Affidavit in Support of Motion for Default Judgment

STATE OF XXX DISTRICT COURT SECOND 

COUNTY OF XXX                                                      JUDICIAL DISTRICT

I, XXX, do hereby swear a solemn oath and states as follows: 

1. THAT Defendant North End Storage and its prior owners have leased a double storage unit to Plaintiff for a period of about 7 years.
2. THAT Defendant North End Storage has also leased space to me to park my 53-foot commercial trailer in the Defendant’s storage facility for approximately five years.  
3. THAT to entice me to lease space, the Defendant North End Storage recommended its site as a secure facility, featuring controlled access via an electric powered gate, with barbed wire and other security features.
4. THAT in the fall of XXX, Defendant North End Storage required me to relocate my 53-foot commercial trailer from the location where Defendant North End Storage directed me to park it years earlier, and to do so at my own expense, under direct threat by Defendant North End Storage to have the trailer towed to an impound lot. I complied with the sudden request and positioned the trailer on the southeastern portion of Defendant’s North End Storage lot, in front of Defendant’s North End Storage rear gate, which Defendant North End Storage secured by a locking system.
5. THAT Defendant North End Storage failed to provide the access to me as promised, and instead surrounded my trailer by other vehicles, including other, large commercial vehicles, making access to my trailer nearly impossible. My trailer was also immobilized due to the way it was surrounded by the said vehicles. I repeatedly requested that Defendant remove the vehicles to afford my reasonable and necessary access to my 53-foot commercial trailer. However, Defendants never granted my request.
6. THAT I have duly paid all rents.
7. THAT my storage locker that he had taken on rent had the locks cut off. The perpetrators burglarized the unit, took many items, even a 12-foot bay window, among numerous other windows, a brand-new garbage disposal, lamps, chandeliers, doors, stone, tile, wine coolers, wood and many other items were stolen. I reported the theft to the Defendant.
8. THAT I repeatedly asked the Defendant North End Storage to move the vehicles surrounding his commercial trailer so he could take his trailer and all of the remaining belongings out of storage, but the Defendant North End Storage did not move the other vehicles that were boxing my 53-foot trailer so I couldn’t get the trailer moved out.
9. THAT on or about May 16, 2020, I visited the premises of the Defendant North End Storage that I had paid rent to park his trailer. But I could not enter since Defendant North End Storage has changed the entire entry security pad to a new yellow box and did not give me the security code.
10. THAT I then went to the Defendant’s North End Storage 1379 Rice St. office, the mother of the Manager (Jake) was there. They refused to give me the code. I followed her into the facility. Upon entry, I noticed that Defendant North End Storage still had their red lock on my storage unit, and the 53- foot commercial trailer had ball peen hammer marks all over the aluminum sheathing where my lock used to be. The trailer was open, and a lot of my items were stolen. 
11. THAT neither I nor anyone else with my authorization had removed a single item from the trailer. There is also no agreement that permits the Defendant North End Storage to empty the stored items. Defendant North End Storage did so without any notice and breached the trust and due process. Accordingly, the burglary at the Defendant’s North End Storage facility resulted in the theft of the of my trailer contents. Defendant North End Storage also damaged the right side of the trailer door, obviously trying to open it with something.
12. THAT I filed a Complaint against the North End Self Storage with the Attorney General on 19 May 2020. Attorney General directed the Defendant to resolve the issues with me swiftly and amicable. Defendant after the Complaint with Attorney General shared the security code with Plaintiff but have not done anything to compensate the damage caused by their breach. 
13. THAT I reached Jennifer at the Defendant’s North End Storage Las Vegas office 702-546-7226 and gave her the aforementioned details. She said someone would call her back. As at the time of this Motion, Complaint, the Las Vegas office has refused to contact me and did not pick up my phone call.
14. THAT Defendant Karl Pigg uttered discriminatory remarks against me to wit, “when I talked to you on the phone, I thought you were going to be, uh taller, and uh, lighter”. 
15. THAT as at the time of this Motion, Defendant North End Storage’s facilities continue possessing my vehicle, which he requested to move out of their facility. This constitutes a denial of property that belongs to me.
16. THAT although, my rent has been fully paid, in excess, Defendants also demand that I relocate the trailer, which resulted in great expense to me and caused theft of items in trailer and loss to me.
17. THAT Defendants have also, inappropriately, and unlawfully delayed in sharing the security code with me to access the storage facility that caused me to suffer great loss.
18. THAT despite demands made by me to give security code and remove vehicles surrounding my trailer to take all of my remaining personal property, Defendants have failed to do so and return my personal property contrary to the lease Agreement. Defendants have failed to cooperate with the police to investigate the burglary of my goods while the trailer was in Defendant’s premises.
19. THAT on or about February 1, 2021, 4th Defendant, North End, submitted a notice of business transfer and demanded that all future storage payments be submitted to the 17th Defendant of address: 1370 Gopher State Storage, 9450 SW Gemini DR Suite 85473, Beaverton, OR 97008-7105.
20. THAT as at the time of the Motion, Defendant North End Storage’s facilities continue possessing Plaintiff’s vehicle, which he requested to move out of their facility. This constitutes a denial of property that belongs to the Plaintiff.
21. THAT I filed a Complaint against the Defendants for the aforesaid reasons. 
22. THAT the Defendants have failed to provide an answer or respond to my Complaint within the required twenty (20) days. 

I declare under penalty of perjury that everything that I have stated in this document is true and correct. Minn. Stat. § 358.116.

Dated: ENTER DATE Respectfully submitted:

At Legal writing experts, we would be happy to assist in preparing any legal document you need. We are international lawyers and attorneys with significant experience in legal drafting, Commercial-Corporate practice and consulting. In the last few years, we have successfully undertaken similar assignments for clients from different jurisdictions. If given this opportunity, we will be able to prepare the legal document within the shortest time possible.