"1", Resident Profile) Tenant also agreed to pay the costs incurred by Landlord for utilities
supplied to her apartment (Pet. "5", §3). Pursuant to section 3 of the lease, Tenant may also
be required to pay other charges to Landlord such as attorney's fees and late fees as Added Rent.
Landlord maintains a Resident Profile for tenant that is updated daily. (Pet. "1") It
includes the Tenant's rent and utility charges and payment history. Lourdes Alicea, the property
manager, testified the Tenant's Resident Profile showed a balance of $4555.68 as of the trial.
This balance includes rent, utilities, late fees and legal fees.
Ms. Alicea testified that she spoke to Tenant in October 2009 about the possible
termination of the housing subsidy because she was not current with her rent. Tenant asked her
to provide a statement that she did not owe Landlord any money so she could give it to the
Public Housing Agency ("PHA"). Ms. Alicea was hesitant to provide the letter but agreed to do
so if Tenant paid $2884.00 and paid the remaining balance of $1874.00 in biweekly $100.00
[*3]installments. This payment agreement was signed by Tenant,
who also agreed not to dispute owing the balance contained therein. (Pet. "4"). As agreed, Ms.
Alicea wrote a letter verifying Tenant was "up to date with her rent and utilities as of October
2009." (Res. "A")[FN3] Ms.
Alicea testified the $1874 balance included rent, utilities and late charges.
When Tenant allegedly failed to make rent payments after November 2, 2009, Ms.
Alicea directed Landlord's counsel to prepare and serve a three day demand for rent on Tenant.
(Pet. "3"). The demand requested payment of $4819.52, representing rent and additional rent, on