IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION

District of Columbia :
:
Plaintiff, :
: Civil Case No. 2019 CA 004144 B
v :
:
Curtis Investment Group, Inc. :
:
Defendant. :
:
____________________________________:

ANSWER TO THE COMPLAINT

Defendant, Curtis Investment Group, Inc., by and through the undersigned, answers the

Complaint as follows:

1. Paragraph 1 states an opinion to which Defendant is under no obligation to admit

or deny.

2. Defendant denies the allegations of paragraph 2.

3. Paragraph 3 states legal conclusions to which Defendant is under no obligation to

admit or deny. To the extent there are any factual allegations in paragraph 3, they are denied.

4. Paragraph 4 states no allegations of fact and therefore no response is necessary.

5. Paragraph 5 states no allegations of fact and therefore no response is necessary.

6. Paragraph 6 states legal conclusions to which Defendant is under no obligation to

admit or deny.

7. Defendant denies the allegations of paragraph 7.

8. Paragraph 8 states no allegations of fact and therefore no response is necessary.

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 9. Defendant admits it is a real estate company with its principal place of business in

the State of Maryland. Defendant denies the balance of the averments contained in paragraph 9.

10. Paragraph 10 states no allegations of fact and therefore no response is necessary.

11. Paragraph 11 states no allegations of fact and therefore no response is necessary.

12. Paragraph 12 states no allegations of fact and therefore no response is necessary.

13. Paragraph 13 states an opinion and no allegations of fact and therefore no

response is necessary.

14. Paragraph 14 states an opinion and no allegations of fact and therefore no

response is necessary.

15. Paragraph 15 states an opinion and no allegations of fact and therefore no

response is necessary.

16. Paragraph 16 states an opinion and no allegations of fact and therefore no

response is necessary.

17. Defendant is not the legal / title owner of any residential properties in DC and

therefore cannot “offer” any residential leases.

18. Admitted.

19. Admitted.

20. Defendant admits an apartments.com link is on its website but is without

sufficient information to admit or deny the balance of the averments of paragraph 20 and

therefore they are denied.

21. Defendant is without sufficient information to admit or deny the averments of

paragraph 21 and therefore they are denied.

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 22. The averments of paragraph 22 are denied.

23. Defendant is without sufficient information to admit or deny the averments of

paragraph 23 and therefore they are denied.

24. Admitted.

25. Admitted.

26. Defendant admits to having an apartments.com link on its website but is without

sufficient information to admit or deny the balance of the averments of paragraph 26 and

therefore they are denied.

27. Defendant is without sufficient information to admit or deny the averments of

paragraph 27 and therefore they are denied.

28. Defendant is without sufficient information to admit or deny the averments of

paragraph 28 and therefore they are denied.

29. Defendant is without sufficient information to admit or deny the averments of

paragraph 29 and therefore they are denied.

30. Defendant is without sufficient information to admit or deny the averments of

paragraph 30 and therefore they are denied.

31. The Answers contained in paragraphs 1 through 30 are incorporated herein.

32. The laws of the District of Columbia speak for themselves and require no

response.

33. The laws of the District of Columbia speak for themselves and require no

response.

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 34. The laws of the District of Columbia speak for themselves and require no

response.

35. Paragraph 35 states a legal conclusion to which Defendant is under no obligation

to admit or deny. To the extent there are any factual allegations in paragraph 35, they are denied.

36. Paragraph 36 states a legal conclusion to which Defendant is under no obligation

to admit or deny. To the extent there are any factual allegations in paragraph 36, they are denied.

Any factual allegation in the Complaint not specifically admitted is hereby denied.

Defendant demands strict proof of each and every allegation contained in the Complaint.

WHEREFORE, Defendant respectfully requests that the Complaint be dismissed with

prejudice, together with attorney's fees and costs, and for such other and further relief as this

cause may require.

AFFIRMATIVE DEFENSES

1. The Complaint fails to state a cause of action upon which relief can be granted.

2. The Court lacks personal jurisdiction over Defendant.

3. The Court lacks subject matter jurisdiction over this matter.

4. The Complaint is barred by estoppel.

5. The Complaint is barred by collateral estoppel.

6. The Complaint is barred by res judicata.

7. The Complaint is barred by fraud.

8. Plaintiff has failed to join proper and indispensable parties.

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 9. Plaintiff has failed to properly disseminate and administer subsidized voucher

programs.

Defendant reserves the right to assert additional defenses as more information is disclosed.

Respectfully submitted,
LAW OFFICE OF ALYSSA W. CHANG, LLC

/s/ Alyssa W. Chang

Alyssa W. Chang
Bar No. 456031
19214 Forest Brook Road
Germantown, Maryland 20874
(301) 353-0081
alyssachang@msn.com

Certificate of Service
The undersigned hereby certify that a copy of the foregoing Answer was served via file
and serve on this 18th day of July, 2019 on Michael A. Tilghman, II, Esq. and Vikram Swaruup,
441 Fourth Street, NW, Suite 600 South, Washington, D.C. 20001.

/s/ Alyssa W. Chang