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- Oct 2, 2025
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IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION
PetitRenard_
Plaintiff
v.
Department of Construction & Transportation
Defendant
COMPLAINT
The Plaintiff complains against the Defendant as follows:
I received plot c115 in clean condition with no violations whatsoever. Then, within just hours of receiving it, the Department of Construction & Transportation filed an eviction report against me. I immediately got to work on the construction and made real progress, but when I requested a deferral, they rejected it without any explanation or legal basis. Their arbitrary refusal to grant me an exemption under Section 20(1) of the Property Standards Act has costed me $70,000 in plot value and construction costs.
I. PARTIES
II. FACTS
III. CLAIMS FOR RELIEF
F͟a͟i͟l͟u͟r͟e͟ ͟t͟o͟ ͟G͟r͟a͟n͟t͟ ͟E͟x͟e͟m͟p͟t͟i͟o͟n͟ ͟U͟n͟d͟e͟r͟ ͟S͟e͟c͟t͟i͟o͟n͟ ͟2͟0͟(͟1͟)͟:͟
T͟h͟e͟ ͟P͟l͟a͟i͟n͟t͟i͟f͟f͟ ͟s͟e͟e͟k͟s͟ ͟t͟h͟e͟ ͟f͟o͟l͟l͟o͟w͟i͟n͟g͟ ͟f͟r͟o͟m͟ ͟t͟h͟e͟ ͟D͟e͟f͟e͟n͟d͟a͟n͟t͟:͟
By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.
DATED: This 11th day of October, 2025
SimplyPiano - Attorney for Plaintiff
CIVIL ACTION
PetitRenard_
Plaintiff
v.
Department of Construction & Transportation
Defendant
COMPLAINT
The Plaintiff complains against the Defendant as follows:
I received plot c115 in clean condition with no violations whatsoever. Then, within just hours of receiving it, the Department of Construction & Transportation filed an eviction report against me. I immediately got to work on the construction and made real progress, but when I requested a deferral, they rejected it without any explanation or legal basis. Their arbitrary refusal to grant me an exemption under Section 20(1) of the Property Standards Act has costed me $70,000 in plot value and construction costs.
I. PARTIES
- PetitRenard_
- Department of Construction & Transportation
II. FACTS
- On September 24, 2025, Plaintiff received ownership of plot c115 with no active violations or eviction reports on file.
- On the same day, September 24, 2025, the Defendant filed an eviction report against plot c115 citing Non-Compliance for Invalid commercial use/purpose.
- The eviction date was set for October 8, 2025, providing fourteen days from the filing date for compliance.
- Throughout the fourteen-day compliance period, Plaintiff actively constructed the building and made substantial progress toward meeting zoning and construction requirements.
- Plaintiff submitted a request for an eviction deferral to the Defendant in accordance with DCT policy.
- On or about October 8, 2025, the Defendant rejected Plaintiff's deferral request without providing legal justification or applying Section 20(1) of the Property Standards Act.
- The Defendant proceeded with eviction on October 8, 2025.
- As a direct result of the eviction, Plaintiff lost ownership of plot c115 and incurred damages totaling $70,000 in lost plot value and construction costs.
III. CLAIMS FOR RELIEF
F͟a͟i͟l͟u͟r͟e͟ ͟t͟o͟ ͟G͟r͟a͟n͟t͟ ͟E͟x͟e͟m͟p͟t͟i͟o͟n͟ ͟U͟n͟d͟e͟r͟ ͟S͟e͟c͟t͟i͟o͟n͟ ͟2͟0͟(͟1͟)͟:͟
- Section 20(1) of the Property Standards Act grants the DCT Secretary authority to issue exemptions when significant progress is being made to rectify a breach.
- Plaintiff demonstrated substantial progress within the fourteen-day compliance period, meeting the criteria established in Section 20(1).
- The Defendant's rejection of Plaintiff's deferral request without applying Section 20(1) was arbitrary, unjustified, and violated the Plaintiff's right to fair administrative process.
- The Defendant failed to exercise its discretionary authority lawfully and deprived Plaintiff of relief to which Plaintiff was entitled under law.
T͟h͟e͟ ͟P͟l͟a͟i͟n͟t͟i͟f͟f͟ ͟s͟e͟e͟k͟s͟ ͟t͟h͟e͟ ͟f͟o͟l͟l͟o͟w͟i͟n͟g͟ ͟f͟r͟o͟m͟ ͟t͟h͟e͟ ͟D͟e͟f͟e͟n͟d͟a͟n͟t͟:͟
- Reversal of the eviction of plot c115.
- Reinstatement of Plaintiff's ownership of the property.
- An exemption or extension under Section 20(1) of the Property Standards Act to allow Plaintiff to complete construction.
- Damages in the amount of $70,000 for losses directly caused by the improper eviction, including lost plot value and construction costs.
- Such other and further relief as the Court deems just and proper.
By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.
DATED: This 11th day of October, 2025
SimplyPiano - Attorney for Plaintiff