STATE OF MINNESOTA CIVIL DISTRICT COURT

COUNTY OF RAMSEY SECOND JUDICIAL

DISTRICT

LA’MONT KNAZZE III, PRO SE Court File No.: 62-CV-21-494

Plaintiff, Judge: Laura Nelson

v.

THE RICCIARDELLA TEAM, INC.; CRYSTAL VIEW

CAPITAL MANAGEMENT LLC; CRYSTAL VIEW PLAINTIFF’S MOTION
HOLDING CO II LLC, D/B/A NORTH END SELF FOR AN EXTENSION OF
STORAGE MN LLC; CRYSTAL VIEW HOLDING CO TIME TO FILE AN
III LLC, D/B/A NORTH END SELF STORAGE MN AMENDED LIST OF
LLC; MATTHEW JACOB RICCIARDELLA (in his PARTIES/CASE CAPTION
individual and official capacity);BRYAN PATRICK
BARZ (in his individual and official capacity);
NOKEY’S 24 HOUR TOWING AND WRECKING
SERVICE; NOKEY LAMAR ANDERSON (in his
individual and official capacity); LOWRELL ROYAL
ANDERSON (in his individual and official capacity);
LOWRELL CURTIS ANDERSON (in his individual and
official capacity); CHRISTOPHER TRUJILLO (in his
individual and official capacity); KARL JOSEPH PIGG
(in his individual and official capacity); JACOB
CARROLL (in his individual and official capacity);
JANE DOE (Jacob Carroll’s Mother) (in her individual
and official capacity); JANE DOE (Jennifer) (in her
individual and official capacity); ST PAUL GOPHER
STATE STORAGE; GOPHER STATE STORAGE ST
PAUL; 1370 GOPHER STATE STORAGE; and,
SPRINT SPECTRUM, LP DBA STC FIVE LLC

NOTICE OF MOTION AND MOTION

 To: The Above-named Defendants

PLEASE TAKE NOTICE that at a date and time be determined by the Court,

PLAINTIFF, La’Mont Knazze III, will move the Court (Judge Laura Nelson) for leave for

extension of time to file an amended list of parties/case caption and amendment to pleadings.

Dated: January 7, 2023, Respectfully submitted:

La’Mont Knazze III, Pro Se

7240 60th Ave. N #7
New Hope , MN 55428
Phone: (952) 217-8004
Email: montiknazze@gmail.com
 PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO FILE AN AMENDED

LIST OF PARTIES/CASE CAPTION

Plaintiff, respectfully alleges that:

1. On February 9, 2022 Plaintiff filed a motion for the third amendment of Pleadings;

this Honorable Court heard the motion on February 23 2022 but has yet to pass an

order in the above-mentioned motion.

2. It is submitted that as per the scheduling order, the time period for filing joinder of

parties and amendment to pleadings was set till 21st March 2022.

3. The Plaintiff hoped to file the amended list of Parties/case Caption with the third

amendment of pleadings.

4. On February 9, 2022 Plaintiff filed a motion for the third amendment of

Pleadings; this Honorable Court heard the motion on February 23, 2022 but has

yet to pass an order in the above-mentioned motion.

5. While Plaintiff is eagerly waiting for the order allowing the amendment to the

Pleadings, whether or not such a motion is permitted by the Court, Plaintiff finds it

necessary to amend the list of parties/case caption and remove all unnecessary

defendants from pleadings.

6. It is submitted that Plaintiff being Pro-se, was not well aware of the proper

procedures, the Plaintiff was hoping to introduce all the amendments and changes

in the case caption through order on the motion allowing for the third amendment

of Pleadings.

7. The undersigned Pro se Plaintiff could not file the said Amendment to List of

Parties/Case Caption by the assigned date of March 21, 2022 and would need an

additional 30 days with the leave of Court to file the respective motion to amend

Case Caption along with amendments.

 8. Missing the deadline was inadvertent, Plaintiff has acted expeditiously and in good

faith, however, the expected order from the Court concerning his amended

complaint which was expected to have been issued significantly in advance of

March 21, 2022 has not yet been received by Plaintiff, and allowing this motion

will not prejudice the Defendants in any way, rather it would reduce the burden on

all parties.

This motion is being filed due to the reason above-stated and not to delay the instant

case.  

       WHEREFORE, Plaintiff prays that he be 1) granted an additional thirty (30) days to

submit the Amended List of Parties/Case Caption from the date of passing of the order.

Dated: January 7, 2023.

Respectfully submitted:

La’Mont Knazze III, Pro Se

7240 60th Ave. N #7
New Hope , MN 55428
Phone: (952) 217-8004
Email: montiknazze@gmail.com
 I. CERTIFICATE OF SERVICE

Plaintiff affirms under penalties of perjury that a copy of Plaintiff’s Notice of Motion, was

served upon the parties to this action by electronic and/or U.S. mail to their respective

addresses as stated below:

North End Storage MN LLC

Meagher & Geer, P.L.L.P.
33 South Sixth Street, Suite 4400
Minneapolis, MN 55402
Tel. (612) 338-0661
Ariel K. Lierz
Tony R. Krall
Email: tkrall@meagher.com
Email: alierz@meagher.com

State Storage Saint Paul LLC

State Storage Midwest LLC
3829 Foss Rod, Minneapolis, MN 55421

& 1370 Gopher State Storage

9450 SW Gemini DR Suite 85473
Beaverton, OR 97008-7105
Dylan Rybak
Tel. (651) 489-3344
Email: stp@statestoragegroup.com

Date: April 15, 2022

 CERTIFICATE OF SERVICE

I hereby certify that I served the foregoing Motion for Extension of Time via the U.S.

and/or electronic mail on counsel listed on the below Service List.

Respectfully submitted:

La’Mont Knazze III, Pro Se

7240 60th Ave. N #7
New Hope , MN 55428
Phone: (952) 217-8004

Acknowledged this 15th Day of April, 2022

By:

Notary Public