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COUNT XVI (JNJ, Brennan Properties, and Brennan) <br /> Breach of Statutory Home Improvement Warranties Under Minn. Stat. § 327A <br /> 229. Plaintiffs restate and re-allege all preceding paragraphs of this Complaint <br /> as if fully set forth herein. <br /> 230. JNJ and Brennan Properties contracted to complete, and did complete, <br /> under Brennan's management, home improvement work involving major structural <br /> changes or additions to the Property, a residential building. <br /> 231. Plaintiffs have uncovered substantial defects in the Property caused by <br /> faulty workmanship and defective materials, noncompliance with building standards, and <br /> major construction defects, as well as faulty installation of heating and cooling systems. <br /> 232. Said defects include, but are not limited to, improper grading around the <br /> improvements on the Property, inadequate moisture abatement measures in the home, the <br /> connection of a gas range to a propane line, the installation a dishwasher without a <br /> drainage line, and the installation of an HVAC system that is inadequate for reasons <br /> including the fact that the ductwork was filled with trash and construction debris. <br /> 233. JNJ, Brennan Properties, and Brennan received within the statutory <br /> warranty period notice of the defects more than 30 days prior to this filing. <br /> 234. JNJ, Brennan Properties, and Brennan have had the opportunity to inspect <br /> the Property. <br /> 235. JNJ, Brennan Properties, and Brennan have failed to offer their own plan of <br /> repair more than 15 days after they inspected the Property. <br /> 35 <br />