On December 30, 2014 a
Complaint,Petition
was filed
involving a dispute between
Feiga Clairmont Lp An New York Limited Partnership,
and
Blaylock, Heather R,
for DELINQUENT TENANT - COUNTY
in the District Court of Pinellas County.
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Case Number: 14-010422-CO
Filing # 22040688 E-Filed 12/30/2014 01:19:11 PM
IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, STATE OF FLORIDA - CIVIL DIVISION
FEIGA/CLAIRMONT, L.P., an New York limited
partnership d/b/a BUENA VISTA I,
Plaintiff,
vs.
HEATHER R. BLAYLOCK,
Defendant /
COMPLAINT FOR EVICTION
Plaintiff FEIGA/CLAIRMONT, L.P. d/b/a BUENA VISTA 1 (hereinafter referred to as
“PLAINTIFF”) hereby sues Defendant HEATHER R. BLAYLOCK (hereinafter referred to as
“DEFENDANT”) and alleges:
1, This is an action to evict tenants from real property in Pinellas County, Florida.
2. PLAINTIFF owns the following described real property in Pinellas County, Florida, to-
wit: 12100 Park Boulevard, Apt. 508, Seminole, Pincllas County, Florida.
3. DEFENDANT has possession of said real property under a written lease agreement
pursuant to which DEFENDANT agreed to pay the sum of $982.00 per month as rent plus month-to-
month fees. Said rent was due on or before the 1“ of cach month. A copy of said lease agreement is
attached hereto as Exhibit A.
4. DEFENDANT failed to pay rent due of $1,080.36. DEFENDANT also owes late rent
charges, which are deemed as additional rent under the terms of the lease (Exhibit A). DEFENDANT
continues to accrue rent.
5. Pursuant to section 83.56, Florida Statutes, PLAINTIFF served DEFENDANT with
a written 3-Day Notice December 4, 2014 stating that DEFENDANT was indebted to PLAINTIFF for
unpaid rent and that DEFENDANT had three days to cure such indebtedness or vacate the leased premises.
A copy of the above-referenced 3-Day Notice is attached hereto as Exhibit B.
6. DEFENDANT failed to pay the rent due within the time period set forth in the attached 3-
Day Notice (Exhibit B) or vacate the leased premises.
7. PLAINTIFF has retained the undersigned counsel in this matter and is responsible to pay a
reasonable fee for his services. PILAINTIFF is entitled to be reimbursed for said reasonable attorney’s fees
pursuant to section 83.48, Florida Statutes, as well as the terms of the lease agreement (Exhibit A).
***ELECTRONICALLY FILED 12/30/2014 1:19:15 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***WHEREFORE, Plaintiff demands judgment against Defendant for possession of the leased
premises described above, plus rent paid into the Registry of the Court (if applicable), and attorney's
fees and costs pursuant to section 83.48, Florida Statutes.
Respectfully submitted,
Date: December 29,2014 Jett. Co seth
Daniel G. Drake, Esq.
Fla. Bar No. 054800
Post Office Box 2327
Brandon, FL 33509-2327
Danielgdrake@aol.com
Vel: (813) 662-1536
Fax: (813) 657-0859
Attorney for Plaintiff
Document Filed Date
December 30, 2014
Case Filing Date
December 30, 2014
Category
DELINQUENT TENANT - COUNTY
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Case Number: 14-010422-CO Filing # 22040688 E-Filed 12/30/2014 01:19:11 PM IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, STATE OF FLORIDA - CIVIL DIVISION FEIGA/CLAIRMONT, L.P., an New York limited partnership d/b/a BUENA VISTA I, Plaintiff, vs. HEATHER R. BLAYLOCK, Defendant / COMPLAINT FOR EVICTION Plaintiff FEIGA/CLAIRMONT, L.P. d/b/a BUENA VISTA 1 (hereinafter referred to as “PLAINTIFF”) hereby sues Defendant HEATHER R. BLAYLOCK (hereinafter referred to as “DEFENDANT”) and alleges: 1, This is an action to evict tenants from real property in Pinellas County, Florida. 2. PLAINTIFF owns the following described real property in Pinellas County, Florida, to- wit: 12100 Park Boulevard, Apt. 508, Seminole, Pincllas County, Florida. 3. DEFENDANT has possession of said real property under a written lease agreement pursuant to which DEFENDANT agreed to pay the sum of $982.00 per month as rent plus month-to- month fees. Said rent was due on or before the 1“ of cach month. A copy of said lease agreement is attached hereto as Exhibit A. 4. DEFENDANT failed to pay rent due of $1,080.36. DEFENDANT also owes late rent charges, which are deemed as additional rent under the terms of the lease (Exhibit A). DEFENDANT continues to accrue rent. 5. Pursuant to section 83.56, Florida Statutes, PLAINTIFF served DEFENDANT with a written 3-Day Notice December 4, 2014 stating that DEFENDANT was indebted to PLAINTIFF for unpaid rent and that DEFENDANT had three days to cure such indebtedness or vacate the leased premises. A copy of the above-referenced 3-Day Notice is attached hereto as Exhibit B. 6. DEFENDANT failed to pay the rent due within the time period set forth in the attached 3- Day Notice (Exhibit B) or vacate the leased premises. 7. PLAINTIFF has retained the undersigned counsel in this matter and is responsible to pay a reasonable fee for his services. PILAINTIFF is entitled to be reimbursed for said reasonable attorney’s fees pursuant to section 83.48, Florida Statutes, as well as the terms of the lease agreement (Exhibit A). ***ELECTRONICALLY FILED 12/30/2014 1:19:15 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***WHEREFORE, Plaintiff demands judgment against Defendant for possession of the leased premises described above, plus rent paid into the Registry of the Court (if applicable), and attorney's fees and costs pursuant to section 83.48, Florida Statutes. Respectfully submitted, Date: December 29,2014 Jett. Co seth Daniel G. Drake, Esq. Fla. Bar No. 054800 Post Office Box 2327 Brandon, FL 33509-2327 Danielgdrake@aol.com Vel: (813) 662-1536 Fax: (813) 657-0859 Attorney for Plaintiff