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Complaint.charletta Lewis

Complaint.charletta Lewis

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Published by: Washington City Paper on Mar 14, 2012
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09/29/2013

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UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA
___________________________________:
 
Charletta Lewis
:2115 Sudbury Place, NW :Washington, DC 20012 :
:Plaintiff, :
Civil Case No. 12-cv-00037BAH
:v. :
Jury Demand
 :
Michael Ressom
:2917 Georgia Ave., NW :Washington, DC 20001 :Defendant :___________________________________ :
COMPLAINT
 COMES NOW the Plaintiff, by and through counsel, the Law Office of Jimmy A.Bell, P.C. and Jimmy A. Bell, Esquire, and respectfully submits this Complaint againstthe Defendant to enforce its rights under 42 U.S.C. § 1981 and DC law.
JURISDICTION
1.
 
Plaintiff alleges a cause of action, in part, arising under 42 U.S.C. § 1981.
Defendant’s actions took place in the District of Columbia.
VENUE
 2.
 
Venue is proper
the Defendant’s
actions took place in the District of Columbia.
STATEMENT OF FACTS
 3.
 
At all times relevant to this Complaint, Plaintiff is an African American Womanand Defendant is a non-African American Man.4.
 
In or about July 2011, Defendant and Plaintiff entered into a lease agreement andcontract ("contract") for 2917 Georgia Ave, NW, Washington, DC 20001.
 
 2
Pursuant to the lease, the lease required the leased premises to be rentable.Plaintiff leased the premises because the Defendant assured her that the buildingwas in good order and up to code. The Defendant made a false representations tothe plaintiff; its falsity was either known to the defendant or that therepresentation was made with reckless indifference as to its truth themisrepresentation was made for the purpose of defrauding the plaintiff: theplaintiff relied on the misrepresentation and had the right to rely on it; and that theplaintiff suffered compensateable injury resulting from themisrepresentation.
All of Defendant’s a
cts, representations, and omissions weremade with malice and or a reckless disregard for the truth.5.
 
Plaintiff informed the Defendant that she was going to open a Theater and JazzLounge.
Plaintiff gave first month’s rent ($6,900) and last month’s rent ($6
,900)and security deposit ($6,900) for a total of $20,700.6.
 
Plaintiff fulfilled all of her duties, responsibilities and obligations under thiscontract, acting in good faith at all times; and was willing and able to continue todo so.7.
 
When Plaintiff informed the Defendant that she,on 7/28/11, applied for aCertificate of Occupancy for the property and learned that the electrical,plumbing, HVAC and other build-outs were done without permits and were neverinspected by DCRA, Defendant stated that he had a signed contract and thatDefendant was required to pay her rent per the contract.8.
 
Defendant breached its contract with Plaintiff as the Defendant knew that thespace was not rentable under DC Law as the Defendant made or allowed others to
 
 3
make illegal changes to the property andsignificant alterations and repairs.Because changes that were neither licensed nor inspected were made to the
 building before Plaintiff occupied it, the District of Columbia’s Department of 
Regulatory Affairs issued a stop-work order on the property. That means Plaintiff was unable, to acquire a permanent Certificate of Occupancy or a permanentliquor license until January 2012 for part of the Building and still cannot acquire apermanent Certificate of Occupancy or a permanent liquor license for the otherpart of the building.9.
 
Upon information and belief Defendant has leased his properties to members
outside of Plaintiff’s protected class and has not treated
those persons they waythat Plaintiff has been treated.10.
 
Defendant is discriminating against Plaintiff because of Plai
ntiff’s race (African
American).
 
COUNT IVIOLATION OF THE CIVIL RIGHTS ACT OF 1866, 42 U.S.C. § 1981
 – 
RACE
11.
 
Plaintiff re-pleads and re-alleges paragraphs 1-10, with the same force and effectas if set forth separately at length herein.12.
 
Plaintiff is a member of a protected class (African-Americans).13.
 
Defendant, themselves and/or by and through agent(s), employee(s), and/orrepresentative(s), acted in a discriminatory manner that a reasonable person wouldfind objectively unreasonable.14.
 
Plaintiff did not enjoy the services, privileges, benefits and protections offered to
other persons outside of Plaintiff’s protected class.
 

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