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`16-2024-CC-014578-AXXX-MA Div: CC-D
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`IN THE COUNTY COURT FOR DUVAL COUNTY, FLORIDA
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`Case No: ___________________________
`Division: Civil-Landlord/Tenant
`
`
`Avner Holdings, LLC
`Plaintiff,
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`vs.
`Lamar D. Brooks
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`Defendant.
`_______________________________/
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`COMPLAINT FOR TENANT EVICTION
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`COMES NOW Avner Holdings, LLC,
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`and brings action against, Lamar D. Brooks, hereinafter
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`s as follows:
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`1. This is an action to evict a tenant from real property in Duval County, Florida.
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`2. Plaintiff is the landlord and Defendant is the tenant of the following described real property in the said county, 2125 Hyde Park
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`Road, Apt. 32, Jacksonville, FL 32210
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`3. Defendant has possession of the property under a month to month agreement to pay rent at $995.00 per month.
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`4. Defendant failed to pay the full rent amount due under the rental agreement.
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`5. Plaintiff served Defendant with a written notice on August 6, 2024 to pay the outstanding rent of $3,050.00 or deliver
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`possession, but Defendant refuses to do either. A copy of the notice is attached to this complaint.
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`6. Plaintiff has not received payment since notice was delivered to Defendant.
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`7. Plaintiff has retained the law firm of Kelley, Grant & Tanis, PA, and is obligated to pay said firm reasonable legal fees to
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`enforce said rights. Plaintiff is
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`
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`WHEREFORE, Plaintiff respectfully demands judgment for possession of the property against Defendant, costs, and
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`reasonable attorney fees for this matter, and that the Court order such further relief this Court deems just and proper.
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`
`
`
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`
`
`/S/ Jerron Kelley
`Jerron Kelley, Esq., FL Bar # 544191
`Kelley, Grant & Tanis, PA
`370 Camino Gardens Blvd., Suite 301
`Boca Raton, FL 33432
`1-877-871-8300
`Fax: 1-877-838-2912
`Email: eservice@kelleygrantlaw.com
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`ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 08/28/2024 02:38:54 PM
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`
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`1Was
`REALTY
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`08/06/2024
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`Avner Holdings
`
`Lamar D. Brooks
`
`2125 Hyde Park Road
`Jacksonville FL 32210 Duval County
`Apartment #32
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`FOURTEEN DAYNOTICE
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`TO PAY RENT OR DELIVER POSSESSION
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`You are herebynotified that you are indebted to me in the sum of _$3050.00_ for the rent, for the use of the
`premiseslocated at 2125 Hyde Park Road JacksonvilleFL32210 Apartment # 32 now occupied byyou, and that we
`demand paymentof the said rent or that you surrender possession of said premises within FOURTEEN (14) DAYS,
`excluding Saturdays, Sundays and legal holidays from the date of delivery of this notice: on 8/96/2024 Result in Eviction
`Proceedings being Instituted against you pursuant to CHAPTER FLORIDA STATUTES, SECTION 83.56(3)
`Termination of your tenancy does not relieve you of any of your obligations includingliability for rental payment.
`You are advised of your right to present a defense in person or by counsel in any judicial proceedingsfor eviction which
`maybeinstituted against you.
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`Avner Holdings
`4000 Hollywood Blvd Suite 555-S
`Pembroke Pines FL, 33084
`954 391 7712
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`Authorized Representative
`Marslline
`
`Angel
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`| hereby certify that | served the original of the foregoing notice upon the tenant(s) at the address, on the day 08/06/2024.
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`Delivery was made by:
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`_JOSe
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`Hand delivery directly to the tenant(s)
`Posting sameat the above-described premisesin the absenceof tenant(s)
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`JZ
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`“Because of the global COVID-19 pandemic, you maybeeligible for temporary protection from eviction under
`Federal law. Learn the steps you should take now: visit www.cfpb.gov/eviction or call a housing counselor
`at 800-569-4287.”
`
`
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