IN THE GENERAL DISTRICT COURT OF ARLINGTON COUNTY
LOUIS A. PAPPAS, TRUST
Vs. Case No. ______________
ANSWER, GROUNDS OF DEFENSE, AND COUNTERCLAIM
COMES NOW, the Defendant, pro se and states the following:
1. Defendant admits he entered into a residential Lease Agreement in July of 2001, with possession to commence on August 1, 2001.
2. Defendant states he was denied the full use and possession of the premises at 509 South 24th Street, Arlington because plaintiff-landlord had not made agreed repairs, and the House was very dirty beyond use as a residential unit. Possession was taken during the second week of August 2001, after hiring cleaners to make the house fit for residential use.
3. Defendant denies that he owes rent money to the landlord and further denies that the landlord is entitled to possession of the premises.
4. Tenant states that at all times during the lease and tenancy that the landlord has been, and remains, in substantial violation of the Virginia Residential Landlord Tenant Act, Code of Virginia Title §55-248.2 - §55-248.40;
5. Landlord has also been at all times from August 2001 to date in material violation of both the housing and building codes and regulations.
6. Landlord has been repeatedly advised of these major Virginia Code violations, both orally, and in writing, commencing at the outset of the lease. Despite these requests and demands that landlord fulfill his duties, he has failed to do so.
7. In addition to the above defenses, Plaintiff-Tenant relies upon the defense of retaliation by the landlord and unlawful bias.
8. All of these defenses shall be set forth more fully in a counter-suit filed herewith by the Tenant.
WHEREFORE, the Tenant prays that the writ of possession be denied, that Landlord’s pleadings be stricken, and that judgment be entered in favor of the Tenant in the amount set forth in the amount of no less than $7,325 dollars, the exact amount requested in a bill of particulars filed in bad faith by the landlord through his counsel. I ask for this,
Robert R. Stone
Tenant Counter Claimant
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this ____ day of ________________, 2003, a certified copy of this foregoing instrument was mailed and postage prepaid to:
FRIEDLANDER, FRIEDLANDER & EARMAN, P.C.
Susan F. Earman, Esq.
1364 Beverly Rd., Suite 201
McLean, VA 22101
Counsel for Plaintiff