Complaint,Petition: Sara E Ewing Plaintiff vs. Kerron Wilson,et al Defendant

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                                Case Number: COSO-20-010760 Division: 61
Filing # 115239961 E-Filed 10/19/2020 11:45:17 PM

IN THE COUNTY COURT,
IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO.:
Landlord-Tenant Division

SARA E. EWING,
Plaintiff{s),

VS.

KERRON WILSON, MINOWA WILSON
(aka MINOWA DOE),

and all others in possession,

Defendants.

COMPLAINT FOR UNLAWFUL DETAINER

Plaintiff SARA E. EWING (the “Plaintiff(s),”) sues Defendant(s) KERRON WILSON,
MINOWA WILSON (aka MINOWA DOE), and all others in possession (the “Defendant(s),”)

and alleges as follows:

GENERAL BACKGROUND
1. This is an action seeking relief for Unlawful Detainer.
2. This action is within the jurisdiction of this Court.
3. Venue is proper as all acts complained of and the property at issue occurred and

are located in BROWARD County, Florida.

4. The Plaintiff(s) are the owners of the real property at issue located at 9391 SW 56
Street, Room, A, Cooper City, FL 33328, Broward County, Florida, (the “Property”).

5. The Defendant(s) are residing on the Property and currently have no agreement
with the Plaintiff(s) to currently remain on the Property or pay any rent towards the Property.

6. The Plaintiff(s) have performed all conditions precedent on their part prior to the

institution of this action.

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*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/19/2020 11:45:15 PM.****Complaint, page 2

COUNT I - UNLAWFUL DETAINER

7. Plaintiff{s) reallege paragraphs 1 through 6 as stated above.

8. This is an action for recovery of possession of real property located in 9391 SW
56 Street, Room, A, Cooper City, FL 33328, Broward County, Florida that has been unlawfully
detained by the Defendant(s) and for damages that do not exceed $15,000.

9. Plaintiff{s) are entitled to present possession of the following real Property in that
county. Plaintiff(s), are the sole, real, and equitable legal owner of said Property.

10. | Defendant(s) have entered the Property in a peaceable manner and/or without
consent of the Plaintiff{s) and remain in actual possession of the Property and have paid no rent to
Plaintiff(s) for use of said Property. Defendant(s) are wrongfully holding possession of the
Property from the Plaintiff{s) and against the Plaintiff(s)’ consent.

ll. Pursuant to Florida Statutes Sections 82.01, 82.02, 82.03, and 82.04, Plaintiff{s),
are entitled to the summary procedure provided in Florida Statutes Section 51.011.

12. Accordingly, Plaintiff{s) are entitled to summary procedure and immediate
possession of the Property.

13. The Plaintiff(s) have retained undersigned attorneys to represent them in this action
and are obligated to pay its attorneys a reasonable fee for their services.

WHEREFORE, Plaintiff(s) demand judgment against Defendants for possession of the

Property, attorney fees and costs.

BY: 4/Kevin H. Fabrikant

KEVIN H. FABRIKANT, ESQ. / FL Bar No.: 0170070
Eviction Law Firm / Fabrikant & Associates, PLLC
9900 Stirling Road

Suite 300,

Hollywood, FL 33024

kevinf@lawfh.com

Tel: (954) 966-0881 / Fax: (954) 966-0886

Eviction Law Firm