Affidavit of Young Mi Kim
I, Young Mi Kim, of [Insert Address] do hereby swear under oath that:
I am a law-abiding male adult citizen of sound mind.
The Plaintiff leased out a condo to me.
The unit I was living in caught fire on 07/14/2017. After it was extinguished, I suffered flood damage. I was forced to live in that unhabitable unit due to the Plaintiff’s failure to conduct the necessary repairs on time. I had to completely cover the window of my unit to block noise from construction outside.
Restoration of the unit began a year later on 08/18/2018 and went on for 60 days. During that period, I was forced to seek alternative housing which turned out to be expensive.
All this while I was paying rent in full to the Plaintiff dutifully without fail.
When I returned after 60 days, the unit was still uninhabitable. It had no hot water, oven, toilet bowl, or living space.
The Plaintiff informed me that construction would be complete in 10 days, after which everything would be fine.
I asked my younger brother to store some household valuables for me so I could resume work.
When the Plaintiff completed construction, the unit was still uninhabitable. It had a rusty refrigerator, exposed wires next to the sink, broken screen window, and faulty toilet and kitchen lights.
On 01/06/2019, the Plaintiff informed me that there was 5 days’ unpaid rent.
On 01/15/2019, the Plaintiff informed me that I was in violation of the rental agreement due to nonpayment of rent for 10 days.
On 01/19/2019, the Plaintiff informed me that an eviction notice had been filed against me with cause.
The Plaintiff wrongly stated that my younger brother was an illegal occupant in the unit. He knew my younger brother and knew that he was only looking after my belongings while I was away working. It is therefore untenable for him to state that my brother was in the unit unlawfully.
The Plaintiff’s failure to repair the unit despite multiple requests from me amounts to breach of contract on the part of the Plaintiff.
The Plaintiff wrongly increased rent by $50.00 without providing any substantial reason.
The fire that occurred on 07/14/2017 was declared a federal disaster and different organizations made donations.
I hereby request this Court to order the Plaintiff to avail discovery information as well as documentation to me.
Under penalty of perjury, I hereby declare and affirm that the above stated facts, to the best of my knowledge and belief, are true and correct.
Dated this 10th day of March, 2022.
Respectfully Submitted,
___________________________________
Young Mi Kim
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