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Argued December 7, 2010

Before OBERLY, Associate Judge, KRAMER,*fn1 Associate Judge, Retired, and FARRELL, Senior Judge.

Lanier Associates (Lanier) filed a possession action against appellant Mary Graham alleging nonpayment of rent after Lanier conditionally increased Graham’s rent pursuant to a pending hardship petition. Graham defended on the grounds that the hardship petition was flawed, housing code violations reduced the value of her rental unit, and the action was in retaliation for her participation in the building’s tenants’ association.

 
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