence if you remain in ynur unit, vou may qualify fur an emergency
transfer if the sexual assauII neeurred 0n the premises ei' the property frem which
ynu are seeking year Iransi'er, and that assault happened within the 9D-ea1entiapday
peried before you expressly request the transfer.

Victoria Townhouses Limited Partnership will keep confidential requests for emergency transfers
hy victims of domestic violence, dating violence, sexual assault, or stalking. and the location of
any move hy such victims and their families.

If you need information on an emergency transfer plan, please contact management at Vista View
Townhomes II.

Documenting You Are or Have Been a Viciiru of Domestic Violence, Dating Violence, Sexual
Assault or Stalking

Victoria Townhouses Limited Partnership can, hut is not required to, ask you to provide
documentation to "certify" that you are or have been a victim of domestic violence, dating
violence, sexual assault. or stalking. Such request from Victoria Townhouses Limited Partnership
must he in writing, and Victoria Townhouses Limited Partnership must give you at least l4
business days (Saturdays, Sundays, and Federal holidays do not count} from the day you receive
the request to provide the documentation. Victoria Townhouses Limited Partnership may, but
does not have to, extend the deadline for the submission of documentation upon your request.

You can provide one of the following to Victoria Townhouses Limited Partnership as
documentation. It is your choice which of the following to submit if Victoria Townhouses Limited
Partnership asks you to provide documentation that you are or have been a victim of domestic
violence, dating violence. sexual assault, or stalking.

I A complete HUD-approved certification form given to you by Victoria Townhouses
Limited Partnership with this notice, that documents an incident of domestic violence,
dating violence, sexual assault, or stalking. The form will ask for your name, the date, time,
and location of the incident of domestic violence, dating violence, sexual assault, or
stalking, and a description of the incident. The certification form provides for including
the name of the abuser or perpetrator if the name of the abuser or perpetrator is known and
is safe to provide.

n A record of a Federal, State, tribal, territorial, or local law enforcement agency, court, or
administrative agency that documents the incident of domestic violence, dating violence,
sexual assault, or stalking. Examples of such records include police reports, protective
orders, and restraining orders, among odrers.

I A statement, which you must sign, along with the signature of an employee, agent, or
volunteer of a victim service provider, an attorney, a medical professional or a mental
health professional (collectively, "professional"} from whom you sought assistance in
addressing domestic violence, dating violence, sexual assault, or stalking, or the effects of
abuse, and with the professional selected by you attesting under penalty of perjury that he

Form HUD-5331'.)
t 12f2tll fr}
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
6/28/2024 1:31 PM

m- she believes that the incident or incidents of domestic vinlencet dating vinlencet sexual
assault, 0r stalking are grounds for protection.

a An}? other statement or evidence that Victoria Townhouses Limited Partnership has agreed
to accept.

If you fail or refuse to provide one of these documents within the 14 business dayst Victoria
Townhouses Limited Partnership does not have to provide you witli the protections contained in
this notice.

If Victoria Townhouses Limited Partnership receives conﬂicting evidence that an incident of
domestic violence, dating violence. sexual assault, or stalking has been committed (such as
certiﬁcation forms from two or more members of a household each claiming to be a victim and
naming one or more of the od'ier petitioning household members as the abuser or perpetratorlt
Victoria Townhouses Limited Partnership has the right to request that you provide third-party
documentation within thirty 3G calendar days in order to resolve the conﬂict. If you fail or refuse
to provide third-party documentation where there is conﬂicting evidence. Victoria Townhouses
Limited Partnership does not have to provide you with the protections contained in this notice.

Confidentiality

Victoria Townhouses Limited Partnership must keep conﬁdential any information you provide
related to the exercise of your rights under VAWA. including the fact that you are exercising your
rights under VAWA.
Victoria Townhouses Limited Partnership must not allow any individual administering assistance
or other services on behalf of Vista View Townhornes II [for example. employees and contractors)
to have access to confidential information unless for reasons that speciﬁcally call for these
individuals to have access to this intonnation under applicable Federal. State, or local law.

Victoria Townhouses Limited Partnership must not enter your information into any shared
database or disclose your information to any other entity or individual. Victoria Townhouses
Limited Partnership, however. may disclose the information provided if:

I You give written permission to Victoria Townhouses Limited Partnership to release the
information on a time limited basis.
I Victoria Townhouses Limited Partnership needs to use the information in an eviction or
termination proceeding. such as to evict your abuser or perpetrator or terminate your abuser
or perpetrator from assistance under this program.
I A law requires Victoria Townhouses Limited Partnership or your landlord to release the
information.

VAWA does not limit Victoria Townhouses Limited Partnership duty to honor court orders about
access to or control of the property. This includes orders issued to protect a victim and orders
dividing property among household members in cases where a family breaks up.

Reasons a Tenant: Eligible for ﬂccupancy Rights under VAWA May Be Evicted or Assistance
May Be Termiitated
Form HUD-533i}
f 12f2ﬂ| ti}
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
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You can be evicted and your assistance can be terminated for serious or repeated lease violations
that are not related to domestic violence. dating violence, sexual assault, or stalking committed
against you. However. Victoria Townhouses Limited Partnership cannot hold tenants who have
been victims of domestic violence. dating violence, sexual assault, or stalking to a more demanding
set of rules than it applies to tenants who have not been victims of domestic violence, dating
violence, sexual assault, or stalking.

The protections described in this notice might not apply. and you could be evicted and your
assistance terminated, if Victoria Townhouses Limited Partnership can demonstrate that not
evicting you or terminating your assistance would present a real physical danger that:

l}1Would occur within an immediate time frame, and
2) Could result in death or serious bodily harm to other tenants or those who work on the
prepare.

If Victoria Townhouses Limited Partnership can demonstrate the above, Victoria Townhouses
Limited Partnership should only terminate your assistance or evict you if there are no other actions
that could be taken to reduce or eliminate the threat.

Other Laws

VAWA does not replace any Federal. State. or local law that provides greater protection for victims
of domestic violence, dating violence. sexual assault, or stalking. You may be entitled to additional
housing protections for victims of domestic violence, dating violence, sexual assault, or stalking
under odter Federal laws, as well as under State and local laws.

Non-Compliance with The Requirements of This Notice

You may report a covered housing provider's violations of these rights and seek additional
assistance. if needed, by contacting or ﬁling a complaint with the HUD Minneapolis Field Ofﬁce
at {are} sic-soon

For Additional Information

You may view a copy of HUD's ﬁnal VAWA rule at https:waw.gpo.govffdsys!pkgfFR-2Lllﬁ-
1 1-1
ﬁfpdti'ﬁﬂl sass saper.

Additionally Victoria Townhouses Limited Partnership must make a copy of HUD's VAWA
regulations available to you if you ask to see them.

For questions regarding VAWA. please contact Kenya Bowie at (651) 464-5'i'ﬂﬂ.

For help regarding an abusive relationship. you may call the National Domestic Violence Hodine
at l-SﬂD-TQQ-TEBB or. for persons with hearing impairments, LEDG-TE'I-EZM {TTY}. You may
also contact:

Form HUD-533i}
Lf
12f2ﬂ| ti}
27-CV-HC-24-4364
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Minnesota Coalition for Battered Women: (366} 223-11 i l

Battered Women Legal Advocacy Project: (BUG) 313-2666:

For tenants who are or have been victims of stalking seeking help may visit the National Center
for Victims of Crime's Stalking Resource Center at httrtsoifwww.victirnsofcrimeorgfour-
prograntsIstalking-resourceicenter.

For help regarding sexual assault, you may contact:

Minnesota Coalition Against Sexual Assault: {+351} EDP-9993

Minnesota Coalition for Battered Women: (BIS-S} 223-1 ll 1

Battered Women Legal Advocacy Project: (SUB) 313-2666

Victims of stalking seeking help may contact:

Minnesota Coalition for Battered Women: (366] 223-11 11

Battered Women Legal Advocacy Project: (Etiﬂ) Eli-26515

Attachment: Certiﬁcation form HUD-5382

Forrn HUD-5331'.)
Lf
12f2ﬂ| fl]
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
6/28/2024 1:31 PM
NOTICE OF DCEUPANCY RIGHTS UNDER LLS. Department of Housing and Urban Developmmrr
THE VIOLENCE AGAINST WUMEN ACT 0MB Approval No. ZSTT-{llﬂﬁ
Expires Uﬁﬂﬂllﬂll

CERTIFICATION OF U'l Department of Housing 0MB Approval No. ﬁll-DEEE
DDMESTIC VIﬂLENCE, and Urban Development Exp. tlEitEﬂtZtl T
I

DATING IitithItLliIl'HlC'E,
SEXUAL ASSAULT, 0R STALKING,
AND ALTERNATE DUEUMENTATIHN

Purpose of Form: The 1|v'iolence Against Women Act [""t-"AWA") protects applicants, tenants, and
program participants in certain HUD programs from being evicted, denied housing assistance, or
terminated from housing assistance based on acts of domestic violence, dating violence, sexual assault, or
stalking against them. Despite the name of this law, VAWA protection is available to victims of domestic
violence, dating violence, sexual assault, and stalking, regardless of sex, gender identity, or sexual
orientation.

Use of This lflptional Funn: If you are seeking VAWA protections from your housing provider, your
housing provider may give you a written request that asks you to submit documentation about the incident
or incidents of domestic violence, dating violence, sexual assault, or stalking.

In response to this request, you or someone on your behalf may complete this optional form and submit it
to your housing provider, or you may submit one of the following types of thirdparty documentation:

{l} A document signed by you and an employee, agent, or volunteer of a victim service provider, an
attorney, or medical professional. or a mental health professional (collectively, "professional") from
whom you have sought assistance relating to domestic violence, dating violence, sexual assault, or
stalking, or the effects of abuse. The document must specify, under penalty of perjury, that the
professional believes the incident or incidents of domestic violence, dating violence, sexual assault, or
stalking occurred and meet the definition of "domestic violence," "dating violence," "sexual assault," or
"stalking" in HUD's regulations at 24 CFR 5.2tlil3.
[2} A record of a Federal, State, tribal, territorial or local law enforcement agency, court, or
adrni nistrative agency; or

[3) At the discretion of the housing provider, a statement or other evidence provided by the applicant or
tenant.

Submission of Documentation: The time period to submit documentation is 14 business days from the
date that you receive a written request from your housing provider asking that you provide documentation
of the occurrence of domestic violence, dating violence, sexual assault, or stalking. Your housing
provider may, but is not required to, extend the time period to submit the documentation, if you request an
extension of the time period. If the requested information is not received within 14 business days of when
you received the request for the documentation, or any extension of the date provided by your housing
provider, your housing provider does not need to grant you any of the 'v'AWA protections. Distribution or
issuance of this form does not serve as a written request for certification.

Conﬁderrtiality: All information provided to your housing provider concerning the incident[s} of
domestic violence, dating violence, sexual assault, or stalking shall be kept confidential and such details
shall not be entered into any shared database. Employees of your housing provider are not to have access
to these details unless to grant or deny 1it"ililvlt'A protections to you, and such employees may not disclose
this information to any other entity or individual, except to the extent that disclosure is: {i} consented to
by you in writing in a timelimited release: {ii} required for use in an eviction proceeding or hearing
regarding termination of assistance: or {iii} otl'rerwise required by applicable law.

Forrn HUD-5331
if 12f2ill b}
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
6/28/2024 1:31 PM
:

T0 BE CﬂhI'PLETED BY OR (IN BEHALF [IF THE 1lip'IICTIlttl 0F DﬂlvlES'I'IC Iit'll]LEI'HICE,
DATING VlﬂLENCE SEXUAL ASSAULT {JR S'l'ALKIN

1. Date the written request is received by victim:

2. Name of victim:

3. Your name [if different from victim's):
4. Namets} of other family memberts} listed on the lease:

5. Residence of victim:

IE. Name of the accused perpetl'ator {if known and can be safely disclosed}:

T. Relationship of the accused perpetrator to the victim:

8. ﬂatetfs) and timeots} ofincident{s} {if knot-m}:

Ill. Location of incidezntlﬁsl:
1n yuur "Wu WlJrdH+ bricl'ly (inscribe U1: incidcntis}:

This is to certify that the information provided on this form is true and correct to the best of my knowledge
and recollection, and that the individual named above in Item 2 is or has been a victim of domestic violence,
dating violence, sexual assault, or stalking. I acknowledge that submission of false information could
jeopardize program eligibility and could be the basis for denial of admission, termination of assistance, or
eviction.

Signature Signed on (Date)

Public Reporting Burden: The public reporting burden for this collection of informaﬁon is estimated to
average hour per response. This includes the time for collecting, reviewing, and reporting the data. The
1

information provided is to he used by the housing provider to request certification that the applicant or
tenant is a victim of domestic violence, dating violence, sexual assault. or stalking. The information is
subject to the confidentiality requirements of VAWA. This agency may not collect this information, and
you are not required to complete this form, unless it displays a currently valid Ofﬁce of Management and
Budget control number.

Form HUD-5331
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Rental Lease Agreement
THE TERMS or THIS Lassa ARE as ENTERED RELoiv:
RESIDENT[s]: {List all perm who will occupy the unit} [Lanna Stailworth
PROPERTY: VICTORIA TDWNIIDUSES
STREET ADDRESS: 6851 GRIh'fES PLACE, ERDDKLYN CENTER, MN 55429
DURATIDN 0F LEASE: {enter nLunher ofrnnnllel 12 DATE. DF ACTUAL- 'EIS'EISIZDZZ
LEASE BEGINS AT NDDN DIN: ﬂﬁit snore LEASE TERlillItIATES AT WINTERS
NDTICE PERIOD: ﬁll-day written notice [beginning on the 1" of the mantis] by either partyr prior to Lease expiration
UNIT #:dSS'i MDNTHLY RENT: SI ,6T0.llil DEPOSITridtlllJltI
ADDITIONAL DEPDSI'I': $3,340.0il LAST MUNTH'S RENT: llillil
UTILITIES INCLUDED IN RENT: []IIEAT DEIWA'IER [ELECTRICITY [XIGARBAGE [}GAS SEWER
UTILITIES earn SEPARATELY nv RESIDENT: [Xil-IEAT "WATER [sqntncrstcrrv [jGARBAGE [xlnas SEWER
ADDITIONAL AGREEMENT [it any}:
Minnesota Statues Section 504.12 requires the following: Ganglion Cornpanies located at 56 East Broadway Suite Elli), Forest Lake, lit-DI 55025 is
the authorized managing company for this property and is an owner of the premises or an agent authorind to accept service of process. receive arid
give receipts for notices and demands
A. RENT
1. PAYMENT: RESIDENT will pay MANAGEMENT the hill montiily rent hefore midrught of the ﬁrst day of each niontli while this
Lease is in effect and during any extensions or rancurals of this Lease. Rent will he paid as required by MANAGEMENT. For insurance
and accounting purposes, MANAGEMENT does not accept cash or second party checks for rent payment or other charges.
1. WED IS RESPDNSIBLE FDR RENT: Each RESIDENT" is mditidtmﬂy responsible for 933mg the hill amount of rent and any other
money owed to MANAGEMENT.
3. DU'I"rr TO PAY RENT AFTER EVIC'I'IDN: IfRESIDENT violated a term of this Lease. RESIDENT must pay the full monthly rent
thin} I} the Apartment is reoccupied: 2] the date this Lease ends; or 3} if the Iease is month-to-Inondi, the date on which the next notice
period ends {month-toInonth notice period is the fulﬁllment of a 60day notice}.
4. LATE RENT SERII'ICE CHARGE AND RETURNED CHECK FEE: It'die RESIDENT does not pay the hill monddy rent by the
4'" day of the month, the RESIDENT will pay a late for set at S% in accordance to Minnesota State Stanites. If by the III" of the month.
all sums due are not paid in full or TENAN'I' dose not have an acceptable, written: payinent agreemerit with MANAGEMENT, an
Eviction Action Tivill he filed. RESIDENT will also pay a minimtnn fee of $25.00 for each renamed check. Once a check is returned,
MANAGENIENT may require that all future rent he paid with a cashier's check or money order. If a second client: is returned, all further
rerit payments must he paid using a cashier's check or money order.
5.CDh1MDN AREAS: The rent paid by Ilse RESIDENT is for the use of the Aparnnent. Use of any exercise recurs. social rooms, pool,
tonnis count or other common facilities may he discontimred 'cy MANAGENIENI' at any time without a change in the rent amotrnt.
ti. UTMTIES AND SERVICES: MANAGEIvIENT may temporarily discontinue utilities or other services without a change in the rent
amount if required due to accidents, repairs. improvunents, strikes, riots or stat-ins.
I. DEPDSIT: MANAGEMENT may keep all or part of the deposit ii for damage to Apartment; and 2] for rent or ntlier money owed to
MANAGEhi'EZIiI'I'. RESIDENTS last month's rent may not he deducted item the deposit Sill-tower it is LANDLGRD or T'ENANT -

who ends the tenancy, he or she must abide by both the terms of the Lease and State Law. The law forbids RESEEN'I'S to use their
deposits to pay rent. RESIDENTS who do. may he takes: to court and may have to pay the LANDLORII the amount of rent owed plus a
penalty. We are notifying you that His illegal to withhold all or nrtinn III rent for the last a II vs
'
LO t' the RES -
entia] reament.

D 5

R. USE OF APARTMENT
ROCCLTPANCY AND USE: lClnly the persons listed above as RESIDENTS may live in the Apartment. Persons not listed as
RESIDENTS may live in the Aparhnertt only with the prior written consent of MANAGEMENT. RESIDENT may use the Aparhnent
and utilities for normal residential purposes only. Any other use constitutes a breach of this Lease.
9. SUBLETI'ING: RESIDENT may not Lease the Apartment. to other persons [sublet], assigrt this Lease or sell this I.ease without prior
written consent of hiANAGEl-IENT.
It). RESIDENT PROMISES: I] not to act in a load, boisterous. Inuilly or thoughtless manner or disnn'o the rights of the other
RESIDENTS to peace arid quiet or to allow hisi'her guests to do so; 2] limit the number of guests andior visitors as to not become
excessive or MANAGEMENT may ask RESIDENT to limit the number of guests as excessive trams: from guests, visits ﬁ'ttrt'tt guests at
all hours, visits of short duration, visitors who leave vehicles rtmning in parking areas are considered dishtrbanoes and violations of the
Least; 3] to use the Apartment only as a private residence and not in any way diet is illegal or dangerous or which would cause a
cancellation, restriction or increase MANAGESIEN'I'S insurance prerm'um; 4} not to use or store any ﬂamrriahle or explosive substances
in or near the Aparhuerrt; 5} not to interfere in the MANAGEMENT and operation of the Aparhnent huildnig', ti] not to engage in
harassing, threatening or discriminatoryr conduct directed at MANAGEMENT or other RESIDENTS; and 'i'} that the Apartment,
common areas or area surrounding the building will not he used by the RESIDENT, any member of the RESIDENT *S

Q ]

Human-ur- ':I'r;*-r"+' ai-an-mi I-h':HH DE'U'TF-Ilh citing-thun- rum-"inne- Thur-lament Tri- 111114
27-CV-HC-24-4364
Filed in District Court
State of Minnesota
6/28/2024 1:31 PM
household, any guest of the RESIDENT nr by anyone acting under blather control to ntannEectnre, sell, give away, barter,
delit'er, exchange, distribute, possess or use any illegal drugs, to engage in prostitution or any prostitution related activityr or to
unlawfully use or possess any ﬁrearm or to allow any stolen pruper'tjt on the premises.
ILWATERBEDS: RESIDENT may not keep a waterbed, aquarium or other ureter-ﬁlled ﬁnnlture in the Aparnnent without the prior
written consent of MANAGEMENT. Upon MANAGEMENT's written approval, the RESIDENT is reqrrired to maintain and provide
proof of renter's insurance. RESIDENT shall reimburse hLANAGEIHIEl'IT for damages caused by use of waterbeds, aquariums and
wareoﬁllcd furniture.
12. I'E'IS: RESIDENT may not keep anhnals or pets of any kind in the Apartment or in common areas without the written consent of
hLANAGEhIENT; this includes visitmg animals or pets.

O.s.

('1. CONDITION OF APARTMENT
13. MANAGEMENT PROh'ﬂSES: I] to keep the Apartment and all cornmon areas ﬁt for use as a residential premises; 2) to keep the
Aparhnent in reasonable repair and tnalre necessary repairs within a reasonable time after receirring written notice by RESIDENT
except when damage is caused by the intentional or negligent conduct of the RESLDEI'IT, a member of the household or
hisdrcr guests;
3} to maintairr the Apartment in compliance with applicable health and safety codes except when a violation of the health safety codes
has been caused by the intentional or negligent conduct of the RESIDENT, a member: of the household or blather guests; and Al to keep
the corurnorr areas clean and in good condition.
14. RESIDENT PROlttlSES: I) not to damage or misuse the Aparunerrt, cormnon areas or waste the utilities provided by
MANAGEl'r-{ENT or allow a member of the household histher guests to do so; 2) not to shampoo. paint or wallpaper the Apartment; 3}
not to install or use washers, dryers, freezers or dishwashers without written consent from MANAGEMENT; 4} not to make any
structural changes in the Apatnneut without the prior written consent of MANAGEMENT; 5} and to keep the Apmnt
clean and in
compliance with all health and safety codes; ti} to give written notice to MANAGEhIENT of any necessary repairs
to he made in
the Apartment or within common areas; 7"] to notify MANAGESIENT immediately of any conditions in the Apartment or within the
coon-non areas that are dangerous to human health or safety or which may damage the Apartment and or common area or waste utilities
provided by MANAGEhdENT; S} that when RESIDENT reeves out, the Apartment will he left in good
clean and sanitary condition,
except for ordinaryr wear and tear; 9} not to remove any ﬁsmres or furnishings supplied by hlANAGElvIEl'iT; I'll) not to install or change
any locks in the Apartment; and II} to cooperate with MANAGEMENTS efforts at pest control.
[5. RESIDENT CHECK IN LIST: The RESIDENT and h'IANAGEhIIENT will complete a checkin list when RESIJJENT moves into the
discovered in the unit.
Apartment. Ifthe RESIDENIT fails to do so hetshe may be held responsible for any defects
Id. DESTROY'ED OR. UNLIVA'BLE APARTMENT: If the Apartment is dastroyed or damaged so it is unﬁt to live in due to any earns,
MANAGEMENT may cancel this Lease immediately and may choose not to rebuild or restore the Apartment. If the destruction or
damage was not the result of any actor omission of RESIDENT. and MANAGEMEJNIT cancels this Lease, rent shall be pro-rated and
the balance will be refunded to RESIDENT.

D5
I

DURATION OF LEASE
Il'. FAILURE TO GIVE POSSESSION: If MANAGEMENT cannot provide the Apartment to RESIDENT at the start of this Lease,
RESIDENT cannot sue MANAGEMENT for any resulting damages but RESIDENT will not start paying rent until helshe is offered
possession of the Apartment.
IS. TERhIINATION OF LEASE WITH SPECIFIED ENDING DATE: If RESIDENT wishes to move out of the Apartment on the date
this Lease ends. RESIDENT mgr give MANAGEMENT pg'or written notig equal to the notice period {tilldays}. If RESIDENT fails
to give proper notice, MANAGEMENT may {a} extend the Lease for one notice period {tillday's} and {b} raise the rent. If RESIDENT
and MANAGEMENT
stays in the Apartment aﬂer the date this Lease ends with the approval of MANAGEMENT. and RESIDENT
have not renewed this Lease or entered into a new Lease, this Lease shall be exterrded under its original terms except {a} the duration
shall be changed to nrontlrwto-month and {b} MANAGEhdENT may raise the rent.
19. MOVING OUT BEFORE LEASE ENDS: If RESIDENT moves out of the Apartment before tlm date this lease ends, RESIDENT is
and any other losses. RESIDENT further agrees to
responsible for rent for the duration of this Lease or until the Apartment reoccupied
is
pay an adnrinistrative fee stardom plus any other costs associated with breaking this lease and as outlined elsewhere in the body of
this Lease.
2D. TERMINATION AND ALTERATION OF MONTH-TO-MONTH LEASE: When the Lease is month-to-nronth, SIANAGEMENT
and RESIDENT may terminate the Lease only by giving the other party written notice corral to the notice period. A notice to cancel a
Lease is effective on the last day of the month. MANAGEMENT may change any of the toms of amonth-to-month Lease, including
the amount of rent. by giving RESIDENT written notice at least equal to the notice period
21. BUY OUT OF LEASE: A RESIDENT wishing to buy their way out of this Lease for purposes of buying a home, job oansfer or other
months of their Lease term: h} give a
extenuating circumstances approved by MANAGEMENT in uniting must: a} have fulﬁlled sir:
proper oil-day com notice to vacate; c} pay at the time of giving the proper till-day written notice all rent, fees and other stuns dire to
MANAGEMENT through the termination of the Lease along with a buy out foe equal to Il'rree month's rent.

2 m2!
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Document for Victoria Townhomes vs Ominee Stallworth, John Doe, Jane Doe

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