MOTION FOR INJUNCTIVE RELIEF

STATE OF MINNESOTA                                                     DISTRICT COURT SECOND

COUNTY OF RAMSEY                                                        JUDICIAL DISTRICT

My name is La’Mont Knazze III.

My written statement if facts is:

1. Defendant North End Storage and its prior owners have leased a double storage unit to Plaintiff for a period of about 7 years.
2. 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. 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. In the fall of 2019, Defendant North End Storage required me to relocate my 53-foot commercial trailer from the location where the said Defendant had 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  the said Defendant’s lot, in front of its  rear gate, which was secured by a locking system.
5. 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. I confirm that I have duly paid all rents.
7. 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. 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. 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. 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. 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 or authorization and breached the trust and due process. Accordingly, the burglary at the Defendant’s North End Storage facility resulted in the theft of most of my trailer contents. Defendant North End Storage also damaged the right side of the trailer door, seemingly in an attempt to open the trailer.
12. 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 amicably. Defendant after the Complaint with Attorney General shared the security code with me but have not done anything to compensate the damage caused by their breach.
13. 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 me back. As at the time of this Complaint, the Las Vegas office had refused to contact me and did not pick up any of my phone call.
14. As at the time of this Complaint, Defendant North End Storage’s facilities continue possessing my vehicle, which I requested to move out of their facility. This constitutes a denial of property that belongs to me.
15. Although my rent has been fully paid, in excess, Defendants also demanded that I relocate the trailer, at my own cost. The said relocation was not only a   great expense to me but also caused the theft of my items in the trailer as well as great loss to me.
16. Defendants have also, in addition to all this, inappropriately, and unlawfully delayed in sharing the security code with me to access the storage facility, which denial continues to infringe in my constitutional rights.
17. 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.
18. On or about February 1, 2021, 4^th Defendant, North End, submitted a notice of business transfer and demanded that all future storage payments be submitted to the 17^th Defendant of address: 1370 Gopher State Storage, 9450 SW Gemini DR Suite 85473, Beaverton, OR 97008-7105.
19. I have complied with all the Defendants unnecessary and inconsiderate demands but despite that, they have refused and/or neglected to give me access to my property.
20. Plaintiff filed a Motion for Leave to File Amended Complaint, to remove some Defendants from the case.
21. Plaintiff has dismissed his claims against Defendant SPRINT SPECTRUM, LP DBA STC FIVE LLC. This was done vide a spoilation letter to the said Defendant dated April 30, 2021 and said Defendant’s confirming correspondence on May 10, 2021.
22. In the circumstances, I swear this affidavit in support of the motion for injunctive relief.

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: