VIRGINIA:
IN THE GENERAL DISTRICT COURT FOR ARLINGTON COUNTY
MONICA A. ______ Plaintiff
Vs. Case No. V01-5661
LOUIS PAPPAS Defendand
Grounds of Defense
1. Defendand denies owing the Plaintiffs any money.
2. Defendant left the rental unit with damage resulting in deductions from their security deposit.
3. The deposit was $1,275. The Defendant suffered damages arising from the failure of the Tenants to leave the property in compliance with the requirements of the lease and the Virginia Residential Landlord Tenant Act. This information was faxed about the expense on February 13, 2001 to Plaintiff.
| 1,275.00 deposit 47.67 interest on deposit |
REBUTTAL |
| 52.48 Sears labor parts Jan 31 | Washer - landlord's responsibility |
| 32.95 Sears labor parts Feb 9 | Washer - landlord's responsibility |
| 265.76 Service master - removed animal odor/hair/carpet cleaning | Cleaning carpet between tenants is the landlord's responsibility. There was no unusual odor. |
| 190.00 Fannon Furnace Service (per lease agreement) | Furnace is part of the house, and subject to ordinary wear and tear. Tenants never did anything unusual to the furnace. |
| 90.00 Vilma Mendez (household cleaning) 12/8/00 | Tenants left the house clean after leaving in November 2000 |
| 90.00 Vilma Mendez (household cleaning) 12/15/00 | Why did Vilma come a second time? |
| 75.00 Install/Repair door track | Door track was fine. This was an improvement Pappas decided to do. Marvin was asked to inflate charge. |
| 75.00 Install smoke detectors (new) | Landlord's responsibility. Smoke detectors only cost about $10 anyway |
| 79.00 Flood lamps/shower head replaced | Ordinary wear on lamps. Tenants are not responsible for changing all light bulbs. |
| $950.19 Total expenses associated with tenant's failure to
comply with the requirements of the lease when leaving the premises Net due to Tenant is $372.48 which sum is paid over to Plaintiff with this Grounds of Defense. |
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4. In the event that Plaintiff fails to accept the sum of $372.48 in full, andproceeds, then pursuant to the provisions of the Virginia Residential Landlord Tenant Act, $ 55-248.2 e ecq.. Defendant hereby seeks all of his attorney's fees in defending the amounts withheld from the deposit arising from the Plaintiff's breach of the lease.
WHEREFORE Defendant prays that this action be dismissed or in lieu thereof, that upon trial that an award be granted Defendant against the Plaintiffs for the landlord's reasonable attorney's fees.
Louis Pappas
By Counsel
Mark P. Friendlander, II
Friedlander & Friedlander, P.C.
1364 Beverly Road, Suite 201
McLean, Virginia 22101-3627
703-893-9600
703-893-9650
Counsel for Defendant
copy delivered to Plaintiffs on July 27, 2001.