Use this security deposit guide to build a clear demand letter for Minneapolis.
Understanding Security Deposit Rights in Minneapolis, Minnesota
For Minneapolis renters, the security deposit often represents a significant sum of money, frequently equivalent to one or two months' rent in a competitive housing market where average rents continue to rise. Whether you lived in a historic apartment in the Wedge, a modern high-rise in Downtown Minneapolis, or a single-family rental in Longfellow, you have substantial legal rights regarding the return of your security deposit when your tenancy ends. Minnesota law provides specific protections for tenants and imposes strict requirements on landlords regarding security deposit handling.
Minnesota Statutes Section 504B.178 establishes a comprehensive framework for security deposits that benefits tenants significantly. Landlords must return deposits within 21 days of tenancy termination, must provide itemized written statements for any deductions, and face penalties for wrongful withholding that can include return of the deposit plus additional damages. Understanding these protections is essential for recovering the money you are entitled to receive.
Many Minneapolis tenants experience security deposit disputes at the end of their tenancies. Landlords sometimes claim excessive damage, charge for normal wear and tear, deduct unauthorized cleaning fees, or simply fail to return deposits within the required timeframe. A well-crafted demand letter referencing specific Minnesota statutes often resolves these disputes without court involvement, as landlords recognize the legal exposure they face for wrongful withholding.
This comprehensive guide will explain Minnesota's security deposit laws in detail, walk you through the process of creating an effective demand letter, identify the evidence you need to support your claim, explain critical deadlines, and help you avoid common mistakes that undermine deposit claims. Whether your landlord has withheld your entire deposit, made questionable deductions, or simply failed to communicate, this guide will help you pursue the return of your money.
The stakes in security deposit disputes extend beyond the immediate financial recovery. When Minneapolis tenants actively enforce their deposit rights, they discourage landlords from wrongful practices that affect the entire rental community. Minnesota's tenant-protective deposit laws only work when tenants know their rights and are prepared to assert them.
Minnesota Security Deposit Laws for Minneapolis Tenants
Minnesota Statutes Section 504B.178 governs security deposits and establishes clear rules that protect tenants. Under Subdivision 3, landlords must return security deposits within 21 days after termination of the tenancy and receipt of the tenant's mailing address or delivery instructions. This deadline is firm, and failure to meet it has significant consequences for landlords.
If a landlord fails to return the deposit or provide a written statement of reasons for withholding within 21 days, the tenant may recover the deposit in full plus interest. Under Subdivision 7, a landlord who wrongfully withholds a deposit may also be liable for punitive damages up to $500, plus attorney's fees. This penalty provision provides powerful leverage when landlords fail to comply with their obligations.
Subdivision 3 requires landlords to provide a written statement itemizing the nature and amount of any deductions from the deposit. This statement must be sent with any returned portion of the deposit. Vague or generic deductions like "damage" without specific descriptions violate this requirement. Tenants can challenge non-compliant statements and may recover the full deposit when landlords fail to properly itemize.
Minnesota law limits what landlords can deduct from security deposits. Authorized deductions include unpaid rent, costs to repair damage beyond normal wear and tear, and cleaning costs only if the lease specifically requires the tenant to pay for cleaning at the end of the tenancy. Landlords cannot deduct for normal wear and tear, which includes ordinary deterioration from everyday use like minor carpet wear, small nail holes, or fading paint.
Subdivision 2 requires landlords to deposit security deposits in financial institutions and provides that deposits cannot be commingled with personal funds. Landlords must also pay interest on deposits held for 12 months or more at an annual rate of one percent simple interest. This interest accrues from the date of deposit.
Minnesota does not cap the amount landlords can charge as security deposits, unlike some states. However, the 21-day return requirement, itemization requirement, and penalty provisions apply regardless of deposit amount. Large deposits increase the stakes of disputes and may justify more aggressive enforcement efforts.
Under Subdivision 8, if a tenant's mailing address is unknown and the tenant has not provided delivery instructions, the landlord must still return the deposit within 21 days to the tenant's last known address. Landlords cannot avoid obligations by claiming they could not locate the tenant. If the tenant provides a forwarding address, the landlord must send the deposit to that address.
Minneapolis tenants can pursue deposit claims in Hennepin County Conciliation Court for amounts up to $15,000. The statute of limitations for deposit claims is six years under Minnesota's general limitations period, though claims should be pursued promptly. Courts consistently enforce Section 504B.178's requirements and regularly award the statutory penalties when landlords violate the law.
Landlords who sell property remain liable for deposit returns unless they properly transfer deposits to new owners and notify tenants of the transfer. Similarly, property management companies are responsible for deposits they hold, even after management agreements end. Understanding these rules helps identify the correct defendant when disputes arise.
Step-by-Step Guide to Security Deposit Demand Letters in Minneapolis
Before or immediately upon moving out, provide your landlord with your new mailing address in writing. Send this information via certified mail with return receipt requested or deliver it in person with a signed acknowledgment. Under Minnesota Statutes Section 504B.178, your landlord must return your deposit within 21 days of receiving your address. Providing clear forwarding information eliminates any landlord excuse for failure to return the deposit.
Before vacating, thoroughly document the condition of the rental unit. Take photographs and video of every room, including walls, floors, ceilings, fixtures, appliances, and any areas where damage might be claimed. Include wide shots and close-ups. If possible, have a witness present during documentation. This evidence will refute false damage claims and demonstrate that any wear is normal wear and tear.
Gather any move-in inspection reports, photographs, or condition checklists from when you began your tenancy. These documents establish baseline conditions and prove that claimed damage predated your tenancy or represents normal wear and tear over the lease term. If you have before-and-after photographs showing similar conditions, these are particularly valuable.
After you vacate and provide your forwarding address, wait 21 days for your landlord to return your deposit or provide a written statement of deductions. Mark the deadline on your calendar. If you receive a partial refund with deductions, review the itemized statement carefully against your documentation. If the deadline passes without any communication, your landlord has violated Minnesota law.
Determine the full amount you are owed. Start with your original deposit amount plus any interest owed (one percent simple annual interest for deposits held 12 months or more). If your landlord failed to return the deposit within 21 days or made wrongful deductions, add the potential penalty of up to $500 and attorney's fees if applicable. Document this calculation in your demand letter.
Review any itemized statement for improper deductions. Common wrongful deductions include charges for normal wear and tear (minor carpet wear, small nail holes, faded paint), cleaning charges not authorized by the lease, repairs for pre-existing conditions, excessive charges for minor repairs, and deductions without proper itemization. Prepare specific responses to each improper deduction.
Prepare a formal demand letter in business letter format. State your name, former address, dates of tenancy, and original deposit amount. Reference Minnesota Statutes Section 504B.178 specifically. Explain how the landlord violated the law by failing to return the deposit within 21 days, failing to provide proper itemization, or making wrongful deductions. State the specific amount you demand.
Explain that Minnesota law provides for recovery of the deposit plus punitive damages up to $500 and attorney's fees for wrongful withholding. Note that you will pursue your claim in Hennepin County Conciliation Court if the landlord does not comply. This demonstrates you understand your rights and are prepared to enforce them.
Give your landlord 14 days to return the full deposit or the disputed portion. This is reasonable given that the landlord already had 21 days to comply with statutory requirements. Make clear that you will file in Conciliation Court if the deadline passes without satisfactory resolution.
Include copies of key documents: the lease showing the deposit amount, your forwarding address notification, the landlord's itemized statement (if any), move-out photographs contradicting damage claims, move-in documentation showing pre-existing conditions, and any relevant correspondence. Organize attachments logically.
Send your demand letter via USPS Certified Mail with Return Receipt Requested to create proof of delivery. If you have the landlord's email address, also send a copy by email. For corporate landlords or property management companies, send to both the local office and corporate headquarters. Retain copies of everything you send.
If your deadline passes without resolution, prepare to file in Hennepin County Conciliation Court. Gather all evidence, complete the required forms, and calculate your filing fee. Many landlords settle after receiving a well-drafted demand letter, but you must be prepared to follow through with legal action if necessary.
Essential Evidence for Security Deposit Claims in Minneapolis
Your lease agreement is the foundational document for any security deposit claim. Retain your original signed lease showing the deposit amount, any provisions about cleaning requirements, and the landlord's legal name and address. The lease establishes your right to the deposit and may contain cleaning clauses that affect the validity of certain deductions. Note any pet deposit provisions, last month's rent payments, or other deposit-related terms.
Move-in documentation establishes baseline conditions that prove pre-existing damage or normal wear over time. Gather any move-in inspection reports, condition checklists, or photographs you took when you started your tenancy. These documents are crucial for refuting claims that you caused damage. If your landlord conducted a move-in inspection, request a copy if you do not have one.
Move-out photographs and video provide the most compelling evidence of unit condition when you vacated. Take comprehensive documentation immediately before returning keys. Photograph every room from multiple angles, including floors, walls, ceilings, windows, fixtures, and appliances. Document the inside of closets, cabinets, and storage areas. Video walk-throughs provide additional evidence that photographs alone cannot capture.
Comparison evidence showing condition at move-in versus move-out demonstrates that claimed damage is either pre-existing or normal wear and tear. Side-by-side photographs are particularly effective. If you have dated photographs from throughout your tenancy showing gradual normal wear, these also support your position that you maintained the property appropriately.
Written communications document your compliance with notice requirements and the landlord's responses or lack thereof. Save copies of your forwarding address notification, any move-out correspondence, the landlord's itemized deduction statement, and all subsequent communications. Email trails, text messages, and letters all constitute relevant evidence. Keep records of dates and methods of delivery.
Payment records prove your deposit amount and any rent payments made. Retain bank records, cancelled checks, or receipts showing your security deposit payment. If there are disputes about final rent payments that affect deposit deductions, gather evidence of all payments made during your tenancy. Credit card or electronic payment records may also be relevant.
Repair estimates from licensed contractors can refute excessive damage charges. If your landlord claims significant damage requiring expensive repairs, obtain independent estimates from qualified contractors. Professional opinions about whether claimed damage exceeds normal wear and tear can be decisive in court. Keep estimates in writing with contractor contact information.
Witness statements may corroborate your account of unit conditions. If anyone helped you move or was present during move-out documentation, obtain written statements about what they observed. Witnesses who can testify about the property's condition provide additional credibility. Include names, contact information, and specific observations with dates.
Organize all evidence chronologically and create both physical and digital copies. Store originals securely and use copies for your demand letter and court filings. Create a clear timeline showing move-in date, tenancy duration, move-out date, forwarding address notification date, 21-day deadline, and any landlord communications. This organization helps judges understand your claim quickly.
Critical Deadlines for Security Deposit Claims in Minnesota
The 21-day return deadline is the most important timeline in Minnesota security deposit law. Under Minnesota Statutes Section 504B.178, Subdivision 3, landlords must return security deposits or provide written statements of reasons for withholding within 21 days after termination of the tenancy and receipt of the tenant's mailing address. This deadline is firm and non-negotiable. Calculate it carefully from the later of your move-out date or when you provided your forwarding address.
Providing your forwarding address starts the 21-day clock. Send your forwarding address notification on or before your move-out date. Use certified mail with return receipt requested or obtain written acknowledgment of hand delivery. If you fail to provide a forwarding address, the 21-day period still runs, but the landlord can send the deposit to your last known address. Providing clear forwarding information eliminates landlord excuses.
Interest calculation dates matter for longer tenancies. Minnesota requires landlords to pay one percent simple annual interest on deposits held for 12 months or more. Calculate interest from the date you paid the deposit to the date of return. For multi-year tenancies, this interest can add meaningful amounts to your claim. Include interest in your damage calculations.
Demand letter response periods should be firm but reasonable. After the 21-day statutory deadline has passed, your demand letter should give the landlord 14 days to return the deposit. This is reasonable since the landlord already had 21 days to comply. Shorter deadlines may appear unreasonable; longer deadlines unnecessarily delay resolution. Set a specific date, not just a number of days.
The statute of limitations for security deposit claims is six years under Minnesota's general limitations period in Section 541.05. However, pursue claims promptly. Evidence becomes harder to gather over time, and courts may question why tenants waited years to assert claims. Most successful claims are filed within months of the tenancy ending.
Conciliation Court scheduling typically allows hearings within 30 to 60 days of filing. Plan for this timeline when deciding whether to proceed with court action. The entire process from demand letter to court judgment often takes two to four months when landlords do not settle.
A typical security deposit dispute timeline follows this pattern: move-out and forwarding address notification on the same day, 21-day waiting period for landlord compliance, demand letter sent on day 22 if no deposit returned, 14-day demand letter response period, Conciliation Court filing if no resolution by day 36, court hearing 30 to 60 days after filing. Emergency circumstances rarely apply to deposit claims, so follow standard timelines.
Property sale or management company changes affect timing. If the property was sold during your tenancy, the new owner typically assumes deposit return obligations, but the original landlord may remain liable if deposits were not properly transferred. If a management company ends its relationship with the property, both the management company and owner may be liable. Identify responsible parties before sending demand letters.
Common Mistakes to Avoid in Minneapolis Security Deposit Claims
Failing to provide a written forwarding address undermines your claim. Minnesota law requires landlords to return deposits within 21 days of receiving your mailing address. If you only provide verbal notification or do not provide a forwarding address at all, landlords may argue the 21-day clock never started. Always provide your forwarding address in writing via certified mail or with signed acknowledgment, keeping proof of delivery.
Not documenting unit condition at move-out leaves you unable to refute damage claims. Landlords frequently allege damage to justify keeping deposits, and without photographic evidence showing actual conditions, disputes become credibility contests. Take comprehensive photographs and video immediately before returning keys. Have a witness present if possible. This documentation is your primary evidence against false damage claims.
Failing to save move-in documentation prevents you from proving pre-existing conditions or normal wear over time. If you cannot demonstrate what the unit looked like when you moved in, landlords can attribute any imperfection to tenant damage. Keep all move-in inspection reports, photographs, and condition checklists. Request copies from your landlord if you do not have them.
Accepting partial refunds without protesting wrongful deductions may waive claims. If your landlord sends a partial refund with an itemized statement, do not cash the check until you decide whether to challenge the deductions. Depositing funds may be construed as acceptance of the settlement. If you believe deductions are wrongful, write immediately to dispute them while preserving your right to the full deposit.
Missing the opportunity to dispute improper itemization loses leverage. Minnesota law requires landlords to provide specific itemized statements for any deductions. Vague entries like "damage" or "cleaning" without details violate this requirement. If the itemized statement is inadequate, you may be entitled to the full deposit even if some deductions would otherwise be valid. Examine statements carefully for compliance.
Not understanding what constitutes normal wear and tear leads to accepting improper deductions. Minor carpet wear in high-traffic areas, small nail holes from hanging pictures, fading or minor scuffs on paint, and worn areas around door handles are normal wear and tear that cannot be deducted. Research Minnesota standards and challenge any deductions for ordinary deterioration from normal use.
Sending demand letters to the wrong party causes delays. Identify the correct landlord entity before sending demands. For property management companies, send letters to both the management company and the actual property owner. Search Minnesota Secretary of State records for registered business names and agents. Incorrect service may require restarting your demand process.
Failing to calculate interest for long tenancies leaves money on the table. For deposits held 12 months or more, Minnesota law requires one percent simple annual interest. Calculate this interest and include it in your demand. For multi-year tenancies, interest can add significant amounts to your claim.
Not following through with court action after sending a demand letter undermines future claims. If you set deadlines and then fail to file when landlords do not comply, you lose credibility. Only send demand letters if you are prepared to file in Conciliation Court. The threat of legal action only works if landlords believe you will follow through.
Waiting too long to pursue claims creates evidentiary and credibility problems. While the six-year statute of limitations allows extended time to file, prompt action preserves evidence and demonstrates that the deposit mattered to you. Courts may question why tenants who waited years to file considered the matter important. Pursue claims within months, not years, of your tenancy ending.
Frequently Asked Questions About Security Deposits in Minneapolis
Minnesota Statutes Section 504B.178 requires landlords to return security deposits within 21 days after termination of the tenancy and receipt of the tenant's mailing address or delivery instructions. This deadline is strict. If your landlord fails to return the deposit or provide a written statement of deductions within 21 days, you may be entitled to the full deposit plus punitive damages up to $500 and attorney's fees.
Minnesota landlords can deduct unpaid rent, costs to repair damage beyond normal wear and tear, and cleaning costs only if your lease specifically requires you to pay for cleaning at the end of the tenancy. Landlords cannot deduct for normal wear and tear, which includes minor carpet wear, small nail holes, faded paint, and ordinary deterioration from everyday use. All deductions must be itemized in a written statement.
Normal wear and tear refers to the ordinary deterioration that occurs through everyday use without negligence, carelessness, or abuse. Examples include minor carpet wear in traffic areas, small nail holes from hanging pictures, fading or slight scuffs on walls, worn areas around door handles, and minor marks on floors. Landlords cannot deduct for these conditions. Damage beyond normal wear, like large holes in walls or stained carpets from spills, can be deducted.
Under Minnesota Statutes Section 504B.178, Subdivision 7, if your landlord wrongfully withholds your deposit, you may recover the deposit amount, punitive damages up to $500, and reasonable attorney's fees. If your landlord fails to return the deposit within 21 days without providing a written statement of reasons, you may recover the full deposit plus these penalties regardless of any actual damage.
Yes, Minnesota law requires landlords to pay interest on security deposits held for 12 months or more at an annual rate of one percent simple interest. The interest accrues from the date you paid the deposit. For multi-year tenancies, this can add meaningful amounts to your recovery. Calculate interest and include it in your demand.
Minnesota Statutes Section 504B.178 requires landlords to provide a written statement itemizing the nature and amount of any deductions within 21 days. Failure to provide proper itemization violates the statute and may entitle you to recover the full deposit plus penalties. Vague entries like "damage" without specific descriptions do not satisfy the itemization requirement. Challenge any inadequate statements.
Minnesota Conciliation Court handles claims up to $15,000. This covers most security deposit disputes, including the deposit amount, interest, and statutory penalties. If your landlord also owes you damages that exceed $15,000 when combined with the deposit claim, you would need to file in District Court. Most tenants find Conciliation Court sufficient for deposit recovery.
First, review the itemized statement against your move-out documentation to identify wrongful deductions. Do not cash any partial refund check until you decide whether to dispute. Send a formal demand letter via certified mail referencing Minnesota Statutes Section 504B.178, explaining which deductions are improper, and demanding return of the wrongfully withheld amount. Give 14 days to respond, then file in Conciliation Court if necessary.
What to Expect When Settling Security Deposit Disputes in Minneapolis
Settlement expectations for security deposit disputes depend on the strength of your evidence, the nature of the landlord's violations, and the landlord's assessment of their legal exposure. Understanding realistic outcomes helps you evaluate settlement offers and decide whether to accept resolution or proceed to Conciliation Court.
For clear violations like failure to return deposits within 21 days or failure to provide proper itemization, you have strong leverage. Minnesota's statutory penalties of up to $500 plus attorney's fees create significant exposure for landlords. Many landlords will return the full deposit to avoid facing these additional damages in court. A well-drafted demand letter referencing specific statutory penalties often produces full resolution.
Disputes over specific deductions require more nuanced evaluation. If your landlord made some legitimate deductions along with wrongful ones, settlement may involve negotiating the disputed amounts. Prepare detailed responses to each deduction, distinguishing between normal wear and tear and actual damage. Strong photographic evidence comparing move-in and move-out conditions substantially increases your negotiating power.
Landlord sophistication affects settlement dynamics. Professional property management companies often settle quickly to avoid litigation costs and negative publicity. Individual landlords may be more personally invested in disputes but may also be more intimidated by formal legal demands. Large corporate landlords have standard procedures but may settle reasonable claims efficiently. Understand your landlord's situation when calibrating demands.
Negotiation typically begins after your demand letter demonstrates legal knowledge. Landlords who realize you understand Section 504B.178's requirements and penalties often reconsider their positions. Be prepared to explain specifically how each deduction violates the law and how your evidence supports your claims. Organized, documented arguments are more persuasive than emotional appeals.
Settlement amounts vary based on circumstances. For complete failures to return deposits within 21 days, expect to recover the full deposit plus interest. For wrongful deductions, recovery of the disputed amounts is typical. Statutory penalties of $500 are often negotiable depending on how egregious the violation was and whether you would actually pursue them in court.
Always document settlement agreements in writing. Specify the exact amount to be paid, the payment method and timing, and whether the settlement resolves all claims. If accepting a compromise, consider whether you are waiving claims for penalties and interest. Do not sign releases that waive claims you have not been compensated for.
If settlement fails, Conciliation Court provides efficient resolution. Claims up to $15,000 are heard without formal rules of evidence, and the process is designed for self-represented parties. Hearings are typically scheduled within 30 to 60 days of filing. Judges regularly enforce Section 504B.178 and award statutory penalties when landlords violate the law. The credible threat of court action often produces better settlements than demand letters alone.
Minneapolis Security Deposit Resources and Contacts
Hennepin County Conciliation Court
File security deposit claims up to $15,000.
Location: Hennepin County Government Center
Address: 300 South Sixth Street, Minneapolis, MN 55487
Phone: (612) 348-5181
Website: www.mncourts.gov/Find-Courts/Hennepin.aspx
Filing can be done in person or electronically through Minnesota Court's e-filing system.
HOME Line - Tenant Hotline
Free tenant counseling and advice on security deposit issues.
Phone: (612) 728-5767
Toll-Free: (866) 866-3546
Website: www.homelinemn.org
HOME Line provides guidance on deposit disputes, demand letters, and tenant rights.
Mid-Minnesota Legal Aid
Free legal services for eligible low-income tenants.
Phone: (612) 334-5970
Website: www.mylegalaid.org
May provide representation in security deposit cases for qualifying clients.
Volunteer Lawyers Network
Pro bono legal assistance for qualifying individuals.
Phone: (612) 752-6677
Website: www.vlnmn.org
Minnesota Attorney General's Office
Consumer protection information and complaint filing.
Phone: (651) 296-3353
Toll-Free: (800) 657-3787
Website: www.ag.state.mn.us
Publishes tenant rights guides and accepts landlord complaints.
Minnesota Secretary of State - Business Services
Search for landlord registered business names and addresses.
Phone: (651) 296-2803
Website: www.sos.state.mn.us/business-liens
Use to identify correct legal entities for demand letters.
Minnesota State Bar Association Lawyer Referral
Attorney referrals for landlord-tenant matters.
Phone: (612) 752-6699
Website: www.mnbar.org/public/lawyer-referral
Legal Aid Society of Minneapolis
Legal assistance for housing issues.
Phone: (612) 334-5970
Website: www.mylegalaid.org
Minneapolis 311
City services and referrals.
Phone: 311 (within Minneapolis) or (612) 673-3000
Website: www.minneapolismn.gov/311
Hennepin County Law Library
Free legal research resources.
Location: Hennepin County Government Center, C-2451
Address: 300 South Sixth Street, Minneapolis, MN 55487
Phone: (612) 348-2903
Website: www.hennepinlawlibrary.org
The Rules They Don't Want You to Know
The Clock is Your Weapon
Most states give landlords 21-30 days to return your deposit or provide an itemized list of deductions. Know your state's deadline.
Document Everything
Photos, videos, inspection reports – evidence is king. Got proof? Use it.
Make Them Show Their Math
They can't just pocket your cash. Demand itemized deductions. No receipts? Demand a full refund.
The Security Deposit Power Play
Many states allow for double or triple damages for bad faith retention. Know the law, and don't be afraid to use it.
Minnesota Security Deposit Laws
Applicable Laws
- Minn. Stat. § 504B.178
Small Claims Limit
$15,000
Consumer Protection Agency
Minnesota Attorney General Consumer Protection
Security Deposit Real Talk
When do I send my demand letter?
Day after their legal deadline expires. Not a day later. They're banking on your hesitation.
What if they ghost me?
That's when it gets interesting. Document everything and head to small claims court. The judge won't be impressed by their silence.
What's normal wear and tear?
Minor scuffs, small nail holes, faded paint, worn carpet in traffic areas. Not normal: holes in walls, stains, broken fixtures, or pet damage.
Can they deduct for professional cleaning?
Only if you left the place dirtier than when you moved in. Normal cleaning isn't your responsibility if you left it reasonably clean.
What if I didn't do a move-in inspection?
Makes it harder to dispute pre-existing damage, but not impossible. Photos from online listings, previous tenant testimony, or property age can help.
How much can I sue for?
The deposit amount plus penalties. Many states award 2x or 3x damages for bad faith retention, plus court costs and sometimes attorney fees.
What if my landlord sold the property?
The new owner typically inherits deposit obligations. Both old and new owners may be liable. Check your state's transfer requirements.
About FreeDemandLetter
FreeDemandLetter provides free, AI-powered demand letter generation with location-specific legal citations. Our content is reviewed by subject matter specialists and regularly updated to reflect current laws. We help thousands of people resolve disputes effectively—but we're not lawyers, and this isn't legal advice. For complex situations, consult a licensed attorney in your jurisdiction.
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