Request to Waive Additional

Couft Fees (Superior Court)

This form asks the coutl to warve additional cowt fees that ar.e not covered in
a current order. Ifyou have not already received an order that waived or
reduced your court fees, you must complete and file a Request to Waive
Court Fees (Superior Court), form FW-001, along with this form.
(1)your lnformatio n (person asking the court to waive thefees):
- Nu-"r Sasha M. Walker
Street or mailing address: 5050 Klump Avenue, UnitNo. 317
Cify: North Holltwood State: CA Zip:91601
Fill in court name and street address:
Superior Gourt of California, County of
phone number: (818) 220-2276
Los Angeles

@ Vora lawyer, if you have one (name, firun or ffiliation, address, phone
J. Bramzon, SBN 214324
6230 Sylmar Avenue
number, and State Bar number): Daniel
Van Nuys, CA 91401
BASTA,lnc.
2500 Wilshire Blvd., Ste. 1050 Fill in case number and case name:
Los A:rgeles, CA 90057 (213) 736-5050 Case Number:

The lawyer has agreed to advance all or a portion ofyour fees or costs
r2805245
(check one): E Yes E No
b. (If yes, your lawyer mwt sign here): Leeds Properly Mgmt v. Walker
Law,ver's signature:
If your lawyer is not providing legal-aid type services based on your low income, you may have to go to a
hearing to explain why you are asking the court to v,aive the fees.
( 3) Date yotx last court fee waiver order, if any, was granted 09lL2ll2

[fv H^ your financial situation improved since your last Request to Waive Court Fees? E No E Yes (If yes, you
must out a new Request to Waive Court Fees, /o rm FW-00I , and attach it to this form.)
fill
(! Wfrat other fees do you want your court fee waiver order to cover? (Check all that appty):
a. E Jury fees and expenses
b. E Court-appointed interpreter fees for a witness
c. tr Fees for a peace officer to testify in court
d. E Reporter's daily fees (beyond 60-days afier grant of afee woiver, at court-approved daily rate)
e. f Fees for court-appointed experts
f. E Other (specifu):

@ *, I am asserting my right to iury trial as granted by the

do you need these other service s? (Exptain): a

California Constitution.

Notice: The court may order you to answer questions about your finances and later order you to pay back the waived
fees. If this happens and you do not pay, the court can make you pay the fees and also charge you collection fees. If there
is a change in your frnancial circumstances during this case that increases your ability to pay fees and costs, you must
notify the trial court within five days. (Use form FW-010.) If you win your case, the trial court may order the other side
to pay the fees. If you settle your civil case for $10,000 or more, the trial court will have a lien on the settlement in the
amount of the waived fees. The trial court may not dismiss the case until the iien is paid.
I declare under penalty of perjury under the laws of the State of California that the ation above is true and
correct.
Oxe:09/21/12
Sasha M. Walker )
Print name here
Judicial Council of Califomia, ww.@urlinfa.ca.gov
Request to Waive Additional Court Fees FW-002, Page 't of 1
Revised July 1, 2009, Mandatory Fom
Govemment Code, S 6851 1.3
Califomia Rules ol Ccun, Rule 3.51 (Superior Court) Erer.an 6rrGJ";. I
lw.FomsWoriolow.mm I
 Order on Court Fee Waiver Cle* stamps date here when form is filed.

(Superior Court)

fi) e"."on who asked the court to waive court fees:

v
Name: Sasha M. Walker
Street or mailing address: 5050 Klump Avenue, UnitNo. 317
City: North Hollywood State: CA Zip: 9001191601

[z) I-r*yer, if person in @ has one (name, address, phone number,

e-mail, and Stote Barrutmber).'Daniel J. Bramzon, SBN 214324
Fill in couft name ard sfreel address,
BASTA Inc.
Superior Court of California, County of
2500 Wilshire Blvd., Ste. 1050
Los Angeles, CA 90057 (213) 736-5050 Los Angeles
A request to waive court fees was filed
(date):09ll2ll2 6230 Sylmar Avenue
on
Van Nuys, CA 91401
E ttre court made a previous fee u,aiver order in this case
on (date):09/l2l|2
on
Case Number:
12805245
Read this form carefully. Atl checked boxesZare court orders. Case Name:
Leeds Prooerfv Msmt v. Walker
Notice: The court may order you to answer questions about your finances and later order you to pay back the waived
fees. Ifthis happens and you do not pay, the court can make you pay the fees and also charge you coilection fees. Ifthere
is a change in your financial circumstances during this case that increases your abilify to pay fees and costs, you must
notify the trial court within five days. (Use form FW-010.) If you win your case, the trial court may order the other side
to pay the fees. If you settle your civil case for $10,000 or more, the trial court will have a lien on the settlement in the
amount of the waived fees. The trial court may not dismiss the case until the lien is paid.

After reviewing your (check one): D Request to Waive Court Fees V Request to Waive Additional Court Fees
the court makes the following orders:
a' E The court grants your request, as follows:
(1) tr Fee Waiver. The court gmnts your request and waives your couft fees and costs listed below. (Cat. Rules of
Court, rule 3.55.) You do not have to pay the court fees for the following:
. Filing papers in Superior Court . Giving notice and certificates
. Making copies and certifying copies . Sending papers to another cout department
. Sheriff's fee to give notice . Court-appointed interpreter in small claims court
. Reporter's daily fee (or up to 60 days following the fee waiver order at the court-approved daily rate)
. Preparing and certifying the clerk's transcript on appeal . Court fees for phone hearings

(2) fI Additional Fee Waiver. The court grarts your request and waives your additional superior court fees and
costs that are checked below. (Cal. Rules of Court, rule 3.56.) You do not have to pay for the checked items.
E frry fees and expenses f Fees for a peace officer to testiSr in court
E Fees for court-appointed experts I Court-appointed interpreter fees for a witness
! Reporter's daiiy fees (beyond the 60-day periodfollowing thefee waiyer order)
n Other (specify):
(3) D fee Waiver for Appeal. The court grants your request and waives the fees and costs checked below, for your
appeal. (Cal. Rules of Court, rules 3.55, 3.56, 8.26, and 8.818.) You do not have to pay for the checked items.
I Preparing and celti$,ing clerk's transcript for appeal
E Other (specifi):
Judicial Council of Cattqnia, ww.@uftinlo.a.gov
Revised July 1, 2009, Mandatory Fom Order on Court Fee Waiver (Superior Court) FW-003, Page 1 ol 2
Gryemment Code, S 68634(e)
Califomia Rules of Courl rule 3.52
 Case Number:
t2805245
Your name:

b. f] fne court denies your request, as follows:

Warning! lf you miss the deadline below, the court cannot process your request for hearing or the court papers
you filed with your original request. lf the papers were a notice of appeal, the appeal may be dismissed.

(1) f] fne court denies your request because it is incomplete. You have 10 days after the clerk gives notice of
this order (see date below) to:
. Pay your fees and costs, or
. File a new revised request that includes the items listed below (spec{y incomplete items):

(2) f] fne court denies your request because the information you provided on the request shows that you are not
eligible for the fee waiver you requested (specify reasons):

The court has enclosed a blank Requestfor Hearing About Court Fee Waiver Order (Superior Court), form
FW-006. You have 10 days after the clerk gives notice of this order (see date below) to:
. Pay your fees and costs, or
. Ask for a hearing in order to show the court more inform ation. (Jse form FW-006 to request hearing.)

I fhe court needs more inforrnation to decide whether to grant your request. You must go to court on the date
below. The hearing will be abottt (specify questions regarding eligibility):

I Bring the following proof to support your request if reasonably available:

Name and address of court if different from page 1:

Date: Time:
Dept.: Rm.:

Warning! lf item c is checked, and you do not go to court on your hearing date, the judge will deny your request to
waive court fees, and you wlll have 10 days to pay your fees. lf you miss that deadline, the court cannot proess
the court papers you filed with your request. lf the papers were a notice of appeal, the appeal may be dismissed.

Date:
Signature of (check onQ: Z Judicial fficer J Clerk, Deputy

Request for Accommodations. Assistive listening systems, computer-assisted real-time captioning, or sign
language interpreter services are available ifyou ask at least 5 days before your hearing. Contact the clerk's
office forRequestfor Accommodation, Form MC4l0. (Civil Code, $ 54.8.)

Clerk's Certificate of Service

I certifu that I am not involved in this case and (check one): n
A certificate of mailing is attached.
n t tranaea a copy of this order to the party and attorney, if any, listed in@ ana@, at the court, on the date below.
I fnis order was mailed frst class, postage paid, to the parry and attorney, if any, at ttre addresses listed in@ aa@ ,
from (city): , Califomia on the date below.

Date: Clerk, by , Deputy

Revised July 1, 20Og FW-003, Page2of 2

Order on Court Fee Waiver (Superior Court)

 MC-050
ATTORNEY (Name, Stete Bar number, and addre$): FOR COURT USE ONLY
- Kevin Hermansen, SBN 266254
BASTA,Inc.
2500 Wilshire Blvd., Ste. 1050
Los Angeles, CA 90057
rELEpHoNENo., 213-736-5050 FluNI.(optionat):
E-MAIL ADDRESS (Opliorar,li

ATToRNEY FoR (Name;: $2914 M. Walkef

SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
srREEr ADDRESS, 6230 Sylmar Avenue
MATLTNG ADDRESS, 6230 Syhnar Avenue
crrYANDztPcoDe: v&nNuys, cA 9140i
BRANCH NAME: van NUyS cOUrthOUSe
CASE NAME:

Leeds Property Management,I:rc. v. Sasha M. Walker

CASE NUMBER:
SUBSTITUTION OF ATTORNEY-CIVIL
(Without Court Order) r2805245

THE COURT AND ALL PARTIES ARE NOTIFIED THAT (name): Sasha M. Walker makes the followlng substitution:
1. Former tegal representative l-71 earty represented self [--l Attomey (name)'.
2. New legal representative l--l prrty is representing self l7-l Attorney
a. Name: Kevin Hermansen b. State Bar No. (ff applicable):266254
c. Address (number, street, city, ZlP, and law firm name, if applicable):
BASTA,Inc. 2500 Wilshire Blvd.. Ste. 1050
Los Angeles, CA 90057
d. Telephone No. (inctude area code). 213-736-5050
3. The party making this substitution is a I--l plaintiff [-71 defendant I-l petitioner (specify).

*NOTICE TO PARTIES APPLYING TO REPRESENT THEMSELVES

. Guardian . Personal Representative

. Conservator 'Probate fiduciary
. Trustee . Corporation

lf you are applying as one of the parties on this list, you may NOT act as your own attorney in most cases.
to substitute one attorney for another attorney. SEEK LEGAL ADVICE BEFORE APPLYING TO REPRESENT

NOTICE TO PARTIES WITHOUT ATTORNEYS

A party representing himself or herself may wish to seek legal assistance. Failure to take
timely and appropriate action in this case may result in serious legal consequences.

4. I consent to this substitution.

Date:09/2lll2
Sasha M. Walker
CTYPE OR PRINT NAME) (SIGNATURE OF

5.47]t I consent to this substitution

Date:09l2lll2
Sasha M. walker
CTYPE OR PRINT NAME) (SIGNATURE OF FORMER ATTORNEY)

6.[ /I I consentto this substitution.

Date:09/2Ll12
Kevin Hermansen
CFYPE OR PRINT NAME) (SIGNATURE OF NEWATTORNEY}
(See reverse for proof of service by mail) Page 'l of 2
Fom Adopted For Mandatory Use Code of Civil PDedure, SS 284(1), 285;
Judicial Council of Califomia SUBSTITUTION OF ATTORNEY--€IVIL cal. Rules of cou( rute 3.1362
MC-050 [Rev. January 1,ZOOV (Without Ccurt Order) Amerien LegalNet, lnc. ww.coutinfo.ca.gov
-
M-FomsWori(row.@m
 MC450
CASE NAME: CASE NUMBER;

Leeds Property Management,Inc. v. Sasha M. Walker 1280s245

PROOF OF SERVICE BY MAIL

Substitution of Attorney4ivil

lnstructions: After having all parties served by mail with the Substitution of Attomey-Civil, have the person who mailed the document
complete this Proof of Service by Mail. An unsioned copy of the Proof of Service by Mail should be completed and seryed with the
document. Give the Substitution of Aftomey-Civil and the completed Proof of Service by Mail to the clerk for filing. lf you are
representing yourself, someone else must mail these papers and sign the Proof of Service by Mail.

1. I am over the age of 18 and not a party to this cause. I am a resident of or employed in the county where the mailing occuned. My
residence or business address is (specify)'.
2500 Wilshire Blvd., Ste. 1050 Los Angeles, CA 9005
2. I served the Substitution of Attorney-Civil by enclosing a true copy in a sealed envelope addressed to each person whose name
and address is shown below and depositing the envelope in the United States mail with the postage tully prepaid.

('1 ) Date of mailing: 09l2lll2 (2) Place of mailing (city and sfafe). Los Angeles, CA
3. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and conect.

Date: 09121172

Kevin Hermansen
CryPE OR PRINI NAME) (SIGNATURE)

NAME AND ADDRESS OF EACH PERSON TO WHOM NOTICE WAS MAILED

4. a. Name of person served: Edward Felman, Esq.
b. Address (number, street, city, and ZIP):
Felman, Daggenhurst & El Dabe
1743 Ventura Blvd. Suite 350, Sherman Oaks, CA91423
c. Name ofperson served:
d. Address (number, street, city, and ZIP):

e. Name ofperson served:

f. Address (number, street, city, and ZIP)'.

g. Name of person served:

h. Address (number, street, city, and ZIP):

i. Name of person served:

j. Address (number, street, city, and ZIP):

E List of names and addresses continued in attachment.

MC{50 [Rev. January 1, 20OI

SUBSTITUTION OF ATTORNEY_CIVIL Page 2 of 2

(Without Court Order)

 I
Daniel J. Bramzon, State Bar No. 214324
2 Sarah Shipitsyna, State Bar No. 258642
Kevin Hermansen, State Bar No. 266254
J
BASTA, Inc.2
4 2500 Wilshire Boulevard, Suite 1050
Los Angeles, Califomia 90057
5 Telephone: (213) 736-505A
6
Attorneys for Defendant Sasha Walker
7

8 SIIPERIOR COTIRT OF TITE STATE OF CALIFORNIA

9
FOR TFIE COLINTY OF LOS ANGELES
l0
LEEDS PROPERTY MANAGEMENT,INC
11 Plaintiff, LASC Case No. 12805245
v.
12

13 CREOLE WALKER JT'RY DEMAND

i.:
<E^: t4 Defendant(s)
vr.:
( ;-;; ou
15
JURY DEMAND
3i 16 TO THE COURT, THE PARTIES, AND THEIR COL]}ISEL OF RECORD:
J
17
PLEASE TAKE NOTICE THAT the above-captioned defendant(s) demand a jury trial in
18
the above-captioned action.
t9
DATED: September 2I, 2072 BASTA,lnc.

/L^ 2/*---
20

21
By:
Daniel J. Bramzon
22
Sarah Shipitsyna
z) Kevin Hermansen
Attorneys for D efendant (s) Sasha Walker
24

25

26

27
'BAStL, Inc. is a California public benefit corporation and federally registered non-profit organization that advocates
28 for tenants' rights and fights to eliminate substandard housing.

JTIRY DEMAND
 I
PROOF OF SERVICE
2 LASC IZBO5245
Leeds Property vs. Walker
a1

STATE OF CALIFORNIA
4 COLINTY OF LOS ANGELES
5
_ I am employed in the County of Los Angeles, State of Califomia; I am over the age of 18
and not a parfy to the within action; my business address is 2500 Wilshire Boulevard, Suite 1050,
6 Los Angeles, California 90057 .
7
On September 21,2012,I sen ed the foregoing document(s) described as:
8
AMENDED ANSWER TO PLAINTTFF'S COMPLAINT and JIIRY DEMANID
9
on the interested parties to this action by placing a copy thereof enclosed in a sealed envelope
10
addressed as follows:

11 Felman, Daggenhurst & El Dabe

13743 Ventura Blvd. Ste 350
t2 Sherman Oaks, Ca9l423

E ? r.
.. ; IJ
i,: (BY MAIL) I am readily familiar with the business practice for collection and processing
i: ! u
"F "oY of correspondence for mailing with the United States Postai Service. This correipondence
-1 .o
"' shall be deposited with the United States Postal Service this same day in the ordinary course
<i==t 15 of business at our office's address in Los Angeles, California. Service made pursuant to this
paragraph, upon motion of a parfy served, shall be presumed invalid if the postal
H; t6 cancellation date of postage meter date on the envelope is more than one day after the date of
I deposit for mailing contained in this affidavit.
t7
(BY OVERNIGHT DELIVERY SERVICE) I served the foregoing document by Federal
18
Express, an express service carrier which provides overnight delivery, as follows. I placed
true copies o.f the foregoing document il s.ealed envelopes or packages designated by the
79
express service carrier, addressed to each interested parfy as set forth above, with fees for
overnight delivery paid or provided.
20

21 tr (BY PERSONAT SERVICE) I caused such envelope to be delivered by hand to the offices
of the above named addressee(s).
22
(BY FACSIMILE) I caused such documents to be delivered via facsimile to the offices of
the addressee(s) at the following facsimile number:

24 Executed on September 21,2012 at Los Angeles, California.

25 I declare under penalty of perjury under the laws of the State of California that the above is
true and correct.
26

27 Rebeca Marcos

28

1
PROOF OF SERViCE
 2l!3?4
ffi,q" i,T,ffil
1
Daniel J. Bramzon, StateBarNo'
z S*rft Sfripitsyna, State Bar No' 258642
Kevin Hermansen, State Bar No' 266254
J
BASTA.Inc.l $EP 21 2CI1?
4 2500 Wiishire Boulevard, Suite 1050
Los Angeles, Caiifomia 90057 i,rls A \'( rr ';t,r,,l
il ..-

5 Telephone: (213) 736-5050 S Ulibir iLjI{ rj

{i u}ti
6
Attorneys for Defendant Sasha Walker
7

8 STIPEzuOR COLIRT OF THE STATE OF CALIFORNIA

9
FOR TFIE COLINTY OF LOS ANGELES
10

l1 LEEDS PROPERTY MANAGEMENT, iNC LASC Case No. 12805245

t2
Plaintifl
t3 v. AMENDED ANSWER TO PLAINTIFF'S
4
_':
=-=
COMPLAINT
F -o:
l4 CREOLE WALKER
< i.;, 15 UURY TRIAL DEMANDED]
Defendant(s)
16
J ANSWER
t7
I. GENERAL DENIAL
18
Pursuant to Section 431.30 of the code of civil Procedure, Sasha walker denies generally
19

and specifically each allegation in the complaint

20 and that plaintiff has been damaged in the sum
or
21 sums alleged, in any sum, or at all, or is entitled
to aay of the relief requested therein, including
22 without iimitation, possession, generar, equitable,
and other damages.
23
II. J[IRY DEMAND
24
The above-captioned defendant(s) demand jury trial in the above-captioned action.
25 a

26

27

28 -itl*'ti;i;",ff#ffii#,##:ff:ffifjffiff*;**",v registered non-pront organizattonthat

advocates

ANSWER
 1

IIL SEPARATE AFFTRMATTVE DEFENSES

2
BREACH OF TIIE IMPLIED OR EXPRESSED WARRANTY OF HABITABILITY
The amount of rent demanded by the plaintiff is not in fact due because the Plainti
4
breached the implied warranty of habitability. The dwelling at issue and/or common areas of the
5

6
building where defendant(s) resides suflers from defects that render it untenantable and those

7
defects include, but are not limited to, the following:

8 lneffective waterproofing and weather protection of roof, exterior walIs, unbroken

9 windows, or doors (i.e., leaks, brsken windows, etc.).

10 X Plumbing is not in good working order, includ.ing a water supply that prod,uces hot

11 and cold rururing water.

t2 l Lack of properly functioning heating unit.

3:
13 tr Defective electricaVwiring or exposed wiring.
* oo:
F -oI
l4 x Rodents and/or other vermin (such as termites, bedbugs, bees or roaches).
< :'a ; 15
X Floors, stairways, or railings are in disrepair.
;<
I
16
x An entry door does not have a firnctioning lock.
t7
X A window accessible from the street-level (approx. 10 feet from the ground) does not
l8
have a functioning lock.
t9
X Holes in the walls or ceiiings.
20

2t
x A Substandard Order or Notice and Order to Comply was issued by a governmental
agency demonstrating additional defects or confirming the defects identified in this answer.
22
X Other: There is mold in the bathroom. The smoke detector is not working. There is
23
no carbon Monoxide detector in the unit.
24

25
X The property is substandard as defined by Section 17920.3 of the Health and Safery

Code.
26

27
X Any habitability defects also constitute reductions in housing services and, therefore,

28
illegal rent increases pursuant to the regulations in Section 1200 of the Rent Adjustment

ANSWER
 I

2 Commission.
LOS ANGELES RENT STABILIZATION ORDINANCE ("LARSO'')
J
The premises at issue a.re subject to LARSO, a chapter of the Los Angeles Municipal Code
4
("LAMC"), and at the time plaintiff served the relevant notice:
5

6
X The premises were not properly registered as requked by the Los Angeles Municipal

Code (including the fulI and current payment of registration and SCEP fees). LAMC $$ 15i.05;
7

1s1.Oe(E) (F).
8

X The plaintiff neither (i) served a copy of the registration statement or renewal
9

statement upon the defendant(s), nor (ii) posted said registration statement or renewal statement in a
10

11
conspicuous place. Therefore, rent can neither be demanded nor accepted by plaintiff. LAMC

t2 $ 1s1.0s(A); LAMC $ 1s1.Oe(F).

!?
13 X The plaintitr did not have a permitted eause for eviction. LAMC $ 151.09(4),
i,:
=tr
F 6::
14 LAMC S 1s1.09(E).
o - -..1
<!E, 15 X The plaintiff held the defendarrt(s) security deposit for over one year and had not

16 credited defendant(s) for any interest payments thereon either on a monthly or yearly basis. LAMC
o
j
17
$ 1s1.06.02(C); LAMC $ 151.Oe(E).
18 The rent demanded exceeded the legal amorurt which could be demanded (i.e., more
79
than the permitted annual increase either this past year or any previous year). LAMC $ 15 1.1 1.

20
X The rent demanded exceeded the legal amount u,hich could be demanded (i.e., more
21
than the permifted annual increase either this past year or any previous year) because the plainti
22
reduced housing services without granting a corresponding decrease in the money charged as rent.
Z3
tr The plaintiff had a legally permissible reason for the eviction but did not pay the
24
defendant( s) the required relocation assistance. LAMC $ 151.09(G).
25
X This is a breach of covenant or nuisance case, and the plaintiff was affempting to
26
evict the defendant(s) as retaliation for the defendant(s) exercising a right granted under I-ARSO.
27
LAMC $ 1s1.0e(B).
28

ANSWER
 1

2 f] The plaintiff performed Primary Renovation Work without the proper approval

3 and/or service of a Tenant Habitability under LARSO. LAMC $ 152, et seq.

4 tr The property is subject to REAP.

5 tr The premises were acquired by foreclosure after December 17,2008.

6
ESTOPPEL. WAIVER. OR BAD FATTII
7 The plaintiff is estopped from pursuing this eviction or has waived the right to prosecute an
8
unlauful detainer because :
9
tr Ptaintiff accepted a rent payment from defendant(s) after service of the notice to quit
10
thereby renewing the tenancy.
11
Plaintiff retained a check or money order without negotiating it for an unreasonably
l2
long time, thereby accepting payment and renewing the tenancy.
13
i.: Plaintiff accepted a rent payment from defendant(s) with full knowledge of the
< 3- i l4
alleged breach of the rental agreement thereby waiving the right to declare a forfeiture by reason of
< 4,: . 15
the breach and renewing the tenancy.
l6
J tr Plaintiff refused to accept the tender of rent payment - either prior to service of the
17
notice to quit or during the notice period.
18

r9
tr In bad faith the Plaintiff prevented the payment of rent payment - either prior to
service of the notice to quit or during the notice period.
20

Defendant is permitted to tender late rent payments if paying a late charge or within a
2t
grace period, so Defendant was not in default of the payment of rent.
22

23 X The deposit may be used to off-set any rent default, tenant has a deposit, so the rent is

24 not delinquent.

25 tr Plaintiff and defendant(s) made other payment arrangements after service of the
26 notice to quit (i.e., revised the notice to quit) - upon which defendant(s) detrimentally relied - so

27 payment in the instant case was not delinquent.

28

ANSWER
 1

NO BREACH OF COVENANT
2
Plaintiffdid not serve a proper notice to enter under Section 1954 of the Civil Code
3
(e.g., the notice did not state the approximate time or the notice did not did not reflect the landlord's
4
actual intent to enter) and, therefore, the defendant was under no obligation to permit the plaintiffto
5
enter.
6

7
f] Plaintiff did not serve a propff notice to use pesticides under governing municipal
and state law and, therefore, the defendant was under no obligation to permit the plaintiff to enter.
8

9
X Plaintiff has demanded compliance with a term of the lease or rental agreement that

10
is not legally enforceable.

11 DEFECTTVE NOTICE
12 The notice is defective and/or inapplicable because:
io
i.:
13 x The amount of rent demanded in the notice is more than the "amount due."
< i^ -
vr .: @o
t4 x The amount of rent demanded in the notice is more than the "amount due" because
< 4-= . 15 the Defendant is entitled to a set off.
16
Plaintiff did not serve the notice either (1) irr person or (2) by both posting the notice
J
17
on the door and mailing said notice.
18
T Plaintiff failed to serve the notice at all.
t9
n The amount requested in the notice included amounts other than rent such as a late
20
fee or rental surcharge.
21
T The notice did not adequately identiff a persorVaddress where the rent could be paid.
22

-/.3
r The person identified on the three-day notice was not actually available at the time

and place stated in the three-day notice.

24
The notice does not "permit a determination of the date, place, witnesses and
25
circumstances conceming the reason" for the eviction. LAMC $ i 51 .09.C.1 .
26

27
f The notice was superseded by a later-served notice.

28

ANSWER
 I
MISCELLANEOUS
2
X Plarntiff served a notice to quit, fi1ed the present unlarnful detainer, or imposed a rent
J
increase to retaliate against defendant(s) for invoking hislher right to complain to a governmental
4
agency, to the plaintiff, or to plaintiff s agent concerning an issue of habitability or a nuisance being
5
perpetrated on the premises.
6
Plaintiff served a notice to quit, filed the present unlaufirl detainer, or imposed a rent

increase to retaliate against defendant(s) for the peaceful and laufirl exercise of other rights.
8

Plaintiff is neither the owner of the premises at issue nor the management company
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authorized to act on plaintiff s behalf by frling a lawsuit.

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Plaintiff is a new owner and did not provide the Defendant with proper notice of the

t2 change in ownership required by Sections 1111 and 1962 of the Civil Code.

l3 tr Phintiff has already evicted Defendant from a substantial portion of the premises
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< :ci- - and, therefore, is not entitled to any rent.
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-, .- U O
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15 A Substandard Order was issued and relocation fees have not been paid by plaint
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t6 as required by the Health and Safety Code.
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t'7
X Plaintiffis enrolled in Section 8 program and has not complied with the requirements

18 of that program.
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f] Plaintiff s unlanfirl detainer action is the product of arbitrarily discrimination against
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defendant(s) by proceeding with the unlau{ul detainer action based on a protected category (i.e.,
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age, gender, tace, etc.).
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f] Plaintiff filed the Compiaint before the expiration of the three-day notice (i.e., if the
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last day of the notice period falls on a Saturday, Sunday, or hoiiday, the notice period actually
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expires on the next non-holiday weekday).
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n Defendant is a tenant of a property obtained through foreclosure and has not received
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the proper notice required by state and federal law.
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ANSWER
 I
ry. RELIEF R.EOTIESTED
2
WHEREFORE, defendant(s) prays as follows:

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1. That the Complaint be dismissed with prejudice and/or judgment entered in favor o

defendant(s);
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2- For the costs of suit incurred herein, including reasonable attomeys' fees to the
extent perr,rissible by law (e.g., Sectionll74.2l of the Code of Civil Procedure and/or 162.09 of the

8 LosAngeles Municipal CoCe), contract or otherwise determined by the Court;

9 3. For statutory damages as permitted by law; and

l0 4. For such other and fi.rther relief as the Court deems just and proper, including (i

11 applicable) an order to repair the relevant dwelling and adjust the monthly rent accordingly.

12
DATED: September 21, 2012 BASTA,INC.
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By: 2/a-'
Daniel J. Bramzon
/rt/ dryr?Cry:-T_
a .! orf
<!'i, l5 Sarah Shipitsyna
EA;@3 Kevin Hermansen
;< l6 Anorneys for Sasha Walker
J
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ANSWER
 1

2 VERIFICATION

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I am a defendant in this action, and I have either read this Answer or had it read to me. I

4 declare under penalty of perjury pwsuant to the laws of the State of California that, based upon

5
information and belief, the foregoing is true and correct.
6
DATED: September 21, 2012
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ANSWER