STATE OF MINNESOTA
IN DISTRICT COURT
COUNTY OF PENNINGTON NINTH JUDICIAL DISTRICT
AMENDED EVICTION
ACTION COMPLAINT
Case Type: Eviction
Court File No.: 57-CV-25-245
Jamar North Rentals, LLC,
Plaintiff,
vs.
Nichole Glenn,
and
James Cooley,
Defendants.
TO: THE ABOVE-NAMED DEFENDANTS, NICHOLE GLENN, P.O. BOX 113, GOODRIDGE, MINNESOTA 56725, AND JAMES COOLEY, ADDRESS UNKNOWN.
1. The Plaintiff is Jamar North Rentals, LLC, of Thief River Falls, Minnesota, hereafter, the Landlord.
2. The Defendants are Nichole Glenn and James Cooley, hereafter, the Tenant.
3. The Landlord leased or rented to Tenant Nichole Glenn, 915 Pleasant Avenue, Lot #58, Thief River Falls, Minnesota 56701, by written agreement on April 1, 2013. The rent is Ninety-five Dollars ($95) a month and is due and payable by the 10th of each month.
The owner of the mobile home located at 915 Pleasant Avenue, Lot #58, Thief River Falls, Minnesota 56701, is Tenant James Cooley.
4. The Landlord having present right of possession of said property, has complied with Minn. Stat.§ 504B.181 by:
a. Disclosing to the Tenant either in the rental agreement or otherwise in writing prior to beginning of the tenancy the name and address of the person authorized to manage the property and a landlord or agent authorized by the landlord to accept service or process and receive and give receipt for notices and demands, AND
b. The above information was known by the Tenant not less than thirty (30) days before filing this action because the Tenant signed the rental agreement on April 1, 2013, and received a copy of the rental agreement.
5. The Landlord seeks to have the Tenant evicted for the following reasons:
a. The Tenant is still in possession of the premises and has failed to pay rent each month. The outstanding rent due to the Landlord totals One Thousand, Five Hundred Twenty Dollars ($1,520) as of the date of this complaint.
6. For the above-stated reasons, the Landlord seeks restitution of the premises within fourteen (14) days; the Landlord seeks restitution for costs and attorney fees for having to bring this matter before the court; and the Landlord seeks an Order from the Court that the Defendant would remove their trailer home from the premises no less than fourteen (14) days from the date of the eviction.
7. For any other and further relief the Court deems just and necessary.
VERIFICATION OF NON-MILITARY STATUS
I, Denise A. Sollund, being affirm that I am the Plaintiff’s attorney in this action, that I have read the complaint and that it is true to the best of my knowledge; that Tenant is not now in the military service of the United States, to the best of my information and belief.
Dated this 27th day of May, 2025
ROKKE, AANDAL & ASSOCIATES, PLLC
/s/ Denise A. Sollund (#0386727)
Attorneys for Plaintiff
423 N Main Street
P.O. Box 159
Warren, MN 56762
(218) 436-2324
dsollund@ralawoffice.com