because the Notice was purportedly mailed 60 days before expiration of the lease.
Respondent also claims that Petitioner is not the Landlord/Owner as alleged in the
Notice.
(7) The Seventh Affirmative Defense states that the July 2018 Notice is also defective
because the sections of the ETPA allegedly violated by Respondent are not set forth.
(8) The Eighth Affirmative Defense asserts that the July 2018 Notice is further defective
because the Notice cannot be signed by Allen Prince, as manager, on behalf of the Petitioner. It is
further contended that the attorney cannot sign the Notice.
(9) The Ninth Affirmative Defense attacks the November 2018 Termination Notice because
it fails to recite details to sustain the Notice's validity, including time periods of nonprimary
occupancy. Respondent asserts that the 2018 Notice is confusing because it does not state that it
supersedes the July 2018 Notice.
(10) The Tenth Affirmative Defense concludes that the November 2018 Notice is defective
because Petitioner is not the owner of the premises which is owned by another entity.
(11) The Eleventh Affirmative Defense claims that the November 2018 Notice is defective
because it fails to specify the ETPA sections relied upon.
(12) The Twelfth Affirmative Defense asserts the November 2018 Notice is defective
because it is improperly signed by Allen Prince as manager for Petitioner as the Landlord/Owner.
Also, the attorney cannot properly sign the Termination Notice.
(13) The Thirteenth Affirmative Defense states that Petitioner admits that it created a new
tenancy with Respondent by accepting the rent for the months of October 2018, November 2018,
December 2018, and for January 2019. Therefore, Petitioner was required to provide Respondent
with a stabilized renewal lease.