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DOCUMENT 2

ELECTRONICALLY FILED
4/4/2016 12:29 PM
41-CV-2016-900104.00
CIRCUIT COURT OF
LAUDERDALE COUNTY, ALABAMA
MISSY HOMAN, CLERK

IN THE CIRCUIT COURT FOR LAUDERDALE COUNTY, ALABAMA

Greater Alabama Building, L.L.C.,


an Alabama limited liability company,
Plaintiff,
v.

Robinson Capital Investments,


LLC, an Alabama limited liability
company

Civil Action No. ___________________

and
Bryan Robinson, an individual
Defendants.

COMPLAINT

Plaintiff, Greater Alabama Building, L.L.C., an Alabama limited liability


company, by and through the undersigned counsel, files this complaint against
Defendants, Robinson Capital Investments, LLC, an Alabama limited liability
company, and Bryan Robinson, individually, and in support thereof states as
follows:
1.

Plaintiff Greater Alabama Building, L.L.C. (Greater Alabama) is a

limited liability company organized and existing under the laws of the State of
Alabama with principal offices in Lauderdale County, Alabama.

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DOCUMENT 2

2.

Defendant Robinson Capital Investments, LLC (Robinson Capital) is

a limited liability company organized and existing under the laws of the State of
Alabama with offices in Lauderdale County, Alabama.
3.

Defendant Bryan Robinson (Mr. Robinson), upon information and

belief, is over the age of 19 years and a resident of Lauderdale County, Alabama.
4.

The Court has jurisdiction over this matter pursuant to Alabama Code

12-11-30(1) (1975).
5.

Venue is proper pursuant to Alabama Code 6-3-2(a)(2) and 6-3-7(a)

(1975).
FACTS
6.

On or about May 1, 2015, Robinson Capital entered into a written

Office Lease Agreement (the Lease) with Greater Alabama. A copy of the Lease is
attached to this Complaint.
7.

Also at that time, Mr. Robinson, in his individual capacity, executed a

Personal Guaranty in which he unconditionally and absolutely guarantees full and


prompt payment and performance of all rent, liabilities, and obligations by
Robinson Capital under the Lease.
8.

The term of the Lease is from May 1, 2015 through April 30, 2020, and

Robinson Capital agreed to pay total rent of $245,824.20 under the Lease.
9.

The Lease further provides for monthly rental payments of $3,866.67

for the first year, with the monthly rental payment increasing each year.

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Count 1
Plaintiff adopts and incorporates paragraphs 1 through 9 and further states
as follows:
10.

Robinson Capital failed to pay the monthly rental payment for

February of 2016.
11.

Greater Alabama sent a letter to Robinson Capital on February 18,

2016, informing Robinson Capital that it was in default under the Lease and
demanding immediate payment of the February rent. A copy of that letter is
attached as an exhibit to this Complaint.
12.

Based on its failure to pay the monthly rent for February 2016,

Robinson Capital has breached the Lease, and that breach continues at the time of
this filing.
13.

As a proximate result of Robinson Capitals breach of the Lease,

Greater Alabama has incurred a loss of future rent under the agreement.
WHEREFORE, THE PREMISES CONSIDERED, Plaintiff demands
judgment against Defendants Robinson Capital Investments, LLC and Bryan
Robinson for the amount of back rent due under the Lease, the amount of lost
future rent under the Lease, late fees, court costs, attorney fees, pre- and postjudgment interest, and such other and further relief as the Court may deem
appropriate.

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DOCUMENT 2

This 4th day of April, 2016.

Respectfully submitted,
/s/ Andrew J. Spry
Andrew J. Spry
(SPR031)
Yates & Spry, P.C.
102 South Court Street, Suite 506
Florence, Alabama 35630
P: (256) 764-7331
F: (256) 764-0766
Attorney for Plaintiff

Plaintiff to obtain service on the Defendant Robinson Capital Investments,


LLC by certified mail, return receipt requested to its Agent for Service of
Process, National Registered Agents Inc., 150 South Perry Street,
Montgomery, Alabama 36104.
Plaintiff to obtain service on the Defendant Bryan Robinson by certified
mail, return receipt requested at his address of record.

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