Under Section 7 of the lease, Black Crow Ventures is responsible for maintaining and repairing all structural, HVAC, plumbing, electrical, and roof systems at the premises — at Landlord's expense. That obligation went largely unmet.

Black Crow did not honor the lease. They failed to repair and maintain building systems that are vital to operating any business. We can't cook or serve guests in a building with broken HVAC. We can't operate when the plumbing is backed up due to the landlord not fixing the septic pumps.

We sent written requests asking Black Crow to meet their obligations. On April 30, 2025, we formally raised the issue by email — documenting the ongoing repair failures and their impact on the business — and requested a meeting. Shortly after, we met with Randy Meucke in person. He told us he would get the issues addressed. We told him we could not continue paying rent until he did. No repairs followed.

Over the course of our tenancy, we repeatedly notified Randy Muecke and his team of building system failures. When repairs were needed and the landlord failed to act, we paid for them ourselves just to keep the restaurant open. Our documented out-of-pocket repair costs total $33,213.18 — covering work by plumbers, HVAC contractors, and others on systems the lease required Black Crow to maintain.

Between 2024 and 2025, these are the individual service calls, all documented with invoices:

On May 3, 2024, the leak was severe enough to penetrate the kitchen ceiling. The videos below were taken that day.

When our HVAC contractor opened the unit on May 28, 2025, they found an air filter that had not been changed since September 2023 — nearly two years. The landlord is responsible for HVAC maintenance under the lease. A clogged filter causes the system to work harder, fail sooner, and degrade air quality in the restaurant.

On November 18, 2025, a water leak from the attic caused the kitchen ceiling to fail. This was a separate incident from the January 2026 sprinkler failure — the attic had an active leak months before the pipes burst.

On November 25, 2025, water was actively leaking through the vent hood above the cooking line.

On January 16, 2026, the fire suppression system failed completely. Water poured into the dining room for over an hour.

On January 16, 2026, the fire suppression system in the attic above our restaurant failed. The system is a "dry system," meaning no water should have been present in the pipes. Water was there because the system had not been properly maintained. When temperatures dropped, the pipes ruptured and the restaurant flooded.

Photographs taken that day show yellow NON-COMPLIANCE tags affixed to the sprinkler system riser.

An independent structural and systems inspection was conducted on March 4, 2026 by Palmer Construction Consultants, Inc. (GA PE Firm No. 004308). Their report identified 10 categories of deficiencies, including:

• Structural damage to the front stud wall, sill plate, and exterior sheathing requiring emergency roof shoring before any repair work could safely begin
• Active roof leaks
• Serious electrical hazards
• HVAC system failures

Black Crow received insurance funds to begin repairs in early February 2026. They began work on March 30, 2026.

On March 10, 2026, Pickens County Fire Rescue issued a formal inspection report for the building.

Repairs began March 30, 2026. Even during the active repair period, new obstacles have emerged.

The passageway dispute

The restaurant occupies two connected dining rooms. Randy Meucke verbally approved keeping the passageway between them open during the Servpro repair work. His only condition was written approval from the county. On April 15, 2026, we asked Pickens County Fire Marshal Jeremy Jones for that written confirmation. His response, the same day: no problem — he believed the passageway had been there previously and noted a second hallway already connected the two rooms. He asked to do a walkthrough when repairs were complete.

We forwarded that written approval to Randy and Lana Meucke the same evening, and asked them to inform the Servpro team.

The following morning, April 16, Black Crow's representative — Sam Hale of Hale Retail Group — responded in writing that "the landlord, after careful consideration, is unable to grant approval for your request at this time." No reason was given.

Section 6(C) of our lease states that the landlord's approval for tenant modifications shall not be unreasonably withheld or delayed. Randy Meucke had already approved this verbally, with our General Manager and the Servpro Project Manager both present. The County Fire Marshal had approved it in writing. There is no reasonable basis for the denial.

Fire suppression reimbursement

Section 3.B of the lease assigns responsibility for the fire suppression system — including fire extinguishers — to the landlord. When the system required inspection and repair to remain compliant, we had the work done rather than leave our employees and guests at risk. On April 16, 2026, we formally requested reimbursement from Black Crow for those costs, with supporting invoices and an estimate for additional approved work, and stated that reimbursement or equivalent rent deferral is expected within 30 days.