Evidence Packet
Every document referenced in our public statement is available here. We have published these because we believe transparency is the most important tool we have.
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.
Signed lease between 60 North Gate Station LLC and Black Crow Ventures, including Special Stipulation 4.
View DocumentSigned signature page of the lease.
View DocumentDocuments from June–November 2025: five months of outreach, two formal letters, and a legal complaint — all before the flood.
First outreach to Black Crow after learning Polar Bear sold its operations to a buyer planning a restaurant.
View DocumentFormal written demand to Black Crow to enforce Special Stipulation 4.
View DocumentEmail transmitting the lease enforcement demand to Black Crow.
View DocumentReply thread on the lease enforcement email.
View DocumentRequest to Black Crow to arrange a meeting with Coffee Ten to resolve the conflict.
View DocumentResponse to the meeting request.
View DocumentFifth attempt to reach Black Crow or Coffee Ten for a meeting before filing.
View DocumentEmail thread regarding a meeting with the Coffee Ten operator.
View DocumentBlack Crow acknowledges North Gate's exclusive rights and requests North Gate waive them.
View DocumentCoffee Ten acknowledges the potential conflict with North Gate's lease and states they intend to open regardless.
View DocumentBlack Crow's default notice to North Gate, issued four days after their waiver request was declined.
View DocumentNorth Gate's filed complaint seeking enforcement of exclusive rights.
View DocumentAmended complaint adding claims related to the January 16 flood.
View DocumentNorth Gate's motion seeking an emergency injunction to stop Coffee Ten's conflicting operation.
View DocumentCourt order denying North Gate's motion for a temporary restraining order.
View DocumentInvoices, emails, and letters documenting the repairs North Gate paid for that were Black Crow's lease obligations.
Itemized record of $33,213.18 in repairs paid by North Gate for Black Crow's lease obligations.
View DocumentVendor repair invoice.
View DocumentVendor repair invoice.
View DocumentArmor Plumbing repair invoice.
View DocumentVendor repair invoice.
View DocumentArmor Plumbing emergency pumping invoice.
View DocumentArmor Plumbing repair invoice, $988.
View DocumentVendor repair invoice.
View DocumentArmor Plumbing repair invoice, $988.
View DocumentVendor repair invoice.
View DocumentHVAC repair invoice.
View DocumentGas appliance repair invoice.
View DocumentWritten request to Black Crow to meet about unresolved property repair obligations.
View DocumentWritten report to Black Crow of leaking gutters.
View DocumentWritten report to Black Crow of sewer odor issues.
View DocumentScreenshot record of internet service outages at the restaurant.
View DocumentFormal letter to Black Crow regarding failure to meet lease repair obligations.
View DocumentLetter from Black Crow's principal (Surden) regarding the repair status.
View DocumentFollow-up letter to Black Crow regarding the required repairs and timeline.
View DocumentFire inspection report from Pickens County Fire Rescue for 60 N Gate Station Dr.
View DocumentEmail 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 DocumentSam 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 DocumentJ. 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 DocumentJ. 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 DocumentDocumentation of the sprinkler system failure, the NON-COMPLIANCE tags, and the engineering inspection findings.
Written notice to Black Crow of the sprinkler system failure and restaurant closure.
View DocumentPhotograph showing the NON-COMPLIANCE tag affixed to the sprinkler system riser at the time of the flood.
Additional photograph of the NON-COMPLIANCE tag on the sprinkler system.
Fire suppression system invoice from Pye Barker Fire & Safety, Dalton, GA.
View DocumentIndependent engineer's report identifying 10 deficiency categories, including structural damage requiring emergency shoring. GA PE Firm No. 004308.
View DocumentEmail transmitting the engineering inspection report to Black Crow and their insurance representative, with notice that remediation was required before repair work could begin.
View DocumentFiled copy of the formal notice that structural shoring was required before repair work could safely proceed.
View DocumentDocumentation related to the insurance claim and payment to Black Crow.
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.
Black Crow's filing to evict North Gate, citing non-payment of rent and alleged lease violations.
View DocumentFiling record in Superior Court.
View DocumentFiling record in Magistrate Court.
View DocumentCompiled 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 DocumentCompiled data record of Square transactions showing Black Crow principals' visits to Night Train Pizza.
View Document