The Lease

The foundation of every claim on this site. Special Stipulation 4 grants North Gate the exclusive right to operate a restaurant, food operation, bar, or alcohol retailer in the plaza.

Lease Agreement — 60 North Gate Station December 2023

Signed lease between 60 North Gate Station LLC and Black Crow Ventures, including Special Stipulation 4.

View Document
Lease — Signature Page December 2023

Signed signature page of the lease.

View Document
The Exclusivity Dispute

Documents from June–November 2025: five months of outreach, two formal letters, and a legal complaint — all before the flood.

Email: Clarification on Food Use Restriction June 27, 2025

First outreach to Black Crow after learning Polar Bear sold its operations to a buyer planning a restaurant.

View Document
Letter: Enforcement of Lease — Exclusive Rights August 25, 2025

Formal written demand to Black Crow to enforce Special Stipulation 4.

View Document
Email: Enforcement of Lease (sent) August 2025

Email transmitting the lease enforcement demand to Black Crow.

View Document
Email: Reply re Enforcement of Lease August–September 2025

Reply thread on the lease enforcement email.

View Document
Email: Meeting Request 2025

Request to Black Crow to arrange a meeting with Coffee Ten to resolve the conflict.

View Document
Email: Re — Meeting Request 2025

Response to the meeting request.

View Document
Email: URGENT — 5th Attempt to Connect 2025

Fifth attempt to reach Black Crow or Coffee Ten for a meeting before filing.

View Document
Email: Re — Meeting with Paul (coffee shop) 2025

Email thread regarding a meeting with the Coffee Ten operator.

View Document
Letter: Black Crow to North Gate — Waiver Request November 10, 2025

Black Crow acknowledges North Gate's exclusive rights and requests North Gate waive them.

View Document
Letter: Because Coffee Ten — Opening Anyway November 2025

Coffee Ten acknowledges the potential conflict with North Gate's lease and states they intend to open regardless.

View Document
Letter: Black Crow — Default Notice November 14, 2025

Black Crow's default notice to North Gate, issued four days after their waiver request was declined.

View Document
Complaint (Original, with Exhibits) November 2025

North Gate's filed complaint seeking enforcement of exclusive rights.

View Document
First Amended Complaint 2026

Amended complaint adding claims related to the January 16 flood.

View Document
Motion for Temporary Restraining Order and Preliminary Injunction 2025–2026

North Gate's motion seeking an emergency injunction to stop Coffee Ten's conflicting operation.

View Document
Order Denying Motion for TRO and Preliminary Injunction February 13, 2026

Court order denying North Gate's motion for a temporary restraining order.

View Document
Building Maintenance & Repairs

Invoices, emails, and letters documenting the repairs North Gate paid for that were Black Crow's lease obligations.

Repair Invoice Summary — All Vendors 2024–2025

Itemized record of $33,213.18 in repairs paid by North Gate for Black Crow's lease obligations.

View Document
Invoice 23101 2024

Vendor repair invoice.

View Document
Invoice 23392 2024

Vendor repair invoice.

View Document
Invoice 24021 — Armor Plumbing 2024

Armor Plumbing repair invoice.

View Document
Invoice 25305 2024–2025

Vendor repair invoice.

View Document
Invoice 25355 — Armor Plumbing (emergency pumping) 2024–2025

Armor Plumbing emergency pumping invoice.

View Document
Invoice 25395 — Armor Plumbing ($988) 2024–2025

Armor Plumbing repair invoice, $988.

View Document
Invoice 25408 2024–2025

Vendor repair invoice.

View Document
Invoice 27271 — Armor Plumbing ($988) 2024–2025

Armor Plumbing repair invoice, $988.

View Document
Invoice 28039 2024–2025

Vendor repair invoice.

View Document
Invoice — Denson Heating & Air 2024–2025

HVAC repair invoice.

View Document
Invoice — Blossman Gas & Appliance 2024–2025

Gas appliance repair invoice.

View Document
Email: Request to Meet — Property Repairs & Business Impact 2024–2025

Written request to Black Crow to meet about unresolved property repair obligations.

View Document
Email: Gutters Leaking and Overflowing 2024

Written report to Black Crow of leaking gutters.

View Document
Email: Sewer Odor 2024

Written report to Black Crow of sewer odor issues.

View Document
Internet/Connectivity Outage Record 2024–2025

Screenshot record of internet service outages at the restaurant.

View Document
Letter to Black Crow re: Repair Obligations February 4, 2026

Formal letter to Black Crow regarding failure to meet lease repair obligations.

View Document
Letter from Black Crow re: Repairs March 20, 2026

Letter from Black Crow's principal (Surden) regarding the repair status.

View Document
Letter to Black Crow re: Required Repairs March 27, 2026

Follow-up letter to Black Crow regarding the required repairs and timeline.

View Document
Pickens County Fire Inspection Report — PCFG-2026-0000072 March 10, 2026

Fire inspection report from Pickens County Fire Rescue for 60 N Gate Station Dr.

View Document
Fire Marshal Approval — Passageway Between Dining Rooms April 15, 2026

Email thread: J. Cornelius requests written approval from County Fire Marshal Jeremy Jones to keep the passageway between dining rooms open. Fire Marshal approves. J. Cornelius forwards approval to Randy and Lana Meucke.

View Document
Black Crow Denies Passageway — Sam Hale to J. Cornelius April 16, 2026

Sam Hale (Hale Retail Group, acting for Black Crow) denies the doorway/passageway between dining rooms, one day after J. Cornelius obtained county fire marshal approval and Randy Meucke had given verbal approval.

View Document
Response to Doorway Denial — J. Cornelius to Sam Hale April 16, 2026

J. Cornelius responds citing Section 6(C) of the lease (approval shall not be unreasonably withheld) and documents that Randy Meucke verbally approved the passageway with witnesses present.

View Document
Reimbursement Demand — Fire Suppression Maintenance April 16, 2026

J. Cornelius formally requests reimbursement from Black Crow for fire suppression inspection and repair costs, citing Section 3.B of the lease (landlord's obligation). Includes invoice and estimate for additional work.

View Document
The January 16 Flood

Documentation of the sprinkler system failure, the NON-COMPLIANCE tags, and the engineering inspection findings.

Notice of Temporary Closure / Sprinkler Failure January 17, 2026

Written notice to Black Crow of the sprinkler system failure and restaurant closure.

View Document
Photo: NON-COMPLIANCE Tag on Sprinkler Riser January 16, 2026

Photograph showing the NON-COMPLIANCE tag affixed to the sprinkler system riser at the time of the flood.

Photo: NON-COMPLIANCE Tag on Sprinkler Riser
Photo: NON-COMPLIANCE Tag (additional view) January 16, 2026

Additional photograph of the NON-COMPLIANCE tag on the sprinkler system.

Photo: NON-COMPLIANCE Tag (additional view)
Invoice — Pye Barker Fire & Safety 2026

Fire suppression system invoice from Pye Barker Fire & Safety, Dalton, GA.

View Document
Engineering Inspection Report — Palmer Construction Consultants March 6, 2026

Independent engineer's report identifying 10 deficiency categories, including structural damage requiring emergency shoring. GA PE Firm No. 004308.

View Document
Formal Notice: Engineering Report Transmitted to Black Crow March 6, 2026

Email transmitting the engineering inspection report to Black Crow and their insurance representative, with notice that remediation was required before repair work could begin.

View Document
Letter: Required Remediation Prior to Repair Work (Filings copy) March 6, 2026

Filed copy of the formal notice that structural shoring was required before repair work could safely proceed.

View Document
Insurance / Travelers Documentation February 2026

Documentation related to the insurance claim and payment to Black Crow.

Insurance / Travelers Documentation
The Dispossessory

The eviction filing and the evidence that Black Crow's principals dined at Night Train Pizza at least 14 times during the period they later claimed its operation violated the lease.

Dispossessory Notice 2026

Black Crow's filing to evict North Gate, citing non-payment of rent and alleged lease violations.

View Document
Entry of Appearance / Substitution of Counsel — Superior Court 2026

Filing record in Superior Court.

View Document
Entry of Appearance / Substitution of Counsel — Magistrate Court 2026

Filing record in Magistrate Court.

View Document
Black Crow Principals — Night Train Pizza Receipts 2024–2025

Compiled receipts showing Black Crow's principals dined at Night Train Pizza at least 14 times while their eviction claim alleged its operation violated the lease.

View Document
Black Crow Principals — Night Train Transaction Record 2024–2025

Compiled data record of Square transactions showing Black Crow principals' visits to Night Train Pizza.

View Document
All documents are primary source materials. Links open original files hosted on Dropbox in a new tab. Document links will be updated as additional materials are cleared for publication.