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ESTADO DE IA/ISCONSIN CORTE DE CIRCUITO RECLAMOS PEOUENOS CONDADO MILWAUKEE
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exo¡es 512912011
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It Case No.
CodeNo.31004
KENNETH P. SKOWRONSKI, and
KS REMODELERS,INC.
1 1 I 13 West Forest Home Avenue
COMPLAINT
Now comes the above-named plaintiff, and as and for causes of actions against the above-named
defendant, respectfully shows to the Court as follows.
1. The plaintiff, Commercial Property Developers, LLC ("CPD") is, and at all times
hereinafter mentioned, a domestic limited liabilrty company duly organized and existing under the laws of
the State of Wisconsin, having its main business offices located at tI723 West Forest Home Avenue,
'Wisconsin
53132. The plaintiff is engaged in, among other things, owning and managing real estate.
The plaintiff is the owner of the premises located at 1 1 1 13 West Forest Home Avenue, Franldin, Wisconsin,
which the defendants occupy under a Modification of Occupancy agreement.
2. At all times hereinafter mentioned, upon information and belief, the defendant, KS
Remodelers, Inc., is a domestic corporation duly organized and existing under the laws of the State of
Wisconsin, having its main business address located at i 1 I 13 West Forest Home Avenue, Franklin,
Wisconsin 53132. The registered agent for said company is the defendant, Kenneth P. Skowronski
("Skowronski"), who can be served at the above address. Although KS Remodelers, Irc. occupies the
space, the Agreement is between the plaintiff and Skowronski, personally.
3, On or about May 31, 2009,the plaintiff and defendant, Skowronski, entered into a written
Modif,rcation of Occupancy Extension of Due Date agreement ("Agreemenf) for the defendant to occupy
designated space in the plaintiffs commercial business property located at 11113 West Forest Home
Avenue, Franldin, Wisconsin.
4. The Agreement, attached hereto as Exhibit A, explicitly states that the Skowronski shall
vacate the shop and storage units he was occupying at the time of the Agreement and shall occupy only 625
feet of hrst floor office space.
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5. The Agreement explicitly st¿tes that Skowronski will be responsible for electric and heating
expenses for the office space occupied.
6. The defendant, Skowronski, is currently delinquent in the payment of electric and heating
expenses, for which he is responsible, in the total amount of $2,987 .7 6.
7.The defendant has breached the Agreement by failing to vacate the shop and storage units,
which remain occupied with his personal property.
8. The defendant has breached the Agreement by fallingto reduce his occupancy of the
building to the designated 625 feet of lower level office space.
9 . The defendant was served with a Five Day Notice to Pay or Yacate on February 23, 2010.
10. The defendant is in possession of the premises without permission of the plaintiff.
11. The plaintiff realleges all the material allegations set forth above in the First Cause of
Action as though fully set forth herein at length.
1.2.
There is still due and owing to the plaintiff from the defendant delinquent electric and
heating expenses due pursuant to the terms of the Agreement in the amount of 52,987.76.
13. There is further due frorn the defendant damages to the premises in an amount to be
determined at the time of the trial in this matter.
WHEREFORE, the plaintiffs seek the following relief against the defendant:
A. Pursuant to the First Cause of Action, for an Order of the Court removing the defendants,
Skowronski and KS Remodelers, Inc. frompossession or access to any and all units/areas
the premises located at 11113 West Forest Home Avenue, Franklin, 'Wisconsin, and that the
plaintiffbe restored the possession thereof.
B. Pursuant to the Second Cause of Action, for judgment against the defendan! Skowronski,
in an amount to be determined at the time of the hial. with interest from the date of
commencement of this action.
D. For such other relief as the Court deems just and equitable.
units currently
P. Skovsronski shall also vacate the shop and storage
utilized by'him.
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The outside space shall conJinìle ^"*anflr;occupÍed âs provlot''gd forrurdgr thg
oo currently
@Ivano DipieTrantonio
Comñercial
Kenneth Plskounonski