tri-state rental property management fiasco

[vabillys]

Need advice.
1. Own home used as rental property in FL.
2. Hired property manager (PM) to act as agent and manage property, 1year contract.
3. PM rented home out to tenant on 2 year lease.
4. Tenant broke lease, abandoned property 6 months later.
5. PM broke cour ontract, wrote letter saying no longer will manage property.
6. PM left state, tracked her down in TN.

Found out after the fact that PM was licensed as agent, not licensed as broker. In FL must have broker's license to be PM.

Questions:
Do i file suit in FL since this is where the PM managed the property and broke the law?
Do i file suit in Tennesse where she currently lives?
Do i file suit in Virginia, where i live?

 

[divgradcurl]

Either FL or TN would appear to be jurisdictionally correct, although you are probably best served filing in TN, because that state would have personal jurisdiction, and if you obtained a judgment and needed to enforce it, you would not need to domesticate the judgment.

 

[vabillys]

thanks

thank you for taking the time to reply. i am fliing the small claims case in TN as you suggested. beyond that, i an not sure what it means to have the judgenet domesticated. please explain.
one more question-how do i word my descripton of why i am suin the manager so as not to leave a loophole thru which she could wiggle out?

 

[tranquility]

As to filing suit, what are your damages here?

Doing things illegally does not mean there is a good reason to sue. How have you been hurt by the breach of the PM?

 

[vabillys]

lots of damages

PM failed to properly screen tenant-poor credit history
PM failed to collect deposits-tenant had a pet that was not aggredd to when she signed the lease
PM failed to supervise property and tenant resulting in damages to property- we received a letter from the county code enforcement office b/c the lawn was out of control, also there was an abandoned vehicle on the property.
we've had over 20k in damages. when the tenant vacated the property, there was no wirtten notice. we had to keep the property vacant while court procedures went on for proper eviciton.
we had to replant the entire front lawn b/c of the neglect to the lawn, repaint and recarpet the interior, plus the loss of 10 months of rent. (until the hose was rerented, not including the remainder of the lease which was broken)
the PM dropped us like a hot cake as soon as things got sour. the stress was unbelievable, the PM knew (and took advantage of the fact) that my husband had left a week earlier for a 6 month deployment, i was 6 months pregnant and could not travel to FL.