Rent Board — Portland, ME
Date: 2025-12-02
Time: 17:30

RENT BOARD
 December 2, 2025
 5:30 PM

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II. ROLL CALL:

III. APPROVAL OF MINUTES

 a. October 22, 2025 Minutes
 b. November 12, 2025 Minutes
IV. COMMUNICATIONS:
 Please note: Written public comment must be received via email
 (rentboard@portlandmaine.gov) by 12pm the day before the scheduled
 meeting. The subject line needs to read "Written Public Comment"
 33 State St Rent Increase Appeal Scheduling Request


V. UNFINISHED BUSINESS:

 a. Rent Increase Application
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner's Representative: Caleb Normandeau with Port Property
 Address: 72 Park Ave, Units 1-12
 CBL: 048-B-008-001
 Type of Increase: Increased Housing Service Costs
 b. Rent Increase Application
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner's Representative: Caleb Normandeau with Port Property
 Address: 157 Grant St, Units 1-26
 CBL: 053-B-024-001
 Type of Increase: Increased Housing Service Costs
VI. New Business

 a. Rent Increase Appeal - Public Comment
 Appellant: Portland Tenant's Union
 Address: 33 State St, all units
 Property Owner: Atanas Dinkov
 CBL: 044-B-016-001
 b. Tenant Rights Appeal - Public Comment
 Appellant: Shelley Swift
 Address: 193 York St, Unit 2
 Property Owner: 193 York Street LLC
 CBL: 044-C-004-001
VII. Adjourn

RENT BOARD
 December 2, 2025
 5:30 PM

ZOOM INFORMATION:

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 Page 1
II. ROLL CALL:

III. APPROVAL OF MINUTES

 a. October 22, 2025 Minutes
 b. November 12, 2025 Minutes
IV. COMMUNICATIONS:
 Please note: Written public comment must be received via email
 (rentboard@portlandmaine.gov) by 12pm the day before the scheduled
 meeting. The subject line needs to read "Written Public Comment"
 33 State St Rent Increase Appeal Scheduling Request


V. UNFINISHED BUSINESS:

 a. Rent Increase Application
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner's Representative: Caleb Normandeau with Port Property
 Address: 72 Park Ave, Units 1-12
 CBL: 048-B-008-001
 Type of Increase: Increased Housing Service Costs
 b. Rent Increase Application
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner's Representative: Caleb Normandeau with Port Property
 Address: 157 Grant St, Units 1-26
 CBL: 053-B-024-001
 Type of Increase: Increased Housing Service Costs
VI. New Business

 a. Rent Increase Appeal - Public Comment
 Appellant: Portland Tenant's Union
 Address: 33 State St, all units




 Page 2
 Property Owner: Atanas Dinkov
 CBL: 044-B-016-001
 b. Tenant Rights Appeal - Public Comment
 Appellant: Shelley Swift
 Address: 193 York St, Unit 2
 Property Owner: 193 York Street LLC
 CBL: 044-C-004-001
VII. Adjourn




 Page 3
 Remote Rent Board Meeting Minutes - Held Via Zoom

Wednesday, October 22, 2025​ ​ ​ ​ ​ ​ ​ ​ ​ ​

II. Roll Call - 0:00:39

Matthew Lax, Tenant, District 1 - Chair
Matthew Walker, Tenant, District 2
Christopher “Buddy” Moore, Tenant, District 3 - ABSENT
Rebecca Bolduc, Homeowner, District 4
Vacant, District 5
Anne-Laure Razat, Tenant, At-Large - ABSENT
Kristen Carreras, Landlord, At-Large - ABSENT

Staff present:
Dylan Orr, Rental Registration Coordinator
Benjamin Plante, Esq., Counsel for the Rent Board

0:01:15 - Chair Lax explains that the Board does not have enough members present to establish
a quorum. Pursuant to Article VIII., Section 2 of the Rent Board Rules of Procedure, all agenda
items are tabled due to lack of quorum.

III. Approval of Minutes - See 0:01:15

 a.​ September 24, 2025 Minutes
 b.​ October 8, 2025 Minutes



IV. Communications

 a.​ Reschedule Regular November Meeting

0:03:11 - Matthew Lax moves to reschedule the regular November meeting to November 19,
2025 at 5:00 PM. Seconded by Rebecca Bolduc. (3-0; Moore, Razat & Carreras absent). The
motion passes.

V. Unfinished Business - See 0:01:15

 a.​ Approval of Written Findings of Fact & Conclusions of Law - See 0:01:15

 b.​ Rent Increase Application - Public Comment - See 0:01:15
 Owner: 56&58 Federal LLC, 104 East St, Carlisle, MA 01741
 Address: 58 Federal St, Unit 58-2
 CBL: 020-D-009-001




 Page 4
c.​ Rent Increase Application - Public Comment - See 0:01:15
 Owner: Dennis Fuller, 3946 Easton Terr, Sarasota, FL 34238-2617
 Representative: Troy Hanna, 394 Meadow Rd, Durham, ME 04222
 Address: 489 Cumberland Ave, all 4 units
 CBL: 048-F-023-001

d.​ Rent Increase Application - Public Comment - See 0:01:15
 Owner: The Fredricka Kapothanasis Testamentary Trust, 27 Running Brook Rd,
 Westbrook, ME 04092
 Representative: Kevin A. King, PO Box 695, Westbrook, ME 04098-0695
 Address: 218 Ocean Ave, Units 218, 220 & 222
 CBL: 140-B-015-001

e.​ Rent Increase Application - Completeness Review - See 0:01:15
 Owner: Woodford Arms, Inc., PO Box 10563, Portland, ME 04104
 Address: 168-180 Woodford St, all 18 units
 CBL: 124-J-014-001 & 124-J-012-001

f.​ Rent Increase Application - Public Comment - See 0:01:15
 Owner: Saunders Street Apartments LLC, 51 Belfield Rd, Cape Elizabeth, ME
 04107
 Representative: Willard Bollenbach and Randi Bollenbach, 51 Belfield Rd,
 Cape Elizabeth, ME 04107
 Address: 23 Saunders St, all 5 units
 CBL: 130-G-014-001

g.​ Rent Increase Application - Completeness Review - See 0:01:15
 Owner: RSAA Properties LLC, PO Box 9, Greenwood, ME 04255
 Address: 118 Providence St, Unit 120
 CBL: 425-I-010-001

h.​ Rent Increase Application - See 0:01:15
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner's Representative: Caleb Normandeau with Port Property
 Address: 72 Park Ave, Units 1-12
 CBL: 048-B-008-001
 Type of Increase: Increased Housing Service Costs

i.​ Rent Increase Application - See 0:01:15
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner's Representative: Caleb Normandeau with Port Property
 Address: 157 Grant St, Units 1-26
 CBL: 053-B-024-001
 Type of Increase: Increased Housing Service Costs




 Page 5
VI. Adjourn

0:04:50 - Matthew Lax moves to adjourn the meeting. Seconded by Rebecca Bolduc. (3-0;
Moore, Razat & Carreras absent). The motion passes.




 Page 6
 Remote Rent Board Meeting Minutes - Held Via Zoom

Wednesday, November 12, 2025​ ​ ​ ​ ​ ​ ​ ​

II. Roll Call - 0:00:52

Matthew Lax, Tenant, District 1 - Chair
Matthew Walker, Tenant, District 2
Christopher “Buddy” Moore, Tenant, District 3
Rebecca Bolduc, Homeowner, District 4
Vacant, District 5
Anne-Laure Razat, Tenant, At-Large
Kristen Carreras, Landlord, At-Large

Staff present:
Dylan Orr, Rental Registration Coordinator
Benjamin Plante, Esq., Counsel for the Rent Board



III. Approval of Minutes - 0:01:25

 a.​ September 24, 2025 Minutes
 b.​ October 8, 2025 Minutes

0:01:41 - Anne-Laurie Razat moves to approve minutes. Seconded by Krisen Carreras. (6-0).
The motion passes.



IV. Communications - 0:02:23

 a.​ 33 State St Tenant Rights Complaint - Scheduling Request - 0:02:31



V. Unfinished Business

 a.​ Approval of Written Findings of Fact & Conclusions of Law - 0:10:32

0:23:43 - Matthew Walker moves to approve 135 Sheridan Unit 102. Seconded by Anne-Laure
Razat. (6-0). The motion passes.​
​
0:25:30 - Krisen Carreras moves to approve 89 Spruce Street, 104 Forest Ave, 139 William
Street, and 202 Dartmouth Street. Seconded by Anne-Laure Razat. (6-0). The motion passes.​




 Page 7
 b.​ Rent Increase Application - Public Comment - 0:26:50
 Owner: 56 & 58 Federal LLC, 104 East St, Carlisle, MA 01741
 Property Address: 58 Federal St, Unit 58-2
 CBL: 020-D-009-001

0:32:10 - The property owner presents the application.

0:49:14 - Anne-Laure Razat moves to close public comment. Seconded by Kristen Carreras.
(6-0). The motion passes.

1:05:40 - Matthew Walker moves to reject the adjustment of Base Year and CPI adjustment.
Seconded by Christopher “Buddy” Moore. (5-1; Carreras votes no). The motion passes.

1:38:04 - Matthew Lax moves to approve an increase in the amount of $54.75. Seconded by
Kristen Carreras.

1:41:33 - Matthe Lax amends the previous motion to the amount of $46.41. Seconded by
Kristen Carreras. (4-2; Walker and Moore vote no). The motion passes.

 c.​ Rent Increase Application - Public Comment - 1:43:26
 Owner: Dennis Fuller, 3946 Easton Terr, Sarasota, FL 34238-2617
 Representative: Troy Hanna, 394 Meadow Rd, Durham, ME 04222
 Property Address: 489 Cumberland Ave, all 4 units
 CBL: 048-F-023-001

1:44:43 - A representative for the property, Troy Hanna, presents the application.

2:08:01 - Christopher “Buddy” Moore moves to close public comment. Seconded by Kristen
Carreras. (6-0). The motion passes.

2:19:01 - Matthew Walker moves to approve application for rent increase in an amount to be
determined. Seconded by Matthew Lax.

2:35:20 - Matthew Walker moves to adjust the capital improvement for the Base Year and the
Current Year to use the 8.7% interest and amortize 5 years for appliances and 10 years for
plumbing, resulting in Base Year 2019 at $2,968.83 and Current Year 2024 at $13,644.15
Seconded by Mattew Lax. (6-0). The motion passes.

2:42:43 - Rebecca Bolduc moves to disallow the amount stated in Section 13 for owner
performed labor as it does not meet the criteria set forth in the form. Seconded by Christopher
“Buddy” Moore. (4-2; Carreras & Lax vote no). The motion passes.

2:47:40 - Matthew Walker moves for $44,400 to be the Base Year rent based on registered
amounts from 2020 rather than $46,250. Seconded by Anne-Laure Razat. (6-0). The motion
passes.




 Page 8
2:56:50 - Kristen Carreras moves to keep the Professional Association Membership fee.
Seconded by Matthew Lax. (1-5; Lax, Walker, Moore, Razat, & Bolduc vote no). The motion fails.

3:02:05 - Anne-Laure Razat moves to remove Professional Association Membership fee.
Seconded by Matthew Walker. (5-1, Carreras votes no). The motion passes.

3:04:40 - Matthew Walker moves to include line item 10-1, $90 for background and credit
check. Seconded by Christopher “Buddy” Moore. (5-1; Matthew Lax no). The motion passes.

3:20:02 - Matthew Walker moves, based on the NOI form, to approve an increase rent of
$393.46 in each of these 4 units, and that amount should be reduced by whatever banked rent
is currently available. Seconded by Matthew Lax. (6-0). The motion passes.

3:29:45 - Anne-Laure Razat moves to, based on the approved $393.46 NOI for each unit and
the current banked rents for each unit, increase the banked rent for each unit as follows: Unit 1:
$393.16, Unit 2: $388.76, Unit 3: $320.11, Unit 4: $304.89. Seconded by Matthew Walker.
(6-0). The motion passes.

3:32:05 Matthew Lax moves to approve the rental application for the amount that has been
determined. (6-0). The motion passes.

3:34:00 through 3:39:00 - The Board takes a recess.

 d.​ Rent Increase Application - Public Comment - 3:39:28
 Owner: The Fredricka Kapothanasis Testamentary Trust, 27 Running Brook Rd,
 Westbrook, ME 04092
 Representative: Kevin A. King, PO Box 695, Westbrook, ME 04098-0695
 Property Address: 218 Ocean Ave, Units 218, 220 & 222
 CBL: 140-B-015-001

3:40:19 - The representatives present the application.

4:06:40 - Matthew Walker moves to close the public comment. Seconded by Christopher
“Buddy” Moore. (6-0). The motion passes.

4:07:35 - Matthew Walker moves to approve a rent increase amount to be determined.
Seconded by Matthew Lax.

4:20:30 - Matthew Walker moves that the application qualifies for major renovation and that the
adjustment to the Base Year rent is unnecessary. Seconded by Kristen Carreras (6-0). The
motion passes.

4:37:27 - Matthew Lax moves to strike expense worksheet Section 8 line items 3, 5, 6, and 7.
Seconded by Rebecca Bolduc. (6-0). The motion passes.




 Page 9
4:42:38 - Matthew Walker moves to adjust the basement repairs from the current year to the
base year and adjust the number from $200,000 to $107,735. Seconded by Kristen Carreras.
(6-0). The motion passes.

4:55:11 - Matthew Walker withdraws his motion from 4:07:35 to approve the rent increase
application for the property.

4:56:07 - Anne-Laure Razat moves in pursuant to Section 6-233(c) to approve the Base Rent
adjustment to $1,846.92 for each of the three units. Seconded by Matthew Lax. (6-0). The
motion passes.

5:12:49 - Matthew Lax moves that the increase is contingent on the applicant presenting
evidence of payment of the costs that have already been incurred. Seconded by Anne-Laure
Razat. (6-0). The motion passes.

5:16:13 - Matthew Walker moves that Board reserves the right to adjust the final Base Rent
adjustment if the landlord’s remaining anticipated construction costs are less than or exceeds
$13,500. Seconded by Matthew Lax. (6-0). The motion passes.

 e.​ Rent Increase Application - Completeness Review - See 5:25:39
 Owner: Woodford Arms, Inc., PO Box 10563, Portland, ME 04104
 Address: 168-180 Woodford St, all 18 units
 CBL: 124-J-014-001 & 124-J-012-001

 f.​ Rent Increase Application - Public Comment - See 5:25:39
 Owner: Saunders Street Apartments LLC, 51 Belfield Rd, Cape Elizabeth, ME
 04107
 Representative: Willard Bollenbach and Randi Bollenbach, 51 Belfield Rd,
 Cape Elizabeth, ME 04107
 Address: 23 Saunders St, all 5 units
 CBL: 130-G-014-001

 g.​ Rent Increase Application - Completeness Review - See 5:25:39
 Owner: RSAA Properties LLC, PO Box 9, Greenwood, ME 04255
 Address: 118 Providence St, Units 188 & 120
 CBL: 425-I-010-001

 h.​ Rent Increase Application - See 5:25:39
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner's Representative: Caleb Normandeau with Port Property
 Address: 72 Park Ave, Units 1-12
 CBL: 048-B-008-001
 Type of Increase: Increased Housing Service Costs




 Page 10
 i.​ Rent Increase Application - See 5:25:39
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner's Representative: Caleb Normandeau with Port Property
 Address: 157 Grant St, Units 1-26
 CBL: 053-B-024-001
 Type of Increase: Increased Housing Service Costs



VII. Adjourn

5:25:39 Anne-Laure Razat moves to adjourn. Seconded by Kristen Carreras. (6-0). The motion
passes. Pursuant to Article VII, Section 3 of the Rent Board’s Rules of Procedure, all remaining
agenda items are tabled to the next regular meeting.




 Page 11
12/2/25, 9:06 AM City of Portland Mail - Rent Board Public Hearing - 33 State St Rent Increase Appeal



 Dylan Orr <dorr@portlandmaine.gov>



  Rent Board Public Hearing - 33 State St Rent Increase Appeal
  Portland Tenants Union <info@portlandtenantsunion.org> Sun, Nov 30, 2025 at 7:33 PM
  To: Dylan Orr <dorr@portlandmaine.gov>, rentboard@portlandmaine.gov

 Mr. Orr,

 We would like to formally request that the appeal for 33 State Street on December 2nd be moved to the top of the
 agenda, if possible. We have at least one tenant from the building who works the night shift, who will not be able to testify
 past 6;30pm.

 Thanks for your consideration and for passing our request on to the Chair and members prior to the meeting.

 PTU Steering Committee

 [Quoted text hidden]
 [Quoted text hidden]
 [Quoted text hidden]




https://mail.google.com/mail/u/0/?ik=11a4336f94&view=pt&search=all&permmsgid=msg-f:1850263968169838245&simpl=msg-f:1850263968169838245 1/1
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 Page 14
 City of Portland – Licensing & Housing Safety Division
 TENANT RIGHTS COMPLAINT

Date of Hearing:

December 2, 2025


Appellant:
Portland Tenants Union


Owner Name and Address:
Atanas Dinkov

33 State St

Portland, ME 04101


Property Address and Unit:


33 State St


CBL:

044-B-016-001




 Page 15
 Portland Tenants Union
 info@portlandtenantsunion.org




September 25, 2025

City of Portland Rent Board
Mr. Mathew Lax
Via email: rentboard@portlandmaine.gov dorr@portlandmaine.gov

Dear Mr. Lax,

Pursuant to the standing granted to tenant unions under section 6-243(a) of the city code, we
submit this appeal under 6-263(c) contesting the City’s amended ruling in Code Case:
RCD2500009 regarding 33 State Street.

We submitted a complaint to the City of Portland on May 8, 2025 asserting the rights of all
tenants residing at 33 State Street since 2024, when Atanas Dinkov first purchased the property.
While the city initially ruled in our favor and rescinded Mr. Dinkov’s owner-occupied exemption,
they amended their ruling a month later to grant the exemption after Mr. Dinkov provided
circumstantial and irrelevant evidence claiming he had been living somewhere in his building
while it was fully occupied by leased tenants for the bulk of 2024 and into 2025.

To be clear, and as our evidence and testimony will show, Mr. Dinkov has not resided
anywhere in the building over the past year and, according to the law, even if he had
slept on a mattress next to the water heater and oil storage tanks in a boarded up
basement room below the first floor tenants for six months, his residency would not meet
either the letter or the intent of the rent control law.

According to the law, as defined by Section 6-231(d), a building with fewer than five units is
exempt from rent control if one of the said units is currently occupied by the owner as their
primary residence. Primary residence is defined in Section 6-150.1 as, “... the dwelling in which
a person resides as his or her legal residence for more than one half of a year and registers as
his or her address for tax and government identification purposes.”

The definition of “rental unit” in Sec 6-232 states, “any dwelling unit that is rented or otherwise
made available for rent for residential use or occupancy, together with all additional rights,
privileges, or services connected with use or occupancy of such a unit…”

In short, there are only three units in this property available for rent, as per the city
assessor’s office and the housing inspection department, and all three of those units
were occupied within three months of Mr. Dinkov purchasing the property, and all three
were fully leased and occupied for the subsequent year.

The only units, by law, Mr. Dinkov could have lived in to be granted the owner-occupied
exemption, were fully occupied by tenants for a year within three months of Mr. Dinkov




 Page 16
purchasing the property. There is simply no way he could have met the requirement for said
exemption.

Our complaint and backup documentation.

Based on reviewing CSS data and documents related to present tenancies at said property, we
believe the violations of the rent control ordinance at this property include:

 1.​ Mr. Dinkov falsely claimed an owner-occupied exemption, as 33 State was not Mr.
 Dinkhov’s principal residence when he registered it as such, nor was it during the
 entirety of the tenancies in this complaint, in violation of 6-231(d).

 a.​ Mr. Dinkov first purchased the property on January 5, 2024 (see exhibit 1) and all
 three of the units were occupied by tenants by April 1, 2024 (see leases for all
 three units respectively: exhibit 2, exhibit 3, and exhibit 4), making it impossible
 for him to claim this as his principal residence.

 b.​ Included are five signed and notarized affidavits from all five tenants occupying
 all three units, stating, under penalty of perjury, that Mr. Dinkov never lived at the
 property, that they never saw him sleep at the building, that they only saw him at
 the property when he was doing work renovating the basement, and, indeed, that
 he told all of them he was a renter in Ogunquit (see exhibit 5, exhibit 6, exhibit 7,
 exhibit 8, exhibit 9)

 c.​ Also included is video and photographic evidence showing the basement being
 torn apart in November of 2024, during the period Mr. Dinkov appears to be
 claiming he lived in the basement (exhibit 10).

 d.​ Additionally, Venmo transactions show him making home rent payments to
 property owner Ms. Donna Lewis in Ogunquit during the period of January, 2024
 to March of 2024 (and the rest of the year), adding to the evidence that he
 resided elsewhere (see exhibit 11). In fact, the Venmo payments actually use the
 emoji for rent.


 2.​ Mr. Dinkov illegally raised rents on all three units in the building in violation of Sec.
 6-234.

 a.​ Because 33 State Street was not owner-occupied, Mr. Dinkov was not allowed to
 raise rents in the building between tenancies by more than 10%. The registration
 of the units for 2023, when the building was owned by the previous landlord,
 shows the prior rents of the units to be $1,225, $1,175, and $1,125 respectively.
 Mr. Dinkov raised the rent the following amounts:

 i.​ Unit 1: 59.1% - From $1,225 to $1,950, as seen in exhibit 2
 ii.​ Unit 2: 61.7% - From $1,175 to $1,900, as seen in exhibit 3
 iii.​ Unit 3: 86.7% - From $1,125 to $2,100, as seen in exhibit 4


 3.​ Mr. Dinkov failed to provide 1 month’s rent as reimbursement for the inconvenience of
 terminating tenant leases in units 1 and 2 between 60 and 90 days, In violation of
 section 6-236(a)3.




 Page 17
 a.​ Mr. Dinkov notified the tenants of unit 1 and 2 that their tenancies would not be
 renewed and that they must vacate the units with less than 90-day notice (see
 exhibit 12 and exhibit 13), with no compensation provided as is required by law.



Mr. Dinkov’s “evidence”

Because there is no way, according to the law, for Mr. Dinkov to have actually lived in the
building to earn the right to an owner occupied exemption, we are reluctant to discuss any of the
circumstantial evidence he submitted attempting to claim he lived in an illegal dwelling in the
basement. However, in case he still wants to argue that he spent 180+ days and nights in this
windowless room, we will address a few of his more specious submissions.


Parking Tickets:
​
Mr. Dinkov provided three parking tickets showing his car was parked in front of his building, two
of which were in the middle of the night (see exhibit 14) as evidence he lived there. It should not
need to be said, but by any means of legal analysis, having a picture of one’s car outside of a
building does not provide any meaningful context about whether that building is one’s primary
residence.

That said, even if this did suggest he lived in the building, in reality, two of the parking tickets do
not even cover the period in question. One was before the building was fully occupied by
tenants (February 6, 2024) and the second was after the tenants left (May 20, 2025). The only
one covering the period in question, from August 22, 2024, was issued at 5:49 pm according to
the city of Portland parking division, a time when even the tenants testified he was sometimes
present demolishing the basement.


Car Registration:

Mr. Dinkov provided his car registration, which claims his legal address as “33 State Street, Apt.
1.” First of all, apartment one was occupied, as evidenced by the lease we submitted. Second,
this registration covers from August 1, 2024-July 31, 2025 (see exhibit 15). He claimed the
owner occupied exemption back in February of 2024, when, according to the city of Portland,
his car was not registered in Portland (see exhibit 15). When we called the State DMV, they
confirmed the car was not registered in Portland prior to August 1, 2024. We’d suggest you ask
for the registration of his car for the year covering February, 2024 when he claimed he lived in
the building.


Note from neighboring landlord:

Mr. Dinkov provided a note from the owner of the property next door (31 State St.) claiming that
in August, 2024, Mr. Dinkov told him that he could no longer share the laundry room with 31
State Street. The reason was that Mr. Dinkov claimed to be moving into the basement at that
time. However, we know this claim to be false because the laundry room remained in use by the
tenants of 33 and 31 State Street until November 11, 2024 when Mr. Dinkov informed his
tenants that it would no longer be safe to enter the basement due to his “improving the heating
system” (see exhibit 16). Again, this bolsters our claim he did not live in the building when he
registered it as owner-occupied and that his “evidence” is false.




 Page 18
Text from upstairs tenant:

Mr. Dinkov provided a text from the tenants in Unit 1, just above the area he claimed to live. In
the text he quotes the tenants as saying, “It feels like there is very little separation between us
and anything going on in the basement. This morning you woke us up at 7:30am.” (see exhibit
17). However, when you read the full text, you see it was from November 2 and clearly talks
about hammering and power tools, which makes sense since he was renovating the basement
by this time. As the tenants state in their affidavit, the disturbance on this occasion was caused
by Mr. Dinkov entering the basement with a contractor below their bedroom early in the
morning. The tenants in unit 1 never sent any messages complaining about noise from the
basement prior, because no one was living there.


Appraisals claiming a “finished basement”:

Mr. Dinkov provided partial documentation from three appraisals of the property. Two from
November, 2023, before he purchased the property and one from October, 2024, after he had
owned it for 10 months. Although we do not have the full appraisals, and hence do not know
what he is refusing to share, none of the appraisals describe a dwelling unit in the basement. In
fact, the appraisal from 2024 describes only a laundry room as finished, and it awards the value
of that space at only $12 per square foot, vs $55 per square foot for the livable spaces. The
second appraisal shows three pictures of the basement, none which show a livable space (they
show the laundry room, the meters, and the water heater). And the first says that while the
basement is “finished” it says, “most of the finishings are old and/or damaged” and
recommended that they be removed.

Beyond this, there is no evidence whatsoever that insinuates the boarded up room in the
basement of 33 State St. meets the robust minimum habitability standards for a “dwelling unit”
outlined in Chapter 6 of the City Code, even if all of these other falsehoods were hypothetically
true. From what we can tell, there wasn’t even a toilet.

We could go on and on...


In light of these violations, and this brazen attempt to sidestep the law, gouge his
tenants, and make these three units unaffordable, we request that the Rent Board:

 1.​ Revoke Mr. Dinkov’s primary residence exemption from rent control for 2024.

 2.​ Repeal all rent increases imposed by Mr. Dinkov in 2024 and restore rents back to the
 last compliant rent ($1,225, $1,175, and $1,125 for units 1, 2, & 3, respectively).

 3.​ Require Mr. Dinkov to fully refund tenants the amounts they were overcharged over the
 course of their leases, which, by our account, looks to be at least $725 per month for
 Units 1 & 2, and $975 per month for Unit 3.

 4.​ Ensure that the tenants of Unit 1 and Unit 2 are each given one month’s rent (at the
 illegally high price that they were paying) as compensation for being given less than
 90-days notice to vacate the unit.




 Page 19
 5.​ Due to the egregious nature of these violations, impose fines on Mr. Dinkov similar to
 recent rent board levies: $100 per month per unit for illegal rent increases collected
 ($3,600) and $100 per violation for inadequate notice compensation ($300). Plus, $1,000
 for his filing false information in regard to owner-occupancy, in violation of Section
 6-150.1.

 6.​ Additionally, we request $100 per instance for not providing the tenant rights document
 (as outlined in the amended NOV), $100 for not posting the tenant rights document (as
 outlined in the amended NOV). The landlord was not fined for either of these.

Thank you for your immediate attention to this matter. We are happy to answer any questions
about this complaint and provide additional backup documentation regarding any and all the
matters discussed in this letter.

We request that all communications regarding this complaint be sent to the union in response to
our complaint and all documents pertaining to this investigation be made public upon
completion.

Portland Tenants Union Steering Committee




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 SWORN AFFIDAVIT OF MARIETTA MALLON

​ I, Marietta Mallon, being duly sworn, state as follows:

 1.​ I was a tenant at 33 State St, Unit 1, Portland, Maine, from April 1, 2024 to April 4,

 2025. I lived at this address with my partner, Sophia Thomas, where we rented from

 Mr. Atanas Dinkov.

 2.​ Our lease included access to the laundry room, which took up about half of the

 basement. The rest of the basement was locked and windowless.

 3.​ At the beginning of our lease term Mr. Dinkov told me that he was a renter in

 Ogunquit, ME and he discussed living in Ogunquit on multiple occasions.

 4.​ Our apartment was on the first floor of the three story building and was located

 directly above the basement.

 5.​ Ms. Thomas and I slept in the unit almost every night during the year of our tenancy,

 and in the bedroom above the enclosed area of the basement.

 6.​ Due to the absence of soundproofing between the floor of my apartment and the

 basement, as well as gaps around pipes that allowed light through, I was aware of any

 activity taking place below us. Noises as subtle as a heavy sigh, mumbling, and

 footfalls were audible in our apartment, and when a light was turned on, I could see it

 through the cracks.

 7.​ At no point during the entirety of my tenancy did my landlord, Mr. Atanas Dinkov,

 make the basement of the building his residence. I know this based on what I saw and

 heard, and based on Mr. Dinkov’s own statements to me.

 8.​ From April 1, 2024 to May 4, 2024, Mr Dinkov did not live in the basement, nor was

 he at the property much.



 1


 Page 44
9.​ On May 4, 2024, Mr. Dinkov informed us that he would be out of the country for an

 extended period of time.

10.​On August 13, 2024, he informed us of his return to Maine.

11.​For several days in early September, Mr. Dinkov came to the building after work to

 remove an old oil tank in the basement. The fumes from this process were so strong

 that my partner and I had to spend a night elsewhere. Mr Dinkov confirmed this when

 I texted him about the chemical fumes (see exhibit A).

12.​His work in the basement continued sporadically through Sept/Oct.

13.​On November 2, 2024, I texted Mr. Dinkov to say that this work was disruptive and

 that he and his contractor had woken me and my partner up at 7:30am as they were

 discussing moving the water heater (see exhibit B).

14.​On November 11, 2024, Mr. Dinkov texted all five tenants of 33 State St. informing

 us that it would no longer be safe to use the laundry room because he was “improving

 the heating system” (see exhibit C).

15.​My partner and I went into the basement on November 11, 2024 and saw parts of the

 ceiling ripped out, wires hanging down, wood and rusty metal debris scattered

 throughout the space, and a large portion of the wall torn down (see exhibit D).

16.​On November 24, 2024, a Sunday, the sound of a smoke detector’s low battery beep

 was audible through the floor from the closed section of the basement. When my

 partner texted Mr. Dinkov in our shared group chat at 12:16pm to let him know, he

 replied by saying that he would stop by the property in a few hours (see exhibit E).

17.​After providing notice of lease non-renewal on January 29, 2025, Mr. Dinkov

 informed me that he needed our unit so that he could move into the property.



 2


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Rent payments made by Mr. Dinkov to Ms. Donna Lewis by Venmo from January 2024 - April, 2025




 Page 59
Rent payments made by Mr. Dinkov to Ms. Donna Lewis by Venmo from January 2024 - April, 2025




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10/28/25, 3:47 PM City of Portland Mail - Rent Board Public Hearing - 33 State St (CBL: 044-B-016-001)



 Dylan Orr <dorr@portlandmaine.gov>



  Rent Board Public Hearing - 33 State St (CBL: 044-B-016-001)
  2 messages

  Atanas Dinkov <addinkov01@gmail.com> Mon, Oct 27, 2025 at 12:10 PM
  To: rentboard@portlandmaine.gov

 Hi there,

 My name is Atanas Dinkov and I own the property located on 33 State St (CBL: 044-B-016-001) Portland Maine.
 I am reaching out regarding a request for a hearing submitted by Portland Tenants Union in regards to a
 potential violation of the City of Portland's Rent Stabilization Ordinance.
 Please note that Portland Tenants Union has already notified Housing Safety/Permitting and Inspection
 department regarding potential violation of the City of Portland's Rent Stabilization Ordinance. As a
 result investigation was completed by Adam O’Conner (Rental Registration Inspector Licensing) that concluded the
 property located at 33 State Street was owner-occupied as defined under Sec 6-150.1 of the City Code from January
 2024 to present, exempting the property from Article XII.

 All this started in May 2024 and I do not understand why I have to go through this again?

 I am providing the following information in addition to investigation completed:

 1. Amendment of Notice of Violation and Order to Correct
 2. House inspection completed by Department of Planning and Urban Development CITY OF PORTLAND – please note
 this is a clear evidence Basement Unit was a Legal rentable unit including operational bathroom/shower and toilet.
 3. Property data card – uploaded from City of Portland website. See towards the end of page This is an additional prove
 (besides Home inspection and two apprisals.) regarding Finished Basement status which is considered a livable area.
 4. Extraction Bank statements regarding Venmo Payment – this is a proof I am paying $500.00 per month for an Office
 space including parking plus $70.00 for a Verizon phone line. Bank statements were provided to Adam O’Conner too.
 5. CPA license for the state of Maine. – I need an office to complete my accounting work.
 6. First pages of 2024 tax return and Tax Transcript showing my legal address 33 State street Portland ME.
 7. Copy of Drivers License. - please note I changed my address beginig of the fiscal year 2024.
 8. Copy of email from Portland Tenant Union insisting me paying $35,937.50 to tenants and identifying my going forward
 rents. Just wondering does the union have the right to enforce City of Portland Housing Safety Department Notice of
 Violation?
 9. Portland Tenants Union Constitution – Please see page 3/5 section Financial Reimbursement from Landlords and
 consider the reason and more specifically the incentives Portland Tenant Union is trying to receive. This file was
 dowloanded from Portland Tenant Union website.
 10. Link where the Portland Tenants Union Constitution was found.
 11. Birth Certificate - explaning the reason I spent few months out of the country. I will provide copy of flight tickets if you
 would like.

 Let me know if you have any additionla questions/requests.
 Plese confirm you have received this email and all files attached

 Thank you.




 11 attachments
 CPA License.pdf
 166K
 Bank stmts Venmo payments.docx
 107K
 ID.docx
 488K
https://mail.google.com/mail/u/0/?ik=11a4336f94&view=pt&search=all&permthid=thread-f:1847152072845833463&simpl=msg-f:184715207284583346… 1/2
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10/28/25, 3:47 PM City of Portland Mail - Rent Board Public Hearing - 33 State St (CBL: 044-B-016-001)

 Gmail - Fw_ NOV for 33 State.pdf
 639K
 Birth Certificate.pdf
 1264K
 LINK Portland Tenants Union Constitution DRAFT link.docx
 14K
 Property data card.pdf
 51K
 PTU Constitution DRAFT (2025) - Google Docs.pdf
 137K
 Amended 33 State Street Notice of Violation (1) - Copy.pdf
 2205K
 Tax return.pdf
 1530K
 33 State St Housing Inspection 4 units.pdf
 3172K


  Dylan Orr <dorr@portlandmaine.gov> Tue, Oct 28, 2025 at 11:30 AM
  Cc: rentboard@portlandmaine.gov

 got it

 Dylan Orr
 Rental Registration Coordinator
 City of Portland
 389 Congress St, Portland, ME
 207-874-8966
 dorr@portlandmaine.gov




 [Quoted text hidden]




https://mail.google.com/mail/u/0/?ik=11a4336f94&view=pt&search=all&permthid=thread-f:1847152072845833463&simpl=msg-f:184715207284583346… 2/2
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10/30/25, 2:03 PM City of Portland Mail - Rent Board Public Hearing 33 State St - additional information



 Dylan Orr <dorr@portlandmaine.gov>



  Rent Board Public Hearing 33 State St - additional information
  1 message

  Atanas Dinkov <addinkov01@gmail.com> Thu, Oct 30, 2025 at 9:29 AM
  To: rentboard@portlandmaine.gov

 Good morning,
 I am providing additional information regarding my case.
 I am kindly asking to consider Rule 80B of Maine Rules of Civil Procedure according to which each side of the case has
 the right to appeal a City of Portland decision to Superior Court within 30 days.

 Portland Tenants Union DID NOT appeal CIty of Portland decision to Superior Court or to the Rent Board within the time
 frame (30 days) according to rule 80B which is explicitly stated within initial email and Notice of Violation by itself. (See
 attached)
 Notice of Violation was issued on 07/17/2025 and Portland Tenants Union letter requesting public hearing is dated
 09/25/2025. I believe this is about a 70 days time period without response. In my understanding if you do not appeal a
 Government decision within time frame defined in this case by Rule 80b of the Maine Rules of Civil Procedure you agree
 with it.

 Thank you very much for your consideration.




 Rule 80b.pdf
 1160K




https://mail.google.com/mail/u/0/?ik=11a4336f94&view=pt&search=all&permthid=thread-f:1847413679445515727&simpl=msg-f:1847413679445515727 1/1
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City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


07/17/2025
License #: LTR-006077-2024
Code Case #: RCD2500009

Atanas Dinkov
33 State St
Portland, ME 04101

 AMENDMENT OF NOTICE OF VIOLATION AND ORDER TO CORRECT

A Notice of Violation and Order to Correct (NOV) was issued on 06/24/2025 and required the violations
related to property at 33 State Street (“Property”) to be corrected by 07/24/2025. The NOV alleged
violations of Section 6-155 (d) (providing false information) and of Section 6-234(c) (improper rent
increases) based, in part, on the finding that the Property was not owner-occupied prior to the Owner,
Atanas Dinkov (“Owner”), moving into Unit 1 on or about April 15, 2025.


At the time of an on-site inspection on June 11, 2025, the Owner was residing in Unit 1. Unit 2 was being
renovated, and Unit 3 was tenant occupied. The basement was also being renovated and was torn down to
the studs. Given the condition of the basement, it was determined that the Owner could not have lived in
the basement prior to moving into Unit 1. As a result, the City issued the NOV based on the premise that the
Property was not owner-occupied when the Owner increased the rent in January 2024.


Following the issuance of the NOV, the Owner provided additional information which, after careful review
and consideration, the City finds sufficiently demonstrates that the Owner resided at the Property from
January 2024 to present and, therefore, the Property was exempt from Article XII of Chapter 6 of the City
Code.


In reaching this conclusion, the City considered the following information from the Owner:
The Owner indicated that he resided at the Property from January 2024 to present. The Owner explained
that a personal family situation required him to travel to and from his home country of Bulgaria. The Owner
initially resided in Unit 1, then relocated to the basement of the Property, and moved back into Unit 1 after
the unit was vacated on or about April 15, 2025.


The Owner also provided the following exculpatory information to support his contention that he resided at
the Property at all times relevant to the NOV:
 • A Home Inspection report dated 11/15/2023 from Square One Inspections, Matthew Tycz
 (inspector). The inspection report refers to the basement as “Finished”. The report goes further to
 say, “Most of the basement ceilings, walls, and floors have been covered with interior finishing”.
 The report contains photos of the basement in a finished state.
 • An Appraisal of Real Property report dated 11/17/2023. The report contains photos of the
 basement in a finished state.




389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov


 Page 73
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager



 • An Appraisal of Real Property report dated 10/18/2024 from Class Valuation, Christina Strong
 (appraiser). The report refers to the basement as “finished”. The report contains photos of the
 basement in a finished state.
 • A text message from a tenant to the Owner dated 11/2/2024 informing the Owner that the noise
 from the basement was disturbing them. The text states, “the sound of voices when someone
 speaks from below is loud enough that they seem to be almost in the same room with us.” The
 message also states, “This morning you woke us up at 7:30 am.”
 • A Google Maps Street View photo dated December 2024 that shows the Owner’s car in front of the
 building.
 • Three parking tickets with photos that show the Owner’s car in front of the building. The tickets
 are dated 2/6/2024, 5/20/2024, and 8/22/2024.
 • A copy of the Owner’s vehicle registration showing the vehicle cited in the parking tickets is their
 registered vehicle.
 • A signed letter dated 7/1/2025 from Dimitry Shevorski, resident of 31 State St, Apt 3, the letter
 states that in August 2024, the Owner told Mr. Shervorski he “will no longer be able to use the
 washer/dryer that was located in the basement unit of his building because he was going to live
 there. Moving forward, I frequently saw him going in and out of that unit, lights being on there, and
 his car being parked by the building.”
 • A signed letter dated 7/3/2025 from UPS driver Joe Dubber that states, “Based on how often I see
 him making deliveries on 33 State Street Portland ME and nearby I believe Atanas resides at 33
 State Street Portland ME.”
 • A signed letter dated 7/12/2025 from Donna Lewis of 62 Cherry Lane, Ogunquit, ME 03907. The
 letter states that “Atanas Dinkov rents a room in our house in Ogunquit, ME which he uses as a
 workspace from time to time. He pays us $500 per month for the room and a parking space; plus
 $70 per month for his Verizon phone line.” The Owner reports that he uses that space as his office
 to conduct his professional accounting work and does not live there.
 • The Owner presented bank records showing a payment of $570 from his Venmo account.
 • The Owner had their own mailbox at the Property to receive correspondence.


Copies of the aforementioned documents are attached for reference. Given the documents and information
provided by the Owner it can reasonably be assumed that the Property was owner-occupied as defined
under Sec 6-150.1 of the City Code from January 2024 to present, exempting the property from Article XII.


The following violation(s) have been resolved as a result of the additional information received:
 • Sec 6-155(d) – Providing False Information
 • At the time of the Short-Term Rental Registration, the information provided by the Owner was
 accurate. Article VI of the City code requires registration for new owners within 30 days of
 purchase, but does not require the City to be notified if an owner vacates the occupied unit. There
 is no evidence that the Owner rented Unit 1 as a Short-Term Rental while it was occupied by the
 long-term tenant.
 • One count of providing false information will remain for Long-Term Registration. The penalty for
 which is $1,000.
 • Unit 1 was not properly registered as a Long-Term Rental in 2024 or 2025. The Owner will be
 required to register the unit for those years and pay all applicable fees and penalties.



389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov


 Page 74
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


 • Sec 6-234(c) – Increase in Rent of over 10%
 • The property is Owner-occupied as defined by Sec 6-150.1 and exempt from this requirement.

 • Sec 6-236 – Termination of Tenancy
 • The property is Owner-occupied as defined by Sec 6-150.1 and exempt from this requirement.
 • The Owner provided the 30-day minimum notice as required by the State of Maine.

 • Sec 6-234(f) – Remedy
 • The property is Owner-occupied as defined by Sec 6-150.1 and exempt from this requirement.
 • As an exempt property, no rent overcharges remain.



In conclusion, the Owner has demonstrated through contemporaneous documentation and signed letters
that the property was owner-occupied at all times relevant to the NOV. A new Notice of Violation has been
issued with the current violations and sent to the Owner.


Thank you,



Adam O’Connor
Rental Registration Inspector




389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov


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Please see pages: 6/8 and 8/8
Note: This is a clear evidence Basement Unit was a Legal
rentable unit including operational bathroom/shower and toilet.




 Dwelling units 4




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Basement




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 Four dwelling units




Basement dwelling unit.




  Page 100
Property Search | Portland ME 11/13/23, 5:23 PM


PARID: 044 B016001 33 STATE ST
GAY ERIC H AND HEATHER GAY JTS

Parcel

Parcel ID 044 B016001
Property Location 33 STATE ST
Unit
Living Unit 3
Land Use Code 13 - THREE FAMILY


Land Area (acreage)
Land Area (square footage) .0436
Notes 1899
 44-B-16
 STATE ST 33
 1901 SF
Utilities
 1 - ALL PUBLIC
 -
 -
Owners

Owner GAY ERIC H &
 HEATHER GAY JTS
Address 33 STATE ST
City, State, Zip PORTLAND ME 04101
Deed Date 10/19/2018
Book 35230
Page 147

Assessed Values

Land $197,900
Building $375,200
Total $573,100
Homestead / Veterans Exemption $0
Other Exemptions $0
Taxable Value $573,100

Sales History

Date Price Grantee Grantor Book Page
10/19/2018 $350,000 GAY ERIC H & CBPC HOLDINGS LLC 35230 147
04/16/2010 $330,000 CBPC HOLDINGS LLC MID-TOWN PROPERTIES LLC 27715 023
05/20/2009 $0 MID-TOWN PROPERTIES LLC SIMPSON WILLIAM P 26907 165
03/25/2008 $0 SIMPSON WILLIAM P 25917 129
11/16/2007 $0 MID-TOWN PROPERTIES LLC 25624 059


Residential

Card 1
Style OLD STYLE
Year Built 1900
Stories 3
Attic 1 - NONE
Fuel Type 4 - OIL
Heat System 5 - STEAM
Heat/AC Type 2 - BASIC
Fireplaces 1
Total Rooms 15
Bedrooms 6
Full Baths 3
Half Baths
Basement 4 - FULL
Basement Garage Spaces
Finished Basement Area 200
Basement Rec Room Area
Unfinished/Cathedral Area
Living Area 1,973

Assessment History



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Property Search | Portland ME 11/13/23, 5:23 PM


 Standard Other Taxable
Year Land Building Total
 Exemption Exemption Value
2023 $197,900 $375,200 $573,100 $0 $0 $573,100
2022 $197,900 $375,200 $573,100 $0 $0 $573,100
2021 $197,900 $375,200 $573,100 $0 $0 $573,100
2020 $133,100 $120,000 $253,100 $0 $0 $253,100
2019 $133,100 $120,000 $253,100 $0 $0 $253,100
2018 $133,100 $120,000 $253,100 $0 $0 $253,100
2017 $133,100 $120,000 $253,100 $0 $0 $253,100
2016 $133,100 $120,000 $253,100 $0 $0 $253,100
2015 $133,100 $120,000 $253,100 $0 $0 $253,100
2014 $133,100 $120,000 $253,100 $0 $0 $253,100




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 State of Maine
 DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION
 OFFICE OF PROFESSIONAL AND OCCUPATIONAL REGULATION
 BOARD OF ACCOUNTANCY




 License Number CP10739
 Be it known that
 ATANAS DIMITROV DINKOV
 has qualified as required by Title 32 MRS Chapter 113 and is licensed as:
 CERTIFIED PUBLIC ACCOUNTANT




ISSUE DATE EXPIRATION DATE
September 30, 2025 Joan F. Cohen, Commissioner September 30, 2026




  Detach
 STATE OF MAINE STATE OF MAINE
 DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION
 OFFICE OF PROFESSIONAL AND OCCUPATIONAL REGULATION
 BOARD OF ACCOUNTANCY
 35 State House Station
 Augusta, Maine 04333-0035
 (207) 624-8603


 License Number CP10739
 ATANAS DIMITROV DINKOV
 CERTIFIED PUBLIC ACCOUNTANT


 Joan F. Cohen, Commissioner
  ISSUED 09/30/2025 EXPIRES 09/30/2026




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10/26/25, 8:27 AM Gmail - Fw: NOV for 33 State



 Atanas Dinkov <addinkov01@gmail.com>



  Fw: NOV for 33 State
  1 message

  Atanas Dinkov <addinkov@yahoo.com> Sun, Oct 26, 2025 at 8:26 AM
  To: Atanas Dinkov <addinkov01@gmail.com>



 ----- Forwarded Message -----
 From: Portland Tenants Union <info@portlandtenantsunion.org>
 To: "addinkov@yahoo.com" <addinkov@yahoo.com>
 Sent: Monday, July 14, 2025 at 12:33:10 PM EDT
 Subject: NOV for 33 State

 Good afternoon Mr. Dimitrov,

 We are Portland Tenants Union. We represent tenants throughout the city of Portland in regard to rent control issues and
 have helped negotiate a number of settlements to resolve complaints and notices of violation.

 In this case we are reaching out at the request of your former tenants at 33 State Street. As you know, the city of Portland
 issued a notice of violation on June 24, 2025 regarding their tenancies, with a deadline of July 24, 2025 to resolve those
 violations in order to avoid fines and possible legal action. Based on that notice, we believe that you owe the tenants the
 following amounts:
 1-0 | |
 Unit 1 - $10,650 1-1 | | 10,650.00
 Unit 2 - $13,587.50 1-2 | | + 13,587.50
 Unit 3 - $11,700 1-3 | | + 11,700.00
 Please keep in mind 10% would go to the union. See work
 1-T | Total | = 35,937.50 paper PTU Constitution DRAFT 2025 attached.
 And the rents for the units going forward must be set at:

 Unit 1 - $1,125 1 bedroom apartment
 Unit 2 - $1,175 1 bedroom apartment
 Unit 3 - $1,125 2 bedroom apartment

 We are reaching out to see if we can help facilitate the resolution of these matters. We are certainly willing to work with
 you to find the best way to make this work for everyone. As the tenants have asked us to represent them in this matter,
 please reach out to us with any questions and to discuss payment details, rather than contacting the tenants directly.

 We look forward to resolving this matter with you before the deadline of July 24, 2025, so you can present something to
 the city saying the matter is satisfied.

 Sincerely,
 PTU Steering Committee




https://mail.google.com/mail/u/0/?ik=b2a7492f9c&view=pt&search=all&permthid=thread-f:1847047333486892585&simpl=msg-f:1847047333486892585 1/1
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See page 3/5 ​Portland Tenants Union Constitution DRAFT​

 ​Table of Contents​
 ​Introduction​
 ​Article I – Name​
 ​Article II – Objectives and Principles​
 ​Article III – Organizational Structure​
 ​Article IV – Membership​
 ​Article V – Tenant Council​
 ​Article VI – Elections​
 ​Article VII – Amendments​

 ​Introduction​

 ​We are a city wide union run by and for Portland tenants. We believe that all people deserve a safe and​
 ​affordable place to live and we are dedicated to fighting for the rights and dignity of all tenants. We​
 ​come from all backgrounds and walks of life, including different races and ethnicities, cultures and​
 ​religions, genders and sexual orientations. We are united by our shared commitment to justice for​
 ​tenants and we are building a powerful union to fight for our rights.​

 ​We prioritize affordability and the fundamental right to housing over the profits of a few wealthy​
 ​landlords, developers, and Wall Street hedge funds. We will work toward a future in which Portland​
 ​guarantees a home for all and where housing is not a speculative investment. Where landlords are held​
 ​accountable to providing safe, well maintained, beautiful housing that is comfortable, stable, and​
 ​affordable.​

 ​Article I – Name​

 ​Portland Tenants Union [PTU].​

 ​Article II – Objectives and Principles​

 ​The objectives of PTU are:​
 ​1)​ ​To educate, organize, and unite Portland tenants.​
 ​2)​ ​To win improved housing conditions and stable and affordable rents.​

 ​Article III – Organizational Structure​

 ​3.1 Annual Membership Convention​
 ​Each year, in January if possible, a Convention of PTU’s membership will decide key matters of​
 ​organization and strategy for the year to come.​

 ​3.2 Tenant Council​
 ​The Tenant Council will carry out the mandate of the membership between Conventions. The Tenant​
 ​1​

 Page 109
​Council will be composed of two Co-Chairs, a Secretary, and a Treasurer, and up to seven (7) members,​
 ​elected by dues-paying Union members.​

 ​Article IV – Membership​

​4.1 Membership Criteria​
 ​1.​ ​All renters in Portland are eligible to become members of PTU.​
 ​a.​ ​A renter shall be defined as any person who pays rent to a landlord for housing or who​
 ​lacks stable housing.​
 ​2.​ ​Any renter who lives in Portland may join PTU by filling out the official member sign up form​
 ​and paying monthly dues.​

​4.2 Rights of Members​
 ​1)​ ​Full backing from PTU in disputes with their landlord.​
 ​a)​ ​Advise members on their rights.​
 ​b)​ ​Contact the landlord on behalf of members, upon request.​
 ​c)​ ​Provide Tenant Advocates to attend meetings with the landlord.​
 ​d)​ ​Recommend lawyers and provide financial support for legal representation, when​
 ​possible and approved by the Tenant Council.​
 ​e)​ ​File complaints on their behalf upon request to the city.​
 ​f)​ ​File complaints on their behalf upon request to the rent board.​
 ​2)​ ​To vote in all Union elections in accordance with these bylaws, agreements directly affecting​
 ​the member as a tenant, and to run for any position on the tenant council.​
 ​3)​ ​To attend, participate, and vote on all questions at the yearly Membership Convention and all​
 ​regular and special membership meetings of PTU.​
 ​4)​ ​To utilize all services provided by PTU and to participate in all social, educational, and cultural​
 ​activities.​
 ​5)​ ​Ability to purchase any PTU merchandise at cost.​
 ​6)​ ​Access to member-only communication channels.​

​4.3 Responsibilities of Members​
 ​1)​ ​Support and defend PTU and members.​
 ​2)​ ​Comply with decisions of PTU made pursuant to this constitution.​
 ​3)​ ​Participate in PTU activities when requested (such as attending rent board meetings, emailing​
 ​city council etc.)​

​4.4 Dues​
 ​1)​ ​Portland Tenants Union collects dues from all Union members to further the activities of PTU,​
 ​such as administrative costs, events, and legal support.​
 ​2)​ ​PTU collects dues as a percentage of rent (minimum .5%, not to exceed 1.5%). Landlords are​
 ​encouraged to stand with PTU in solidarity by pledging to pay these dues on behalf of their​
 ​tenants.​


 ​2​

 Page 110
 ​a)​ ​Tenants receiving public support (section 8, voucher, general assistance, etc) pay dues​
 ​based on their portion of rent.​

 ​Dues Exemptions:​
 ​Tenants may request dues waivers in the following circumstances:​
 ​1)​ ​Rent is more than 50% of monthly income and income is below 80% of median average​
 ​income ($68,500 as of 2024).​
 ​2)​ ​Tenants who are unemployed.​
 ​3)​ ​Unhoused.​
 ​4)​ ​Other extenuating circumstances.​

 ​Financial Reimbursement from Landlords​
 ​In the case that PTU assists a member, or group of members, in receiving monetary​
 ​compensation from their landlord in relation to a violation of tenants rights, a donation of 10%​
 ​is recommended back to PTU from the member.​

 ​Article V – Officers and Tenant Council​

​5.1 Co-Chairs​
 ​1)​ ​The Co-Chairs will be elected by the general membership of PTU. The term of the Co-Chairs​
 ​shall be 2 years with no term limit (terms will be staggered).​
 ​2)​ ​The Co-Chairs are empowered by their elections to carry out the plans and programs decided on​
 ​by the Tenant Council and are responsible for the day-to-day administration of PTU, including,​
 ​but not limited to:​
 ​a)​ ​Facilitates broad rank-and-file participation​
 ​b)​ ​Grows the membership and power of PTU​
 ​c)​ ​Represents PTU publicly and with key coalitional partners​
 ​d)​ ​Drives strategic planning, including providing an annual budget to the Tenant Council​
 ​for approval​
 ​e)​ ​Calls and chairs regular and emergency meetings of the Tenant Council.​
 ​f)​ ​Create committees as needed​
 ​g)​ ​Sign official documents​

​5.2 Secretary​
 ​The Secretary will be elected by the general membership of PTU. The term shall be 1 year.​
 ​1)​ ​Maintain PTU documents and organizational systems​
 ​2)​ ​Maintain PTU communication channels including the website​
 ​3)​ ​Manage membership lists and CRM​

​5.3 Treasurer​
 ​1)​ ​The Treasurer will serve as PTU’s chief fiscal officer.​
 ​2)​ ​The Treasurer will receive, manage, and distribute dues/funds according to the principles of​
 ​PTU, as authorized by the Tenant Council, as executed by the Co-Chairs.​

 ​3​

 Page 111
​5.4 Tenant Council Members​
 ​1.​ ​In addition to the officers, the tenant council shall consist of up to 7 members of the Portland​
 ​Tenants Union willing to take an active role in developing and promoting the activities of PTU.​
 ​2.​ ​Tenant council terms shall be one year, with no term limit.​
 ​3.​ ​The Tenant Council will meet at least 10 times a year and will be chaired by one of the PTU​
 ​Co-Chairs.​​The Council may decide to meet more frequently,​​and may also meet on an area or​
 ​committee basis.​
 ​4.​ ​At any time, one-third of the members of the Council may request that the Co-Chairs Convene a​
 ​special meeting of the Council which must be held within ten days after receipt of such request.​
 ​5.​ ​An elected Tenant Council member who fails to attend three Council meetings in a year,​
 ​without proper excuse, will cease to be a member of the Council. The vacancy will be filled by​
 ​a special election no later than six weeks from the time the vacancy occurs. Procedure for other​
 ​elections, except as otherwise provided in these bylaws, will be determined by the Tenant​
 ​Council.​

​The Tenant Council will have the following powers:​
 ​1)​ ​To formulate plans, programs, and policies for PTU.​
 ​2)​ ​To receive and act upon reports of the Co-Chairs and other​​officers.​
 ​3)​ ​To approve an annual budget recommended by the Co-Chairs, including the expected dues​
 ​level, and authorize the officers to execute said budget.​
 ​4)​ ​To call rent strikes, when authorized by the members direc​tly affected as tenants.​
 ​5)​ ​To recommend a city-wide rent strike with 70% support of the membership.​

  ​5.5 Recalls​
​All Officers and Tenant Councilors may be recalled through procedures developed by the full Tenant​
 ​Council and approved by membership​

 ​Article VI – Elections​
​6.1 Voting​
 ​1)​ ​The officers and members of the Tenant Council shall be elected at the annual Membership​
 ​Convention by majority vote through ranked choice.​
 ​2)​ ​The first two Co-Chairs will be elected to staggered terms (one for two years, and one for one​
 ​year). Thereafter, one or the other will be up for re-election annually.​
 ​3)​ ​The Tenant Council reserves the right to revise these election proceedings after the 2024​
 ​Membership Convention.​

​6.2 Vacancies​
 ​1)​ ​Each officer elected at the Membership Convention shall take office immediately upon the​
 ​officer’s election and shall serve until the officer’s successor is elected.​
 ​2)​ ​In the event of a vacancy in the office of either Co-Chair or the Secretary or Treasurer, the​
 ​remaining Tenant Council will appoint an interim within 30 days of the vacancy until a​
 ​replacement is elected at the next Annual meeting to fill the remainder of the term.​

 ​4​

 Page 112
 ​Article VII – Amendments​

​Amendments to these bylaws may be initiated by:​
 ​1)​ ​A majority vote of the Tenant Council; or,​
 ​2)​ ​A petition signed by ten percent (10%) of the members of PTU who are in good standing.​

​The Tenant Council shall submit the proposed amendment(s) to a vote of the general membership with​
 ​at least 30 days notice at any membership meeting. Amendments will be approved with a 3/5ths vote.​




 ​5​

 Page 113
Portland Tenants Union Cons�tu�on DRAFT

htps://docs.google.com/document/d/1OwHMLK2tMa4NhsbE4bKgZ1CgoH82GdMMiCAtUmhO
5rg/edit?link_id=4&can_id=2a122f020fc2a9cf67d9a1c5332407b9&source=email-ptu-march-
5th-general-mee�ng-2&email_referrer=&email_subject=ptu-goes-to-city-council-and-may-
general-
mee�ng&&&link_id=7&can_id=1be104dc5f419c213ba0cc0�4e5fa94&email_referrer=email_27
21751&&&email_subject=portland-tenants-union-events-this-week&tab=t.0




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City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


To: Rent Board Chair and Members
From: Adam O’Connor, Rental Registration Inspector
Subject: Address – 33 State Street, CBL 044 B016001
Code Case: RCD2500009
Date: November 25, 2025
RE: Memorandum – Interpretation Appeal – Portland Tenant Union



 Introduction

By letter dated September 25, 2025, the Portland Tenants Union (“PTU” herein) filed a complaint with this
Board challenging the City’s findings that the property located at 33 State Street in Portland (“Property”)
met the definition of “owner-occupied” under Section 6-150.1 of Article VI of the City of Portland Code of
Ordinances (the “City Code” herein).


 Historical Background

The PTU submitted a formal rent control complaint regarding 33 State St by email on May 8, 2025. The
complaint alleged that the owner of the Property, Atanas Dinkov (the “Owner” herein) falsely claimed an
owner-occupied exemption, illegally raised rents on all three units in the building, failed to provide 1
month’s rent as reimbursement for the termination of tenant leases between 60 and 90 days, and failed to
provide tenants with required documentation upon leasing the premises. City staff commenced an
inspection.


City staff reviewed rental data, lease documentation, and deed information from the Cumberland County
Registry of Deeds, among other documents. An on-site inspection was conducted on June 11, 2025. On June
24, 2025, a Notice of Violation was issued to the Owner citing violation of City Code sections 6-155(d), 6-
234(c), 6-236, 6-244(b), and 6-234(f). The Owner was given 30 days to resolve or appeal the violations.


The Owner contested the City’s Notice of Violation, asserting that they had occupied the basement space at
the Property during the time period in question. The Owner asserted they were occupying the basement
unit as their primary residence while also renovating the space.


The basement unit was viewed during the on-site inspection conducted on June 11, 2025. The unit was
observed to have its own entrance, completely separate from the main entrance to the other three units in
the building. The unit was also observed to be free of water and relatively damp-proof, and to have a full set
of windows in the front of the building. The space was partitioned into two separate spaces, each consisting
of roughly 50% of the footprint of the building. One space was used primarily as a laundry facility. The
other space was separated by a wall with a door and contained a bathroom. At the time of the June 2025
inspection, the toilet was still functional, and the rough plumbing for a sink and a possible shower were
visible.


City staff conducted open-source searches that did not reveal a secondary address for the Owner. In fact, 33
State Street was the only resulting address when “Atanas Dinkov Maine” was searched. A search of the

389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov


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City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


Owner’s name in the Cumberland County Registry of Deeds did not yield any results that would indicate the
owner owned any other property in the county.


The Owner submitted documentation showing 33 State Street as their address on their Maine Driver’s
License and on their US Individual Income Tax Return (Form 1040) for 2024. These documents sufficiently
show that the Owner used 33 State Street as their address for “tax and government purposes”.


City staff reviewed Chapter 6 (Building and Building Regulations) and Chapter 14 (Land Use Code) of the
City Code. Neither chapter prohibits a property owner from occupying a property while under renovation,
nor does it prohibit occupying unfinished spaces within the property.


On July 17, 2025, an Amendment of Notice of Violation and Order to Correct was issued. The Amended
Notice of Violation included the supplementary documents the City received and relied upon when it
revised its findings, as well as details regarding which violations were satisfied. A secondary Notice of
Violation was issued on July 17, 2025, and cited violations of City Code sections 6-151, 6-155(d), and 6-
224(b). All fines and penalties have been paid, and violations have been satisfied as of the drafting of this
memorandum.


 Current Appeal

Interpretation of “Owner-Occupied”


The PTU disputes that the Owner “occupied” the basement unit of the property as their primary residence.


Section 6-231(d) of the City Code exempts “Rental Units within a building containing two (2), three (3) or
four (4) dwelling units, one of which the property owner currently occupies as his or her principal
residence1”. The property located at 33 State St is listed by the City Assessor as a “Three Family” building
with a “Full” basement. Historical records dating back as far as 1983 show that the basement of the building
was once a dwelling unit. Part of the basement space was converted to a laundry room facility at some
point prior to the Owner purchasing the property.


The basement unit would fit the definition of a “rooming unit”2 under Sec 6-106 of the City Code. Per Sec 6-
150.1 of the Code, a “rooming unit” is a rental unit.3


The City’s position that a rooming unit is a rental unit was affirmed in the District Court case of City of
Portland v. William Schoen4. Schoen goes further to state that only rental units as defined under Sec 6-232

1 “Principal residence” is an undefined term under the City Code. For this exercise, City staff used the definition of Primary Residence
under 6-150.1
2 Sec 6-106 Rooming unit shall mean one (1) or more rooms forming a single unit used, or intended to be used, for living and sleeping
purposes, but not designed for food preparation, by two (2) or more persons living in common or by a person living alone.
3 Sec 6-150.1 Rental unit is a portion of any residential structure that is rented or available for rent to any individual or individuals for
any length of time. Any portion of a Single-Family Home, Condominium, or Apartment that is rented or available to be rented to an
individual or individuals who are not the owner or owners shall be considered a rental unit. Dwelling units and rooming units as
defined in §6-106 are, without limitation, rental units. [emphasis added]
4 City of Portland v. Schoen “this court finds that the two bedrooms in question are not ‘Covered Units’ under the Rent Control
Ordinance but do remain ‘Rental Units’ under 6-151”

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City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


are considered to be a “covered unit”5. A “Covered Unit” under section 6-232 is a non-exempt “rental unit”6.
“Rental unit” under section 6-232 is limited to “dwelling units” as defined7.


“Rooming units” and “dwelling units” are distinct and separate under the City Code. Under case law, a
“rooming unit” is a “rental unit” but not a “dwelling unit” and, therefore, not a “covered unit” under the City
Code.


Section 6-150.1 defines Owner-Occupied as “a rental unit owned and occupied by the registrant as their
primary residence”. Primary residence is defined as an owner’s “legal residence for more than one-half of a
year and registers as his or her address for tax and government identification purposes”.


“Occupied” is not a defined term in the City Code. The Maine Supreme Court decision of Freeport v.
Brickyard Cove Associates8 states that in the event a term is undefined in the ordinance, the term will be
given its “common, everyday meaning”. “Occupied” is defined as “being used by someone” in the Oxford
Language Dictionary. “Occupied” is defined as “being used by someone; with someone in it” by the
Cambridge Dictionary.


 Conclusions

The PTU is not challenging the City’s finding that Mr. Dinkov owned the Property. The PTU is also not
disputing that the Owner used 33 State as their address for “tax and government purposes”. The crux of the
PTU’s argument is that the Owner did not sleep at the property for more than half of the year. That
argument is not supported by the plain language of the ordinance or the “common, everyday meaning” of
“occupied.”


Under the definitions of “occupied” cited above, the Owner, without question, “used” the space. No other
person has contended that they “occupied” the basement unit. Whether a person slept at the property for a
certain number of days is not determinative when testing for owner occupancy as defined under the City
Code.


If the Board were to adopt PTU’s interpretation, it would eliminate a significant portion of the population
from being able to maintain a “primary residence”. For instance, active military members, long-haul
truckers, airline flight crews, traveling salespeople, and traveling nurses (to name a few examples) would
likely not be found to have a primary residence as defined in the City Code if this interpretation were
applied. The Rent Board recently took up a case in the past where the owner of the property was a
merchant marine attending the meeting via Zoom from a ship at sea whose deployment was for weeks, if



5 City of Portland v. Schoen “The court determines that the rooms Mr. Schoen provides for rental do not meet the definition of
‘Dwelling Unit’ in the Rent Control Ordinance, and thus not ‘covered units’ and not ‘rental units’ subject to the Rent Control Ordinance.
6 Sec 6-232 Covered unit means a Rental Unit within the City of Portland that does not fall within a category exempted from this
Article by Section 6-231.
7 Sec 6-232 Rental unit means any dwelling unit that is rented or otherwise made available for rent for residential use or occupancy,
together with all additional rights, privileges, or services connected with use or occupancy of such a unit, including but not limited to
vehicle parking spaces, storage, and commons areas and/or recreational facilities held out for use by the Tenant. [emphasis added]
8 Freeport v. Brickyard Cove Assocs. “The absence of a definition of a term in an ordinance does not compel a finding of invalidity; it

means only that the term will be given its common, everyday meaning unless the context dictates otherwise.”

389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov


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City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


not months, at a time. Under the PTU’s interpretation, this property owner would not have a primary
residence.


Per the City’s analysis, the record shows that the Owner used the rooming unit located in the basement of
33 State Street for more than one-half of the year and registered the property as his primary residence for
tax and government purposes. This qualifies the property as “owner-occupied” under Section 6-150.1 of the
City of Portland Code of Ordinances. As such, the property is exempt from the Rent Stabilization Ordinance.
9




Thank you,



Adam O’Connor
Rental Registration Inspector




9 6-232 Rent stabilization ordinance means Chapter 6, Articles XII and XIII of the Code of Ordinances, City of Portland, Maine, as
amended.

389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov


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City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


06/24/2025
License #:
Code Case #: RCD2500009
ATANAS DIMITROV /
PO BOX 1453
WELLS, ME 04090

 NOTICE OF VIOLATION AND ORDER TO CORRECT
To Whom It May Concern,

The City of Portland Permitting and Inspections Department inspected the rental data for 33
STATE ST PORTLAND, ME 04101 on 06/04/2025 and found violations of the City of Portland
Code of Ordinances, which are listed on the attached page(s). You are hereby ordered to
correct these violations by 07/24/2025. Please be advised that penalties will be applied if the
violations are not corrected by that date.

If you do not correct the attached violations by the date given, then this matter will be referred to
the City of Portland Corporation Counsel for legal action, and you will be charged $150 for re-
inspection per the City’s fee schedule. In the event of court action, the City may be entitled to
an order to correct the violations, civil penalties in the minimum of $100 per violation per day,
costs and fees, and other relief under §1-15 of the City Code and 30-A M.R.S. §4452.

Please respond in writing via email to rentcontrol@portlandmaine.gov or send response by
USPS to 389 Congress St, Portland, Maine 04101.

You have a right to appeal this decision to Superior Court within 30 days of the date of this
notice pursuant to Rule 80B of the Maine Rules of Civil Procedure.

I appreciate your anticipated cooperation, and please contact our office by calling 207-874-
8900 if you have any questions.


Thank you,




Adam O’Connor
Rental Registration Inspector




ATANAS DIMITROV /
PO BOX 1453
WELLS, ME 04090


 389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov
 Page 126
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


 Total Violations: 5
 NON‑COMPLIANCE VIOLATION LIST

  APPLICABLE CODE
 City Code 6-155(d)
 SECTION(S)
 Any person, business entity, or other organization providing false
 CODE DESCRIPTION information with respect to registration. Notwithstanding the provisions of
 § 6-1, the penalty for such violation shall be $1,000.00
 The owner’s license, provided during short-term rental registration, stated
 the owner resided in Unit 1 of 33 State Street. The owner also registered 33
 State Street as a long-term rental, registering Unit 1 as a tenant-occupied
 unit. A long-term lease was provided by the owner, which stated a tenant
 COMMENTS was occupying Unit 1.

 The city finds this as two violations of providing false information; one
 violation for short-term rental information and one violation for long-term
 rental information. These violations total a penalty of $2,000.00.
 DEADLINE 07/24/2025


  APPLICABLE CODE
 City Code 6-234(c)
 SECTION(S)
 At no time may a Landlord raise the rent of a Covered Unit by more than
 CODE DESCRIPTION ten (10) percent. Any rent increases available to a Landlord in excess of ten
 (10) percent must be banked for later use.
 At the time the owner obtained 33 State Street, January 2024, the property
 did not qualify for the owner-occupied exemption. This means all rental
 units for 33 State Street were covered units required to follow allowable
 rental increases and limitations explained in the Rent Control Ordinance.
 Unit 1: Rent increased from $1,225 to $1,950, resulting in a 59.1% increase.
 COMMENTS Unit 2: Rent increased from $1,175 to $1,900, resulting in a 61.7% increase.
 Unit 3: Rent increased from $1,125 to $2,100, resulting in an 86.7%
 increase.

 The city finds that the owner must refund the tenants who occupied this
 property from January 2024 to April 2025.
 DEADLINE 07/24/2025




ATANAS DIMITROV /
PO BOX 1453
WELLS, ME 04090


 389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov
 Page 127
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


  APPLICABLE CODE
 City Code 6-236
 SECTION(S)
 Termination of Tenancy
 (a) In order to be terminated by a Landlord, all tenancies must be
 terminated by providing a minimum of 90 days' written notice to Tenant
 except as provided below:

 3. Where a Landlord provides the amount of one month's rent as
 reimbursement to Tenant for the inconvenience of termination, tenancies
 CODE DESCRIPTION
 may be terminated by notice to the Tenant of sixty (60) to eighty-nine (89)
 days;

 4. Where a Landlord provides the amount of two months' rent as
 reimbursement to Tenant for the inconvenience of termination, tenancies
 may be terminated by notice to the Tenant of thirty (30) to fifty-nine (59)
 days.
 The owner provided Unit 1 a notice of lease non-renewal on January 29,
 2025, requiring the tenant to leave by April 15, 2025. This notice provided
 76-day notice of termination. The city finds that the owner must provide
 the tenant of Unit 1 one month’s rent, $1,950, as reimbursement to the
 Tenant as it is less than the 90-day requirement.
 COMMENTS
 The owner provided Unit 2 a notice of lease non-renewal on February 17,
 2025, requiring the tenant to leave by April 18, 2025. This notice provided
 57-day notice of termination. The city finds that the owner must provide
 the tenant of Unit 2 with two months’ rent, $3,800, as reimbursement to the
 Tenant, as it is less than the 90-day requirement.
 DEADLINE 07/24/2025


  APPLICABLE CODE
 City Code Sec 6-224(b)
 SECTION(S)
 The Rental Housing Rights document shall be provided by Landlords to all
 CODE DESCRIPTION Tenants in the City of Portland at the commencement of the rental of a
 housing unit.
 The owner did not provide proof of a signed copy of the Rental Housing
 Rights document per tenant and does not have a copy of the Rental
 COMMENTS
 Housing Rights document hanging in a common space.




ATANAS DIMITROV /
PO BOX 1453
WELLS, ME 04090


 389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov
 Page 128
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


 The city requires the owner provide proof of the Rental Housing Rights
 document being displayed in a common area and a signed copy of the
 Rental Housing Rights document per tenant.
 DEADLINE 07/24/2025


  APPLICABLE CODE
 Remedy - City Code Sec 6-234(f)
 SECTION(S)
 A landlord who is not in substantial compliance with any provision of this
 chapter, including but not limited to the Rent Stabilization Ordinance, may
 CODE DESCRIPTION
 not demand, accept or retain any rent increase otherwise permitted by this
 section or any other provision of this Code or Maine statute.
 The owner is ordered to reduce the rent to the last code-compliant amount
 of and reimburse the tenant(s) any overcharge.

 Unit 1 last code complaint rent: $1,125
 Unit 2 last code complaint rent: $1,175
 COMMENTS Unit 3 last code complaint rent: $1,125

 Proof of reimbursement and resolution must be sent in writing to our office
 by the deadline listed below. Resolution documents can be mailed to 389
 Congress St, Portland, ME, 04101 or sent electronically to
 rentcontrol@portlandmaine.gov.
 DEADLINE 07/24/2025




ATANAS DIMITROV /
PO BOX 1453
WELLS, ME 04090


 389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov
 Page 129
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


07/14/2025
License #: LTR-006077-2024
Code Case #: RCD2500009

Atanas Dinkov
33 State St
Portland, ME 04101

 AMENDMENT OF NOTICE OF VIOLATION AND ORDER TO CORRECT

A Notice of Violation and Order to Correct (NOV) was issued on 06/24/2025 and required the violations
related to property at 33 State Street (“Property”) to be corrected by 07/24/2025. The NOV alleged
violations of Section 6-155 (d) (providing false information) and of Section 6-234(c) (improper rent
increases) based, in part, on the finding that the Property was not owner-occupied prior to the Owner,
Atanas Dinkov (“Owner”), moving into Unit 1 on or about April 15, 2025.


At the time of an on-site inspection on June 11, 2025, the Owner was residing in Unit 1. Unit 2 was being
renovated, and Unit 3 was tenant occupied. The basement was also being renovated and was torn down to
the studs. Given the condition of the basement, it was determined that the Owner could not have lived in
the basement prior to moving into Unit 1. As a result, the City issued the NOV based on the premise that the
Property was not owner-occupied when the Owner increased the rent in January 2024.


Following the issuance of the NOV, the Owner provided additional information which, after careful review
and consideration, the City finds sufficiently demonstrates that the Owner resided at the Property from
January 2024 to present and, therefore, the Property was exempt from Article XII of Chapter 6 of the City
Code.


In reaching this conclusion, the City considered the following information from the Owner:
The Owner indicated that he resided at the Property from January 2024 to present. The Owner explained
that a personal family situation required him to travel to and from his home country of Bulgaria. The Owner
initially resided in Unit 1, then relocated to the basement of the Property, and moved back into Unit 1 after
the unit was vacated on or about April 15, 2025.


The Owner also provided the following exculpatory information to support his contention that he resided at
the Property at all times relevant to the NOV:
 • A Home Inspection report dated 11/15/2023 from Square One Inspections, Matthew Tycz
 (inspector). The inspection report refers to the basement as “Finished”. The report goes further to
 say, “Most of the basement ceilings, walls, and floors have been covered with interior finishing”.
 The report contains photos of the basement in a finished state.
 • An Appraisal of Real Property report dated 11/17/2023. The report contains photos of the
 basement in a finished state.




389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov


 Page 130
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager



 • An Appraisal of Real Property report dated 10/18/2024 from Class Valuation, Christina Strong
 (appraiser). The report refers to the basement as “finished”. The report contains photos of the
 basement in a finished state.
 • A text message from a tenant to the Owner dated 11/2/2024 informing the Owner that the noise
 from the basement was disturbing them. The text states, “the sound of voices when someone
 speaks from below is loud enough that they seem to be almost in the same room with us.” The
 message also states, “This morning you woke us up at 7:30 am.”
 • A Google Maps Street View photo dated December 2024 that shows the Owner’s car in front of the
 building.
 • Three parking tickets with photos that show the Owner’s car in front of the building. The tickets
 are dated 2/6/2024, 5/20/2024, and 8/22/2024.
 • A copy of the Owner’s vehicle registration showing the vehicle cited in the parking tickets is their
 registered vehicle.
 • A signed letter dated 7/1/2025 from Dimitry Shevorski, resident of 31 State St, Apt 3, the letter
 states that in August 2024, the Owner told Mr. Shervorski he “will no longer be able to use the
 washer/dryer that was located in the basement unit of his building because he was going to live
 there. Moving forward, I frequently saw him going in and out of that unit, lights being on there, and
 his car being parked by the building.”
 • A signed letter dated 7/3/2025 from UPS driver Joe Dubber that states, “Based on how often I see
 him making deliveries on 33 State Street Portland ME and nearby I believe Atanas resides at 33
 State Street Portland ME.”
 • A signed letter dated 7/12/2025 from Donna Lewis of 62 Cherry Lane, Ogunquit, ME 03907. The
 letter states that “Atanas Dinkov rents a room in our house in Ogunquit, ME which he uses as a
 workspace from time to time. He pays us $500 per month for the room and a parking space; plus
 $70 per month for his Verizon phone line.” The Owner reports that he uses that space as his office
 to conduct his professional accounting work and does not live there.
 • The Owner presented bank records showing a payment of $570 from his Venmo account.
 • The Owner had their own mailbox at the Property to receive correspondence.


Copies of the aforementioned documents are attached for reference. Given the documents and information
provided by the Owner it can reasonably be assumed that the Property was owner-occupied as defined
under Sec 6-150.1 of the City Code from January 2024 to present, exempting the property from Article XII.


The following violation(s) have been resolved as a result of the additional information received:
 • Sec 6-155(d) – Providing False Information
 • At the time of the Short-Term Rental Registration, the information provided by the Owner was
 accurate. Article VI of the City code requires registration for new owners within 30 days of
 purchase, but does not require the City to be notified if an owner vacates the occupied unit. There
 is no evidence that the Owner rented Unit 1 as a Short-Term Rental while it was occupied by the
 long-term tenant.
 • One count of providing false information will remain for Long-Term Registration. The penalty for
 which is $1,000.
 • Unit 1 was not properly registered as a Long-Term Rental in 2024 or 2025. The Owner will be
 required to register the unit for those years and pay all applicable fees and penalties.



389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov


 Page 131
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


 • Sec 6-234(c) – Increase in Rent of over 10%
 • The property is Owner-occupied as defined by Sec 6-150.1 and exempt from this requirement.

 • Sec 6-236 – Termination of Tenancy
 • The property is Owner-occupied as defined by Sec 6-150.1 and exempt from this requirement.
 • The Owner provided the 30-day minimum notice as required by the State of Maine.

 • Sec 6-234(f) – Remedy
 • The property is Owner-occupied as defined by Sec 6-150.1 and exempt from this requirement.
 • As an exempt property, no rent overcharges remain.



In conclusion, the Owner has demonstrated through contemporaneous documentation and signed letters
that the property was owner-occupied at all times relevant to the NOV. A new Notice of Violation has been
issued with the current violations and sent to the Owner.


Thank you,



Adam O’Connor
Rental Registration Inspector




389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov


 Page 132
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Page 149
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


07/17/2025
License #: LTR-006077-2024
Code Case #: RCD2500009
ATANAS DINKOV
PO BOX 1453
WELLS, ME 04090

 NOTICE OF VIOLATION AND ORDER TO CORRECT
To Whom It May Concern,

The City of Portland Permitting and Inspections Department inspected the rental data for 33
STATE ST PORTLAND, ME 04101 on 06/24/2025 and found violations of the City of Portland
Code of Ordinances, which are listed on the attached page(s). You are hereby ordered to
correct these violations by 08/16/2025. Please be advised that penalties will be applied if the
violations are not corrected by that date.

If you do not correct the attached violations by the date given, then this matter will be referred to
the City of Portland Corporation Counsel for legal action, and you will be charged $150 for re-
inspection per the City’s fee schedule. In the event of court action, the City may be entitled to
an order to correct the violations, civil penalties in the minimum of $100 per violation per day,
costs and fees, and other relief under §1-15 of the City Code and 30-A M.R.S. §4452.

Please respond in writing via email to rentcontrol@portlandmaine.gov or send response by
USPS to 389 Congress St, Portland, Maine 04101.

You have a right to appeal this decision to Superior Court within 30 days of the date of this
notice pursuant to Rule 80B of the Maine Rules of Civil Procedure.

I appreciate your anticipated cooperation, and please contact our office by calling 207-874-
8900 if you have any questions.


Thank you,




Adam O’Connor
Rental Registration Inspector




ATANAS DINKOV
PO BOX 1453
WELLS, ME 04090


 389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov
 Page 150
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager


 Total Violations: 3
 NON‑COMPLIANCE VIOLATION LIST

  APPLICABLE CODE
 City Code 6-151
 SECTION(S)
 Rental units must be registered in accordance with this article by January
 1st of each year; Rental units entering the rental housing market must be
 CODE DESCRIPTION registered within fourteen days. Registration must be renewed annually, on
 or before January 1st, including updating all changes in previously
 submitted registration information.
 The Owner did not properly register Unit 1 in 2024 or 2025. The Owner is
 COMMENTS required to provide registration documents for both years and pay all
 applicable fees and penalties.
 DEADLINE 08/16/2025


  APPLICABLE CODE
 City Code 6-155(d)
 SECTION(S)
 Any person, business entity, or other organization providing false
 CODE DESCRIPTION information with respect to registration. Notwithstanding the provisions of
 § 6-1, the penalty for such violation shall be $1,000.00
 The Owner provided Long-Term Rental Registration documents that
 COMMENTS claimed they resided in Unit 1 of the Property. This information proved to
 be false at the time of filing. The penalty for such a violation is $1,000.
 DEADLINE 08/16/2025


  APPLICABLE CODE
 City Code Sec 6-224(b)
 SECTION(S)
 The Rental Housing Rights document shall be provided by Landlords to all
 CODE DESCRIPTION Tenants in the City of Portland at the commencement of the rental of a
 housing unit.
 The Owner must provide the Rental Housing Rights document to all long-
 COMMENTS
 term tenants of the Property
 DEADLINE 08/16/2025




ATANAS DINKOV
PO BOX 1453
WELLS, ME 04090


 389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov
 Page 151
Page 152
Page 153
Page 154
Page 155
Page 156
RENT BOARD HEARING
 Tuesday, December 2, 2025



 Page 157
 WHO WE ARE
 Portland Tenants Union was founded by tenants
across the city who came together to defend their
rights. We aim to educate tenants, support them in
addressing violations with their landlord, and help
 submit complaints with the City of Portland.


 Page 158
 We are here today asserting the rights of the
 former tenants of 33 State Street


“Any Tenants Union shall have standing as a party to assert the
 rights or interests of ANY Tenants,individually or
 collectively, under this Chapter in any complaint, appeal, or
 other proceeding …” Sec. 6-234(a) (emphasis added)




 Page 159
Mr. Atanas Dinkov falsely registered 33 State Street as Owner-
 Occupied in order to raise rents well above the allowable
 limits and avoid 90-day notice requirements

 Unit 1: 59.1% - From $1,225 to $1,950
 Unit 2: 61.7% - From $1,175 to $1,900
 Unit 3: 86.7% - From $1,125 to $2,100

 Mr. Dinkov failed to compensate tenants for lease
 termination notice of less than 90 days

“(d) Rental Units within a building containing only two (2), three (3) or four (4) dwelling
units, one of which the property owner currently occupies as his or her principal residence”


 Page 160
 Timeline to Deception
 Jan. 5, 2024
Mr. Dinkov purchased
 33 State Street




 Page 161
 Timeline to Deception
 Jan. 5, 2024
Mr. Dinkov purchased
 33 State Street
 Jan. 10, 2024
 Only units 2 & 3 are
  applied for LTRs




 Page 162
 Timeline to Deception
 Jan. 5, 2024
Mr. Dinkov purchased
 33 State Street
 Jan. 10, 2024
 Only units 2 & 3 are
  applied for LTRs
 Apr. 1, 2024
 All 3 units were
 rented out




 Page 163
 Timeline to Deception
 Jan. 5, 2024
Mr. Dinkov purchased
 33 State Street
 Jan. 10, 2024
 Only units 2 & 3 are
  applied for LTRs
 Apr. 1, 2024
 All 3 units were
 rented out




 Page 164
 Timeline to Deception
 Jan. 5, 2024
Mr. Dinkov purchased
 33 State Street
 Jan. 10, 2024
 Only units 2 & 3 are
  applied for LTRs
 Apr. 1, 2024
 All 3 units were
 rented out




 Page 165
 Timeline to Deception
 Jan. 5, 2024
Mr. Dinkov purchased
 33 State Street
 Jan. 10, 2024
 Only units 2 & 3 are
  applied for LTRs
 Apr. 1, 2024
 All 3 units were
 rented out
 Apr. 17, 2024
 Only units 2 & 3 are
 registered


 Page 166
 False Claim of Owner Occupancy
Mr. Dinkov repeatedly claimed Apt #1 as his residence, a unit that was occupied by tenants.

 Apr 1, 2024 Apt 1 rented out




 Page 167
 False Claim of Owner Occupancy
Mr. Dinkov repeatedly claimed Apt #1 as his residence, a unit that was occupied by tenants.

 Apr 1, 2024 Apt 1 rented out

 Claimed Apt 1 as
 Apr. 22, 2024
 residence on license




 Page 168
 False Claim of Owner Occupancy
Mr. Dinkov repeatedly claimed Apt #1 as his residence, a unit that was occupied by tenants.

 Apr 1, 2024 Apt 1 rented out

 Claimed Apt 1 as
 Apr. 22, 2024
 residence on license

 Claimed Apt 1 as
 Apr. 23, 2024 voting address




 Page 169
 False Claim of Owner Occupancy
Mr. Dinkov repeatedly claimed Apt #1 as his residence, a unit that was occupied by tenants.

 Apr 1, 2024 Apt 1 rented out

 Claimed Apt 1 as
 Apr. 22, 2024
 residence on license

 Claimed Apt 1 as
 Apr. 23, 2024 voting address


 July 1, 2024 Claimed Apt 1 on his
 car registration




 Page 170
 False Claim of Owner Occupancy
Mr. Dinkov repeatedly claimed Apt #1 as his residence, a unit that was occupied by tenants.

 Apr 1, 2024 Apt 1 rented out

 Claimed Apt 1 as
 Apr. 22, 2024
 residence on license

 Claimed Apt 1 as
 Apr. 23, 2024 voting address


 July 1, 2024 Claimed Apt 1 on his
 car registration
 Claimed Apt 1 as his
 residence on notarized
 Nov. 7, 2024 STR affidavit
 Only submits 2025 LTRs
 for Units 2 & 3 again
 Page 171
Exposed. Fined.




 Page 172
 And Then The Story Changes
After this, Mr. Dinkov submited claims that he lived in the basement/laundry room rather than unit
 1, contradicting every legal document he submitted during the tenancies in question.




 Page 173
 And Then The Story Changes
After this, Mr. Dinkov submited claims that he lived in the basement/laundry room rather than unit
 1, contradicting every legal document he submitted during the tenancies in question.


 “And in the beginning of August 2024, he told me that I wil no longer be
able to use the washer/dryer that was located in the basement unit of his
 building because he was going to live there.” Neighbor.




 Page 174
 And Then The Story Changes
After this, Mr. Dinkov submited claims that he lived in the basement/laundry room rather than unit
 1, contradicting every legal document he submitted during the tenancies in question.


 “And in the beginning of August 2024, he told me that I wil no longer be
able to use the washer/dryer that was located in the basement unit of his
 building because he was going to live there.” Neighbor.

 “I believe he was residing in his basement unit for a certain time.”
 Neighbor.




 Page 175
 And Then The Story Changes
After this, Mr. Dinkov submited claims that he lived in the basement/laundry room rather than unit
 1, contradicting every legal document he submitted during the tenancies in question.


 “And in the beginning of August 2024, he told me that I wil no longer be
able to use the washer/dryer that was located in the basement unit of his
 building because he was going to live there.” Neighbor.

 “I believe he was residing in his basement unit for a certain time.”
 Neighbor.


“The Owner [told us that he] initially resided in Unit 1, then relocated to the
 basement of the Property...” City of Portland
 Page 176
Now Mr. Dinkov claims to have lived in the basement rather than unit 1.
 However, there was no 4th dwelling unit in the basement.




 Page 177
Now Mr. Dinkov claims to have lived in the basement rather than unit 1.
 However, there was no 4th dwelling unit in the basement.




 Page 178
Now Mr. Dinkov claims to have lived in the basement rather than unit 1.
 However, there was no 4th dwelling unit in the basement.




 Page 179
Now Mr. Dinkov claims to have lived in the basement rather than unit 1.
 However, there was no 4th dwelling unit in the basement.




 Page 180
Now Mr. Dinkov claims to have lived in the basement rather than unit 1.
 However, there was no 4th dwelling unit in the basement.




 Page 181
 Rooming Unit vs Dwelling Unit




 -Mr. Dinkov’s testimony




 -City memo



All parties concede that the basement of 33 State Street is not a dwelling unit.



 Page 182
 Decision Avenue #1:
 Mr. Dinkov needs to have lived in a
dwelling unit to be exempt from rent control




 -33 State Street LTR Registration

 Page 183
 Decision Avenue #2:
Mr. Dinkov provided no evidence that the basement
 unit was his principal residence under the law




 -City memo


The “rental unit” currently under question for owner occupancy is the
 supposed “basement unit”. All of Mr. Dinkov’s tax and government
identifications list Unit 1 as his address, which is a rental unit that was
 occupied by tenants the entire year.


 Page 184
 Decision Avenue #2:
Mr. Dinkov provided no evidence that the basement
  unit was his principal residence under the law




 -City memo




 Page 185
 Decision Avenue #3:
The basement did not, and still does not, meet the
 standards of habitability for a rooming unit




 -Sec. 6-111. Minimum plumbing standards.




 Page 186
 Decision Avenue #3:
The basement did not, and still does not, meet the
 standards of habitability for a rooming unit




 -Sec. 6-111. Minimum plumbing standards.




 Page 187
 Decision Avenue #3:
The basement did not, and still does not, meet the
 standards of habitability for a rooming unit




 -Sec. 6-111. Minimum plumbing standards.




 Page 188
 Decision Avenue #3:
The basement did not, and still does not, meet the
 standards of habitability for a rooming unit




 -Sec. 6-111. Minimum plumbing standards.




 -City memo
 Page 189
 Boarded up windows to 33 State Street
 Basesment. 1/20/2025



Page 190
  Adding to the evidence that the
  basement did not meet the living
  standards of a rooming unit, Mr.
 Dinkov texted his tenants on
 November 11, 2024,
“Based on some safety issues
concern and conversation with
certified plumber the laundry
 room will not be available till
 the end of the year”
 Page 191
 Decision Avenue #4:
Mr. Dinkov did not live anywhere in 33 State St.


All five tenants, occupying all
 three units, confirm, under
oath, that the landlord never
 lived at the property


 Page 192
Mr. Dinkov did not live anywhere in 33 State St.
 Tenants confirm, under oath, that landlord never lived at the property




 Page 193
Mr. Dinkov did not live anywhere in 33 State St.
 Tenants confirm, under oath, that landlord never lived at the property




 Page 194
Mr. Dinkov did not live anywhere in 33 State St.
 Tenants confirm, under oath, that landlord never lived at the property




 Page 195
Mr. Dinkov did not live anywhere in 33 State St.
 Tenants confirm, under oath, that landlord never lived at the property




 Page 196
Mr. Dinkov did not live anywhere in 33 State St.
 Tenants confirm, under oath, that landlord never lived at the property




 Page 197
  Mr. Dinkov’s “Evidence” Doesn’t Add Up


 Mr. Dinkov has failed to provide
  meaningful evidence that he lived
anywhere at 33 State Street during the
 time period in question.


 Page 198
 Mr. Dinkov’s “Evidence” Doesn’t Add Up

 The UPS Driver’s note

The letter provided by a UPS driver was signed 3 months
after the tenants had moved out, and does not contradict
 the evidence provided.




 Page 199
 Mr. Dinkov’s “Evidence” Doesn’t Add Up

 The Neighboring Landlord’s note

The neighboring landlord claims he could no longer use the
laundry room, as Mr. Dinkov was moving into the basement
 in Aug., 2024. However, the laundry room remained in use
until Nov. 11, 2024, when Mr. Dinkov informed his tenants that
 it would no longer be safe, reducing their rent by $15.
 (As a side note, if what the note said were true, it, again, contradicts his having
 registered 33 State as owner-occupied in April, 2024.)
 Page 200
 Mr. Dinkov’s “Evidence” Doesn’t Add Up

 The Parking Tickets

 Mr. Dinkov provided 3 parking tickets from in front of his
 building. Two were imposed outside the time period in
question. Only one covers the time period and it is during
the afternoon – a time when even the tenants testified he
  was sometimes present demolishing the basement.


 Page 201
 Mr. Dinkov’s “Evidence” Doesn’t Add Up

 Text From Apt #1

  Mr. Dinkov uses a text from the first floor tenants about
  noise at 7:30am on Nov. 2, 2024 to suggest that he was
there overnight. In truth, the full text references demolition
noise from the basement. The tenants confirm this fact in
 their affidavit.


 Page 202
 Mr. Dinkov’s “Evidence” Doesn’t Add Up

 Appraisals

Mr. Dinkov provided two partial appraisals of the property,
 neither of which describe a room that fits the city’s
 habitability criteria for a dwelling unit. Indeed, the 2024
appraisal valued the basement at $12 per sf, vs $55 per sf
 for “Living Areas.”


 Page 203
 Mr. Dinkov’s “Evidence” Doesn’t Add Up

 1983 Inspection

 This inspection is 42 years old, and every official
document surrounding his purchase of the property, and
his ownership, shows there are only 3 dwelling units and
only 3 bathrooms in the building, as shown in slides 17-21.




 Page 204
 Mr. Dinkov’s “Evidence” Doesn’t Add Up

 Where did he live?

While we cannot prove where Mr. Dinkov lived from 4/1/2024 to
 3/31/2025, (because all his documents claim he lived in Unit 1,
when clearly he did not), nor is it necessary, we suspect he lived
 at 33 Cherry Lane in Ogunquit, as he issued monthly Venmo
payments to the owner of this property often using the “rent”
  emoji 🏠 , which corresponds with what he told his tenants.
 Page 205
 Mr. Dinkov’s “Evidence” Doesn’t Add Up

 Where did he live?

 Despite a note from his landlords claiming that he was merely
  renting office space, a note not given under oath, the same
landlords posted on Mr. Dinkov’s Facebook page over the years:


 “Nasco [his nickname] moved into our home in Ogunquit...”
 “Will clean the crackers off your bed!”
 “See you back at Cherry Lane soon.”
 Page 206
Where Did He Live?
  More than just a rented
 “work space”?




 Page 207
Summary Findings




 Page 208
 Summary Findings

There are only 3 dwelling units in the building.




 Page 209
 Summary Findings

There are only 3 dwelling units in the building.

All 3 dwelling units were occupied by tenants.




 Page 210
 Summary Findings

There are only 3 dwelling units in the building.

All 3 dwelling units were occupied by tenants.

Mr. Dinkov falsely claimed to live in Unit 1.




 Page 211
 Summary Findings

There are only 3 dwelling units in the building.

All 3 dwelling units were occupied by tenants.

Mr. Dinkov falsely claimed to live in Unit 1.

 After our complaint, Mr. Dinkov changed his story to claim he
lived in the unfinished basement.




 Page 212
 Summary Findings

There are only 3 dwelling units in the building.

All 3 dwelling units were occupied by tenants.

Mr. Dinkov falsely claimed to live in Unit 1.

 After our complaint, Mr. Dinkov changed his story to claim he
lived in the unfinished basement.

The basement is not a dwelling unit.




 Page 213
 Summary Findings

There are only 3 dwelling units in the building.

All 3 dwelling units were occupied by tenants.

Mr. Dinkov falsely claimed to live in Unit 1.

 After our complaint, Mr. Dinkov changed his story to claim he
lived in the unfinished basement.

The basement is not a dwelling unit. Nor is it a rooming unit.




 Page 214
 Summary Findings

There are only 3 dwelling units in the building.

All 3 dwelling units were occupied by tenants.

Mr. Dinkov falsely claimed to live in Unit 1.

 After our complaint, Mr. Dinkov changed his story to claim he
lived in the unfinished basement.

The basement is not a dwelling unit. Nor is it a rooming unit.

Regardless, all tenants testified he never lived at 33 State. Ever.

 Page 215
 Conclusion



Mr. Dinkov did not live at 33 State Street in
Unit 1 or the basement between April 1, 2024
 and April 1, 2025.




 Page 216
 Accountability
In light of these violations, and this brazen attempt to sidestep the law, gouge his
tenants, and make these three units unaffordable, we request that the Rent Board:




 Page 217
 Accountability
In light of these violations, and this brazen attempt to sidestep the law, gouge his
tenants, and make these three units unaffordable, we request that the Rent Board:

 1. Revoke Mr. Dinkov’s primary residence exemption.




 Page 218
 Accountability
In light of these violations, and this brazen attempt to sidestep the law, gouge his
tenants, and make these three units unaffordable, we request that the Rent Board:

 1. Revoke Mr. Dinkov’s primary residence exemption.

 2. Repeal all rent increases imposed by Mr. Dinkov in 2024 and require that
 tenants be fully refunded the amounts they were overcharged.




 Page 219
 Accountability
In light of these violations, and this brazen attempt to sidestep the law, gouge his
tenants, and make these three units unaffordable, we request that the Rent Board:

 1. Revoke Mr. Dinkov’s primary residence exemption.

 2. Repeal all rent increases imposed by Mr. Dinkov in 2024 and require that
 tenants be fully refunded the amounts they were overcharged.

  3. Ensure that the tenants of Unit 1 and 2 are each given one month’s rent as
 compensation for being given less than 90-days notice to vacate the unit.




 Page 220
 Accountability
In light of these violations, and this brazen attempt to sidestep the law, gouge his
tenants, and make these three units unaffordable, we request that the Rent Board:

 1. Revoke Mr. Dinkov’s primary residence exemption.

 2. Repeal all rent increases imposed by Mr. Dinkov in 2024 and require that
 tenants be fully refunded the amounts they were overcharged.

  3. Ensure that the tenants of Unit 1 and 2 are each given one month’s rent as
 compensation for being given less than 90-days notice to vacate the unit.

 4. Impose fines on Mr. Dinkov of at least $100 per month per unit for illegal
 rent increases collected; $100 per violation for inadequate notice
 compensation; $1,000 for filing false information in regard to owner-
 occupancy in his STR application; and $100 per instance for not posting the
 tenant rights document.
 Page 221
 City of Portland – Housing Safety Division
 TENANT RIGHTS COMPLAINT

Date of Hearing:
December 2, 2025


Appellant:
Shelley Swift


Owner Name and Address:
193 York Street LLC

PO BOX 361

Lynnfield, MA 01940


Property Address and Unit:


193 York St, Unit 2


CBL:

044-C-004-001




 Page 222
City of Portland Rent Board
Matthew Lax, Chair
Via email: rentcontrol@portlandmaine.gov, rentboard@portlandmaine.gov

Dear Chair Lax and members of the Rent Board,

Pursuant to the standing granted to tenant unions under section 6-243(a) of the city code, we
submit this appeal under 6-263(e) regarding a retaliatory tenancy termination 191-193 York
Street.

My evidence stands as follows:​
​
Within six months of the tenant sending a complaint to the landlord that they had not received
the appropriate forms required as part of satisfying a signature on the Rental Housing Rights
Document, the landlord sent notice to the tenant that they now must vacate in 30-days (see
exhibit A ) and included a check for two months rent.

I have been in this building for 11 years. I am up-to-date on all of my rent. Since this owner has
purchased this building, they have had many difficulties in their role as a property manager.
They had failed to register the units. They had failed to give proper notice when they increased
rents. They were found in violation and appealed and lost the appeal. They had to pay me back
for the overage that they had charged in April of this year.

 Matt Greico sent me three docusign documents 1 stated I received the money, 2 stated that I
had a 90 day notice for rent increase, and 3, the final document, that was the rental housing
rights document.
When I advise them that I could not sign the form until they gave me the appropriate
disclosures (because the document states that I have received them) I can’t sign it unless I’ve
actually received them. Louann Grieco was combative.
This is the transcript of our text:
Apr 29 2025

shelley swift :

I reached out to Matt several times about trying to address this, but he is unresponsive. Other
than to say that if the math was wrong, then I should just take it out of one of the rents .
One of the documents was asking me to confirm the amount for the reimbursement in the math
was not correct.

 One of the forms that I’m being requested to sign is a statement of acknowledgment of receipt
of disclosure forms that I have not received. Which include :
1 Landlords Disclosure To Tenants Of Radon Gas Hazards
In A Residential Rental Property
2 Energy efficiency disclosure form for a rental units in Maine




 Page 223
3 Lead paint disclosure form
Will you be sending those along?

And the third document regarding the rent increase I corrected the mistakes on that form and
signed it and asked him where to send it and he never responded. Do you want me to send a
photo of that to you?




https://content.civicplus.com/api/assets/a9616b64-2442-4645-b4e3-ffaf645b06ac
Here is the link to access these forms




 Page 224
Louann Grieco:

Shelley you received all those docs previously as a tenant there is no need to send again. You
just need to sign the rent increase and sign the confirmation that you got paid. They are in a
docusign so no need to meet or mail

Thursday May 1

Louann Grieco:
Shelley can you please send over the signed rent increase document today to
Kjmminc@gmail.com

And any other forms you signed



In conclusion
My landlords refused to follow through on their responsibilities as property owners and
landlords. They are very disgruntled that I have one my case against them for their Rent Control
violation. The tenant downstairs from me just moved out and filed their Rent Control violation
against them only days before they sent me this Tenancy termination, and I believe this is a
factor!
There is simply no financial reason for this landlord to terminate the my tenancy. By giving
30-days notice against the tenants’ wishes, the landlord forfeits the 5% bump he might
otherwise be allowed.

In light of this evidence, we ask that the rent board:

 1.​ Find that the landlord has retaliated against me for requesting the appropriate
 disclosure that they are required to supply.

 2.​ That the landlord forfeit all available banked rent at the unit, and all the others, as he
 was not in substantial compliance.

 3.​ That the landlord be fined $200 a day for the retaliatory act against the tenant in until
 the retaliation is withdrawn (the tenant is re-offered the unit for another year, the
 tenant vacates by mutual agreement, or the tenant is evicted by the legal statutory
 process).

Thank you for your immediate attention to this matter. I am happy to answer any questions
about this complaint and provide additional backup documentation, screenshots of text
messages, etc. regarding any and all the matters discussed in this letter.




 Page 225
11/7/2025

Matthew Grieco
Authorized Agent for 193 York Street LLC

Rent Board of Portland, ME
City of Portland
389 Congress St, Portland, ME

Dear Members of the Rent Board,

I am writing to respond to the complaint filed against my company 193 York Street LLC by Shelley Swift and to clarify
my position regarding Unit 2 at 193 York Street, which I purchased in 2020.

Why Shelley is being asked to leave
My plan at the time of purchasing this building was to move into Unit 2 as soon as I could, but, because of certain medical
issues, I have not been able to move in yet. Currently, I’m renting a room that I share with three roommates. I have always
wanted to move into the house I bought in Portland, but I’ve been living in a shared room for two years because of
specific medical issues I’ve faced. Although it would be invasive and embarrassing, I would potentially be willing to
share more information with the Rent Board about my medical history, but I am not willing to publicly broadcast my
private medical information to the world.

At this time, I’ve reached a point where I’m ready to leave my current housing situation and move into Unit 2. I need
additional space for work and personal use, and Unit 2 is the largest unit in the building. The other units are too small for
my needs or have tenants with leases living in them. Shelley does not have a lease and has been a tenant at will for over a
year now. My current living situation no longer meets my personal and professional needs. I need a dedicated work from
home area and I need storage space for work and personal use. Unit 2 is the ideal home for me. It offers the storage space,
off street parking, and location to satisfy all my professional and personal needs.

I want to live in my home, and that’s the only reason Shelley is being asked to leave.

Shelley’s Complaint
I am not aware of any complaints or cases brought by Shelley against me. In May of 2024, the City conducted an audit of
all of the units in 193 York Street and decided that I had made a mistake in how I handled a past rent increase in Unit 2.
To my knowledge, Shelley had nothing to do with the City notifying me of this violation. I was informed by the City that
it was a standard periodic audit being performed without a specific complaint having been made. I exercised my right to
appeal and complied with the City’s requirements in April 2025, over six months ago, when my appeal was denied.

As far as I know, none of that had anything to do with Shelley, and I am not aware of any ongoing complaints from her
relating to rent control or any other topic. In her complaint to this Board, Shelley refers to documents she is claiming I
failed to supply. Shelley lived in Unit 2 when I bought the building, so I have never been required to supply her with any
of the documents she is complaining about. Shelley had already received those documents from the former owner. Even
so, I sent her a complete packet to ensure that she had everything she needed. In her complaint, she provides a link to the
City’s website where the documents are available. Shelley has not only been given the documents by the prior owner and
by me, but she has easy access to download them for herself. Her complaint about not receiving documents seems like a
transparent attempt to manufacture a reason that she should be permitted to occupy my home without my consent.

There is no rent control issue that Shelley asserts she has filed a complaint or appeal about. Her only allegation is that she
refused to sign a form stating that she had received the informational documents that I would only be required to give her
at the commencement of her tenancy based on the City’s ordinances. Her tenancy commenced before I owned the
building. Not only have I provided those documents to Shelley before, the requirement to provide them is not part of the
Rent Stabilization Ordinance, and I don’t understand how her refusal to sign a paper saying she received them has been
brought before this Board. This is not a rent or rent control issue, and, because I don’t really need her to acknowledge
receipt of those documents, it isn’t an issue at all.




 Page 226
Shelley says that communications from my mother Louann Grieco were combative, but it is clear from the conversation
she quotes that they were not. My mother was patient and friendly and clarified that Shelley didn’t need to acknowledge
that she had received the rental documents, even though she had received them from me in the past. She requested that
Shelley acknowledge receipt of a check and a rent increase notice which Shelley is not appealing or complaining about
and which were not connected to her receipt of the tenancy commencement documents that I didn’t need to give her.

My intention to move into Unit 2 has always been consistent, it is important for me in order to move forward with my
plans and the next stage of my life, and I am now prepared to move into and live in my own home. Shelley’s allegations
don’t really make sense, and they have nothing to do with why I want to live in the unit she has been renting.

I appreciate your consideration of my statement and look forward to answering any questions you have at the upcoming
hearing on this complaint.

Thank You,

Matthew Grieco
Mgrieco07@gmail.com
803-221-2100




 Page 227
Gmail - Rent Control - 193 York Street - BLDG0107314 11/6/25, 6:01 PM




 Matthew Matthew <mgrieco07@gmail.com>



 Rent Control - 193 York Street - BLDG0107314
 1 message

 Rent Control- City of Portland <rentcontrol@portlandmaine.gov> Tue, May 28, 2024 at 9:33 AM
 To: MGRIECO07@gmail.com, KJMMINC@gmail.com

 The City of Portland conducts audits of submitted information for registered rental properties to ensure compliance
 with Residential Rental Unit Requirements and Rent Control and Tenant Protections.

 The property located at 193 York Street is due for a review. Please submit the documentation requested in the
 attached letter for staff review within two (2) weeks of the date of this email. Failure to provide the City with the
 requested documents will be considered a refusal to allow an inspection, which is a violation of the City of Portland
 Code of Ordinances, and is subject to civil penalties, potential legal action, and other remedies.

 Please reference case number BLDG2407314. I appreciate your anticipated cooperation, and please contact our
 office by calling 207-874-8900 if you have any questions.


 --
 Licensing and Registration
 389 Congress Street
 Portland, Maine 04101
 rentcontrol@portlandmaine.gov
 207-874-8900

 Notice: Under Maine law, documents - including e-mails - in the possession of public officials or city employees about
 government business may be classified as public records. There are very few exceptions. As a result, please be
 advised that what is written in an e-mail could be released to the public and/or the media if requested.

 193 York RFI.pdf
 269K




https://mail.google.com/mail/u/1/?ik=cc39329511&view=pt&search=…Cmsg-f:1800303537787977723&simpl=msg-f:1800303537787977723&mb=1 Page 1 of 1



 Page 228
City of Portland | Permitting and Inspections
Zachary Lenhert, Licensing and Housing Safety Manager

05/28/2024
Case Number: BLDG2407314
Business License: LTR-0050803-2023


193 York Street LLC
PO Box 361
Lynnfield, MA 01940


 REQUEST FOR INFORMATION
To Whom It May Concern,


The City of Portland conducts audits of submitted information for registered rental properties to
ensure compliance with Residential Rental Unit Requirements and Rent Control and Tenant
Protections. The property located at 193 York Street is due for a review. Please submit the
documentation requested below for staff review within two (2) weeks of the date of this
correspondence. Failure to provide the City with the requested documents will be considered a
refusal to allow an inspection, which is a violation of the City of Portland Code of Ordinances, and is
subject to civil penalties, potential legal action, and other remedies.

Please provide the following for each Covered unit:
 • A valid rental agreement, rent payment receipt, copy of cashed check, or bank statement
 that validates the rent charged for each unit for the period of June 2020 to Present.
 • Acknowledgement of receipt of the Rental Housing Rights document signed by the current
 tenants of each unit.
 • Copies of any Rent Increase Notices issued.

Additional follow-up documentation may be requested if further investigation is required.

Letters have also been sent to each unit requesting confirmation of registered rental amounts from
the tenants. Be advised, you may be required to reimburse your tenant if it is determined that the
rent being charged for a Covered Unit violates the Rent Control and Tenant Protections Ordinance.

Please respond the City of Portland within two (2) weeks regarding this matter. The requested
documents can be sent to rentcontrol@portlandmaine.gov, faxed to 207-874-8900, or sent via
USPS to 389 Congress St, Licensing and Housing Safety Division, Portland, Maine 04101. If no
response is received within two (2) weeks this matter may be referred to Corporation Counsel for
legal action. Please reference case number BLSG2407314. I appreciate your anticipated
cooperation, and please contact our office by calling 207-874-8900 if you have any questions.

Thank you,



Adam O’Connor
Rental Registration Inspector



 389 Congress Street, Portland, Maine 04101 | 207-874-8900 | rentcontrol@portlandmaine.gov

 Page 229

Remote Rent Board Meeting Minutes - Held Via Zoom

Tuesday, December 2, 2025​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​

II. Roll Call - 0:01:02

Matthew Lax, Tenant, District 1 - Chair
Vacant, District 2
Christopher “Buddy” Moore, Tenant, District 3
Rebecca Bolduc, Homeowner, District 4
Vacant, District 5
Anne-Laure Razat, Tenant, At-Large
Kristen Carreras, Landlord, At-Large - Absent

Staff present:
Dylan Orr, Rental Registration Coordinator
Adam O'Connor, Rental Registration Inspector
Benjamin Plante, Esq., Counsel for the Rent Board



III. Approval of Minutes - 0:01:48

 a.​ October 22, 2025 Minutes

 b.​ November 12, 2025 Minutes

0:02:07 - Anne-Laure Razat moves to approve the minutes for October 22nd and November
12th, 2025. Seconded by Christopher “Buddy” Moore. (4-0; Carreras absent) The motion passes.

IV. Communications - 0:02:34

 a.​ 33 State St Rent Increase Appeal Scheduling Request - 0:02:34

0:04:19 - The Board decides to hear items VI.a. and VI.b. ahead of Unfinished Business.

V. Unfinished Business - 4:02:33

 a.​ Rent Increase Application - See 4:02:33
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner’s Representative: Caleb Normandeau with Port Property
 Property Address: 72 Park Ave, Units 1-12
 CBL: 048-B-008-001
 Type of Increase: Increased Housing Service Costs
 b.​ Rent Increase Application - See 4:02:33
 Owner: SPAR Inc., 82 Hanover St, Portland, ME 04101
 Owner’s Representative: Caleb Normandeau with Port Property
 Property Address: 157 Grant ST, Units 1-26
 CBL: 053-B-024-001
 Type of Increase: Increased Housing Service Costs



VI. New Business - 0:04:58

 a.​ Rent Increase Appeal- Public Comment - 0:08:58
 Appellant: Portland Tenant’s Union
 Property Address: 33 State St, all units
 Property Owner: Atanas Dinkov
 CBL: 044-B-016-001

0:10:40 - Portland Tenant’s Union presents the appeal.

0:55:12 - The property owner, Atanas Dinkov, speaks as an Objector and presents his rebuttal.

1:55:12 - Public comment received.

3:03:35 - Anne-Laure Razat moves to close public hearing and public record. Seconded by
Matthew Lax. (4-0; Carreras absent) The motion passes.

3:06:04 through 3:14:24 - The Board takes a recess.

4:00:22 - Christopher “Buddy” Moore moves to table the deliberations of the 33 State St appeal
to the regularly scheduled December meeting. Seconded by Matthew Lax. (4-0; Carreras absent)
The motion passes.

 b.​ Tenant Rights Appeal - Public Comment - 3:14:46
 Appellant: Shelley Swift
 Property Address: 193 York St, Unit 2
 Property Owner: 193 York Street LLC
 CBL: 044-C-004-001

3:14:46 - Appellant was not in attendance to present the appeal.

3:17:20 - A representative for the property owner, Matthew Grieco, speaks as an Objector and
presents his rebuttal.

3:24:15 - Public comment received.
3:56:58 - Christopher “Buddy” Moore moves to table the appeal to the next regular meeting
with requests sent to parties. Seconded by Anne-Laure Razat. (4-0; Carreras absent). The
motion passes.

4:02:33 - The Board resumes items V.a. and V.b.

4:06:41 - Matthew Lax moves to approve the rent increase applications for 72 Park and 157
Grant, totaling 38 units, at the requested amount of $125.97 a month per unit. Seconded by
Anne-Laure Razat. (4-0; Carreras absent) The motion passes.

VII. Adjourn - 4:09:47

4:09:47 - Anne-Laure Razat moves to adjourn. Seconded by Christopher “Buddy” Moore. (4-0;
Carreras absent) The motion passes.