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Stephanie Watkins Defendant. ) ) ) ) Case No. GV95-11120 ) ) ) BILL OF PARTICULARS COMES NOW the Plaintiff, Three Chopt West Apartments, by counsel, and moves for judgment against Defendant, Stephanie Watkins on grounds and in the amount as hereinafter set forth: 1. In June, 1994, the defendant and Wendy A. Fravel leased from the plaintiff an apartment at 8832-A Three Chopt Road. 2. The lease commenced on June 10, 1994 and was ended on December 31, 1994.

Trial Date: 6-16-95

3. The defendant failed to pay the amount of $845.50 in rent and late fees, for the final months of November and December, 1994. 4. The defendant left the premises prior to expiration of the lease and without proper notice.

5. Pursuant to paragraph 10(b) of the lease, the defendant covenanted that she would leave the premises in as good a condition as when she took possession of same, reasonable wear and tear excepted. 6. The defendant failed to leave the leased premises in as good a condition as when they received them and further failed to leave the premises in good clean order, reasonable wear and tear excepted, and, as a direct and proximate result of the defendants failure to do so, the plaintiff has incurred expenses and/or sustained damages as follows: a. b. c. d. e. f. $325.00 $ 90.00 $ 35.00 $ 30.00 $ 10.00 $ 25.00 $515.00 Replace carpet, stained/destroyed Kitchen floors, countertops, sink, and appliances dirty. All bathroom fixtures dirty Floors throughout apartment dirty Nail holes in walls Trash removal from apartment Total of a thru f

7. The plaintiff and/or its agent has in its possession a deposit in the amount of $150.00 which has been subtracted from the above total, leaving a balance due of $365.00 in damages.

8. The plaintiff has demanded payment from the defendant; however, the defendant has failed and/or refused to pay same. 9. The lease between the plaintiff and the defendant, as well as the applicable sections of the Virginia Residential Landlord and Tenant Act to provide for attorneys fees in the amount of $302.63 at 25%. 10. The plaintiff reserves the right to amend and/or supplement this Bill of Particulars at any time up to and including the date of trial. WHEREFORE, Plaintiff prays for judgment against Defendant in the principal sum of $1,210.50 plus interest on said sum at the rate of 9% per annum from June 16, 1995 until paid plus attorneys fees of $302.62 plus its cost expended in prosecuting this action. Respectfully submitted, Three Chopt West Apartments By: Counsel - D. Robie Ingram 12 E. Cary Street Richmond, Virginia 23219 (804)783-1667 CERTIFICATE I certify that a copy of the foregoing Bill of Particulars was mailed, first class postage pre-paid, to Ms. Nancy L. Quinn, Esquire, Counsel for Defendant, at her address at 4198 Cox Road, Suite 104, Glen Allen, Virginia 23060, on May 12, 1995.

D. Robie Ingram