Defendant’s Answer to Complaint for Declaratory Judgment, and Defendant’s Counterclaim

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION

 

ROSEMARY KILKENNY,    

 

Plaintiff,

   

  1.                                                   CASE NO.: 2020 CA 4315 B 

 

EDWARD SARGENT,                               JUDGE: HEIDI PASICHOW

 

Defendant.

 

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT FOR DECLARATORY JUDGMENT AND COUNTERCLAIM

COMES NOW, Defendant, Edward Sargent, pro se and answers Rosemary E. Kilkenny, Esq.’s complaint for declaratory judgment; and submits affirmative defenses and counterclaims as follows:

NATURE OF CASE

  1. This case is a matter of a contractual dispute regarding Plaintiff’s promise to repay a $20,000 loan in a manner that is clearly delineated in a notarized, legally valid, and enforceable agreement that Plaintiff signed in the District of Columbia, while they were both adults of sound mind. 
  2. Plaintiff, a corporate attorney who helped write and edit the Agreement, challenges the existence and/or the validity of the legal document. However, her claim is false. The Agreement does indeed exist. (See Exhibit A: The Note; Exhibit B: Addendum No. 1 and Exhibit C: Addendum No. 2) 
  3. Factual reasons affirming the legitimacy of the Agreement are provided in the Affirmative Defenses section of this Answer. 
  4. Under the terms of the Agreement, the Repayment is not yet due. The due date is set to occur on the date Plaintiff retires from Georgetown University—whenever that might occur—or whenever she mortally expires or resigns from her position as the university’s Vice President for Diversity, Equity, Inclusion and Chief Diversity Officer. She has worked at the university for about 40 years.
  5. In the event she dies while working for GU, responsibility for repayment transfers to other named parties in compliance with the provision in the Agreement that states: The Agreement “shall be the joint and several obligations of all makers, sureties, guarantors and endorsers, and shall be binding upon them and their successors and assigns.”
  6. Starting 17 years after the Agreement was created, Defendant, a professional writer, used periodic emails—none of them defamatory (as they are based on facts known to the Defendant), illegal or damaging—to that request plaintiff refresh her commitment to fulfill her contractual responsibility as delineated in the 1999 Agreement. 
  7. Defendant was compelled to seek Plaintiff’s written affirmation that she intended to live up to her word, because during the fall of 2017, plaintiff flippantly and verbally told him in a face-to-face conversation over dinner near the Georgetown University that she did not intend to fulfill her promise. 
  8. The Plaintiff dispassionately stated she had what amounts to borrower’s remorse. Her verbal statement has caused the defendant to suffer intense emotional distress—a prolonged distress that is now only exacerbated by Plaintiff’s burdensome complaint.
  9. The plaintiff has filed her complaint hoping this Court will provide her cover. She is asking the Court for permission to violate her promise to pay and give her a legal way out, a legal way to relieve herself of her borrower’s remorse. 
  10. Plaintiff has packed her totally baseless and outrageously frivolous complaint with statements she knows to be either partially or completely false. She has shamelessly laid before this court intentional misinterpretations of facts. 
  11. Her current behavior reflects her unsavory behavior years ago when she in the middle of the day, hurriedly without invitation nor advance notice, walked through the unlocked front door of Defendant’s Northwest Washington, D.C. home. In a bold and immoral manner entered his bedroom, where he was resting from working the night shift at his job, to persuade the defendant to give her money. She knew his work schedule and where to find him at that time day.
  12. Ms. Kilkenny was not then his intimate partner. Their relationship had evolved into a distant professional and platonic relationship focused on family, her work as an affirmative action lawyer at GU, and Defendant’s work as a technical writer at MicroStrategy XXX an IT corporation. 
  13. Mr. Sargent was in a committed and satisfying intimate relationship with another partner at the time and in no way whatsoever was interested in a sexual encounter with Ms. Kilkenny. 
  14. Nevertheless, she perched herself atop his bed, touched him seductively and proposed that if he gave her $20,000 right away in an unsecured loan, she would “do anything you want me to do. I’m yours. We can have sex anytime you want. Right now, if you want.” 
  15. Thus, in Defendant’s opinion, she prostituted herself—not necessarily in an allegedly criminal sense as an alleged common whore perhaps—but in the moral sense. Black’s Law Dictionary, 7th Edition informs defendant’s characterization of the plaintiff’s pitiful act. The document defines prostitution as a person’s voluntary effort to engage “in sexual activity for money or its equivalent … The act of debasing” oneself.
  16. Defendant was shocked and offended by her solicitation and declined her offer. His opinion of her declined and he felt sorry for her. Yet, he wanted to help her son not get kicked out of St. Alban’s School for Boys, where he was preparing to attend Georgetown University to study law. It was clear that she was in a panic and willing to debase herself to obtain favor from him. 
  17. She told Defendant she needed the money to pay his tuition and was not in a financial position to do so.
  18. It was so unnecessary for her to take the approach she took. 
  19. Defendant felt plaintiff was trying to take advantage of him by playing on his emotions in multiple ways. Assured her he would never take advantage of her, and he was able to settle down her anxiety. 
  20. Then as now via this court case, she has proven that she will do and say anything she believes she needs to do and say to achieve substantial financial gain—by hook or by crook.
  21. Defendant promised to help her, but he needed some time to think of a way to do so without damaging his own financial status. 
  22. Plaintiff informed him that not only did she not have the cash, but she was also ashamed to ask one of her professional peers or family members out of embarrassment. She was ashamed that she had mismanaged her funds to the extent that she put her child’s education at risk. Being kicked out of St. Alban’s would have troubled him emotionally and recked his career path by damaging his ability to qualify to attend Georgetown, which he did tuition free.
  23. She wanted to withdraw the money from her retirement annuity account, however TIAA/CREF penalties and restrictions were very severe. In addition, withdrawing the money would have a lasting negative impact through loss of potential gains.
  24. Based on this information, the parties embarked upon a path that would result in a win-win. He would loan her the money and she would reserve $20,000 worth of stock her annuity. When she retired, she would repay the $20,000 plus 50 percent of growth of entire annuity account.  
  25. She did not know how long she would work before retiring. She ultimately decided to keep working another 20 years. 
  26.   As stated in her complaint, after 40 years at GU, she still does not know when she will retire.
  27. Now she has made baseless, nonsensical, and false claims in her effort to persuade this court to believe that the contract she begged the defendant to create, helped the defendant write and voluntarily signed in the presence of a notary never existed.

 

ANSWER TO THE COMPLAINT

  1. Mr. Sargent neither admits nor denies allegations contained in paragraph 1 of the complaint.
  2. Complaint Paragraph 2: Defendant admits he loaned the plaintiff $20,000 (Twenty Thousand Dollars); Defendant denies the parties were dating when the loan was made. 
  3. The Defendant denies allegations contained in paragraph 3 of the complaint.
  4. The Defendant denies the allegation contained in paragraph 4 of the complaint.
  5. The Defendant denies allegations contained in paragraph 5 of the complaint. 
  6. The Defendant denies allegations contained in paragraph 6 of the complaint.
  7. The Defendant denies allegations contained in paragraph 7 of the complaint.
  8. The Defendant denies allegations contained in paragraph 8 of the complaint.
  9. The Defendant denies allegations contained in paragraph 9 of the complaint.
  10. The Defendant admits allegations contained in paragraph 10 of the complaint that Plaintiff resides in Virginia and that she was/has been employed by Georgetown University and currently serves as the Vice President for Diversity, Equity, Inclusion, and Chief Diversity Officer.
  11. The Defendant admits allegations contained in paragraph 11 of the complaint as to Defendant’s residence.
  12. The Defendant neither admits nor denies allegations contained in paragraph 12 of the complaint.
  13. The Defendant neither admits nor denies allegations contained in paragraph 13 of the complaint.
  14. The Defendant neither admits nor denies allegations contained in paragraph 14 of the complaint.
  15. The Defendant neither admits nor denies allegations contained in paragraph 15 of the complaint.
  16. The Defendant admits allegations contained in paragraph 16 of the complaint to the extent that Plaintiff currently serves as Georgetown University’s Vice president for Diversity, Equity, Inclusion, and Chief Diversity Officer.
  17. The Defendant fully admits allegations contained in paragraph 17 of the complaint.
  18. The Defendant partially admits allegations contained in paragraph 18 of the complaint to the extent that Defendant lent Plaintiff $20,000 to assist in payment for Plaintiff’s son’s education.
  19. The Defendant denies allegations contained in paragraph 19 of the complaint.
  20. The Defendant denies allegations contained in paragraph 20 of the complaint.
  21. The Defendant admits allegations contained in paragraph 21 of the complaint.
  22. The Defendant partially admits allegations contained in paragraph 22 of the complaint to the extent that on the said date, Defendant wrote an email to Plaintiff’s son.
  23. The Defendant partially admits allegations contained in paragraph 23 of the complaint to the extent that on the said date, Defendant wrote to the Plaintiff requiring Plaintiff to make a commitment to honor her promise to pay Defendant.
  24. The Defendant partially admits allegations contained in paragraph 24 of the complaint to the extent that on the said date, Defendant wrote an email to Plaintiff’s son.
  25. The Defendant partially admits allegations contained in paragraph 25 of the complaint to the extent that on the said date, Defendant wrote an email to Plaintiff and Plaintiff’s son.
  26. The Defendant partially admits allegations contained in paragraph 26 of the complaint to the extent that on the said date, Defendant wrote an email to Plaintiff’s son.
  27. The Defendant partially admits allegations contained in paragraph 27 of the complaint to the extent that on the said date, Defendant wrote an email to Plaintiff’s son.
  28. The Defendant partially admits allegations contained in paragraph 28 of the complaint to the extent that on the said date, Defendant wrote an email to Plaintiff and Plaintiff’s son.
  29. The Defendant denies allegations contained in paragraph 29 of the complaint.
  30. The Defendant denies allegations contained in paragraph 30 of the complaint.
  31. The Defendant denies allegations contained in paragraph 31 of the complaint.
  32. The Defendant partially admits allegations contained in paragraph 32 of the complaint to the extent that on the said date, Defendant wrote an email to Plaintiff.
  33. The Defendant partially admits allegations contained in paragraph 33 of the complaint to the extent that on the said date, Defendant wrote an email to Plaintiff and Plaintiff’s son.
  34. The Defendant denies allegations contained in paragraph 34 of the complaint.
  35. The Defendant denies allegations contained in paragraph 35 of the complaint.
  36. The Defendant denies allegations contained in paragraph 36 of the complaint.
  37. The Defendant denies allegations contained in paragraph 37 of the complaint.
  38. The Defendant denies allegations contained in paragraph 38 of the complaint.
  39. The Defendant denies allegations contained in paragraph 39 of the complaint.
  40. The Defendant admits allegations contained in paragraph 40 of the complaint to the extent that on the said date, Defendant wrote an email to Georgetown University’s Vice President and General Counsel, Lisa Brown.  
  41. The Defendant admits allegations contained in paragraph 41 of the complaint.
  42. The Defendant denies allegations contained in paragraph 42 of the complaint.
  43. The Defendant denies allegations contained in paragraph 43 of the complaint.
  44. The Defendant denies allegations contained in paragraph 44 of the complaint.
  45. The Defendant denies allegations contained in paragraph 45 of the complaint.
  46. The Defendant denies allegations contained in paragraph 46 of the complaint.
  47. The Defendant denies allegations contained in paragraph 47 of the complaint.
  48. The Defendant denies allegations contained in paragraph 48 of the complaint.
  49. The Defendant denies allegations contained in paragraph 49 of the complaint.
  50. The Defendant denies allegations contained in paragraph 50 of the complaint.
  51. The Defendant denies allegations contained in paragraph 51 of the complaint.
  52. The Defendant denies allegations contained in paragraph 52 of the complaint.
  53. The Defendant denies allegations contained in paragraph 53 of the complaint.
  54. The Defendant denies allegations contained in paragraph 54 of the complaint.
  55. The Defendant denies allegations contained in paragraph 55 of the complaint.
  56. The Defendant denies allegations contained in paragraph 56 of the complaint.

 

AFFIRMATIVE DEFENSES

  1. Plaintiff’s complaint, paragraph 8 states: “Plaintiff now seeks a declaratory judgment that no agreement between the Parties was ever formed for Plaintiff to 1) pay any amount more than $20,000.00, or 2) to pay any amount whatsoever until she has retired. In paragraph 46, Plaintiff claims: “Plaintiff and Defendant never formed an agreement for Plaintiff to pay Defendant more than $20,000.00.” In the Prayer for Relief, item (a), Plaintiff requests this court to issue “a declaration that the parties never formed an agreement for Plaintiff to pay Defendant more than $20,000.00. 
  2. AFFIRMATIVE DEFENSES: Contrary to Plaintiff’s averments, the Note (Exhibit A) provided that the Plaintiff should pay more than $20,000.00. 

 

  1. The Note stated in this regard that, 

 

“… the undersigned (“Borrower”) promises to pay Sargent Communications, Inc. (SCI), (Note Holder), headquartered at … the sum of $20,000 (Twenty Thousand Dollars) plus whichever of these two investment proceeds is greater: a.) $58,000 (Fifty-eight Thousand Dollars) or b.) 55 (Fifty-five) percent of the Borrower’s annual College Retirement Equities Fund (CREF) investment growth as shall be reported in the December 31, 1999 Teacher’s Insurance and Annuity Association/College Retirement Equities Fund (TIAA/CREF) Quarterly Confirmation Transaction Report… “. (Emphasis Added). 

 

  1. Further, in the Addendum (No. 2) to the aforesaid Note, the Parties agreed that the investment funds were meant to accrue. (Exhibit C). The Addendum states expressly that, 

 

“It is agreed that Borrower/Investee intends for SCI’s investment funds to accrue in value at a ROI commensurate with stock market performance as reported in Borrower/Investee’s TIANCREF Annuity Benefits Report”.  

…

It is further agreed that the Note, as an investment instrument, represents an investment in Borrower’/Investee’s TIAA/CREF accounts in lieu of SCI’s making investments in other accessible stock plans, and shall provide a return on investment equal to 50 percent of the total investment growth for the CREF annuity account (CREF Account No. …) each year until such time as Borrower/Investee retires (or separates/terminates from working for Georgetown University”. (Emphasis Added). 

 

  1. AFFIRMATIVE DEFENSES: Contrary to Plaintiff’s averment that she should only pay the amount when she retires, the Addendum (No. 2) to the aforesaid Note provided otherwise. (Exhibit C). 

 

  1. Defendant maintains that there is no provision in the Note that supports Plaintiff’s averment. The Note provided two options for settlement of the debt. These are as follows:

 

“… It is further agreed that payment shall be made in full within 24 hours following Borrower/Investee’s retirement date OR on the first date that Borrower/Investee gains access to the TIAA/CREF funds, whichever date occurs first. …”. (Emphasis Added). 

 

The aforementioned provision resonates a similar provision in the Note (Exhibit A) to wit:

 

“… the indebtedness shall continue until such time as she is allowed to withdraw funds… The total indebtedness shall continue until the entire indebtedness evidenced by this Note is fully paid … “. (Emphasis Added). 

 

  1. It is Defendant’s contention that the Plaintiff already has an opportunity to gain access to the said TIAA/CREF funds. The CREF’s prospectus states in this regard that “… you can set up a program to make cash withdrawals or transfers automatically by specifying that we withdraw or transfer from an Account accumulation any fixed number of accumulation units, dollar amount or percentage of accumulation…”. (College Retirement Equities Fund, Rules of the Fund, 2020, page 63). It is also worth noting that CREF does not set a maximum limit for withdrawals. It only sets a minimum withdrawal amount. (Id.).

 

  1. Defendant further avers that in interpreting the said provisions from the Note and the Addendum (Note 2), this honorable court should look at the intent of the parties to the said agreements. The court in Greenfield v. Philles Records, Inc. held in this regard that, “The fundamental, neutral precept of contract interpretation is that agreements are construed in accord with the parties’ intent.” 98 N.Y.2d 562, 569 (2002). Accordingly, the Court should “attempt to fulfill, to the extent possible, the reasonable shared expectations of the parties at the time they contracted.” See Comrie v. Enterasys Networks, Inc., 837 A.2d 1, 13 (Del. Ch.2003). In doing so, the court should focus on the “entire contract and consider[ing] the relation of the parties and the circumstances under which it was executed … in the light of the obligation as a whole and the intention of the parties as manifested thereby.” Kass v. Kass, 91 N.Y.2d 554, 566, 673 N.Y.S.2d 350, 696 N.E.2d 174 [1998].

 

  1. The Court must avoid interpreting a contract in a manner that would be “absurd, commercially unreasonable, or contrary to the reasonable expectations of the parties.” Landmark Ventures, 2012 WL 3822624, at *3 (quoting In re Lipper Holdings, LLC, 766 N.Y.S.2d 561, 561 (1st Dep’t 2003)). An interpretation as suggested by the Plaintiff in this case would be precisely that Absurd.  It is a longstanding principle of law that a construction of a contract that would give one party an unfair and unreasonable advantage over the other, or that would place one party at the mercy of the other, should, if at all possible, be avoided. The Court must avoid interpreting a contract in a manner that would be “absurd, commercially unreasonable, or contrary to the reasonable expectations of the parties.” Id., at *3. It follows; the aforesaid provisions from the Note and the Addendum show that the Plaintiff has an opportunity to access the funds but failed to do so.

 

  1. AFFIRMATIVE DEFENSE: A live, valid, signed and notarized Agreement between the Parties does exist (Exhibit A, B, and C). The Agreement, as a matter of law and in accordance with standard contractual edicts (i.e., “pacta sunt servanda”), compels the Plaintiff to pay an amount that exceeds the $20,000 principal upon retirement. A valid/enforceable contract/agreement must satisfy all the elements of a contract namely: an offer, acceptance, and consideration. In the said Note and/or Addenda, all the elements are clearly traceable. For instance, Plaintiff promised to pay Defendant back (offer), the amount specified in the Note/Addenda (Consideration) under the terms of the said Agreements. Therefore, all the elements of a contract are satisfied in the aforesaid Agreements. It follows; Plaintiff is not entitled to her prayer that this honorable court declares no contract existed with the aforesaid terms. 
  2. Complaint paragraph 9 alleges “Defendant waived his right to payment by failing to accept payment of the debt prior to Plaintiff’s retirement” and if Plaintiff is somehow in breach of Defendant’s 1999 Agreement, that any such claim is barred by the statute of limitations.” Prayer for Relief, item (d), requests this court to issue a “declaration that any claim by Defendant that Plaintiff is somehow in breach of the 1999 Agreement is barred by the applicable statute of limitations.” 
  3. AFFIRMATIVE DEFENSES: The above statement and request are moot and not factual. The Defendant has not waived his right to receive the repayment. 

 

  1. The Agreement between Plaintiff and Defendant has not expired. The Addendum (No. 2) contains a provision regarding the term of the Agreement. It provides:

 

“The term of this Addendum is perpetual or until such time as all return on investment (ROI) funds as defined in the Note and in this Addendum have been transferred from the Borrower/Investee to the Note Holder”. (Emphasis Added). 

 

The Court should interpret the aforementioned provision to reveal the intent of the parties to keep the Agreement running until the Defendant obtains the accrued amount he stated in the Agreement. “The interpreting court must look beyond the language of the contract to ascertain the parties’ intentions” at time of drafting. In making such determination, the court may consider objective parol evidence, including the overt statements and acts of the parties, the business context, the parties’ prior dealings, and industry custom.’” Convergent Wealth Advisors LLC v. Lydian Holding Co. 2012 WL 2148221 S.D.N.Y.,2012, June 13, 2012.

 

Upon Defendant’s information and belief, Plaintiff has not made any attempt(s) to settle the debt per the terms of the Agreement. Therefore, Plaintiff’s obligation under the Agreement remains. 

 

  1. Plaintiff attempted to make an offer to pay only $20,000, contrary to the Agreement. 

 

Plaintiff avers that Defendant refused to accept payment from her, in settlement of her debt. However, Defendant avers that the said payment was in contradiction to the terms of the Parties’ Agreement. Notably, the Agreement provided that Defendant’s investment funds were to accrue in value at a ROI commensurate with stock market performance. (Exhibit C). Therefore, Defendant had a right to deny payment that contravened their Agreement. 

 

A correct interpretation to the Agreements would reveal the intent of the parties (at the time they entered the contract), that Plaintiff should settle a higher amount than the money lent. “The fundamental, neutral precept of contract interpretation is that agreements are construed in accord with the parties’ intent.” Hillside Metro Associates, LLC v. JPMorgan Chase Bank, Nat. Ass’n 2012 WL 1617157 E.D.N.Y.,2012. Accordingly, the Court’s interpretation should “attempt to fulfill, to the extent possible, the reasonable shared expectations of the parties at the time they contracted.” See Comrie v. Enterasys Networks, Inc., 837 A.2d 1, 13 (Del. Ch.2003). 

 

It would be absurd for the Court to hold that Plaintiff should only pay the $20,000 offered by Plaintiff. Accordingly, the Court must avoid interpreting a contract in a manner that would be “absurd, commercially unreasonable, or contrary to the reasonable expectations of the parties.”  Landmark Ventures, 2012 WL 3822624, at *3 (quoting In re Lipper Holdings, LLC, 766 N.Y.S.2d 561, 561 (1st Dep’t 2003)). 

  1. Defendant was justified from accepting Plaintiff’s offer to settle a lower amount than agreed. 

 

In this case, Plaintiff’s action of attempting to settle strictly $20,000 showed her unwillingness to perform her part of the Agreement. Therefore, Defendant had no obligation to accept the said payment because it would be contrary to what the parties agreed. It follows; the Agreement has not yet been breached since Defendant has not accepted the erroneous payment from the Plaintiff. The term of the Agreement has also not ceased. This means that Plaintiff still has the obligation to fulfill their part of the obligations. Accordingly, the statute of limitations has not begun to toll. 

 

  1. AFFIRMATIVE DEFENSES: The Agreement is between plaintiff and defendant’s company; thus, this case may be moot because it is founded in a careless, uniformed, errantly captioned filing by the plaintiff and her counsel. Defendant entered the Agreement as the representative of his corporation. Notably, the Note Holder is not the Defendant in his personal capacity, but Sargent Communications, Inc. which is a separate legal entity from Defendant. Defendant is willing to agree to re-caption the case to resolve the core issue issues in this case. 


COUNTER CLAIM

Defendant brings the following Counterclaim against the Plaintiff and alleges as follows: 

  1. This Court has jurisdiction pursuant to D.C. Code Section 11-921 and 28 U.S.C. Section 2202.
  2. Venue is proper in this Court pursuant to D.C. Code Ann. Section 13-423.  

 

CLAIM 1: SPECIFIC PERFORMANCE OF CONTRACT

  1. Defendant incorporates by reference Paragraphs 1-28 above.
  2. The Agreement between Plaintiff and Defendant remains as evidenced by the Note and the Addenda. (Exhibits A, B, and C). The Plaintiff has not yet fulfilled her obligation under the said Agreement. Plaintiff has a duty to settle her debt per the provisions of the Agreement. 
  3. Therefore, Defendant seeks an order of specific performance to make the Plaintiff enforce the Agreement accordingly. 

 

CLAIM 2: DECLARATORY JUDGMENT

  1.  Defendant incorporates by reference Paragraphs 1-28 above.
  2. This matter before this honorable court creates an actual controversy that places the parties in a position of uncertainty as to their respective rights in the Agreement.
  3. Defendant has no remedy other than declaratory judgment that could adequately protect his right in the Agreement. A declaratory judgment is necessary to declare that the Plaintiff honor her obligation and settle the debt with its accruals per the terms of the Agreement and to relieve any uncertainty as to the status of their rights and obligations under the Agreement. 

 

CLAIM 3: PUNITIVE OR EXEMPLARY DAMAGES AGAINST PLAINTIFF

  1. Defendant incorporates by reference Paragraphs 1-28 above.
  2. The actions or omissions of the Plaintiff demonstrate malice or aggravated egregious fraud toward or against Defendant. It follows; her Complaint is frivolous. 
  3. Defendant is thereby entitled to an award of punitive or exemplary damages, including costs and fees, against Plaintiff.   

 

PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully prays that this Court do the following:

  1. That this honorable Court dismiss Plaintiff’s Complaint with prejudice. 
  2. That this honorable Court declare that the allegations of Plaintiff’s Complaint do not set forth sufficient facts to show that it is entitled to a declaratory judgment.
  3. That this honorable Court enter an order for specific performance in favor of Defendant. 
  4. That this honorable Court enter declaratory judgment that Defendant is entitled to receive the amount lent plus the investment proceeds. 
  5. That this honorable Court enter an order awarding Defendant punitive damages for Plaintiff’s unfair, deceptive, and unconscionable conduct.
  6. Award fees and litigation expenses to Defendant.
  7. Award such other and further relief as the Court deems just and proper.

 

Respectfully Submitted,

 

Edward D. Sargent
Pro se
1820 Clydesdale Pl. NW #203
WDC 20009

 

CERTIFICATE OF SERVICE

Defendant affirms under penalties of perjury that a copy of the above response was served upon the Plaintiff to this action by electronic and/or U.S. mail to her respective address as stated below:

 

Martinis M. Jackson

Jackson Legal Services PLLC

1629 K Street NW, Suite 300

Washington, D.C. 20006

Telephone: (301) 631-4964

Facsimile: (301) 851-6019

Martinis.jackson@jlegalservices.com

 

Dated: 

 

Edward D. Sargent
Pro se
1820 Clydesdale Pl. NW #203
WDC 20009

 

 

ADDENDUM

EXHIBIT A

 

EXHIBIT B

 

EXHIBIT C

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