This is the case of a careless landlord who valued money more than safety.

She was careless because she failed to make numerous repairs after she received several complaints, and careless because she failed to consider the safety of her occupants.
I. II. L. Smith is A. Devoted mom of 3 and hardworking B. Single parent- to make ends meet and provide best for kids, works late over 40 hours 5 days a week C. Living situation contributing to problem III. Today you will hear from L. Smith herself regarding lease w/ plaintiff last March and problems since then A. House wasnt in perfect condition when she moved in, but excited to start fresh in new home B. Spoke to plaintiff several times regarding conditions, and always reassured problems would be taken care ofbut to this day, problems havent been corrected and no other option but to live in unpleasant and unsafe environment 1. Suffer through summer heat w/ no air conditioning 2. Toilet in bathroom constantly overflowing 3. Living room heater improperly ventilated 4. Problems related to electrical wiring and lights 5. Flies and insects in home as a result of broken window in kitchen C. Letter she sent to P on July 1st requesting action be taken to correct & subsequent convo w/ Tenants Rights Org about decision to withhold rent until conditions improved D. Last and most importantyou will hear about eviction notice she received from P. Important to keep in mind that she received notice only after Boom County Dept. of Health Services conducted investigation of home, discovered numerous violations, and ordered P to make the repairs IV. P will tell you a diff story A. Testify that 1. Poor living conditions caused by D and kids 2. She was barred from making repairs 3. Unreasonable for her to be expected to constantly make repairs 4. Home is not uninhabitable B. But I ask you ask jury to keep open mind throughout trial. Listen to testimony and evidence as its presented. Use your common sense. Think about what you would do if you were in this situation

V. Members of the jury, at the conclusion of this trial, you will understand that L. Smith is just a tenant who wants to live in a decent home wants a landlord who will carry out her responsibilities and properly take care of the situation at hand. We will ask you to return a verdict against the plaintiff and in favor of the defendant, L. Smith.