Summary of Facts as to Claim & Explanation of Damages I would like to begin by saying that I have never refused to paid rent owed as entitled and outlined in the leased. The reason why rent has not been paid as of January is because I again requested to be let out of my lease and compensated for damages in part the plaintiff acknowledges as my concerns or habitability. The plaintiff would not accept a prorated amount of rent as previously presented by myself. The plaintiff feels that I should have to pay full rent for a non-working heater and accessible access for my disabled mother. Even despite management acknowledging defective non operable equipment. • The Plaintiff was notified in August of 2014 that My mother who is a party on the lease; needed to terminate the lease due to grave illness o As a result; I contacted the leasing office and was told that there would be a $3000 lease break fee despite the reason for the lease break is due to medical necessity. o As per the initial conversation with management; I attempted to contact the corporate offices of UDR for assistance with discussing the termination of the lease as per ADA compliance. o I was told by UDR corporate offices; that the lease break fee would still apply and that I can either stay the remainder of the lease or pay the free despite a medical necessity as such. o By the end of August, my mother’s condition became so bad that she was hospitalized and upon release from the hospital, she could no longer climb stair without exhaustion and she could no longer operate a motor vehicle. o At this time, it was explained to the plaintiff that there was a need for the defendant to fix the elevators in the building as well as make a reasonable accommodation to the parking area to allow my mother access to our apartment. Management said they would look into the concerns and get back to me. I did not hear from anyone for several days until I attempted to call back and spoke to a receptionist at the leasing office. The receptionist informed be that they were still working on the matter. o Per my last conversation with “Andy” in August; I have attempted numerous times to contact the management office for follow up and most importantly a resolution; to no avail. After several months of unanswered correspondence, and wasted visits to the leasing office, I experienced the following issues:  My Heater in the apartment does not turn on or respond to the switch  My kitchen sink garbage disposal does not work, leaks water and traps black water in the sink  The sink in my bathroom often become clogged and cannot maintain consistent water pressure  The fan in the bathroom does not adequately clear steam as there is only one window in the apartment. As a result; the paint in the bathroom is pealing and cracking. There are also signs of rust and mold as a result of this poor ventilation system.  The blinds of the only window in the apartment continue to fall off; thus limiting my privacy.  Security Personnel often takes longer to respond to noise complaints that often carry on until 3 to 5 am in the morning  Common areas of the property can often times be covered with discarded remodeling materials (Such as nails, rusted pipes and sharp ended tools)  Common areas can often be see with drug paraphernalia and hypodermic needles.  The police are often present due to obscene and unruly resident and guest behavior  My front door of my apartment was vandalized; brought to management’s attention and never repaired.  Clothing totaling $500 in value was stolen on 2/4/2015 as a result of management not replacing a faulty lock or installing monitoring equipment.  Security Staff used racial terminology to refer to me as a resident as a “Black Idiot”  The Handicap accessible lift has been left inoperable several times over the course of several months. Additionally, the equipment is rusted and unsafe as such. After months of calls not being returned and emails unanswered; I finally contacted the leasing office and had a horribly exchange with the staff which resulted in my communication with Mark who is the new community director. Per my conversation with Mark; I have expressed by grievances as well as my proposed resolution for compensating myself and my family for the damages sustained. Mark Acknowledged the items addressed as well as acknowledged defect in the handicap accessible equipment that we were repeatedly invited to use. We have yet to reach a resolution; nor at the very least has by heat been fixed. In light of the Defendant’s negligence, I sustained damages which I am requesting to be compensated as follows and for the following respective reasons.  $2000 in traveling expenses and costs incurred personally as a means of providing alternative arrangements for my mother’s when she should have had access to her residence she shares with me.  $8000 in rent paid in good faith while requesting to have concerns of habitability  I am also requesting punitive damages awarded due to the egregious negligence of the plaintiff on the poor maintenance of the properly, the request of a lease break fee and not following the guidelines of ADA in their request; as well as emotional damages sustained in this unnecessary and lengthy process to address basic and simple issues.  Finally, I would like a written letter of apology from the UDR corporate office citing and acknowledging my concerns and apologizing for my distress as well as the dress of my mother due to their cruel, hostile, and negligent behavior. I also would like to point out that aside from these clear issues of habitability, I have a huge problem with the way that this property and management company entirely misrepresented the community, response for service as well as the overall condition of the property. The property, can be seen photographed in marketing materials entirely different from the true state and condition of the property. Also, based on my experience, it is apparent that even parts of the property not shown on tour; are deliberately not shown for a deceptive purpose. Moreover, I was blatantly lied to by leasing staff when I asked about the noise level of the surrounding area that had led to additional distress and damages stemming from their omission of facts about the property when specifically asked. My mother has “End-Stage” Heart Failure. For the defendant to subject my mother as well as myself trough such an inhumane unnecessary legal process in this unwavering time of grief; is absolutely cruel and should earn appropriate sanctions by the court as such.