Filing # 235993336 E-Filed 11/17/2025 05:56:29 PM
`
`Lake House Apartments IN THE COUNTY COURT OF THE
`PLAINTIFF, 11TH JUDICIAL CIRCUIT IN AND
`
`FOR MIAMI DADE COUNTY, FLORIDA
`Vs.
`Patty Nance
`DEFENDANT, Case No.:
`
`COMPLAINT FOR RESIDENTIAL EVICTION
`
`Plaintiff, Lake House Apartments, (the “Plaintiff”) hereby sues the Defendant, Patty Nance
`(the “Defendant”), and alleges:
`
`COUNTI
`This is an action to evict Defendant from real property located in Miami-Dade County, Florida.
`2. Plaintiffs are the Landlord and the Defendant is the Tenant of the following described real
`property in Miami-Dade County, Florida:
`
`—
`
`21025 NW 22nd Avenue #131, Miami Gardens, FL 33056
`
`3. The Defendant has possession of the premises pursuant to a lease with the Plaintiff where they
`pay $1,800.00 per month. A copy of the Lease is attached hereto as Exhibit “A.”
`
`4. The Defendant breached the Tenancy by failing to pay for the months of October of 2025 and
`November of 2025.
`
`5. The Plaintiff served the Defendant via personal service with a Notice from Landlord to
`Tenant-Termination for Termination of the tenancy (“Three Day Notice”) on October 9, 2025. A
`copy of the Three day notice is attached hereto as Exhibit “B.”
`
`6. To date, the Defendant has not vacated the property or paid rent monies owed.
`
`7. The Plaintiff is requesting that the Honorable Court enter an order removing the Defendant from
`the property.
`
`8. The Plaintiff has retained the undersigned counsel to represent them in this action and have agree
`to pay a reasonable fee for their services rendered.
`
`9. All conditions precedent to the institution of this action have either occurred, been performed on
`have been waived.
`
`WHEREFORE, the Plaintiff demands Judgment against the Defendant or possession of the
`Premises, the costs of this action, and such other relief as this Court deems just and proper.
`
`LAW OFFICE OF BRIAN P. KOWAL, PA.
`7351 Wiles Rd. #103
`
`Coral Springs, Florida 33067
`
`(954) 990-7552
`
`bpkowal@gmail.com
`
`/s/ Brian P. Kowal, Esq.
`
`Florida Bar Number: 44386
`
`
`
`
`
`
`
`
`FAA
`
`Date'of Lease Contract:
`
`FLORIDA
`APARTMENT
`ASSOCIATION
`
`June 9, 2025
`(when the Lease Contract is filled out)
`
`APARTMENT LEASE CONTRACT
`
`This is a binding document. Read carefully before signing.
`
`~/
`
`Moving In — General Information l
`
`1.
`
`PARTIES:. This Lease Contract (sometimes referred to as the
`“lease") is between you, the resident(s) (list all people signing the
`Lease Contract):
`
`Patty Nance
`
`and us, the owner: Lake House Apartments Miami
`Gardens, LLC
`
`(name of apartment community or title holder). You've agreed to
`rent Apartment No. 21025-131 at 21025 NW
`22nd Avenue
`
`(street address) in Miami Gardens
`
`(city), Florida, 33056 (zip code) (the "dwelling unit” or
`the "premises”) for use as a private residence only. The terms "you"
`and “your” refer to all residents listed above. The terms "we,"” "us,”
`and "our” refer to the owner listed above (or any of owner's
`successors' in interest or assigns). Written or electronic notice to
`or from our managers constitutes notice to or from us. lfanyene
`else has guaranteed performance of this Lease Contract, a separate
`Lease Contract Guaranty for each guarantor is attached.
`
`The X Owner or ] Manager of these apartments is Lake
`House Apartments
`
`whose address is2601 NW 207th Street, Leasing
`Office Miami Gardens, FL 33056
`
`. Such person or company is authorized to receive
`notices and demands in the landlord's behalf.
`
`A lease termination notice must be given in writing. Notice to the
`landlord must be delivered to the management office at the
`apartment community or any other address designated by
`management as follows: 2601 NW 207th Street,
`Leasing Office Miami Gardens, FL 33056
`
`Except as otherwise required by applicable law, any notice required
`by this Lease or law shall be in writing and shall be deemed to be
`delivered to you if: (a) delivered personally; (b) sent electronically
`via email to any email address on file with us as provided by you;
`(c) posted to the door of your address shown above; or (d) mailed
`by U.S. First Class Mail to your address shown above.
`
`OCCUPANTS. Theapartmentwill be occupied only by you and (list
`all other occupants not signing the Lease Contract):
`
`No one else may occupy the apartment. Persons not listed above
`must not stay in the apartment for more than days
`without our prior written consent. If the previous space isn't filled
`in, two days per month is the limit.
`
`© 2023, National Apartment Association, Inc. - 7/2023, Florida
`Blue Moon eSignature Services Document ID: 512443636 |
`
`3.
`
`4.
`
`LEASE TERM AND TERMINATION NOTICE REQUIREMENTS.
`
`The initial term of the Lease Contract beginsonthe __1st day
`of July 2025 and ends at 11:59 p.m.
`the _30th day of June 2026 .
`
`This Lease Contract will automatically renew month-to-month
`unless either party gives at least __30 days' written notice of
`termination or intent to move-out as required by this paragraph
`and paragraph 47 (Move-Out Notice). If the number of days isn't
`filled in, at least 30 days’ notice is required. In the event you fail to
`provide us with the required number of days’ written notice of
`termination and intent to vacate coinciding with the lease expiration
`date, as required by this paragraph and paragraph 47 (Move-Out
`Notice), you acknowledge and agree that you shall be liable to us
`for liquidated damages in the sumof$ __1800.00 (equal to
`one month's rent) if we give you the advanced written notice
`required by Fla. Stat. § 83.575(2). This liquidated damages amount
`is exclusive to insufficient notice under this paragraph and
`paragraph 47 (Move-Out Notice), and does not limit collection rights
`with regard to other amounts potentially owed to us. If the lease
`term is not a month-to-month tenancy, we must notify you with
`written notice no later than __30 ___ days before the end of the
`lease term if the lease will not be renewed.
`
`Month-to-Month Tenancies: In the event this Lease Contract
`renews on a month-to-month basis, you must pay the amount of
`rent we charge at the time the month-to- th tenancy cc e:
`pursuant to this paragraph and paragraph 15 (Rent Increases and
`Lease Contract Changes), inclusive of any applicable month-to-month
`fees and/or premiums. We may change your rent at any time
`thereafter during a month-to-month tenancy by giving you no less
`than 30 days® written notice. You will be required to abide by all
`notice requirements set forth in the lease and remain liable to pay
`all other applicable charges due under the lease during your month-
`to-month tenancy unless specifically changed in writing. All sums
`due under this paragraph shall be additional rent. We may require
`you to sign an addendum written for month-to-month tenants.
`Either party may terminate a month-to-month tenancy by giving
`the other party written notice no later than 30 days' prior to the
`end of the monthly rental period. If you fail to provide us at least
`30 days' written notice to terminate a month-to-month tenancy
`priorto the end of the monthly rental period, you shall be liable to
`us for an additional 1 month's rent.
`
`SECURITY DEPOSIT. Unless modified by addenda, the total security
`deposit at the time of execution of this Lease Contract for all
`residents in the apartmentis$__1250.00 due on or before
`the datethis Lease Contract is signed.
`
`Any securitydeposit or advance rent you paid is being held in one
`ofthe following three ways as indicated below [Landlord check one
`option]:
`
`X 1. Inaseparate NON-INTEREST bearing account for your benefit
`in the following bank: Key Bank
`
`whose address is.
`
`; OR
`
`. In a separate INTEREST bearing account for your benefitin
`the following bank:
`
`whose address is
`
`If an interest bearing account, you will be entitled to receive and
`collectinterestin an amount of atleast 75 percent of the annualized
`average interestrate payable on such account or interestat the rate
`of 5 percent per year, simple interest, whichever the landlord elects.
`
`[ 3. In acommingled account at the following bank
`
`whose address is
`
`provided that the landlord posts a surety bond with the
`county or state, as required by law, and pays you interest on
`your security deposit or advance rentat the rate of 5 percent
`
`per year simple interest.
`Page 1 of 10
`
`“A”
`
`
`
`
`
`
`
`
`
`THREE (3) DAY NOTICE TO PAY RENT
`OR DELIVER POSSESSION
`
`TO: ‘PnrHr Y alanae
`
`Premises addres§ 014 NO 52 A 3 i3]
`City, State, Zip Miami Gardens, FL 33056
`County Miami-Dade County, Florida
`
`YOU ARE HEREBY NOTIFIED that you are indebted to Lake House Apartments, (landlords) in the
`
`sum of $ lq IB 00 for the rent and use of the above premises now occupied by you. Your rental
`
`agreement provides that the rent in the-amount of $_ [ 00 . OO0 shall be paid on the 1% day of
`
`each month. You have failed to make the required payment due for the month(s) of
`
`Oepeer 2025. The past due rent payment or possession of
`
`the premises is hereby demanded within three (3) days, excluding Saturdays, Sundays, and Legal Holidays,
`
`from the date of delivery of this notice, to wit: on or before’_October 15 , 2025. Payment or possession may
`
`be delivered to the landlord either at the location indicated below by mailihg the keys or via email or voice
`message using the landlord contact information indicated below. If you do not pay the rent due or vacate and
`deliver possession prior to the expiration of this Notice, your rental agreement shall be deemed terminated and
`the landlord will commence eviction proceedings.
`
`This notice is given to you pursuant to Florida Statutes 83.56 (3) and 83.59(1), Florida Statutes.
`
`PROOF OF SERVICE By:
`Name Kenisha Riettie , as Landlord
`This notice was served upon the person owing the rent. Full Address 2601 NW 207% Street, Office
`
`X The person owing the rent was absent from his/her usual Miami Gardens Flon'c;a 33056
`place of residence, and this Notice was left at the said Miami-Dade County
`residence by posting. Phone (305) 625-6586
`BY: ‘fi Email: assistantmanager(@lakchouse-apartments.com
`Kenisha Riettie as, agent for landlord DATE: _October 09, 2025
`
`Because of the global COVID-19 pandemic, you may be eligible for temporary protection from eviction under Federal law. Learn the
`steps you should take now: visit vwww.clpb.o ov/eviction or call a housing counselor at 800-569-4287
`
`“B”
`
`
`
`
`
`
`
`
`