Vermont Tenant's Answer to Eviction Complaint with Affirmative Defenses, Counterclaims, and Jury Demand

TENANT'S ANSWER, AFFIRMATIVE DEFENSES, COUNTERCLAIMS, AND JURY DEMAND — VERMONT

TABLE OF CONTENTS

1. Caption
2. General Response to Plaintiff's Allegations
3. Paragraph-by-Paragraph Response
4. Affirmative Defenses
5. Counterclaims
6. Prayer for Relief
7. Demand for Trial by Jury
8. Reservation of Rights and Defenses
9. Signature Block
10. Verification (if required)
11. Certificate of Service
12. Vermont Practice Notes for Tenants
13. Sources and References

1. CAPTION

STATE OF VERMONT

SUPERIOR COURT, CIVIL DIVISION

[COUNTY] UNIT

Docket No. [________________________________]

TENANT'S ANSWER, AFFIRMATIVE DEFENSES, COUNTERCLAIMS, AND JURY DEMAND

NOW COMES Defendant [TENANT'S FULL LEGAL NAME] ("Tenant"), by and through undersigned counsel [OR pro se], and for Tenant's Answer, Affirmative Defenses, Counterclaims, and Jury Demand, states as follows:

2. GENERAL RESPONSE TO PLAINTIFF'S ALLEGATIONS

Except as expressly admitted, modified, or qualified herein, Tenant DENIES each and every allegation contained in Plaintiff's Complaint and demands strict proof at trial. Tenant denies that Plaintiff is entitled to any of the relief requested.

3. PARAGRAPH-BY-PARAGRAPH RESPONSE

3.1. As to paragraph 2.1 of the Complaint (Plaintiff): [Admitted / Denied / Tenant lacks knowledge or information sufficient to form a belief and therefore denies].

3.2. As to paragraph 2.2 (Tenant): [Admit identity of Defendant; otherwise denied].

3.3. As to paragraph 2.3 (Other Occupants): [Admit / Deny / Lack of information].

3.4. As to paragraph 2.4 (Subject-matter jurisdiction): Admitted.

3.5. As to paragraph 2.5 (Venue): Admitted, without conceding that any termination notice was properly served or sufficient.

3.6. As to paragraph 3.1 (Premises): Admitted.

3.7. As to paragraph 3.2 (Rental Agreement): [Admit existence of [written/oral] rental agreement; deny any characterization not supported by the document attached as Exhibit A].

3.8. As to paragraph 3.3 (Rent): [Admit / Deny / Qualify — e.g., "admit contractual rent of $X but deny that any rent is currently due in light of habitability abatement"].

3.9. As to paragraph 3.4 (Continuous Tenancy): [Admit / Deny].

3.10. As to paragraph 3.5 (Security Deposit): Admit Tenant tendered a security deposit of $ [________]; deny that Plaintiff has accounted for the deposit or returned it as required by 9 V.S.A. § 4461.

3.11. As to paragraph 4.1 (Termination Notice): [Deny — the asserted notice was defective for the reasons set forth in the Affirmative Defenses below; OR: admit a notice was received but deny it complied with 9 V.S.A. § 4467].

3.12. As to paragraph 4.2 (Statutory basis): Denied. The notice was defective on its face and/or failed to satisfy the statutory minimum.

3.13. As to paragraph 4.3 (Service): [Admit / Deny — describe defects in service or in computation of "actual notice"].

3.14. As to paragraph 4.4 (Specifically stated termination date): [Deny — the date stated does not satisfy the statutory minimum / the date is missing or ambiguous].

3.15. As to paragraph 4.5 (Failure to vacate): [Admit Tenant remains in possession; deny that Tenant has any obligation to vacate based on the defective notice].

3.16. As to paragraph 4.6 (Conditions precedent): Denied.

3.17. As to all paragraphs of Count I (Nonpayment): [Deny — habitability abatement, security deposit setoff, or other defenses reduce or extinguish any alleged arrears].

3.18. As to all paragraphs of Count II (Material Breach): [Deny — no breach occurred / cure was timely tendered / conduct does not constitute material noncompliance].

3.19. As to all paragraphs of Count III (No-Cause): [Deny — notice was retaliatory / discriminatory / defective / barred by Burlington Just Cause Charter Amendment].

3.20. As to all paragraphs of Count IV (Holdover): [Deny — Lease was renewed by operation of law / Plaintiff accepted rent post-expiration thereby creating new month-to-month tenancy / notice was defective].

3.21. As to the Prayer for Relief: Denied in all respects.

3.22. All other allegations of Plaintiff's Complaint not specifically admitted herein are DENIED.

4. AFFIRMATIVE DEFENSES

Tenant asserts the following Affirmative Defenses without conceding the burden of proof on any matter as to which Plaintiff bears that burden:

FIRST AFFIRMATIVE DEFENSE — Defective Termination Notice (9 V.S.A. § 4467)

The termination notice on which Plaintiff relies fails to satisfy 9 V.S.A. § 4467 because [select all that apply]: (a) it does not specifically state the termination date; (b) the termination date is fewer days from the date of "actual notice" than the statute requires for the basis asserted; (c) it fails to identify the specific breach with sufficient particularity; (d) it cites the wrong statutory subsection; (e) it was not delivered in a manner constituting actual notice; or (f) other: [describe]. Vermont courts strictly construe termination notices, and a defective notice bars the present action.

SECOND AFFIRMATIVE DEFENSE — Breach of Implied Warranty of Habitability (9 V.S.A. §§ 4457, 4458)

Plaintiff has breached the implied warranty of habitability codified at 9 V.S.A. § 4457 by failing to deliver and maintain premises that are safe, clean, and fit for human habitation in compliance with applicable building, housing, and health regulations, including without limitation [describe defects — e.g., heat failure, mold, vermin, water intrusion, lead, code violations]. Tenant gave Plaintiff written notice of the conditions on [__/__/____], and Plaintiff failed to repair within a reasonable time. Pursuant to 9 V.S.A. § 4458, Tenant is entitled to rent abatement and other remedies, which extinguish or reduce any alleged rent arrears and bar termination based on nonpayment.

THIRD AFFIRMATIVE DEFENSE — Repair-and-Deduct (9 V.S.A. § 4459)

Tenant lawfully repaired minor defects after providing 30 days' written notice and deducted the costs from rent up to one-half of one month's rent, as authorized by 9 V.S.A. § 4459, as itemized in Counterclaim Exhibit [__].

FOURTH AFFIRMATIVE DEFENSE — Retaliation (9 V.S.A. § 4465)

Plaintiff's termination was issued in retaliation for Tenant's [complaint to a government agency / membership in a tenant organization / good-faith assertion of rights under 9 V.S.A. ch. 137] on or about [__/__/____]. Because the termination was initiated within 90 days of a government compliance notice or Tenant complaint, a rebuttable presumption of retaliation arises under 9 V.S.A. § 4465, and Plaintiff cannot rebut it.

FIFTH AFFIRMATIVE DEFENSE — Discrimination (9 V.S.A. § 4503; Federal Fair Housing Act; VAWA)

The termination is unlawfully motivated, in whole or in part, by Tenant's status as a member of a protected class under the Vermont Fair Housing Act, 9 V.S.A. § 4503 (including but not limited to race, color, religion, sex, sexual orientation, gender identity, age, marital status, national origin, disability, presence of minor children, receipt of public assistance, source of income, or status as a victim of abuse/sexual assault/stalking), the federal Fair Housing Act, 42 U.S.C. § 3601 et seq., and/or the Violence Against Women Act, 34 U.S.C. § 12491. Specifically: [describe — e.g., disparate-treatment evidence, refusal to accept Section 8 voucher (source-of-income discrimination), refusal to provide reasonable accommodation, etc.].

SIXTH AFFIRMATIVE DEFENSE — Security-Deposit Setoff (9 V.S.A. § 4461)

Plaintiff holds Tenant's security deposit of $ [________] without lawful retention basis. Pursuant to 9 V.S.A. § 4461, Plaintiff must return any unearned portion within 14 days after discovering Tenant has vacated; willful failure exposes Plaintiff to forfeiture of all deductions, double damages, and attorney's fees. Tenant is entitled to setoff against any rent allegedly owed.

SEVENTH AFFIRMATIVE DEFENSE — Self-Help Eviction Bar (9 V.S.A. §§ 4463, 4464)

Plaintiff engaged in unlawful self-help by [describe — e.g., changing locks, removing belongings, shutting off utilities, denying access to the Premises] on [__/__/____] outside the proper court process under 12 V.S.A. ch. 169. Such conduct violates 9 V.S.A. § 4463 and entitles Tenant to damages, costs, and attorney's fees under 9 V.S.A. § 4464.

EIGHTH AFFIRMATIVE DEFENSE — Improper Acceptance of Rent / Waiver

Plaintiff accepted rent from Tenant after issuance of the termination notice and/or after the stated termination date, thereby creating a new rental period and waiving the prior termination as a matter of law and equity.

NINTH AFFIRMATIVE DEFENSE — Failure to Mitigate

To the extent any damages are awardable, Plaintiff failed to mitigate damages by failing to make reasonable efforts to re-rent the Premises after any actual or claimed termination.

TENTH AFFIRMATIVE DEFENSE — Burlington Just Cause Eviction Charter Amendment

The Premises are located in the City of Burlington. The Burlington Just Cause Eviction Charter Amendment (and any related municipal ordinance) is in force at the time of this action and bars Plaintiff's facially no-cause termination because the asserted basis is not an enumerated municipal ground and/or Plaintiff has failed to comply with municipal procedural prerequisites.

ELEVENTH AFFIRMATIVE DEFENSE — Statute of Limitations / Stale Notice

The termination notice on which Plaintiff relies is stale; Plaintiff failed to commence this action within a reasonable time after the asserted termination date and has thereby waived or forfeited the basis pleaded.

TWELFTH AFFIRMATIVE DEFENSE — Equitable Estoppel / Course of Dealing

Plaintiff is estopped from asserting the alleged breach by [course-of-dealing / written representation / oral assurance] on [__/__/____] that [Plaintiff would not enforce / Plaintiff accepted Tenant's conduct / Plaintiff would correct conditions].

THIRTEENTH AFFIRMATIVE DEFENSE — Unclean Hands

Plaintiff comes to this Court with unclean hands by reason of [describe — e.g., fair-housing violation, prior self-help, retaliation, breach of warranty] and is barred from equitable relief.

FOURTEENTH AFFIRMATIVE DEFENSE — Reasonable Accommodation Owed (Federal FHA / ADA / 9 V.S.A. § 4503)

Tenant is a person with a disability and requested a reasonable accommodation on [__/__/____], which Plaintiff unlawfully denied. The accommodation, if granted, would have eliminated the asserted basis for termination.

FIFTEENTH AFFIRMATIVE DEFENSE — Subsidized-Housing Good-Cause Defense

The tenancy is governed by [Section 8 Housing Choice Voucher / Public Housing / Section 8 Project-Based / LIHTC / RD-515 / Other] program, which requires "good cause" termination and HUD-form notice compliance. Plaintiff has failed to plead and prove such good cause and to comply with applicable program notice requirements (e.g., 24 C.F.R. Part 247).

SIXTEENTH AFFIRMATIVE DEFENSE — VAWA Protection

Tenant is a victim of domestic violence, sexual assault, dating violence, or stalking and is entitled to protections under VAWA (34 U.S.C. § 12491) and 9 V.S.A. §§ 4471–4475, which bar termination based on incidents of abuse and require lease bifurcation rather than eviction.

SEVENTEENTH AFFIRMATIVE DEFENSE — Reservation of Additional Defenses

Tenant reserves the right to assert any additional defenses that may become known through discovery, including all defenses available under V.R.C.P. 8(c).

5. COUNTERCLAIMS

Tenant, by way of Counterclaim against Plaintiff, alleges and says:

5.1. Parties and Jurisdiction (incorporated)

Counterclaim Plaintiff (Tenant) is the same Defendant identified above. Counterclaim Defendant (Landlord) is the same Plaintiff identified above. The Court has subject-matter jurisdiction over these counterclaims under 4 V.S.A. § 30 and supplemental jurisdiction over them under V.R.C.P. 13.

5.2. COUNT ONE — Breach of Implied Warranty of Habitability (9 V.S.A. §§ 4457, 4458)

Landlord materially breached the implied warranty of habitability by [describe defective conditions, dates of notice, lack of repair, periods of impairment]. Tenant suffered damages including but not limited to rent abatement, replacement-housing costs, personal-property damage, mental-anguish damages, and out-of-pocket expenses. Tenant is entitled to recover damages, equitable abatement of rent for the period of impairment, costs, and attorney's fees.

5.3. COUNT TWO — Illegal Eviction / Self-Help (9 V.S.A. §§ 4463, 4464)

Landlord engaged in unlawful self-help eviction by [describe — lockout, utility shutoff, removal of belongings, denial of access] on [__/__/____], in violation of 9 V.S.A. § 4463. Tenant is entitled to actual damages, equitable relief, costs, attorney's fees, and (where authorized) treble damages under 9 V.S.A. § 4464.

5.4. COUNT THREE — Retaliation (9 V.S.A. § 4465)

Landlord's termination, rent increase, or other adverse action was issued in retaliation for Tenant's lawful complaints, organization, or assertion of rights under 9 V.S.A. ch. 137, within 90 days of such protected activity. The rebuttable presumption of retaliation under § 4465 applies. Tenant is entitled to damages, costs, and attorney's fees.

5.5. COUNT FOUR — Violation of Vermont Fair Housing Act (9 V.S.A. § 4503)

Landlord violated 9 V.S.A. § 4503 by [describe — disparate treatment, refusal to accept Section 8 voucher (source-of-income discrimination), refusal to grant reasonable accommodation, gender-identity / sexual-orientation discrimination, etc.]. Tenant is entitled to damages, equitable relief, civil penalties, costs, and attorney's fees.

5.6. COUNT FIVE — Violation of Federal Fair Housing Act (42 U.S.C. § 3604)

Landlord violated the federal Fair Housing Act by [describe], entitling Tenant to actual and punitive damages, costs, and attorney's fees under 42 U.S.C. § 3613.

5.7. COUNT SIX — Failure to Return Security Deposit (9 V.S.A. § 4461)

Upon Tenant's vacation (or upon any judgment of possession), Landlord must return any unearned portion of Tenant's security deposit, with itemized statement of deductions, within 14 days. Landlord's willful failure to do so entitles Tenant to forfeiture of all deductions, double damages, costs, and attorney's fees.

5.8. COUNT SEVEN — Repair-and-Deduct (9 V.S.A. § 4459)

Tenant lawfully invoked repair-and-deduct by giving 30 days' written notice and incurring $ [________] in repair costs that Landlord refused to undertake. Tenant is entitled to credit and any further damages.

5.9. COUNT EIGHT — Violation of VAWA / Vermont Abuse-Survivor Provisions (34 U.S.C. § 12491; 9 V.S.A. §§ 4471–4475)

[As applicable] Landlord's adverse action against Tenant was based, in whole or in part, on incidents of domestic violence, sexual assault, dating violence, or stalking, in violation of VAWA and Vermont law. Tenant is entitled to damages, equitable relief, costs, and attorney's fees.

5.10. COUNT NINE — Burlington Just Cause Violation (Conditional)

[Where Burlington Just Cause Charter Amendment is in force.] Landlord's facially no-cause termination violates the Burlington Just Cause Eviction Charter Amendment and any implementing municipal ordinance. Tenant is entitled to dismissal of the eviction action, damages, costs, and attorney's fees authorized by municipal law.

5.11. RESERVATION

Tenant reserves the right to amend these Counterclaims under V.R.C.P. 15 as additional facts develop in discovery.

6. PRAYER FOR RELIEF

WHEREFORE, Tenant respectfully prays that this Court:

A. Dismiss Plaintiff's Complaint with prejudice;

B. Enter judgment for Tenant on each Affirmative Defense pleaded;

C. Enter judgment for Tenant on each Counterclaim pleaded;

D. Award Tenant compensatory damages in an amount to be proven at trial;

E. Award Tenant rent abatement under 9 V.S.A. §§ 4457, 4458 for the period of impaired habitability;

F. Award Tenant statutory double damages and forfeiture under 9 V.S.A. § 4461 for willful failure to return the security deposit;

G. Award Tenant treble damages where authorized by 9 V.S.A. § 4464 for self-help eviction;

H. Award Tenant statutory damages and equitable relief under 9 V.S.A. § 4465 (retaliation) and 9 V.S.A. § 4503 (Vermont Fair Housing Act);

I. Award Tenant actual and punitive damages under 42 U.S.C. § 3613 (federal FHA) and VAWA, 34 U.S.C. § 12491, where applicable;

J. Award Tenant costs of suit and reasonable attorney's fees as authorized by statute or contract;

K. Where applicable, order Plaintiff to perform necessary repairs to bring the Premises into compliance with 9 V.S.A. § 4457;

L. Where applicable, set or modify any rent escrow order under 12 V.S.A. § 4853a to credit habitability abatement and minimize Tenant's exposure;

M. Grant Tenant such other and further relief as the Court deems just and equitable.

7. DEMAND FOR TRIAL BY JURY

Pursuant to 12 V.S.A. § 4852, V.R.C.P. 38, and the Vermont Constitution, Tenant DEMANDS A TRIAL BY JURY on all issues so triable, including all Affirmative Defenses and Counterclaims.

8. RESERVATION OF RIGHTS AND DEFENSES

Tenant expressly reserves: (a) the right to amend this Answer to assert additional affirmative defenses or counterclaims as facts develop (V.R.C.P. 15); (b) the right to invoke the one-time-per-12-months cure under 12 V.S.A. § 4773 by paying into court all rent due plus interest and costs before writ execution; (c) the right to seek a stay or supersedeas pending appeal under V.R.A.P. 4 and 8; (d) the right to seek any reasonable accommodation under federal and state disability law; and (e) any and all other rights and remedies available at law or in equity.

9. SIGNATURE BLOCK

DATED at [CITY], Vermont, this [__] day of [MONTH], [YEAR].

[TENANT'S NAME]

[ ] Pro se / [ ] By their attorneys

___________________________________

[ATTORNEY NAME], Esq. (if represented)

Vermont Bar No. [____]

[FIRM NAME]

[ADDRESS, CITY, STATE, ZIP]

Telephone: [PHONE]

Email: [EMAIL]

(Counsel for Defendant / Tenant)

10. VERIFICATION (if required)

STATE OF VERMONT

COUNTY OF [__________], ss.

I, [TENANT NAME], having been duly sworn, depose and say:

10.1. I am the Defendant in the above-captioned action and have personal knowledge of the matters set forth in the foregoing Answer, Affirmative Defenses, and Counterclaims;

10.2. The facts alleged are true to my own knowledge, except as to those alleged on information and belief, and as to those, I believe them to be true.

___________________________________

[TENANT NAME]

Subscribed and sworn to before me on this [__] day of [MONTH], [YEAR].

___________________________________

Notary Public / Vermont Attorney

My commission expires: [__/__/____]

11. CERTIFICATE OF SERVICE

I certify that on [__/__/____], I served a true copy of the foregoing TENANT'S ANSWER, AFFIRMATIVE DEFENSES, COUNTERCLAIMS, AND JURY DEMAND on Plaintiff's counsel of record by:

☐ Vermont Judiciary Electronic Filing System (Odyssey File & Serve), to the email address(es) of record;

☐ Personal delivery to [ATTORNEY / ADDRESS];

☐ U.S. First-Class Mail, postage prepaid, to [ATTORNEY / ADDRESS];

☐ Email to [EMAIL] with consent to email service per V.R.C.P. 5;

☐ Other: [describe].

___________________________________

[NAME / TITLE]

12. VERMONT PRACTICE NOTES FOR TENANTS

12.1. Get an attorney now. Vermont eviction cases move quickly, and habitability/retaliation/discrimination defenses are fact-intensive. Vermont Legal Aid (1-800-889-2047), Legal Services Vermont, the Vermont Tenants Project at CVOEO (1-800-287-7971), and South Royalton Legal Clinic provide free or low-cost help to income-eligible tenants. Local pro bono panels and the Vermont Bar Association lawyer-referral service may also help.

12.2. 21-day deadline. V.R.C.P. 12(a) requires a written Answer within 21 days after service. Filing late risks default judgment for Plaintiff. If you missed the deadline, a Motion to Set Aside Default under V.R.C.P. 55(c) and 60(b) is essential and should be filed immediately.

12.3. Habitability documentation. Photographs, dated written notices to Landlord, code-enforcement reports, doctor's notes (e.g., for mold-related illness), and contemporaneous text messages dramatically strengthen a habitability defense and counterclaim.

12.4. Rent escrow. If Landlord moves under 12 V.S.A. § 4853a for an order requiring Tenant to pay accruing rent into court, attend the hearing prepared with habitability evidence and request that the court order partial payment reflecting abatement, OR that the court withhold an escrow order entirely. Failure to comply with a § 4853a order entitles Landlord to immediate judgment for possession.

12.5. One-time-per-12-months cure. In nonpayment cases, even after judgment but before writ execution, Tenant may pay into court all rent due through the end of the current rental period plus interest and costs and stop the action — but only ONCE in any 12-month period (12 V.S.A. § 4773). Use carefully.

12.6. Writ of possession 14-day rule. The sheriff cannot execute the writ earlier than 14 days after serving it on Tenant (12 V.S.A. § 4854). Plan replacement housing, ask the Court for a stay where appropriate, and consider whether a § 4854a 15-day property hold applies.

12.7. Self-help is illegal. If Landlord locks you out, removes your belongings, or shuts off utilities outside court process, that violates 9 V.S.A. § 4463; you can seek emergency injunctive relief, damages, costs, attorney fees, and (where authorized) treble damages under 9 V.S.A. § 4464. Call police and counsel immediately.

12.8. Retaliation window. If you complained to a code-enforcement or government agency in the 90 days before the termination notice, or organized with other tenants, the rebuttable presumption of retaliation under 9 V.S.A. § 4465 may shift the evidentiary burden to Landlord.

12.9. Discrimination. Vermont's Fair Housing Act protects more classes than federal law, including source of income (Section 8 vouchers and other public assistance), sexual orientation, gender identity, age, marital status, presence of minor children, and victims of abuse/sexual assault/stalking. Refusal to accept a Section 8 voucher is unlawful source-of-income discrimination under 9 V.S.A. § 4503.

12.10. Security deposit. 9 V.S.A. § 4461 requires return within 14 days after Landlord discovers vacancy; willful failure forfeits all deductions and triggers double damages plus attorney fees. Demand a written itemization.

12.11. Burlington / Brattleboro / Montpelier. Verify whether any local just-cause / eviction-protection ordinance is currently in force. The Burlington 2021 Charter Amendment has been repeatedly considered, vetoed, and reintroduced at the State level; status changes session by session.

12.12. Mobile home parks. 10 V.S.A. ch. 153 governs mobile-home-park lot-rent disputes; specialized notice, eviction, and abandonment rules apply.

12.13. Subsidized housing. Section 8, public housing, LIHTC, and RD-515 tenants have additional federal "good cause" protections, HUD-form notice requirements, and grievance procedures. 24 C.F.R. Part 247 governs HUD multifamily.

12.14. Appeal. Notice of appeal to the Vermont Supreme Court must be filed within 30 days of entry of final judgment under V.R.A.P. 4. A supersedeas bond may be required for stay; consult counsel about V.R.A.P. 8.

12.15. Resources. Vermont 211 (dial 211); Vermont Department for Children and Families — Economic Services (emergency rental assistance); Community Action agencies (CVOEO, BROC, NEKCA, SEVCA, CVCAC); Vermont State Housing Authority; Champlain Valley Office of Economic Opportunity Tenants Project.

13. SOURCES AND REFERENCES

• 9 V.S.A. § 4457 — Implied warranty of habitability. Available at: https://legislature.vermont.gov/statutes/section/09/137/04457
• 9 V.S.A. § 4458 — Habitability; tenant remedies. Available at: https://legislature.vermont.gov/statutes/section/09/137/04458
• 9 V.S.A. § 4459 — Minor defects; repair and deduct. Available at: https://legislature.vermont.gov/statutes/section/09/137/04459
• 9 V.S.A. § 4461 — Security deposits. Available at: https://legislature.vermont.gov/statutes/section/09/137/04461
• 9 V.S.A. § 4463 — Illegal evictions. Available at: https://legislature.vermont.gov/statutes/section/09/137/04463
• 9 V.S.A. § 4464 — Remedies for illegal evictions. Available at: https://legislature.vermont.gov/statutes/section/09/137/04464
• 9 V.S.A. § 4465 — Retaliatory conduct prohibited. Available at: https://legislature.vermont.gov/statutes/section/09/137/04465
• 9 V.S.A. § 4467 — Termination of tenancy; notice. Available at: https://legislature.vermont.gov/statutes/section/09/137/04467
• 9 V.S.A. §§ 4471–4475 — Protected tenants (abuse / sexual assault / stalking). Available at: https://legislature.vermont.gov/statutes/fullchapter/09/137
• 9 V.S.A. § 4503 — Vermont Fair Housing Act. Available at: https://legislature.vermont.gov/statutes/section/09/139/04503
• 12 V.S.A. ch. 169 — Ejectment (full chapter). Available at: https://legislature.vermont.gov/statutes/fullchapter/12/169
• 12 V.S.A. § 4773 — Ejectment for nonpayment of rent. Available at: https://legislature.vermont.gov/statutes/section/12/169/04773
• 12 V.S.A. § 4853a — Payment of rent into court; expedited hearing. Available at: https://legislature.vermont.gov/statutes/section/12/169/04853a
• 12 V.S.A. § 4854 — Judgment for plaintiff; writ of possession. Available at: https://legislature.vermont.gov/statutes/section/12/169/04854
• Vermont Rules of Civil Procedure. Available via Vermont Judiciary: https://www.vermontjudiciary.org/about-vermont-judiciary/rules-procedure
• V.R.A.P. 4 — Appeal as of right; time for filing. Available via Vermont Judiciary.
• Vermont Judiciary — Eviction Process. Available at: https://www.vermontjudiciary.org/civil/eviction-process
• VTLawHelp.org — Court Process: Steps in an Eviction Case. Available at: https://vtlawhelp.org/court-process-eviction
• Vermont Legal Aid. Available at: https://www.vtlegalaid.org/
• CVOEO — Notice Periods & Tenants Project. Available at: https://www.cvoeo.org/
• Federal Fair Housing Act, 42 U.S.C. § 3601 et seq.
• VAWA, 34 U.S.C. § 12491.
• 24 C.F.R. Part 247 — HUD multifamily good-cause eviction.
• 10 V.S.A. ch. 153 — Mobile Home Parks. Available at: https://legislature.vermont.gov/statutes/fullchapter/10/153
• Burlington Just Cause Eviction Charter Amendment (status & history). See VTDigger and the City of Burlington Clerk's Office.

END OF ANSWER, AFFIRMATIVE DEFENSES, COUNTERCLAIMS, AND JURY DEMAND.