Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 1 of 111

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
Baltimore Division
Heaven White, individually and on
behalf of her three minor children,
D.C. and K.C. and H.C.
1164 Frederick Douglas Street
Annapolis, Maryland 21403
Anne Arundel County,
Nashell Smith, individually and on
behalf of her three minor children,
D.E.P. and D.X.P. and M.P.
813 Betsy Court
Apartment B
Annapolis, Maryland 21401
Anne Arundel County,
Nicole Clark, individually and on
behalf of her two minor children,
T.L. and N.C.
813 Betsy Court
Apartment A
Annapolis, Maryland 21401
Anne Arundel County,
Tyneice Holliday, individually and on
behalf of her three minor children,
D.R. and A.H. and E.D.
808 Brooke Court
Apartment B
Annapolis, Maryland 21401
Anne Arundel County,
LaDawn Camp, individually and on
behalf of her one minor child,
A.R.
801 Brooke Court

Civil Action No.

JURY TRIAL DEMANDED

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 2 of 111

Apartment C
Annapolis, Maryland 21401
Anne Arundel County,
Tiamani Johns, individually and on
behalf of her one minor child,
N.J.
1125 Madison Street
Apartment B3
Annapolis, Maryland 21403
Anne Arundel County,
Jonathan and Breonna Dixon,
individually and on behalf of their two
minor children,
B.J. and A.D.
1324 Maryland Avenue
Johnstown, Pennsylvania 15906,
D’Andre Covert
1164 Frederick Douglas Street
Annapolis, Maryland 21403
Anne Arundel County,
Glenn Rogers
701 Glenwood Street
Apartment 616
Annapolis, Maryland 21401
Anne Arundel County,
Lakisha Fuller, individually and on
behalf of her two minor children,
M.D. and O.D.
1432 Tyler Avenue
Annapolis, Maryland 21403
Anne Arundel County,
Plaintiffs,
v.
2

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 3 of 111

The City of Annapolis by and through
the City Council
A municipal corporation
160 Duke of Gloucester Street
Annapolis, Maryland 21401
Anne Arundel County,
Gavin Buckley as Mayor of the City of
Annapolis
160 Duke of Gloucester Street
Annapolis, Maryland 21401
Anne Arundel County,
Housing Authority of the
City of Annapolis,
A public body corporate and politic
1217 Madison Street
Annapolis, Maryland 21403,
Housing Authority of the
City of Annapolis
Board of Commissioners,
1217 Madison Street
Annapolis, Maryland 21403,
Beverly Wilbourn as Executive
Director of the
Housing Authority of the
City of Annapolis
1217 Madison Street
Annapolis, Maryland 21403,
Defendants.

3

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 4 of 111

COMPLAINT
COMES NOW, before this Honorable Court, your Plaintiffs by and through
counsel, P. Joseph Donahue and Wise & Donahue, PLC attorneys, hereby sue the
Defendants, and as grounds therefore state as follows:
NATURE OF ACTION
Plaintiffs are primarily African American 1 residents of housing developments
owned and operated by the Housing Authority of the City of Annapolis (“HACA”
or the “Housing Authority”). This action challenges the ongoing discriminatory
policies of the City of Annapolis and the officials of the City to forego their statutory
obligation to inspect and license the leased properties owned by the Housing
Authority. It further challenges the long-standing pattern and practice of preventing
African American and other Black persons from residing in predominantly White
communities of Annapolis, and furthering policies of racial segregation, thereby
perpetuating not only the exclusion of minorities from the overwhelmingly White
City of Annapolis, but also the pattern of racial housing segregation in Annapolis
generally, which has, for decades, officially and unofficially acknowledged the

1

With reference to the racial makeup of the individuals concerned in this action, the
term “African American” is primarily used throughout instead of the term “Black.”
The determination of how to refer to an African American or Black individual should
be left to the individual. However, it is a foundational allegation in this Complaint
that the City of Annapolis has consistently mistreated its population of African
American residents since the end of African slavery. It is the decision of Plaintiffs
to be referred to as such for this matter.
4

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 5 of 111

significant presence of racial segregation.

By these and other illegal and

discriminatory acts, the Defendants have continued the City’s tradition of
perpetuating violations of Plaintiffs’ rights under the Fair Housing Act as amended,
42 U.S.C. § 3601, et seq.; the Civil Rights Act of 1866, 42 U.S.C. §§ 1982, 1983,
1985, and 1986; the Equal Protection clause of the Fourteenth Amendment to the
United States Constitution; the “affirmatively furthering” obligations of the Fair
Housing Act, 42 U.S.C. § 3608; and the Civil Rights Act of 1964, 42 U.S.C. § 2000d,
et seq, in addition to violations of the Maryland Consumer Protection Act, as well
as other State causes of action.
JURISDICTION AND VENUE
1.

This civil action arises under the laws of the United States of America.

This Court has original jurisdiction over Plaintiffs’ claims under 28 U.S.C. § 1331
(federal question), 28 U.S.C. § 2201 (declaratory relief), and 42 U.S.C. § 3613 (Fair
Housing Act, private right of action for damages and injunctive relief).
2.

Under 28 U.S.C. § 1367, this Court has supplemental jurisdiction over

the claims brought under Maryland law because they are related to Plaintiffs’ federal
claims and arise out of a common nucleus of related facts.
3.

Venue herein is proper under 28 U.S.C. §§ 1391 (b)(1) and (2).

Plaintiffs all reside or resided in the City of Annapolis, Anne Arundel County,
Maryland. Defendants City of Annapolis, Mayor Gavin Buckley, Aldermen and
5

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 6 of 111

Alderwomen of the City of Annapolis, Beverly Wilbourn, Director, Housing
Authority of the City of Annapolis, the Housing Authority of the City of Annapolis,
and the Housing Authority of the City of Annapolis Board of Commissioners all
maintain their principal place of business in the City of Annapolis, Anne Arundel
County, Maryland; the events or omissions giving rise to the claim occurred in this
district and division.
PARTIES
Plaintiffs
Newtowne Twenty Residents
4.

Plaintiff Nashell Smith (“Ms. Smith”) is an African American woman.

She and her three minor children live at 813 Betsy Court, Apartment B, an apartment
in Newtowne Twenty.
5.

Plaintiff Nicole Clark (“Ms. Clark”) is an African American woman.

She and her two minor children live at 813 Betsy Court, Apartment A, an apartment
in Newtowne Twenty.
6.

Plaintiff Tyneice Holliday (“Ms. Holliday”) is an African American

woman. She and her three minor children live at 808 Brooke Court, Apartment B,
an apartment in Newtowne Twenty.

6

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 7 of 111

7.

Plaintiff LaDawn Camp (“Ms. Camp”) is an African American woman.

She and her minor child live at 801 Brooke Court, Apartment C, an apartment in
Newtowne Twenty.
Harbour House Residents
8.

Plaintiff Tiamani Johns (“Ms. Johns”) is an African American woman.

She and her minor child live at 1125 Madison Street, Apartment B3, an apartment
in Harbour House.
9.

Plaintiffs Jonathan and Breonna Dixon (“the Dixons”) lived at 960

President Street, Apartment B3, in HACA’s Harbour House Property. Ms. Dixon
and her two minor children are African American.
Eastport Terrace
10. Plaintiff Heaven White (“Ms. White”) is an African American woman.
She and her three minor children live at 1164 Frederick Douglas Street, a townhouse
in Eastport Terrace.
11. Plaintiff D’Andre Covert (“Mr. Covert”) is an African American man,
and the adult child of Plaintiff Heaven White. He lives at 1164 Frederick Douglas
Street, a townhouse in Eastport Terrace.
Morris H. Blum Senior Apartments

7

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 8 of 111

12. Plaintiff Glenn Rogers (“Mr. Rogers”) is an African American man. He
has lived at 701 Glenwood Street in Apartment 502 and now lives in Apartment 616
located at the Morris H. Blum Senior apartments.
Robinwood
13. Plaintiff Lakisha Fuller (“Ms. Fuller”) is an African American woman.
She lives at 1432 Tyler Avenue with her two minor children.
Defendants
14. Defendants City of Annapolis by and through the Aldermen and
Alderwomen of the Annapolis, duly elected members of the City Council in their
official capacities.
15. Defendant Gavin Buckley, duly elected Mayor and City Official of the
City of Annapolis.
16. Defendant Beverly Wilbourn, Executive Director of the Housing
Authority of the City of Annapolis.
17. The Housing Authority of the City of Annapolis (“HACA”), a “public
body corporate and politic that: (1) exercises public and essential governmental
functions; and (2) has all the powers necessary or convenient to carry out the
purposes of this Division II.”2

2

Md. Code Ann., Hous. & Comty Dev. §13-103.
8

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 9 of 111

18. The Housing Authority of the City of Annapolis Board of
Commissioners (“Board of Commissioners”).

HACA and the Board of

Commissioners are referred to herein collectively as “HACA.”
FACTUAL AND HISTORICAL BACKGROUND
Historical Treatment of African Americans by the City of Annapolis
19. Throughout its nearly 370-year history, Annapolis has been home to
many people of African descent. However, the roots of that bond forever endure as
a stain on the fabric of the City, the State of Maryland, and that of the United States
as a whole.
20. The historical record is clear: Annapolis was integral in the
perpetuation of the African slave trade, which resulted in the subjugation of newly
imported Africans to white slaveholders.

Those slaves populated plantations

throughout Maryland and its surrounding states and provided free labor to an
adolescent country.

As policy, Annapolis facilitated the slave trade for over a

century, its harbor an auction block, which served as a stepping stone to lifetimes of
bondage for hundreds of thousands of human beings.
21. Slavery was practiced in Maryland for nearly 200 years before its
abolition by the Maryland Legislature in April 1864. Following Emancipation, and
during the early part of Reconstruction, the population of former slaves and other
African descendants in Maryland’s Capital remained segregated. However, despite
9

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 10 of 111

obtaining citizenship through passage of the 14th Amendment in 1868, these former
African slaves remained subject to the indignities and disparate treatment of Jim
Crow racism for much of the next century.
22. To protect and bolster their community, much of the African American
population in Annapolis settled into an area that had been redistricted by the City in
1914 and was known then as the 4th Ward (the “Old 4th Ward”). The Old 4th Ward
was located on the western side of the City of Annapolis, only a short walk from the
State House and the Governor’s Mansion. It is highlighted in Figure 1 infra. By the
mid-1940s the Old 4th Ward had become a self-contained community of primarily
African American residents, and was home to bars, lunchrooms, supper clubs,
churches, a theater, and the Dixie Hotel, which was home to live music and
entertainment. The rich culture of the Old 4th Ward, located in the shadow of the
State House, was created by its African American population through resilience,
hard work, patience, and a determination to overcome the obstacles of racial
animosity still much a part of daily life in the early 20th century. The Old 4th Ward
was regularly represented on the City Council by duly elected African American
community leaders.
23. The culture, establishments, and nightlife of the Old 4th Ward were
shared and enjoyed by more than just the African American residents of the City.
The vibrant community attracted the majority White citizenry of Annapolis, the all10

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 11 of 111

White Naval Academy midshipmen, the all-White naval officers stationed in the
City, as well as legislators from all over the State who traveled to and often resided
full-time in the State’s Capital.
Federal Programs Bring Change to the City
24. Housing authorities in the United States were initially brought about
through New Deal legislation in the 1930s. The legislation sought to eliminate slumlike conditions throughout the country, while in turn creating thousands of
construction jobs for unemployed Americans of all racial backgrounds. At that time,
only a few generations removed from the horrors of slavery, African American
families benefited greatly from those various Acts, and in addition to receiving jobs,
many African Americans were provided clean homes for the first time since
bondage. The Housing Authority of the City of Annapolis was founded in 1937 and
sought to take advantage of the newly available federal development funds.
25. From the beginning, HACA sought to provide affordable housing to
any Annapolis citizens in need. However, segregation persisted. The first properties
under the management of HACA were Bloomsbury Square with its Caucasian
occupants, and College Creek Terrace, occupied by African Americans. Both
properties were in the Old 4th Ward. HACA would not desegregate these housing
developments until the mid-1960s.

11

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 12 of 111

26. The 1950’s brought continued growth to Annapolis, and with expansion
in utility services, the City’s boundaries had begun to grow. The City passed
legislation, which caused the boundaries of the Old 4th Ward to be subsumed by
Ward 2 as it exists today. The African American community persisted against the
encroaching tide. However, the 1960’s policies of urban renewal devastated the
neighborhood, destroying nearly all of its 33 businesses. Eminent domain policies
led to the demolition of numerous homes in the almost entirely African American
Old 4th Ward areas, which displaced 237 families.

Bulldozers leveled the

community almost entirely. The result was a housing crisis for the African American
community in Annapolis.
27. Contemporaneously with the reorganization of the Old 4th Ward, which
historically had been represented on the City Council predominantly by African
Americans from the community, was a shift in its representation at the City Council
level. Today, Ward 2 is represented by predominantly White Alderpersons, while
Ward 4 and Ward 6 – the Wards which are home to the majority of HACA units in
the areas that received an influx of the displaced citizens as a result of urban renewal
– are represented by African Americans.3

3

Exhibit A is a current map of the City of Annapolis Wards. Lest there be any
confusion about whether or not Ward 6 was drawn specifically to marginalize
African Americans, the Robinwood neighborhood was carved out of Ward 5, and
is circled in red.
12

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 13 of 111

28. As the Civil Rights movement was taking hold across the nation, the
City of Annapolis, in cooperation with HACA, moved its African American
residents away from the City center. These residents were provided public housing
units, and many, then stripped of their livelihood, were congregated into dense
developments scattered miles from employment opportunities and without a viable
public transportation system. Given no alternative, the once vibrant community was
decimated, and its population crammed into public housing against their will. The
African American residents of Annapolis have never recovered from the 1960’s
urban renewal policies of the City of Annapolis.4
The HACA Properties Today
29. HACA now manages approximately 790 apartments spread over six (6)
developments, which are home to approximately 1,600 residents. As illustrated in
Figure 1 infra, and highlighted in yellow, there are six remaining developments:
a. Bloomsbury Square – Rebuilt in 2003, this is HACA’s newest property,
and it consists of 51 units;

4

Sources of information relating to the urban renewal policies of the City of
Annapolis are difficult to access without significant effort. One article from The
Washington Post dated June 3, 1979 relays in fine detail the devastation of those
policies and the aftershocks still felt approximately a decade after the decimation
of the Old 4th Ward. The Annapolis Land Grab, Wash. Post, June 3, 1979,
available at
https://www.washingtonpost.com/archive/lifestyle/magazine/1979/06/03/theannapolis-land-grab/435030bc-7355-475c-a3ab77b80e0bfeb5/?utm_term=.ba1de6aa58c9.
13

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 14 of 111

b. Harbour House – Constructed in 1964, is comprised of 273 units;
c. Eastport Terrace – Constructed in 1953, is HACA’s oldest property and
is comprised of 84 units. Eastport Terrace and Harbor House share a
property line, and the residents share the same recreational facilities;
d. Morris H. Blum Senior Apartments – Constructed in 1976, are HACA’s
only dedicated units for the elderly and disabled, and require tenants be
55-years-old (or 50-years-old if disabled) to apply;
e. Robinwood – Constructed in 1970 is comprised of 150 units; and
f. Newtowne Twenty (or “Newtowne 20”) – Constructed in 1971 is
comprised of 78 units.

14

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 15 of 111

Figure 1 – Map of the HACA Properties
15

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 16 of 111

As compared to the footprint of the Old 4th Ward, which is highlighted in blue, these
six (6) remaining HACA properties (the “HACA Properties”) are randomly located
around the City.
The Myth of Free Housing
30. It is a common misperception that Public Housing is “free” for lowincome families. Nothing could be further from the truth. Congress designed the
Public Housing Program in order to afford low-income families with a dignified
opportunity to pay their fair share for safe, decent, habitable housing. Under the
Public Housing program, families pay rent to Public Housing Authorities (“PHA”)
that manage the properties. Federal rules govern the calculation of tenant rents,
which, for the vast majority of public housing residents, the family share of the rent
is based on household income.
31. The United States Housing Act of 1937 established the conventional
public housing program.

Public Housing admission is limited to low-income

families and individuals earning below 80% of the Area Median Income (“AMI”),
although in many areas, applicants may need to earn incomes below 50%, or even
30% of the AMI. The average income of an average-sized public housing family of
2.1 persons was $14,412 in 2015, which is below the poverty level.
32. The policy of defining maximum Public Housing rents as a percentage
of family income began in 1969 when Congress passed the “Brooke Amendment,”
16

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 17 of 111

the current version of which is codified at 42 U.S.C.A. § 1437. Congress has
subsequently amended the Brooke Amendment many times. The rent-income ratio
has increased to its current level of 30 percent of adjusted household income.
Additional changes in federal policy allow Public Housing tenants the option to pay
“flat rents” based on the reasonable market value of their units. In addition, HACA
has established its own minimum rent of $50 per month, even if a tenant’s income
is zero. Rents in the HACA Properties range as high as $1,500 per month or more.
Rental Unit License – A Requirement of the Annapolis City Code
33. Chapter 17.44.010 of the City Code states: “No person shall let for
occupancy or use any vacant single rental dwelling unit, multiple dwelling, bed and
breakfast home, roominghouse, or bargehouse without a current operating license
issued by the Department of Planning and Zoning, after the application for the
license has been approved by the Director of Planning and Zoning, with the
concurrence of the Fire Chief, and the County Health Officer, for the specific named
unit, multiple dwelling, bed and breakfast home, roominghouse, or bargehouse.”
34. Chapter 17.44.020 of the City Code states: “No operating license shall
be issued or renewed unless the applicant owner first has made application on an
application form provided by the Director of the Department of Planning and
Zoning. The Director shall develop the forms and make them available to the
public.”
17

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 18 of 111

35. Pursuant to this and other portions of the City Code, all rental units
require a license issued by the City if they are to be legally authorized to operate.
36. In order to obtain a license, rental units must be inspected and found to
be in compliance with the City’s Residential Property and Maintenance Code.
Annapolis City Code, Chapter 17.44.010.
37. HACA Properties managed solely by HACA are neither licensed nor
inspected by the City. These properties are the only rental properties within the
City that are neither licensed nor inspected. They are not licensed because the City
Code is simply not enforced on the HACA Properties.
38. Pursuant to policies of the City’s Office of Licenses & Permits
Division, when conditions that present a danger to health or safety are found in an
apartment that is currently occupied by tenants, a landlord will be required to
relocate that tenant, remediate the danger, request a reinspection, and provide other
proof at the landlord’s expense to the City Inspector demonstrating the danger is no
longer present.
39.

Chapter 17.44.130 of the City Code states: “Upon suspension,

revocation, denial, or expiration of a license, the director shall have the authority to
cause notices to be posted on the property which shall state as follows:
“OCCUPANCY OF ANY DWELLING UNIT IN THIS BUILDING NOW
VACANT OR BECOMING VACANT IS UNLAWFUL UNTIL A LICENSE TO
18

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 19 of 111

OPERATE HAS BEEN OBTAINED AND IS DISPLAYED ON THE PREMISES.”
No such postings are made by the City on the HACA Properties.
The City’s Notice of its Failure to Evenly Enforce its Code
40. Rental licenses have been a requirement of prospective landlords by the
City since approximately 1985. Despite the inspection requirement, the public
housing units managed by HACA were rarely, if ever, subjected to any City
inspections, but have never been fully, finally, or properly inspected and licensed in
accordance with the City Code.
41. Former Annapolis City Mayor Michael J. Pantelides was elected to that
office in November 2013 and sworn in on December 2 of that year. To assist
incoming Mayors with their transition into office, teams of relevant professionals
are commissioned by the City to conduct in-depth reviews of specified areas subject
to the purview of the Mayor and City Council.
42. On October 27, 2014, a Public Housing Transition Team report (the
“Transition Report”) was presented to and adopted by incoming Mayor Pantelides.
A copy of that Transition Report is attached hereto as Exhibit B.
43. On slide eight (8) of that report, the Transition Team stated: “The
condition of HACA properties is in serious decline. The latest available [U.S.
Department of Housing and Urban Development] score for their physical condition

19

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 20 of 111

is 25 out of 40. Residents say the condition and maintenance of their units are their
biggest problems.”
44. The Transition Team recommended two specific courses of action.
Recommendation 1 provided: “Per State code unless an exception is made, the City
should begin inspecting HACA units under the City’s rental licensing program that
applies to all other rental housing in the City.” Exhibit B, p. 8. Recommendation 2
provided: “The City has an obligation to protect health and safety of public housing
residents, as they do other City renters, and should work with HACA to phase in
City inspection of HACA properties.” Id. For each of these recommendations, the
Transition Team identified the recommended timeline for the inspections as
“Immediate.”
45. The Transition Team report was more than a recommendation,
however, as it provided the Mayor and City Council with notice that their policy not
to inspect HACA properties was also a violation of the Maryland State Code.
46. Maryland Housing and Community Development Code § 12-403
states: “Except as provided in § 12-506(b)(9) of this title, all housing projects of an
authority are subject to the planning, zoning, sanitary, health, fire, housing,
subdivision, and building laws, ordinances, codes, rules, and regulations that apply
where the housing project is located.”

20

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 21 of 111

47. Maryland Housing and Community Development Code § 12-506(b)(9)
states: “To aid and cooperate in the planning, undertaking, construction, or operation
of housing projects located wholly or partly in the area in which it may act, a State
public body, with or without consideration and on terms that it determines, may …
plan, replan, zone, or rezone any part of the State public body, make exceptions to
its sanitary, building, housing, fire, health, subdivision, or other similar laws, rules,
regulations, and ordinances or make any changes to its map or master plan….”
48. On December 18, 2014, during a public hearing of the Annapolis City
Council the testimony of the Transition Team resulted in the following
recommendations/observations:
Recommendation/Observation 1:
“The City should inspect HACA properties, so they conform to
City Code. State Code Section 12.403 requires that HACA
Properties conform to City’s health, fire, and housing codes, or
be explicitly exempt from doing so; however, the City does not
currently inspect HACA properties, and therefore treats HACA
properties differently from every other rental property in the City
with regard to inspections. So, the City should be aware of
potential liability because they have chosen to basically ignore
this issue over the years. And I believe we have had a
conversation with the finance officer in regard to this and he too
indicated that there was potential issue with liability for the
City.”
Recommendation/Observation 2:
“We should note that HACA right now inspects their own
properties by basically having a contractor come in and do a
random inspection every year just before HUD comes in. So,
21

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 22 of 111

HUD, which does not inspect all of the properties, it also does a
random inspection, it’s [only] about 20% of the properties
actually get looked at, so that is how these scores are addressed.
They are not looking at the property in totality, and it does
include all of those properties that have already been revitalized.”
Recommendation/Observation 3:
“Why would the worst housing in town occupied by the lowest
income people not be of concern to the City of Annapolis where
we are concerned about wealthy high rent apartments?”
49. One member of the Transition Team was queried regarding the
difference in standards between the HUD inspections and those of the City of
Annapolis. In addition to providing the fact that HUD only inspects a sample of the
units and not 100% of the units as required by City Code, the following response
was proffered:
[HUD requirements are] different from the City Code in at least
one material way that we found, and that is with regard to fire
safety. HUD requirements as far as inspections, for example
with respect to smoke alarms, say that smoke alarms can be
battery operated, and one smoke alarm per level. The City Code
with respect to fire safety says that the smoke alarms have to be
wired, and there has to be a smoke alarm outside of each
bedroom. So just with respect to fire safety, there is a disconnect
between HUD inspection requirements and City Code.
In response to this explanation, Mayor Pantelides replied: “That is a great example.
Very big public safety concern. Residents of Annapolis should be up to the same
standard as well.”

22

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 23 of 111

50. During that same meeting on December 18, 2014, Mayor Pantelides
made the following observation regarding the City’s prior failures with respect to
inspections of the HACA properties:
Your transition report probably more than any other one that
came forward sparked a lot of debate, especially within the
newspaper, which I think was a healthy dialogue to have. I’m
sure everyone didn’t agree on everything that was said but the
fact that we’re talking about it, and such an important part of our
population gets overlooked, had gone on for too long.
51. Following the findings and recommendations of the Transition Team,
Mayor Pantelides set in motion a plan for the City to carry out the first inspections
of the HACA properties, which would not ultimately begin until April 2016.
Mayor Pantelides’ Notice to HACA and HUD
52. In November 2015, Mayor Pantelides put HACA and HUD on notice
that he intended to enforce inspections on the HACA Properties pursuant to his legal
duties as Mayor. The Mayor acknowledged that it was not until approximately the
Fall of 2014 that he realized that the City had the authority and legal responsibility
to inspect the HACA properties.
53. In a November 20, 2015 article published in The Capital Gazette, the
Mayor acknowledged that: “The City has taken a passive role, but that’s not going
to be the case anymore.”
54. In a November 23, 2015 article published in The Capital Gazette, the
Mayor was reported to have sent a letter to HACA officials outlining his intent to
23

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 24 of 111

inspect.

The letter stated: “Unless there are substantial improvements in the

condition of the housing stock between now and then, I suspect that a number of
residents will need to be relocated until repairs and/or major reconstruction is
completed. I hope you take this matter as seriously as I do.”
55. In November 2015, a similar letter was sent to HUD officials. The
HUD spokesperson at the time declined to comment to The Capital Gazette
reporters, but reportedly responded to the Mayor in writing.
56. In January 2016, in response to a reporter’s questions about HUD’s
ongoing investigation of HACA’s use of grant funding, Pantelides stated: “It is a
good thing that HUD is coming in and investigating HACA. This is an agency with
a troubling past and present.”
57. On November 26, 2015, Trudy McFall, a previous chairman of the
HACA Board and member of the Mayor’s Housing Transition Team wrote a Letter
to the Editor in The Capital Gazette wherein she praised the Mayor for his decision
to finally enforce City inspections on the HACA Properties. She stated as follows:
For many years, previous mayors and other elected officials have
been told this by me and others, but none made any move to
comply with the state law and better protect the residents of
public housing.
…
I congratulate the mayor for his leadership in deciding to do this,
when others before him have ignored the issue.
Unquestionably, it will not be easy for the city and will raise
complex issues. However, it is well past time for the elected
officials for the city to ensure that public housing residents
24

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 25 of 111

have the same protections as other city renters. All city
residents will benefit by improved public housing.”
(Emphasis added).
Rental License Application Process in the City of Annapolis
58. Chapter 17.44.060 (A) of the City Code states: “The operator of a multifamily dwelling consisting of fifty or more units who employs a full-time
maintenance staff of three or more employees on-site shall have its license initially
issued or renewed for a two-year period. All other licenses shall be issued or
renewed on an annual basis.” (Emphasis added).
59. Pursuant to the City Code, given the characteristics of the HACA
Properties, all of its 790 units are required to be inspected and re-licensed by the City
of Annapolis annually. 5
60. The Rental Operating License Application mandated by the City of
Annapolis states:
A property owner must obtain a license prior to operating a rental
facility within the City of Annapolis. License application and
rental operating license are non-transferable. Application must
include fee of $100.00 per unit. Property must be inspected for
compliance of the City’s Code and International Property
Maintenance Code before the license will be issued.
See Exhibit C (emphasis in original).

5

HACA does not maintain a large enough maintenance staff across all six (6) of its
properties to qualify for the “two-year” license.
25

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 26 of 111

61. The City requires smoke alarms in rental units to be supplied with
installed AC powered smoke alarms pursuant to City Code Section 17.40.440. The
Rental Operating License Application states in italicized language the following:
“***Must have smoke alarms installed on each ceiling or wall outside of each
separate sleeping area in the immediate vicinity of bedrooms, in each sleeping room,
and each story of the dwelling unit (International Property Maintenance Code
704.2).” Exhibit C (emphasis in original).
62. The Rental Operating License Application requires that the landlord
certify that “they will comply with the ICC Code and the Charter and Code of the
City of Annapolis, which are applicable hereto; [] they agree to inspections by the
Department of Planning and Zoning and the Fire Department to determine if the
property is in compliance with the provisions of the ICC Code and the Charter and
Code of the City of Annapolis.” Id.
Logistical Issues Raised Prior to Inspections
63. After the December 2014 meeting, it took nearly a year for the
inspection process to begin to take shape. That intervening year of 2015 was fraught
with political infighting around the issue of the HACA inspections.
64. Pursuant to the City Code, HACA was required to pay $79,000 in order
to apply for rental licenses for each of its 790 units. Despite HACA’s status as a
landlord in the City, Alderwoman Sheila Finlayson proposed legislation to the City
26

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 27 of 111

Council which would waive the inspection fees. On December 7, 2015, Resolution
31-15 (the “Waiver Legislation”) was proposed by Alderwoman Finlayson.
65. Included within R-31-15 was the following language:
FOR the purpose of waiving fees associated with the licensure
and inspection of HACA residential rental units.
…
WHEREAS City Code Chapter 17.44 requires the City to
license and inspect all rental housing units in the City; and
WHEREAS the cost of such licensure, inspection and associated
fees could encumber HACA with tens of thousands of dollars of
expenses.
See Exhibit D.

In the proposed legislation itself, the City acknowledged its

responsibility to license and inspect the HACA Properties.
66. The Fiscal Impact Note related to R-31-15 issued by the City made the
following observation:
Analysis of Fiscal Impact: This legislation waives the fees
associated with the licensure and inspection of HACA residential
rental units as required by City Code Chapter 17.44. The current
fee structure, section 17.44.040 of the City Code, includes a
$100.00 fee per annum for an operating license for rental unit
and rooming house. According to HACA, there are currently
seven hundred and ninety (790) HACA residential rental units
within the City of Annapolis. Based on the number of units, the
net fiscal impact would be $79,000.
See Exhibit E.

27

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 28 of 111

67. The Waiver Legislation created some contention among the City’s
leadership, but the debate centered less on whether the fee should be waived, and
more on the effect of a City inspection of the HACA Properties. One exchange
among former Aldermen highlighted the “concern”:
Alderman Littman:
If this legislation was approved, and if the City did these
inspections, presumably we all suspect there will be a number of
violations. I would like to know the “So what” question. So
what do we do then? Is there going to be any… Assuming that
we have a list of, let’s just say arbitrary 30 units, that need some
repair, 10 of them should not be habitable, So what? Are we
going to put those people somewhere else and do the work? Are
we going to ask HACA nicely to do the work? Are we forcing
HACA to do the work? Is HUD going to force HACA to do the
work? If those people are going to be moved out are they going
to be moved out in any sense of maintaining community? Are
they going to be guaranteed their units back when the work is
done? So I would like to know what the impact of this work is
before we just go ahead and do a lot of paperwork that might not
have any impact at all to actually accomplishing the very
important goal that I do support of improving the housing for our
HACA residents.
Alderman Kirby:
I guess I have some of those same issues myself. Right now, we
don’t inspect. It’s always been left up to the HUD officials and
they did their own inspections, and I do not believe they went
through every unit. So we’ve never been responsible for the
Housing Authority inspections. So this is different and it is going
to raise some further questions about condemning units and what
happens to tenants when we condemn the unit.
Alderman Budge:
28

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 29 of 111

What’s the plan? We know that the Mayor has stated it is his
intention to proceed with the inspections whether or not we pass
R-31, and that is going to invoke the whole list of questions that
Alderman Littman has been asking regardless so I think we
should proceed with that line of questioning…. We as a council
need an understanding of what the plan is to bring HACA
housing up to standard. It is my understanding that the Mayor
intends to make it a HUD problem. HUD doesn’t want to pick
up the problem. HACA doesn’t have a plan. We don’t have a
plan. There is train wreck in front of us.
(Emphasis added).
68. At some point a question was raised as to the Constitutionality of the
Waiver Legislation itself. Counsel from the City Attorney’s office testified before
the City’s Finance Committee with regard to the potential Constitutional conflict as
follows:
Very simply… the difficulty we face structurally is that there is
no specific right Constitutionally under the 14th Amendment to
have fees waived and so under the legal tests, there has to be a
rational basis, or if a suspect class is involved there has to be
what is called strict scrutiny, and in either case, and in this
particular case, because we are dealing with a quasi-public entity
that is bound to a federal agency, it does not preclude their
responsibilities under the host jurisdiction of laws to meet the
letter of the law. Now, historically there has been a
presumption, as I understand it, that HACA and HUD were
doing their own investigations and their own inspections on
an annual basis. We have discovered that the inspections
that are done, are not of all units, but rather are, from a
statistical sampling, and our law is rather clear that it
requires each and every unit to be inspected in terms of
multi-units like this, on a bi-annual basis. And our law is also
clear that there is a fee associated with that, and to grant this
particular quasi-public agency a waiver without some specific
legal justification simply because they may not have the money,
29

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 30 of 111

does potentially create some constitutional legal issues for us.
So, if it is the desire of the council going forward, to find a way
to work with them economically, I am sure that we can do that,
but the blanket waiver is probably unconstitutional.
…
HUD does have a responsibility, both under the legislation that
controls their relationship with HACA, and under our laws to
make certain that these units are habitable, and our inspection
process is how we determine that.
(Emphasis added).
69. As a result of this opinion of the City Attorney’s Office, Alderwoman
Finlayson withdrew R-31-15. In doing so, she provided her thought process about
the City’s decision to inspect, and the concern she had for holding HACA
accountable as the City should any other landlord:
I sponsored this legislation when the City decided, wisely so,
to inspect all of our rental units including those in public
housing. What concerned me was the fact that we were then
going to turn around and charge the very agency who is
struggling to maintain some semblance of quality residences
in the City. That bothered me considerably. So this legislation
was poised to waive the fees that we would charge the housing
authority for those inspections. I’ve since been assured by the
City Manager that there is no intention for the city to charge
the housing authority for these inspections. And I have also
been informed by the previous city attorney that it is probably
unconstitutional to waive the fees because being poor is not a
protected class. But again, I’ve been assured by the City
manager… that there will not be any fees or any charges to
the housing authority. So for that reason I am going to
withdraw this legislation.
(Emphasis added).
30

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 31 of 111

Revelations from the City’s Initial Inspections of the HACA Properties
70. Pursuant to City Policy provided in the City’s “Rental Operating
License Application,” the inspections are held to the standards set out in the
International Property Maintenance Code.
71. When the City finds violations of its Code in an initial inspection, it
does not issue a rental license until those violations are fixed by the prospective
landlord.
72. Despite expressed concern that it would be unconstitutional to waive
the fee through legislation, the City did not enforce the City Code provision requiring
HACA pay the 2016 inspection fee of $100 per unit ($79,000 total), and seemingly
waived it without legislation, or otherwise credited HACA for the fee.
73. On May 1, 2016, the City began inspections of the HACA Properties.
This initial round of inspections was not completed until July or August 2016. The
results of the inspections were abysmal. Of the 790 units inspected there were 2,498
City Code violations uncovered by inspectors. The initial inspection results for each
of the 790 units are attached hereto as Exhibit F.
74. Each of the six HACA Properties inspected lacked the “Electric
Hardwired Smoke Detectors” required by City Code of all rental units. Many of the
battery powered smoke detectors required of HUD’s lower inspection standard were
not functioning.
31

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 32 of 111

75. Many of the City Code violations presented dangers to health and
safety. Consistent with the City Code, the City should have required HACA to
relocate tenants pending the correction of the dangerous conditions or to reimburse
tenants for their costs related to securing adequate substitute housing. Even after it
conducted the initial inspections, the City did not enforce its own Code requirements
of revocation of the licenses or vacation of the HACA Properties.
76. After the initial inspection results were provided to HACA officials in
the summer of 2016, the Housing Authority was provided with follow-up inspection
dates for when the City would be back out for a second round of inspections. Some
follow-up inspections were conducted, but none of the six HACA Properties were
ever fully and properly licensed.
77. On September 12, 2016, the approximate time when the follow-up
inspections were set to begin, Members of the HACA Board testified before the City
Council. HACA Interim Director Richard Walton testified as follows:
Mr. Mayor I just wanted to comment a little bit about the City
inspections. It went very well actually, and I want to say thank
you and your staff. They worked very well with our staff. All
of the inspections were completed by the end of our fiscal year,
which was June 30th, to all properties but one, and that was
Newtowne 20. That inspection was completed in August.
HACA, the Mayor, and the City Council maintained the appearance to the citizenry
of Annapolis that the City inspections of the HACA properties had been completed,
even going so far as to issue licenses to many of the units despite their continued
32

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 33 of 111

failed status and the pending follow-up inspections. The 2016 City inspections of
the HACA Properties were never fully completed.
78. On February 13, 2017, members of the HACA Board testified before
the City Council. Then HACA Board Member John Dillon testified as follows
regarding the results of the inspections:
The buildings and structures, and I think we are all well aware
of, are, for the most part … past their useful life. For at least a
decade or so we really stopped doing any plan of any major
renovation or construction.
He went on to further clarify that “as you well know,” Eastport Terrace and Harbour
House “are shot.” (Emphasis added).
79. On April 18, 2017, Beverly Wilbourn was introduced as HACA’s new
Executive Director.
HACA’s Presentation to the New Mayor and City Council on
February 26, 2018
80. City elections were held in November 2017. Mayor Pantelides, who
had emphasized during his reelection campaign that he was the “First Mayor to
Inspect Public Housing,” was unseated by Gavin Buckley.
81. Mayor Buckley was sworn into office on December 7, 2017. At that
time, the follow-up inspections for HACA properties were still in slow progress.
82. Mayor Buckley did not have a transition report dedicated to public
housing. Despite the drastic change that had occurred three (3) years previously
33

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 34 of 111

with regard to City inspection policy as related to the HACA Properties, no mention
was made in Mayor Buckley’s transition reports to the status of inspections or the
state of the public housing.
83. On February 26, 2018, HACA presented its Quarterly Report to the City
Council. Mayor Buckley opened the meeting as follows:
We had a visit… for the first time in a long time the Mayor, the
HACA Executive Director, the HACA Board Chair, and several
representatives of the United States Department of Housing and
Urban Development were around a table talking about the future
of HACA. I want to thank Beverly for her leadership of HACA
and her help to bring us all together to discuss the issues
important to this community. I would also like to thank Sandra
Chapman and the HACA board chair and for her leadership as
well. There were several high-ranking leaders there including
our region’s administrator Joseph DeFelice, our division director
Russell DeSouza, and Carol Payne, the director of HUD’s
Baltimore office. And I can tell you it was a lovefest. We had
a great great meeting. And at the end of the meeting, it was
decided that they believe that HACA is in better shape than
it has ever been. There are currently no HUD restrictions on
HACA, they have no major issues with HACA. The reports are
right on target, and they are ready to support HACA with its
initiatives. It was very clear to me that HUD credits Beverly
Wilbourn with turning the agency around, and I am grateful for
her leadership and hard work, we are lucky to have you Beverly,
thank you so much.
(Emphasis added). The Mayor concluded his opening remarks by saying: “We
cannot be a great community until we make a great community for everybody.
Beverly [Wilbourn] believes in the mission of public housing, and it’s going to be
amazing when we are finished.”
34

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 35 of 111

84. Director Wilbourn began her remarks by clarifying: “We can’t really
have a strong housing authority without the full support of the City of Annapolis.”
85. Director Wilbourn then spoke about the various issues faced by HACA
when it came to maintenance:
Let me be clear, I can’t do maintenance. I can’t get
maintenance to get me away clear on properties that are 40,
50, in the case of Eastport Terrace 65 years old, and in need
of major rehab. That is where redevelopment comes into play.
And that is what we have RAD, that is what we have selected as
the redevelopment tool… But the reality is, there is only so far
we can get with maintenance. At a point real estate needs some
capital infusion, some major system rehabs, changing out,
renewal, even the layouts need to be changed some.
Obsolescence comes into play. And that’s where we are with
probably about five of our developments. And we are
committed to taking that through so that we have in each of our
communities, communities that all of us can be proud of.
(Emphasis added).
86. Mayor Buckley acknowledged at the meeting that the prior and current
HACA Properties in higher visibility areas have received funding, but that the
City has not invested in the other developments:
I just want to say that there are only 750 units [sic] that HACA
are in charge of…. So if we look at the city and we see where
problems are, its areas where we haven’t invested. So you see
the areas where we have invested in … Annapolis Gardens or
Bloomsbury Square, they don’t have the same issues in the
areas that have been forgotten. They haven’t been invested in
in 50 or 60 years. We have to find the money and the apparatus
to get them invested in so that we can move forward.
(Emphasis added).
35

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 36 of 111

87. Alderwoman Shaneka Henson explained some of the historical aspects
of public housing in Annapolis to the HACA members and the City Council.
Alderwoman Henson specifically acknowledged that the HACA Properties were
home to the African American population that had been displaced through urban
renewal:
Annapolis is a City where we had a concentration in our African
American population concentrated in our Old 4th Ward area.
After urban renewal came, then everyone was dispersed and then
pushed out into these public housing neighborhoods. So for
better or worse it is the unfortunate legacy that [all] some people
have is just the public housing. People were not paid fair prices
for their homes. People were not really given a fair deal when
urban renewal came. So public housing was what they had left
over. We live in a country that hasn’t paid reparations. We
haven’t righted all the wrongs, but one of the apples in the basket
was public housing, and this program forever changes that, and
it will not be a true public housing anymore.
Alderwoman Henson sought here to highlight that the public/private partnership
model would replace the public housing model provided that HACA’s application
for the various programs were accepted by HUD.
The Cooperation Agreement and The City’s Violation of its Contractual
Obligations to HACA’s Residents
88. Alderwoman Finlayson’s proposed legislation which would have
relieved HACA’s obligation as a landlord to pay for annual inspections of its rental
properties was not the first effort to alleviate a perceived financial burden on HACA

36

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 37 of 111

without the Housing Authority having even made an affirmative public request for
relief.
89. Maryland State Code allows for agreements between a state public
body such as the City of Annapolis and housing authorities such as HACA. Referred
to as “Cooperation Agreements,” these agreements make it possible for HACA to
receive federal funds.
90. Under Maryland’s constitution and statutes, the low-rent housing
developed by HACA with funding assistance from what is now known as HUD, is
exempt from real and personal property taxes and special assessments. See Md.
Code. Ann. Tax-Prop. §7-215. The Cooperation Agreement allowed the City to
receive money from the Federal Government, but importantly, it also obligated
HACA to make Payment in Lieu of Tax (“PILOT”) payments to the City on a regular
basis.
91. Cooperation agreements and tax-exempt status are intended to go handin-hand as a protection for publicly owned low-income housing. The cooperation
agreement is a contract between the local government and the housing authority that
is intended to ensure that local governmental services will be provided to the housing
in exchange for the PILOT payments.
92. The City of Annapolis entered a Cooperation Agreement with HACA
on March 10, 1950. Subsequent amendments were made to that Cooperation
37

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 38 of 111

Agreement, with the most recent amendment having been approved by the City
Council on February 6, 2009. The Cooperation Agreement details the special
relationship between the City and HACA and outlines various obligations of the City
for the benefit of HACA’s residents.
93. Under the PILOT scheme devised, HACA is required to return to the
City of Annapolis 10% of the rents it collects from its tenants annually or “the
amount permitted to be paid by applicable state law in effect on the date such
payment is made, whichever amount is the lower.” In either event, the payments
would never exceed the amount of real property taxes which would have been paid
if the property were not exempt. Of the amount remitted to the City by HACA, 50%
is to be distributed to Anne Arundel County.
94. Under the Agreement, the City was required to:
Furnish or cause to be furnished to [HACA] and the tenants of
such Project public services and facilities of the same
character and to the same extent as are furnished from time
to time without cost or charge to other dwellings and
inhabitants in the Local Government.
(Emphasis added). In other words, HACA was required to make the PILOT
payments, and the City in return was to provide all the services for the residents of
the HACA properties that it provided to all other members of the City in exchange
for the property taxes paid by those residents.

38

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 39 of 111

95. In August 2018, Mayor Buckley introduced legislation (R-41-18) to
supersede and void the Cooperation Agreement as amended, in its entirety. Under
the proposed legislation, all HACA “obligations and liabilities under the
Cooperation Agreements” were declared to “have been fully satisfied and
discharged” even though the City acknowledged that it “ha[d] not collected any
payments under these agreements for years.” 6 (Emphasis added).
96. In addition to alleviating HACA of its prior debt which HACA owed to
the City (50% of which was by extension owed to the County), the proposed
legislation aimed to reduce HACA’s PILOT to $1.00 annually. However, it was not
just HACA that the City sought to benefit with this proposed legislation. As a bonus,
the legislation would also apply to real property owned by HACA, but that was
subject to contracts with third parties who were providing low-income housing to
City residents. In other words, this legislation sought to alleviate the tax obligations
of private companies that partnered with HACA to provide low-income housing.
This allowed out-of-state vendors to come into the City, engage in qualifying
operation, construction, or management of qualified low-income housing
developments, and then not have to pay any local taxes or any payments for the
services of its tenants.

6

See Exhibit G, Staff Report and Fiscal Impact Note, Resolution: R-41-18,
Housing Authority of the City of Annapolis (HACA) – Payment in Lieu of
Property Taxes (PILOT) Agreement, August 30, 2018.
39

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 40 of 111

97. The proposed legislation also failed to set out any obligations on the
part of the City of Annapolis toward the residents of HACA properties that are
addressed under the Cooperation Agreement, apparently alleviating the City of its
responsibilities to HACA’s tenants.
98. By excusing HACA from making the required PILOT payments to the
City and County, by excusing HACA from paying the fees associated with licensure,
and by excusing HACA from adhering to the same building code standards as other
landlords in the City of Annapolis, the City has been, and continues to be, complicit
in furthering the sub-standard conditions in which the residents of HACA properties
find themselves and for which they have no avenue for recourse.
99. The proposed legislation of R-41-18 is illustrative of the reality that
City officials, perceive HACA as an extension of the City itself. HACA and the City
hold themselves out as independent entities, but their singular operation further
highlights the disparate treatment of the tenants of the HACA Properties as
compared to the tenants of all other rental properties in the City.
100. The Cooperation Agreement is a Contract between the City and HACA,
made for the express benefit of the tenants of HACA Properties and the taxpayers.
The failure of the City to enforce that Contract has for years caused significant harm
to all concerned parties.

40

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 41 of 111

The Mayor, The City Council, and HACA Officials Agreed to Halt
Inspections and to Suspend Indefinitely the Enforcement of the City Code on
HACA’s Properties
101. Upon information and belief, Director Wilbourn and others at HACA
approached the City and requested that the City of Annapolis no longer enforce the
City Code on the HACA Properties.
102. Upon information and belief, Director Wilbourn and others at HACA
advised the City that HACA could not pay for the annual inspection fees required of
landlords by the City Code.
103. Upon information and belief, Director Wilbourn and others at HACA
requested that Mayor Buckley prevent the City Inspectors from responding to
complaints received by tenants residing in the HACA Properties.
104. Upon information and belief, Director Wilbourn and others at HACA
requested that Mayor Buckley direct the City Inspector’s Office to forward any
complaints received by tenants residing in the HACA Properties to the HACA
property managers themselves instead of responding in the City’s own capacity
through the City Inspector’s Office.
105. Upon information and belief, at some point during 2018, Mayor
Buckley, the Aldermen and Alderwomen of the City Council, Director Wilbourn,
and/or other officials at HACA conspired to suspend City inspections of the HACA
Properties.
41

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 42 of 111

Changes to the HACA Properties and Management Under Director Wilbourn
106. In July of 2018, HACA reported to the City that its fiscal year ending
June 30, 2018 reflected a net income surplus that increased from $92,059 in 2017 to
$537,900. This surplus was tremendous as compared to HACA’s budget numbers
in the preceding five years. HACA officials attributed this to increased rent
enforcement on its public housing tenants and decreased spending on
maintenance.
107. Mayor Buckley and the City Council praised Director Wilbourn and her
staff profusely for the financial shift. Alderwoman Finlayson stated: “You are to be
congratulated on this report.” Alderwoman Tierney described the jump in revenues
as “remarkable.”
108. However, Alderman Savage pointed out that HACA’s financials
reflected that despite the previous leadership having budgeted $1 million for
“resident services,” under Director Wilbourn’s leadership, she and her HACA staff
had cut down the “resident services” for the 2017-2018 fiscal year to only $400,000.
HACA spent $600,000 less than budgeted for residential services.
109. When asked about residential services, Director Wilbourn explained
that given the cuts from the federal government, they were no longer funded for
“residential services,” but only for “bricks and mortar.”

This was Director

Wilbourn’s interpretation of the funding, and not a specific direction from HUD.
42

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 43 of 111

110. Based on HACA’s reported financials presented in July 2018, as well
as Director Wilbourn’s conduct that year, the Mayor and City Council were on notice
that Director Wilbourn and the HACA staff had increased efforts to increase its
income flow by aggressively seeking, often without affording tenants with proper
due process, payments from residents under threat of eviction, demanded that the
City not inspect the properties, and decreased services it had previously budgeted
and provided for its residents.
111. Director Wilbourn acknowledged in the July 2018 testimony before the
City Council that, indeed, it was the fact that Mayor Buckley and the City Council
were so willing to work with HACA that made the extra funds available:
It has been a sea-change, it really has, in working very closely
with the City and the administration and council members to
say, hey, this is all I’ve got. This is where mine is going. I can
bridge, but I need some wrap around services from other
folks getting some money, because my funding really is housing.
(Emphasis added).
112. By foregoing their legal obligation to inspect and license HACA’s
properties as required by the City Code and State Law, Mayor Buckley and the City
Council knowingly enabled Director Wilbourn to decrease the quality standard of
housing and services to HACA residents.
113. Once the City officials stopped carrying out their legal obligation to
evenly enforce City Code on HACA, they stepped up their praise of Director
43

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 44 of 111

Wilbourn. To close the July 2018 meeting, Mayor Buckley expressed: “Thank you
so much for making our City better, we really appreciate all of this.”
The HACA Properties Continue their Downward Spiral
114. Newtowne Twenty has been in a “near-demolition” status for half a
decade. In 2015, then HACA Executive Director Vincent Leggett was asked why
there was such a deficit with regard to Newtowne 20. He responded as follows:
Why continue to put tens and twenties and hundreds of thousands
of dollars into Newtowne 20 when it might end up in the county
landfill? And so we are trying to keep it operational enough.
And HUD has a process called demolition and disposition that
once we move the pre-development work along a little further,
HUD will not hold a lack of occupancy against our scoring or our
funding. So that’s what we are really trying to do. So that’s what
it is, it’s just not throwing off the rent. They have gas lines, water
lines, high maintenance, so that’s really part of it, it’s not fully
occupied.
(Emphasis added).
In other words, once the application was accepted, Newtowne 20 could be
demolished. Director Leggett closed by explaining that, regarding Newtowne 20,
“the physical plant is collapsing on us.” That application is still pending five (5)
years later.
115. In August 2018 the Newtowne 20 residents were without power or with
only partial power for days when the aging electrical infrastructure suffered an
outage that required Baltimore Gas and Electric to spend time locating an antiquated
replacement part. The Salvation Army responded to provide meals, and the City
44

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 45 of 111

opened the Pip Moyer Recreation Center as a “cooling zone” due to the significant
summer heat.
116. The HACA Properties as a whole, and specifically Newtowne 20, have
continued their decline. In a January 2019 city council meeting, Director Wilbourn
explained to the Mayor and City Council that Newtowne Twenty is so old that it has
gotten to the point where they simply can’t patch it anymore, and they must
redevelop the property.
The impetus for RAD was the continually deferred maintenance and
deteriorating condition of public housing nationally, and Newtowne
is in that place. Newtowne was built in 1971. I don’t know the
history, but I haven’t seen any indications of major capital placed
into it. That is why we have a fragile electrical system. It’s those
kinds of things that you can’t patch anymore, that you have to move
out to redevelop. So we are providing the safe and sanitary housing
in Newtowne in operable condition. And we are trying to move as
quickly as possible to empty out the units, and we think that will
happen in August of this year.
Despite these representations, no additional federal funds have been allocated, and
these properties continue to degrade.
117. One month prior to those comments, on December 6, 2018, The Capital
Gazette reported then Speaker Mike Busch had conducted a walk-through of the
Newtowne 20 development. He was quoted as follows: “I don’t really know how
people live in that housing,” Busch said. “It is by far in my estimation the greatest
challenge in the county.” (Emphasis added).

45

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 46 of 111

118. Despite this grounded assessment by Speaker Busch, just weeks later,
at the same January 2019 meeting, well after she, the Mayor, and other members of
the City Council had agreed to refuse further enforcement of the City Code on
HACA, Alderwoman Henson expressed her view of Director Wilbourn and her
actions as they related to Newtowne 20:
Can I just commend your leadership and the board’s support for
you on that. It would have been really easy to feel like something
new is coming just around the corner and to not do all the efforts
that you all did to make sure that the residents who are there now
have a safe place to live. To go into the vacant units, to listen to
people’s concerns like that is … and to put the resources there
when you knew it was something that you were going to
demolish. It really shows your commitment to the quality of life
of the residents. So for whatever it’s worth I just want to
commend you for that.
Alderwoman Henson’s comments belie reality.

Her praise reflects the City’s

recklessly deliberate indifference to the actual status of the properties and the danger
it poses to the tenant residents of the City. Her description patently misrepresents
the dire conditions of the HACA Properties, and only represents what she, the
Mayor, and City Council want the public to believe about the public housing in
Annapolis, thus maintaining the status quo.
The Mayor and City Council are Aware of Continuing Violations of City
Code and Have Not Only Ignored the Violations But Have Taken Affirmative
Steps to Avoid Enforcement of the City Code on HACA

46

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 47 of 111

119. On February 27, 2019 and March 4, 2019, the Senior Inspector of the
City of Annapolis was provided notice of alleged violations of the City Code on
HACA Properties by representatives of Plaintiffs Ms. Smith and Ms. Clark.
120. Consistent with the City’s new policy pertaining to HACA properties,
the Senior Inspector did not respond to the properties to inspect the alleged
violations.
121. The central complaint by Ms. Smith and Ms. Clark to HACA was
related to mold and moisture, as well as filth in the ventilation systems of their
apartments that were affecting the air quality due to years of failed maintenance by
HACA. Specifically, Ms. Smith and Ms. Clark complained, and as was confirmed
by a certified industrial hygienist, that the Housing Authority had fraudulently and
negligently covered up mold that was present in their shared attic, by simply sealing
the attic shut. Furthermore, it was alleged that the mold was caused by an ongoing
roof leak, and that not only did the leak need to be stopped at its source, but to make
the apartment suitable for occupancy, the attic also needed to be professionally
remediated.
122. The ventilation ducts which were on separate loops within the
apartments, and therefore independent of one another, nevertheless had nearly
identical characteristics. Neither appears to have been cleaned at any time since the
buildings were erected in 1971:
47

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 48 of 111

Figure 2 - Apartment 813 A Ventilation Duct

48

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 49 of 111

Figure 3 - Apartment 813 B Ventilation Duct

49

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 50 of 111

123. In response, HACA personnel blamed Ms. Smith and Ms. Clark for
failing to clean their home and failing to properly use their ventilation systems in the
home, specifically in the bathroom where humidity and moisture collects on the
walls as a result of normal use.
124. Ms. Smith presented a letter from her doctor explaining her condition:
“She has had testing that shows she has an allergy to mold and dust. She has severe
symptoms related to this allergy and it [was] worsening a severe medical condition.”
125. Based on these reports, the Senior City Inspector advised HACA of the
appropriate way to remediate the mold, but given the restrictions placed on her by
Mayor Buckley, the City Council, and/or their agents, she could only recommend to
HACA the appropriate course of action based on how the City enforces its Code on
all of the other landlords in the City.
126. On February 27, 2019 regarding the apartment of Ms. Smith, the Senior
Inspector provided the following notice to Director Wilbourn and other senior
HACA personnel:
I have received the attached reports of mold in the above
referenced unit which is located in Newtowne Twenty (HACA)
properties. 7

7

It is worth noting that the Senior Inspector for the City specifically refers to
Newtowne Twenty as “(HACA) properties.” The indication of a specific landlord
otherwise licensed in the City would not require such identification except when,
as here, that landlord is going to be treated differently by the City.
50

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 51 of 111

Based on the report, I would recommend having resident
relocated, hire a licensed accredited mold remediation company
to perform the work and then have the unit re-tested to clear of
any further mold spores before having resident move back in to
the unit.
If you have any further questions, please don’t hesitate to contact
our office.
(Emphasis added). As reflected in this email, it is the policy of the City to require
landlords to relocate tenants when hazardous conditions exist within the rented
apartment.
127. On March 4, 2019, regarding the shared attic of Ms. Smith and Ms.
Clark, the Senior Inspector provided the following notice to Director Wilbourn and
other senior HACA personnel:
I have received the air quality samples for this attic area (same
sampling since a shared space above both units) for both 813-A
& B Betsy Ct. I would suggest that the mold remediation be
conducted in the attic area as well since this is the highest levels.
If you have any questions, please don't hesitate to contact me.
This requirement to remediate the mold in the attic was never followed by HACA.
128. On February 18, 2019, March 1, 2019, March 6, 2019, March 14, 2019,
March 15, 2019, and again on March 20, 2019, Mayor Buckley, his staff, and the
City Council were again placed on notice of the ongoing violations of the City Code
and the failure of the City Inspector to take action, and were aware at that time that
residents of the HACA Properties had requested the City respond to the Properties.
51

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 52 of 111

129. The City’s website reflects that on March 5, 2018, just days after Ms.
Clark and Ms. Smith sought the assistance of the City regarding their apartments,
and after Mayor Buckley had been placed on notice of the alleged violations of the
City Code, the City created a “file” on their website titled “Discussion on MOLD in
Housing Authority Properties.” This “file” reflected the scheduling of a meeting of
the Mayor and City Council on March 21, 2019.
130. On March 21, 2019, at the request of the Mayor and the City Council,
Dr. Clifford Mitchell, the Director of the Environmental Health Bureau at the
Maryland Department of Health was summoned to City Hall to speak before the
Council. Seemingly unaware of why he was there, he explained that “he was asked
basically to come and talk about mold.”
131. He spoke to the City Council for approximately one hour about the
various types of mold, air quality in indoor spaces, and the dangers to persons who
are sensitized to mold exposure. At the conclusion, the Mayor and Council Members
asked questions and made comments.
132. Dr. Mitchell explained the dangers of failing to hire professional mold
remediators to abate mold conditions and stressed that once mold is discovered it
needs to be remediated professionally. HACA has repeatedly failed to properly
remediate mold and other hazardous conditions present on their properties.

52

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 53 of 111

133. The Mayor and City Council were aware of the allegations Ms. Smith
and Ms. Clark had made regarding mold and air quality issues in their apartments.
HACA management, to include Director Wilbourn, responded directly to
representatives of Ms. Smith and Ms. Clark, and the Mayor and City Council were
aware of those HACA responses.
134. Instead of following their procedure to inspect the property, the Mayor
and City Council called the March 21, 2019 meeting to talk about the alleged
violations that neither they nor their Senior Inspector had ever actually observed or
inspected.
135. It is the policy and practice of Mayor Buckley and the City Council to
refuse to enforce on the Housing Authority the same standard that is enforced on
every other landlord in the City of Annapolis by administering the City Code evenly
regardless of the race of the tenants.
136. The certified industrial hygienist hired by Ms. Smith to inspect her
apartment confirmed that the mold in the bathroom ceiling was directly related to
the mold that had formed in the attic above, and was the result of a leak in the roof.
At the time of the March 21, 2019 meeting, Mayor Buckley and the City Council
had received copies of the correspondence from Ms. Smith’s representatives which
included the photos in Figure 4, 5, and 6 below.

53

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 54 of 111

Figure 4 – Mold on the Bathroom Ceiling of the Smith Apartment

Figure 5 – Mold on the Bathroom Ceiling of the Smith Apartment
54

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 55 of 111

Figure 6 – Black Mold in the Attic immediately above the Bathroom Ceiling
that was not remediated, but instead sealed into the Attic in the Smith
Apartment days after this photo was taken.
137. In March 2019, Mayor Buckley, as well as the rest of the City Council,
were on notice of the mold, air quality, and ventilation issues found in the Smith and
Clark apartments. The Mayor and City Council were aware that HACA:
a. Had refused to remediate the toxic levels of mold found in the attic with
professional remediators;
b. Had simply sealed the mold into the attic, an action that failed to
address the ongoing significant danger to health and safety of the Smith
and Clark families;
55

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 56 of 111

c. Had threatened the Smith and Clark families with criminal trespass if
they entered their attic spaces which were in fact a part of the Smith and
Clark apartments according to their leases as well as HUD regulations;
d. Had refused to correct the source of the moisture which caused the mold
in the first place; and
e. Had refused to clean the ventilation ducts which were contributing to
the hazardous air quality.
138. These actions were in direct contravention of what Dr. Mitchell had
recommended, yet Mayor Buckley and the City Council took no further action to
enforce the City Code or to mitigate the health and safety dangers created through
HACA’s actions.
139. Mayor Buckley concluded the March 21, 2019 meeting by further
confirming that HACA had dictated to the City how it would handle the mold issues,
instead of holding HACA to the same standard that the City holds the rest of its
landlords:
So, our housing authority is telling us as soon as they find an
incident, or as soon as it is reported, they go to its source, mitigate
the moisture, let it dry, and that’s how they treat it, they treat it
sectionally. So, and then they say, it reoccurs in the bathroom.
So, how many people in this group, put your hand up if you have
mold in your bathroom. [Mayor and one other raise hands.
Laughing.] Just us two? Us three? Geez. Alright. So, thank
you Mr. Mitchell, when is your next convention? I want to come
party with you guys.
56

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 57 of 111

(Emphasis added).
140. Neither the Mayor, the City Council, nor the City Inspector ever
responded to the Smith and Clark properties to enforce the standards of the
Annapolis City Code on the Housing Authority.
Annapolis Receives Community Development Block Grants (“CDBG”) –
CDBG Anti-Discrimination Certification and Regulatory Obligations
141. For decades, Annapolis has been a recipient of millions of dollars in
federal CDBG funds for low and moderate-income benefit, including housing in the
City, among other purposes. CDBG is one of many federal community planning and
development grant programs in which Annapolis participates.
142. One of the stated goals of planning and development programs,
including CDBG, is “to develop viable urban communities by providing decent
housing and a suitable living environment and expanding economic opportunities
principally for low- and moderate-income persons.” 24 C.F.R. § 91.1 (a)(1).
“Decent housing includes … increasing the availability of permanent housing in
standard condition and affordable cost to low-income and moderate-income
families, particularly to

members of disadvantaged minorities, without

discrimination on the basis of race, color, religion, sex, national origin, familial
status, or disability.” 24 C.F.R. § 91.1 (a)(1)(i) (emphasis added).. The U.S.
Congress explained further that “[a] suitable living environment includes …
reducing the isolation of income groups within a community or geographical area
57

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 58 of 111

through the spatial deconcentration of housing opportunities for persons of lower
income and the revitalization of deteriorating or deteriorated neighborhoods….” 24
C.F.R. § 91.1 (a)(1)(ii).
143. Despite U.S. Congressional goals of using federal CDBG funds to
develop and increase “the availability of permanent housing in standard condition,”
to citizens of Annapolis who are “members of disadvantaged minorities, without
discrimination on the basis of race, color, religion, sex, national origin, familial
status, or disability,” the City of Annapolis has adopted policies that are in direct
contradiction to those federally-stated goals. By refusing to inspect the HACA
Properties, Mayor Buckley and the City Council have adopted a policy of racial
discrimination against a protected class of Annapolis citizens.
144. Since the actions were undertaken by the City to destroy the Old 4th
Ward Community, there has been a near constant policy – spoken and unspoken –
to perpetuate the racial segregation of the citizens of Annapolis. Mayor Buckley
and the City Council have reinforced the City’s dedication to further undermining
the goals of the U.S. Congress by, among other actions and inactions, refusing to
take affirmative steps to redevelop the aging public housing infrastructure that is
currently in place, and instead allowing the besieged Housing Authority to flounder,
and its residents to suffer the consequences.

58

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 59 of 111

145. As a condition of payment and receipt of CDBG funds, Annapolis
provides HUD annual written certifications including Annapolis’ “Specific CDBG
Certifications,” which include a certification that the City’s policies and actions will
be in “Compliance with anti-discrimination laws.” That certification of the City of
Annapolis includes the following language:
Compliance With Anti-discrimination laws – The grant will be
conducted and administered in conformity with title VI of the
Civil Rights Act of 1964 (42 U.S.C. 2000d), the Fair Housing
Act (42 U.S.C. 3601-3619), and implementing regulations.
146. Congress has provided HUD with authority to administer the FHA,
including authority to issue regulations interpreting the Act. 42 U.S.C. §§ 3608(a).
147. HUD’s regulations provide that, “[a] practice has a discriminatory
effect where it actually or predictably results in a disparate impact on a group of
persons or creates, increases, reinforces, or perpetuates segregated housing patterns
because of race, color, religion, sex, handicap, familial status, or national origin.”
24 C.F.R. § 100.500 (emphasis added).
148. HUD’s disparate impact rule applies to individuals, businesses, and
government entities, and applies here to both the City of Annapolis and HACA.
The City’s Affirmative Duty to Further Fair Housing
149. As a yearly recipient of CDBG funding and by its execution of “Local
Grantee Certification” to HUD, Annapolis consents annually to a mandatory duty to
“affirmatively further fair housing” in the City (hereinafter “AFFH duty”).
59

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 60 of 111

150. As a recipient of CDBG funds, the AFFH duty of the City of Annapolis
requires the City to:
a. conduct an analysis of impediments to fair housing choice;
b. take appropriate actions to overcome the effects of impediments
identified through that analysis; and
c. maintain records reflecting the analysis and actions.
24 C.F.R. Part 91, Exhibit H, 1-2, HUD’s Fair Housing Planning Guide (“FHPG”). 8
HUD’s “Basically CDBG” Course Training Manual for Annapolis
151. For the past twelve (12) years, HUD has annually provided Annapolis
with a “Basically CDBG” Course Training Manual (hereinafter, “CDBG Manual”)
to assist the City in administering the CDBG program. The latest version of the
CDBG Manual was published in July 2012.
152. HUD’s CDBG Manual, Section 19.2.1 states, “To be in compliance, the
grantee must adhere to all the basic tenets of fair housing and equal opportunity
regulations. To demonstrate support for ensuring these tenets, grantees must endorse
in attitude and deed all regulations for fairness in the provision of CDBG funded
programs and projects.” Exhibit I, p. 19-1.

8

The full FHPG can be found at the following web address:
https://www.hud.gov/sites/documents/FHPG.PDF
60

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 61 of 111

153. HUD’s CDBG Manual Section 19.1.1 states:
Grantees should be aware that fair housing provisions apply to
the locality as a whole and not just those activities that are CDBG
funded; and that implementing fair housing activities is an
essential part of the CDBG responsibilities. No person shall be
subjected to discrimination because of: race, color, religion,
sex, disability, age, familial status, or national origin.
Fair housing actions should increase housing opportunities and
affirmatively promote fair housing throughout the entire housing
market at all income levels. These activities may include
independent actions by the grantee or cooperative ventures
with housing related industries, such as mortgage lenders, home
builders, and local non-profits working in housing. The grantee
is expected to take progressive actions to further fair housing
with each CDBG project.
Exhibit I, p. 19-6 (emphasis added).
154. HACA is a recipient of CDBG funding through the City’s grant. The
City’s failure to enforce its Code on HACA has subjected the HACA property
tenants to racial discrimination in violation of HUD requirements for entities that
received CDBG funds.
155. In order to receive CDBG funds, the City is required to affirmatively
act, which in the present case requires “independent actions” by the City with
housing related industries to redevelop the neglected HACA properties.

61

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 62 of 111

HUD’s Fair Housing Planning Guide Provided to Annapolis
156. Since 1996, Annapolis has had knowledge of and access to HUD’s
FHPG which provides information to federal Entitlement Jurisdictions like
Annapolis on how the City may take steps to affirmatively further fair housing.
157. The FHPG provides that an “analysis of impediments to fair housing
choice” (“AI”) involves “[a]n assessment of conditions, both public and private,
affecting fair housing choice for all protected classes.” Initially in 2006, and then
again in 2015, the City submitted an Analysis of Impediments Report (“AI Report”)
to HUD officials.
158. The 2006 AI Report identified Impediment No. 6 as follows:
There is overlap between census tracts containing high
percentages of low-income households and large numbers of
members of the protected classes indicating that the lack of
affordable housing has a disproportionate impact to members
of the protected classes making their affordability problem a fair
housing problem.
(Emphasis added). Since this was acknowledged by the City in 2006, little
has changed.
159. Nearly a decade later, Mayor Pantelides and the City Council submitted
their 2015 AI Report, which included critical census data that identified significant
segregation within the City and confirmed that little had been done to address these
very significant issues.

The 2015 AI Report provided: “In response to the

62

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 63 of 111

dissimilarity, isolation, and exposure data, the City will continue to incorporate
strategies to address segregation and encourage diversity across the region.”
To Receive HUD CDBG Annual Funding the City of Annapolis Falsely
Represented to HUD that the City Code is Enforced on the HACA Properties
160. As mandated by HUD, in order to receive federal CDBG funding, the
City is required to file annually a Consolidated Annual Performance and Evaluation
Report (“CAPER”).
161. The purpose of the CAPER is to report the City’s success in meeting
the housing and community development goals and objectives contained in its FiveYear Consolidated Housing and Community Development Plan (the “Five-Year
Plan”), and to report on the prior fiscal year’s successes in meeting those goals.
162. The last Five-Year Plan was submitted on May 15, 2015. In that plan,
submitted by Mayor Pantelides one year prior to the commencement of HACA
Property inspections, the Mayor certified the following:
Because the City licenses and inspects all rental units (except
HACA properties) annually, most of the rental units are
considered in good repair. Specifically, all Section 8 properties
are inspected twice; since both the City and HACA inspect the
Section 8, existing and project-based units. Thus, the City’s
affordable housing stock is generally considered not to be
substandard in nature.
(Emphasis added).
163. As discussed supra, Mayor Pantelides was the first Mayor to enforce
City Code on the HACA Properties. As a result, when the City submitted its CAPER
63

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 64 of 111

in 2016 and 2017, the language reflected that change, and the “(except HACA
properties)” language was removed.
164. As discussed supra, Mayor Buckley, with the agreement of Director
Wibourn and the City Council, reversed Mayor Pantelides policy. However, when
the Mayor and City Council submitted their 2018 CAPER on September 28, 2018,
they falsely reported as follows:
Because the City licenses and inspects all rental units
annually, most of the rental units are considered in standard
condition. All Section 8 properties are inspected twice; since both
the City and the Housing Authority inspect the Section 8, existing
and project-based units and all public housing units are
inspected both by the City and HACA. Thus, the City’s
affordable housing stock is generally considered not to be
substandard in nature.
(Emphasis added). This statement is misleading for at least two reasons. First, as
discussed extensively supra, the City does not license or inspect any of the HACA
Properties, and in fact, all of the HACA Properties are unlicensed at this time.
Second, regarding the public housing apartments in the HACA Properties, neither
the City nor HACA inspects all of these apartments annually. During the spring of
2018, HACA defunded or otherwise removed its full-time inspector on staff. The
HACA properties are only visited by HACA staff when maintenance complaints are
received from tenants, if ever.
165. HUD’s inspection of the HACA Properties affect a maximum of 20%
of the HACA apartments in total, and HACA has up to four (4) months of advanced
64

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 65 of 111

notice to ensure those apartments are prepared for the inspection. Additionally, and
as discussed supra and acknowledged by the City, the HUD inspections are held to
a significantly lower standard than those conducted by the City Inspector.
Demographic Context and Disparate Impact
166. The Housing Authority of the City of Annapolis has six low-income
housing properties: Bloomsbury Square; Harbour House; Newtowne Twenty;
Eastport Terrace; Robinwood; and Morris H. Blum Senior Apartments. As its name
indicates, Morris H. Blum Senior Apartments is restricted primarily to older persons.
167. Racial composition of these low-income housing developments is not
directly available from public sources, but the racial composition of the Census
block (the immediate neighborhood) where each property is located can be
determined from the 2010 Census. The Census blocks for each of the six lowincome housing properties are identified using the street addresses listed by the
Housing Authority of the City of Annapolis. The Census Bureau’s American
FactFinder street address function identifies Census blocks based on street
addresses.
168. Five of the Housing Authority properties are located in majority Black
Census blocks. Three of the Housing Authority properties (Bloomsbury Square,
Newtowne Twenty, and Robinwood) are in blocks where more than 90% of
residents are Black. Whites comprise 58.9% of the residents in the block where
65

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 66 of 111

the Morris H. Blum Senior Apartments is located, 16.3% of the residents are Black
and 21.3% of the residents are Latino.9 This is the only Housing Authority property
designated for seniors, and the only Housing Authority property located in a majority
White Census block.
169. The six Housing Authority properties are in blocks where Blacks
comprise 67.5% of the residents, Whites comprise 22.6% of the residents, and
Latinos comprise 5.7% of the residents. In contrast, in the City of Annapolis as a
whole, Whites accounted for 53.5% of residents, Blacks accounted for 25.7% of
residents, and Latinos accounted for 16.8% of residents. Residents of the six
Housing Authority properties are disproportionately Black. The proportion of Black
residents in these properties is 2.6 times greater than the proportion of Black
residents in the City of Annapolis.
170. The five Housing Authority properties not designated as senior housing
are in blocks where Blacks comprise 71.5% of the residents, Whites comprise 19.7%
of the residents, and Latinos comprise 4.4% of the residents. As noted above, Whites
accounted for 53.5% of residents in the City of Annapolis, Blacks accounted for
25.7% of residents, and Latinos accounted for 16.8% of residents. Residents of the
five Housing Authority properties not designated as senior housing are
disproportionately Black. The proportion of Black residents in the neighborhoods

9

White refers to Non-Hispanic Whites.
66

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 67 of 111

where these properties are located is 2.8 times greater than the proportion of Black
residents in the City of Annapolis.
171. The City of Annapolis Five Year Consolidated Housing and Community
Development Plan Federal Fiscal Year 2015-2019 identifies the racial distribution
of residents in the public housing properties. Of the 831 public housing units,10 759
(91.3%) were identified as occupied by Blacks and 58 (7.0%) were occupied by
Whites. 11 A separate table reports 20 Hispanic residents. 12 The race of the Hispanic
residents is not reported. This report was submitted in May 2015, so these numbers
presumably represent the public housing population in 2015.

In 2010, Whites

accounted for 53.5% of residents in the City of Annapolis, Blacks accounted for
25.7% of residents, and Latinos accounted for 16.8% of residents. Based on the
City’s report and the 2010 Census data, the proportion of Black residents in these
properties is 3.6 times greater than the proportion of Black residents in the City of
Annapolis.

10

This figure of 831 public housing units references the additional HACA units
which are located outside of the HACA managed properties in other public/private
developments, and incipiently, are inspected by the City.

11

Table 24, The City of Annapolis Five Year Consolidated Housing and
Community Development Plan Federal Fiscal Year 2015-2019.

12

Table 25, The City of Annapolis Five Year Consolidated Housing and
Community Development Plan Federal Fiscal Year 2015-2019.
67

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 68 of 111

Harm to Plaintiffs
General Harm to All Plaintiffs
172. All the Plaintiffs have suffered harm in this case. Each of the Plaintiffs
to a varying degree has suffered the loss of personal property that was ruined by
water or sewage intrusion due to structural failures, mold, or other actions or
inactions of HACA or City personnel.
173. When dealing with HACA, at no point has any Plaintiff been offered
the opportunity to be relocated into an apartment that was deemed safe for habitation
by the City of Annapolis or that is currently licensed by the City.
The Smith Family
174. Prior to living at her present address of 813 Betsy Court, Apt. B, in
Newtowne 20, Ms. Smith and her three minor children lived at 1125 Madison Street,
Apt. B3, in Harbour House. During the winter 2015 and spring 2016, Ms. Smith
discovered water seeping into the corner of her bedroom from a leak in the
foundation and wall outside of the apartment. She also discovered raw sewage
leaking into her bathroom from the apartment above.
175. The moisture from the leaks led to significant mold growth behind the
walls and ceilings of the bedroom and bathroom of the apartment. Despite numerous
complaints to HACA about the presence of the water and mold, HACA refused to
hire a professional mold remediation company to remediate the mold, but instead
68

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 69 of 111

simply wiped the mold away with bleach, and directed Ms. Smith to do the same if
the mold returned.
176. Between May 16 and May 19, 2016, the City inspectors completed their
initial inspections of the Harbor House development. During that inspection, the
City found multiple violations of the City Code. The apartment did not have any of
the AC powered smoke detectors required by the City Code.
177. The City inspectors failed HACA on the May 2016 inspection but did
not require the relocation of Ms. Smith and her family at that time and issued the
rental license to HACA despite the failures.
178. One month later, in June 2016, an attorney for Ms. Smith contacted
HACA and advised them of the presence of toxic mold in the air at Ms. Smith’s
apartment. HACA refused to act to remediate the mold.
179. In August 2016, the attorney for Ms. Smith contacted the City’s Senior
Property Maintenance Inspector Mary E. Emrick. As a result of the correspondence,
a follow-up inspection was conducted of Ms. Smith’s apartment. During that
inspection on August 3, 2016, HACA was cited for numerous additional violations
of the City code, including the presence of mold and sewage leaking through the
ceiling of the Smith bathroom, which was located on the basement floor. As a result
of this August 2016 inspection, the City issued a Notice of Inspection that provided
HACA 30 days to fix the violations. In accordance with City policy, the City
69

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 70 of 111

Inspector directed HACA to relocate Ms. Smith and her family for the duration of
the remediation. See Exhibit J.
180. Instead of relocating the Smith family temporarily, shortly after the
receipt of the notice, the Smith family was moved to an entirely different
development, where they continue to reside currently at 813 Betsy Court in
Newtowne 20.
181. Later in 2016, and as discussed infra, Plaintiff Tiamani Johns and her
infant son were moved into the Smith’s old apartment at Harbour House.
182. Shortly after moving into the Newtwone 20 apartment, Ms. Smith
complained to HACA maintenance staff regarding mold in the new apartment as
well. The mold growth was constantly reappearing in the upstairs bathroom.
Maintenance would arrive after calls, and simply state that the mold growth was Ms.
Smith’s fault because she did not use the ventilation system in the apartment to
control the moisture.
183. Ms. Smith retained a certified industrial hygienist to conduct air quality
tests of the apartment and the attic directly above the bathroom. The testing revealed
high concentrations of toxic mold present in the air in both the living space of the
apartment, as well as the attic. Some of the highest and most dangerous types of
mold discovered in the apartment were in the attic.

70

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 71 of 111

184. Ms. Smith’s children have each on several occasions suffered nose
bleeds and headaches as a result of exposure to the conditions of the apartment. Ms.
Smith herself had significant health issues since moving into the apartment to
include breathing difficulties related to her asthma. She advised HACA of these
medical problems, but they refused to move her to an apartment that is inspected by
the City.
185. In February 2019, Ms. Smith put HACA on notice of the mold present
in the apartment. She also made the City Inspector’s office aware of the mold as
well, but as discussed supra, unlike its response in 2016 which subjected HACA to
further inspections and forced HACA to act for the benefit of the tenants, the City’s
new policy prevented the City Inspector from enforcing the City Code on the
Housing Authority. As a landlord, HACA was then permitted to respond as it
desired, instead of being held to the standard of all other landlords in the City.
186. HACA chose to ignore the City’s guidelines regarding remediation of
mold. After confirming the mold presence in the attic, HACA’s maintenance
personnel used caulk to seal the wood hatch to the attic shut. In doing so, HACA
personnel threatened Ms. Smith that if she accessed her attic – the space directly
above her bathroom – she would be guilty of trespass.
187. Pursuant to HUD regulations as well as Ms. Smith’s lease, she had the
right to access the attic crawl space.
71

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 72 of 111

188. During the time period while HACA’s personnel and contractors were
making these alterations to her apartment, HACA relocated the family to a hotel.
The family lived in the hotel for nearly a month during the school year, with no
access to the children’s school transportation. The children missed some days of
school during this time period. Additionally, Ms. Smith, who had recently begun a
new job, was forced to quit or be fired as a result of the difficulties related to the
sudden relocation and the transportation difficulties faced by her children.
189. Ms. Smith and her children’s mental and physical health have been
greatly affected by the failures of both HACA and the City, and those failures have
caused them significant damage.
190. Ms. Smith and her family live in an unlicensed rental apartment, and no
effort has ever been made by the City to advise her that the apartment is not licensed.
Despite HACA having failed the 2016 inspection, she and her family were never
relocated from the home in accordance with the requirement of the City Policy at the
time.
The Clark Family
191. Ms. Clark and her two minor children live at 813 Betsy Court,
Apartment A, in the apartment immediately adjoining the Smith family home.
192. In 2017, Ms. Clark’s oldest son suffered an accident. As a result of the
accident, he was forced to spend significant time in recovery at home. However, the
72

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 73 of 111

mold and moisture presence in the home was so great, that he could not stay at the
Newtowne 20 residence, the Clark family was forced to live elsewhere for
approximately six months while he recovered.
193. HACA was on notice of the terrible condition of the apartment during
this time when the family was forced to live elsewhere.
194. During their time living at the Newtowne 20 apartment, the family has
been plagued by plumbing and sewage leaks behind the walls. On three (3) separate
occasions, the ceiling on the first floor below the bathroom collapsed due to leakage
from the bathroom.
195. During the last City inspection of the property in June 2016, it was also
discovered that the property did not have adequate smoke detectors as required by
City Code. In fact, two of the bedrooms had no working smoke detectors at all, and
the apartment did not have any of the AC powered detectors required by the City
Code. It was discovered that the electrical outlets in the kitchen were not properly
grounded which presented a serious safety risk. However, the City did not enforce
the City Code on HACA as it does other landlords, and instead of requiring HACA
to relocate the Clark family, they were left in the home with the violations unfixed.
To date, the apartment still does not have the smoke detectors required by City Code.
196. The Smith and Clark apartments share the same attic. In March 2019,
Ms. Clark put HACA and the City on notice that she too had hired a certified
73

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 74 of 111

industrial hygienist to test her apartment. Ms. Clark, along with Ms. Smith, also
provided the City and HACA with photographs of the ventilation system in their
homes, which are reflected in Figures 2 and 3 supra.
197. As with Ms. Smith’s apartment, and as a direct result of the City policy
not to inspect HACA properties, the City refused to respond to inspect Ms. Clark’s
apartment and enforce the City Code on HACA as a landlord.
198. Ms. Clark and her children’s mental and physical health have been
greatly affected by the failures of both HACA and the City, and those failures have
caused them significant damage.
199. Ms. Clark and her family live in an unlicensed rental apartment, and no
effort has ever been made by the City to advise her that the apartment is not licensed.
Despite HACA having failed the 2016 inspection, she and her family were never
relocated from the home in accordance with the requirement of the City Policy at the
time.
The Johns Family
200. Ms. Johns and her son live at 1125 Madison Street, Apartment B3 in
Harbour House, and as indicated supra, Ms. Johns was moved into this apartment
just months after the Smith family was relocated.
201. Ms. Johns has made numerous complaints to HACA regarding the
continued presence of mold in her apartment.
74

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 75 of 111

202. Ms. Johns has also contacted the City regarding the mold in her home
however, the City refused to respond to inspect Ms. Johns’ apartment and enforce
the City Code on HACA as a landlord and only forwarded Ms. Johns’ complaint on
to HACA.
203. Ms. Johns and her child’s mental and physical health have been greatly
affected by the failures of both HACA and the City, and those failures have caused
them significant damage.
204. Ms. Johns and her family live in an unlicensed rental apartment, and no
effort has ever been made by the City to advise her that the apartment is not licensed.
The Holliday Family
205. Ms. Holliday and her three (3) minor children live at 808 Brooke Court,
Apartment B, at Newtowne 20, where she has resided since 2017.
206. Brooke Court is located approximately 200 yards from Betsy Court
which is also located in Newtowne 20. Prior to 2017, Ms. Holliday lived at 804
Betsy Court, Apartment C. This was a basement level apartment.
207. In the June 2016 inspection of 804 Betsy Court, where Ms. Holliday
was living at the time, the City Inspector discovered a number of violations in the
apartment. The City inspector discovered that none of the bedrooms had working
smoke detectors, and that none of the smoke detectors were AC powered as required
by the City Code. Flaking paint was discovered in the apartment, and Ms. Holliday’s
75

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 76 of 111

children were very young at the time. It was discovered that mold was present inside
the bathroom, and the City required HACA to repair the bathroom, prepare the area,
and paint. However, the City did not enforce the City Code on HACA as it does
other landlords, and instead of requiring HACA to relocate the Holliday family, they
were left in the home with the violations unfixed.
208. In 2017, while living at that apartment, there was an infestation of bats,
and as a result of that infestation, HACA moved the Holliday family out of the
apartment and into their present residence on the other side of the development. At
the time they were moved out of that apartment, none of the violations of the City
Code had been fixed by HACA.
209. Ms. Holliday’s children suffer from asthma, with which they were
diagnosed during the time they lived in the HACA properties. One of her sons
requires breathing treatments administered with a nebulizer numerous times a day
as a result of his breathing difficulties. HACA has been on notice of these issues
and has refused to accommodate the family.
210. On several occasions, the sewage pipes have backed up into the
Holliday home. On at least one occasion, a sewage pipe located in a closet of the
apartment ruptured, and leaked sewage all over the floor of the apartment. The leaks
in the plumbing have caused ongoing moisture issues in the walls and attic of the
home.
76

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 77 of 111

211. From the time she moved in, Ms. Holliday has complained to HACA
about persistent mold, moisture, and sewage in the home. In addition to these issues,
the ventilation systems have never adequately been maintained. Figures 7 and 8
are photographs of the ventilation ducting system in the Holliday apartment. This
building is on the opposite side of the development from that of Ms. Smith and Ms.
Clark, yet their ventilation systems, as illustrated supra, are equally vile.

77

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 78 of 111

Figure 7 - Apartment 808 B Ventilation Duct

78

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 79 of 111

Figure 8 - Apartment 808 B Ventilation Duct

79

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 80 of 111

212. Ms. Holliday and her children’s mental and physical health have been
greatly affected by the failures of both HACA and the City, and those failures have
caused them significant damage.
213. Ms. Holliday and her family live in an unlicensed rental apartment, and
no effort has ever been made by the City to advise her that the apartment is not
licensed. Despite HACA having failed the 2016 inspection, she and her family were
not relocated from the home at the time in accordance with the requirement of the
City policy.
The White Family
214. Ms. White and her three minor children live at 1164 Frederick Douglas
Street, which is located in HACA’s Eastport Terrace Property. Mr. D’Andre Covert
is Ms. White’s 18-year-old son who also lives with his mother and siblings at the
residence.
215. On May 12, 2016, the City inspected 1164 Frederick Douglas Street. It
was discovered that mold was present inside the bedroom ceiling, and the City
required HACA to repair the bedroom, prepare the area, and paint. However, the
City did not enforce the City Code on HACA as it does other landlords, and instead
of requiring HACA to relocate the White family, they were left in the home with the
violations unfixed. To date the mold is still present in the ceiling.

80

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 81 of 111

216. On numerous occasions since they have lived in the home, HACA has
been notified of the continued presence of mold growth on walls throughout the
home. Ms. White continuously cleans and paints over the mold, but due to the
condition of the structure and the moisture in the walls, she is unable to stop the
growth.
217. Ms. White’s 19-year-old son Mr. Covert has significant breathing
issues related to asthma. He takes medicine for his asthma through a nebulizer which
assists him to breathe. In the summer, when the mold content in the apartment air is
the highest, he has on numerous occasions been forced to sleep a few houses down
at a friend’s house where the mold in the apartment air is not as bad.
218. Ms. White and her children’s mental and physical health have been
greatly affected by the failures of both HACA and the City, and those failures have
caused them significant damage.
219. Ms. White and her family live in an unlicensed rental apartment, and
no effort has ever been made by the City to advise her that the apartment is not
licensed. Despite HACA having failed the 2016 inspection, she and her family were
never relocated from the home in accordance with the requirement of the City Policy
at the time.

81

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 82 of 111

The Dixon Family
220. Jonathan and Breonna Dixon lived at 960 President Street, Apartment
B3, in HACA’s Harbour House Property.
221. In May 2016, the City inspected the Dixon Apartment. The City cited
HACA for the presence of mold in the apartment, as well as peeling paint. However,
when they moved into the apartment in September 2016, HACA representatives
affirmatively misrepresented to the Dixons that there was never any mold found in
their apartment prior to September 2016.
222. Two years later, in May 2018, the Dixons advised HACA that there
appeared to be a leak in the foundation which was allowing rainwater direct access
to their bedroom. As a result of the moisture, mold immediately began to grow again
in the apartment.
223. Mr. Dixon had been diagnosed with multiple sclerosis (“MS”) in June
2016. At the time the Dixons moved into the apartment in September 2016, they
advised HACA representatives that Mr. Dixon had MS. In addition to his MS, he
had severe allergies to airborne mold and in the summer of 2018, he provided a
detailed doctor’s note and report regarding his mold sensitivity to his property
manager at HACA.
224. The Dixons advised HACA of the mold and moisture but were told by
HACA there was no mold present.
82

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 83 of 111

225. The Dixon family left town for a week at the end of May, but when they
returned, the mold had only gotten worse. The Dixons demanded that testing be
done, and as a result of HACA testing, significant levels of mold were found in the
apartment.
226. HACA provided the Dixon family a hotel room for approximately one
week while they were forced out of the apartment in May 2018.
227. HACA responded to the apartment and removed portions of drywall.
HACA did not, however, hire a professional remediator, which is the policy
requirement of the City.

As a result, the remediation was not completed in

accordance with the relevant professional guidelines. Once the Dixon family was
allowed back into the home, mold was still present in the air, and Mr. Dixon advised
HACA immediately that he was not able to live in the apartment due to his sensitivity
as a result of his allergy and his MS. Mr. Dixon could not be in the apartment for
more than a few minutes without intense physical reaction to the air quality.
228. When the Dixons complained again to HACA, they were told by the
property manager that HACA would not be spending any more money on the
apartment, and that the family could either move back in or “get a lawyer.” A HACA
representative also explained that they would not accommodate tenants who were
allergic to mold or other contaminants in the HACA Properties because allergies
were not a disability.
83

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 84 of 111

229. The Dixon family stayed out of the apartment for the remainder of June,
July, and August, and lived with family.
230. In July, Mr. Dixon visited an allergist about his breathing. As a result
of the testing, the allergist advised that Mr. Dixon had a heightened sensitivity to
elevated levels of mold in the air. HACA was again notified of Mr. Dixon’s MS
diagnosis and his sensitivity to the mold, but the Housing Authority refused to help
he and the family.
231. HACA was also put on notice of medical conditions related to the
Dixons’ youngest son. Due to a genetic disorder, he too was sensitive to the
conditions of the apartment, and HACA was provided information explaining that
condition which had been presented to them by the child’s doctor. HACA refused
to act based on that information.
232. During the summer of 2018, the Dixons contacted the Mayor’s office,
and made the City aware of the ongoing mold problem in their apartment. The City
did not send inspectors to the home. The City did not enforce its policies on HACA
as it would have any other landlord in the City.
233. In September 2018, Mrs. Dixon contacted the Mayor’s office and spoke
with a Ms. Janice. Mrs. Dixon was advised that: “Director Wilbourn will be coming
in for a meeting at the Mayor’s office that Monday [September 17, 2018], and that
she would bring the issue up with the Mayor at the meeting.” For the remainder of
84

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 85 of 111

September 2018, HACA did nothing to remediate the mold still present in the
apartment.
234. On October 3, 2018, the Dixons returned to the apartment to conduct a
visual inspection. When they entered the apartment, they were overcome by a strong
smell of sewage. They contacted HACA maintenance personnel who arrived at the
apartment. The maintenance person explained that the apartment on the third floor
had a sewage leak that leaked down into the second floor apartment above, and that
HACA had cleaned up the sewage from those apartments, but had not realized that
the leak had made it all the way to the Dixon apartment on the basement floor.
235. After maintenance cleaned the feces out of the ceiling of the Dixon
apartment, they dried the ceiling out, but claimed that there was no moisture and so
there was no reason to replace the drywall.
236. Ms. Dixon was advised that one of HACA’s policies is that if a tenant
is not living in the home for a period of time, HACA has the right to evict them and
move their belongings outside of their home and place them next to the dumpster.
During the time when the Dixons were not living in the apartment due to the mold,
HACA continued to threaten them with eviction due to their failure to be present in
the home despite the ongoing issues with the air quality.
237. On approximately October 5, 2018, Mrs. Dixon contacted Senior City
Inspector Mary Emerick. Ms. Emerick explained that HACA had told the City that
85

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 86 of 111

the work was completed and the whole apartment had been tested. In fact, only one
bedroom had been tested by HACA. Mrs. Dixon asked Ms. Emerick if the City
could come out and test the apartment and she replied that “HACA did not want any
government officials including the health department on their property without
HACA knowing.”
238. Shortly after the October 5, 2018 conversation with Ms. Emerick,
HACA maintenance personnel Francisco Castellanos reached out to Mrs. Dixon.
Mr. Castellanos explained that he had spoken to the City’s inspector, and that as a
result, he had ordered additional testing to be performed at the apartment.
239. On approximately October 19, 2018, Mr. Castellanos requested to meet
with the Dixons in person at their apartment to speak about the results of the air
testing. Mr. Castellanos advised the Dixons that due to health reasons, they could
not move back into their apartment. HACA explained that they would find a
different apartment for the family.
240. The Dixons had moved to public housing while Mr. Dixon, who could
no longer work due to his MS diagnosis, was waiting for his disability to be
approved. Public housing was a steppingstone at a difficult time in their lives. As a
result of HACA’s failure to take their complaints seriously, the family was forced to
live out of their car and with family for approximately six (6) months prior to
permanently leaving town.
86

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 87 of 111

241. During that difficult time, the City never responded to the Dixons’
complaints as required by the City Code and policy, State Law, and consistent with
the City’s enforcement of the City Code on other landlords in the City.
242. Mr. and Mrs. Dixon and their children’s mental and physical health
have been greatly affected by the failures of both HACA and the City, and those
failures have caused them significant damage.
243. The Dixons lived in an unlicensed rental apartment, and no effort was
ever made by the City to advise their family that the apartment was not licensed.
Glenn Rogers
244. Mr. Rogers lives alone in his apartment at the Morris H. Blum Senior
Apartments. He previously resided in Apartment 502. While at that apartment, he
endured numerous problems due to the lack of regular maintenance by HACA and
the failure of the City to enforce inspections on HACA. In 2014, the Capital Gazette
interviewed him regarding the water leaking through his ceiling and the resulting
smell related to HACA’s failure to properly fix the damage.
245. Beginning in 2018, Mr. Rogers began complaining to HACA about
discoloration in his ceiling that resulted from water damage and odors coming out
of his ventilation that were causing intense burning to his eyes and skin. HACA was
made aware of the issues immediately but did nothing to fix the source of the

87

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 88 of 111

problem in the building. Mr. Rogers was forced to seek treatment at the emergency
room and at his primary care physician on multiple occasions.
246. In approximately April 2018 one HACA maintenance worker painted
over discoloration related to the water damaged drywall to conceal the leak from
HUD inspectors.
247. In September and October of 2018, Mr. Rogers continued to reach out
to the Maryland Department of Health as well as the City of Annapolis Permitting
Office to seek assistance. Neither the Maryland Department of Health nor the City
responded in person or sent representatives to his apartment. The person he spoke
with at the City put him in contact with a member of the HACA maintenance staff
instead of sending a City inspector out to the property.
248. During the fall and winter of 2018/2019, Mr. Rogers often left his room
at night to escape the strong fumes in his apartment and would stand outside in the
fresh air.
249. Mr. Rogers had applied for a transfer in 2014 but had not received the
offer of a different apartment where the air was clean or that had been properly
licensed by the City.
250. During the time in his apartment, he was plagued by a cockroach
infestation. The insects would access his kitchen through holes in the ceiling that
HACA refused to patch, and no amount of cleaning could deter their presence.
88

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 89 of 111

251. In October 2018, maintenance personnel from HACA inspected the
apartment and discovered that the vents likely needed to be cleaned. Shortly
thereafter, Mr. Rogers purchased a home mold testing kit, and performed a test of
the growth he observed on the walls and other areas of the apartment. The results
confirmed the presence of toxic mold in the apartment. Mr. Rogers presented the
results of the test to HACA personnel, but nothing was done.
252. In December and January 2018/2019, HACA still refused to take action
to address the air quality issues within Mr. Rogers’ apartment. In February 2019,
Mr. Rogers provided HACA with a letter he had received from his Doctor which
stated that Mr. Rogers was:
having numerous severe symptoms that have been suspected to
be a reaction to some toxin or irritant (in his apartment) to which
he is sensitive. He has been undergoing evaluation by specialists,
and has been referred to the Environmental/Occupational Health
clinic at University of Maryland. Because these symptoms abate
when he is not in the Morris Blum building, he is being advised
to move out of the building.
Despite this notice, HACA did not move Mr. Rogers out of the building or even out
of the apartment.
253. In March 2019, Mr. Rogers again reached out to the City and explained
his problems with the apartment. This time, the Senior City Inspector Mary Emerick
responded by going to the apartment with a member of HACA’s staff, and days later,
Mr. Rogers was transferred to a new apartment in the building. No City inspection
89

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 90 of 111

was completed, and no rental license was issued by the City despite the visit to the
apartment by the City’s Senior Inspector.
254. Mr. Rogers’ mental and physical health have been greatly affected by
the failures of both HACA and the City, and those failures have caused him
significant damage.
255. Mr. Rogers lives in an unlicensed rental apartment, and no effort has
ever been made by the City to advise him that the apartment is not licensed. Despite
HACA having failed the 2016 inspection, he was never relocated from the home in
accordance with the requirement of the City Policy at the time.
The Camp Family
256. Ms. LaDawn Camp lives with her 14-year-old son at 801 Brooke Court,
Apartment C, in the Newtowne 20 Development. She has a chronic illness which
affects her immune system and makes her particularly sensitive to poor
environmental conditions. Since Ms. Camp has lived in her current unit, she has
been hospitalized on at least 3 occasions and has been on and off a peripherally
inserted central catheter line for approximately 3 years. HACA has been on notice
of this disability for the entire relevant period.
257. Ms. Camp’s unit is situated at the end of a row of garden style
apartments with a unit directly above her. The entrance to her home is at the bottom

90

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 91 of 111

of a steep grade with poor drainage. As a result, water pools outside of her front
entrance when it rains.
258. During her tenure at her current address, Ms. Camp has experienced
numerous maintenance issues. In 2013, the hot water heater in the unit above Ms.
Camp broke flooding the unit above and causing her living room ceiling to collapse.
Both Ms. Camp and her neighbor were relocated to a hotel for approximately two
weeks. The flooding greatly exacerbated the presence of mold in the apartment
which was previously present.
259. In 2014, Ms. Camp presented a letter to the management office from
her physician requesting the she be moved due to her weakened immune system. At
the time, Ms. Camp’s Social Security benefits had been reduced, her rent was not
adjusted accordingly, and she fell behind in her payments. As a result, HACA
refused her transfer request because she was “not in good standing.” The rent issue
was ultimately resolved, however, HACA never processed the transfer.
260. In July 2016, as part of the City inspections the City inspected her
apartment, and it failed the inspection as a result of safety violations.
261. Ms. Camp has made numerous requests for maintenance which have
largely been ignored. Most recently, Ms. Camp’s unit has had mold, flaking, peeling
and bubbling paint, and gaps between her window and bedroom wall allowing
airflow and rainwater from outside to enter.
91

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 92 of 111

262. In addition to Ms. Camp’s requests, on February 14, 2019, HACA was
sent written notice of the conditions in Ms. Camp’s unit, along with photographs,
and a request to relocate her to a healthier living environment “as quickly as
possible.” To date, there has been no response to that request.
263. On Friday, March 8, 2019, a report was made to the City Inspector’s
office. They responded by sending an inspector to the unit on March 21, 2019 and
then contacting HACA to request they make a site visit to check for possible mold
and fungus present in the apartment and to make some other repairs.
264. On or about April 3, 2019, HACA recaulked the tub and shower
surround, repaired the area around the bedroom window so that it no longer leaks,
and advised Ms. Camp that there was no mold in the unit. At no time did any
inspector test for mold. Ms. Camp’s unit has never been inspected by HUD to her
knowledge.
265. Ms. Camp and her child’s mental and physical health have been greatly
affected by the failures of both HACA and the City, and those failures have caused
them significant damage.
266. Ms. Camp lives in an unlicensed rental apartment, and no effort has
ever been made by the City to advise her that the apartment is not licensed. Despite
HACA having failed the 2016 inspection, she was never relocated from the home in
accordance with the requirement of the City Policy at the time.
92

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 93 of 111

The Fuller Family
267. Ms. Lakisha Fuller lives with her two minor children at 1432 Tyler
Avenue in the Robinwood community. Ms. Fuller is expecting a third child in
October. The townhouse the Fullers live in is at the end of the complex, adjacent to
the woods. Ms. Fuller put in a transfer request about two years ago because her
house needed various repairs that HACA refused to fix. Shortly before her HUD
inspection was set to take place in 2018, a HACA maintenance person advised that
certain repairs were needed. She showed the maintenance person documentation
that she had already put in work orders for repairs, and that HACA had done nothing.
Once the HUD inspection was scheduled, HACA sent someone out to do the repairs.
Ms. Fuller asked about the transfer again in April 2019, and she was told they are
not doing any transfers.
268. In addition to needed repairs, there is mold growing in the unit. The
HACA maintenance person has come out repeatedly to try to get rid of the mold but
the source of the problem has not been remediated, so the problem persists.
269. Ms. Fuller’s son has been diagnosed with asthma and is required to use
a nebulizer when he has trouble breathing. The air in the apartment is a constant
source of concern. The ventilation has not been cleaned in years, and the family is
constantly suffering from sinus-related issues while they are in the apartment. The
same issues ease when they are not in the apartment.
93

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 94 of 111

270. There are also paint chips coming off the walls throughout the home.
Ms. Fuller is concerned about this because she is expecting a baby in October.
271. When the City inspected their apartment in May 2016, it was
discovered that none of the bedrooms had smoke detectors at all, let alone the AC
powered detectors required by the City Code. It was discovered that mold was
present inside the bathroom ceiling, and the City required HACA to repair the
bathroom, prepare the area, and paint. However, the City did not enforce the City
Code on HACA as it does other landlords, and instead of requiring HACA to relocate
the Fuller family, they were left in the home with the violations unfixed. To date the
mold is still present in the apartment.
272. Ms. Fuller and her children’s mental and physical health have been
greatly affected by the failures of both HACA and the City, and those failures have
caused them significant damage.
273. Ms. Fuller and her family live in an unlicensed rental apartment, and
no effort has ever been made by the City to advise her that the apartment is not
licensed. Despite HACA having failed the 2016 inspection, Ms. Fuller and her
family were never relocated from the home in accordance with the requirement of
the City Policy at the time.

94

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 95 of 111

FIRST CAUSE OF ACTION
(Violation of the Civil Rights Act of 1866, 42 U.S.C. § 1982)
Against all Defendants
274. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
275. Defendants’ discriminatory practices, made in reckless or callous
indifference or disregard for the rights of Plaintiffs, deprive Plaintiffs of their right
to purchase, lease, or otherwise hold or convey property on the basis of race, color,
and national origin and thus deprive them of the same such rights as are enjoyed by
White persons in violation of the Civil Rights Act of 1866, 42 U.S.C. § 1982.
276. The Plaintiffs have been injured by Defendants’ discriminatory conduct
and have suffered damages as a result.
SECOND CAUSE OF ACTION
(Violation of the Civil Rights Act of 1871, 42 U.S.C. § 1983 and the Equal
Protection Clause of the Fourteenth Amendment to the
Constitution of the United States)
Against all Defendants
277. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
278. Defendants’ discriminatory customs, patterns, practices, and usages in
contravention of Plaintiffs’ constitutional and federal statutory rights made in
reckless or callous indifference or disregard for the rights of Plaintiffs, did deprive
Plaintiffs of their right of equal access to housing under color of law in violation of
95

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 96 of 111

the Federal Civil Rights act of 1871, 42 U.S.C. § 1983, and their rights under the
Equal Protection Clause of the Fourteenth Amendment of the United States
Constitution with regard to housing.
279. The Plaintiffs have been injured by Defendants’ discriminatory conduct
and have suffered damages as a result.
THIRD CAUSE OF ACTION
(Violation of the Civil Rights Act of 1871, 42 U.S.C. § 1985 and the Equal
Protection Clause of the Fourteenth Amendment to the
Constitution of the United States)
Against all Defendants
280. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
281. Defendants conspired with discriminatory purpose to deprive either
directly or indirectly the rights of Plaintiffs, members of a protected class, to equal
protection of the laws or equal privileges and immunities under the laws, and one or
more of the Defendant conspirators did or caused to be done acts in furtherance of
the object of the conspiracy, and Plaintiffs were injured in person or property or
deprived of having and exercising their rights as citizens of the United States.
282. The Plaintiffs have been injured by Defendants’ discriminatory conduct
and have suffered damages as a result.
FOURTH CAUSE OF ACTION
(Violation of the Civil Rights Act of 1871, 42 U.S.C. § 1986 and the Equal
Protection Clause of the Fourteenth Amendment to the
Constitution of the United States)
96

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 97 of 111

Against all Defendants
283. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
284. Defendants were in a position of power and knowledge of the
conspiracy to deprive Plaintiffs of their rights in violation of 42 U.S.C. § 1985.
285. Defendants were on notice through City Council meetings, both open
and closed to the public, as well as communications between the Mayor, City
Council, the Executive Director, and Housing Authority officials, that the City had
an obligation to inspect the HACA Properties. Despite this obligation, the City
adopted the policy not to inspect the HACA properties. In continued refusal of
enforcement of City Code, and despite notice of that obligation, Defendants failed
to uphold their duty to ensure the health and safety of Plaintiffs. Plaintiffs’ civil
rights were violated as a result.
286. The breach of Defendants’ duty was the proximate cause of the
violations of the Plaintiffs’ civil rights.
FIFTH CAUSE OF ACTION
(Violation of the “Affirmatively Furthering” Obligations Under the Fair
Housing Act, 42 U.S.C. § 3608)
Against all Defendants
287. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.

97

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 98 of 111

288. Defendants, in connection with their use of federal funds related to
housing, including funds from the federal CDBG program, have used the funds
received in a discriminatory manner which promotes segregation and otherwise
failed to meet the “Affirmatively Furthering Fair Housing” obligations of the Fair
Housing Act.
289. The Plaintiffs have been injured by Defendants’ discriminatory conduct
and have suffered damages as a result.
SIXTH CAUSE OF ACTION
(Violation of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.)
Against all Defendants
290. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
291. Defendants’ discriminatory practices regarding the administration of
federal programs are carried out with reckless or callous indifference or disregard
for the rights of Plaintiffs, and violate the Civil Rights Act of 1964, 42 U.S.C. §
2000d et seq.
292. The Plaintiffs have been injured by Defendants’ discriminatory conduct
and have suffered damages as a result.
SEVENTH CAUSE OF ACTION
(Violation of Fair Housing Act, 42 U.S.C. § 3601 et seq.)
Against all Defendants

98

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 99 of 111

293. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
294. Defendants’ policy of non-enforcement of the City Code on the HACA
Properties constitutes a violation of the Fair Housing Act, 42 U.S.C. §3604(b), which
makes it unlawful to “discriminate against any person in the terms, conditions, or
privileges of sale or rental of a dwelling, or in the provision of services or facilities
in connection therewith, because of race, color, religion, sex, familial status, or
national origin.”
295. Defendants Mayor Buckley, the City of Annapolis, the Aldermen, and
Alderwomen of the City of Annapolis’ facially neutral housing acts, policies, and
actions challenged herein inflict disproportionate harm on African American
residents of the HACA Properties. The disproportional harm experienced by the
African American residents of the HACA Properties is the direct and immediate
consequence of the Defendants’ policy of non-enforcement of the City Code on the
HACA Properties.
296. As a result of Defendants’ Mayor Buckley, Aldermen, and
Alderwomen of the City of Annapolis’ acts, the Plaintiffs have been denied the
opportunity to live in safe rental housing inspected by the City of Annapolis on an
annual basis, a right they would enjoy if they lived in any other rental property in
the City that was not managed by the Housing Authority.
99

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 100 of 111

297. Defendants’ acts, policies, and practices constitute discrimination in
violation of the Fair Housing Act, as amended, 42 U.S.C. §3604, and its
implementing regulations, in that:
a. Defendants’ acts, policies, and practices have made and continue to
make housing unavailable because of race in violation of 42 U.S.C.
§3604(a); and
b. Defendants’ acts, policies, and practices provide different terms,
conditions, and privileges of rental housing on the basis of race, in
violation of 42 U.S.C. § 3604(b)
298. Plaintiffs are aggrieved persons as defined in 42 U.S.C. § 3602 (d) and
(i). They have been injured by Defendants’ discriminatory conduct and have
suffered damages as a result.
EIGHTH CAUSE OF ACTION
(Writ of Mandamus)
Against Defendant City of Annapolis, Defendant Mayor Gavin Buckley, and
Defendants City Council of the City of Annapolis
299. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
300. Plaintiffs, pursuant to Md. Rule 15-701, seek a writ of mandamus to
compel Defendants Mayor and the Aldermen and Alderwomen of Annapolis to
perform their statutory duties.

100

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 101 of 111

301. Mayor and Aldermen and Alderwomen of Annapolis comprise a body
corporate and politic and a chartered municipal corporation under Maryland Code
and are responsible for issuing rental licenses through its Department of Planning
and Zoning pursuant to its ordinance codified at 17.44.010.
302. Mayor and Aldermen and Alderwomen adopted a policy not to inspect
any properties of the Housing Authority, all of which are leased to low-income
public housing tenants, who are predominately African American.
303. Mayor and Aldermen and Alderwomen have a clear duty to enforce the
rental licensing requirements of the City Code on all persons letting for occupancy
a multiple dwelling unit such as those which are let by the Housing Authority.
304. Plaintiffs who live in low-income public housing have a plain and clear
right to have their dwelling units inspected.
305. Plaintiffs have no other adequate remedy by which to obtain this right
of City inspection of their rented dwellings.
NINTH CAUSE OF ACTION
(MARYLAND CONSUMER PROTECTION ACT)
Against all Defendants
306. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
307. At the inception of the leases with each of the Plaintiffs, which is
required by HACA policy to occur annually, Defendants had both actual and
101

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 102 of 111

constructive knowledge that the HACA Properties were not properly licensed
pursuant to City Code.
308. On some occasions, HACA represented to Plaintiffs that it was properly
licensed pursuant to the rental laws of the Annapolis City Code when it was not.
309. In some instances, HACA or its agents falsely represented to Plaintiffs,
HACA tenants, and judicial tribunals of the State of Maryland that HACA was not
licensed, but that it was by law not required to be licensed.
310. Prior to entering the leases, Defendant HACA affirmatively showed the
units to Plaintiffs and represented them to be free of any material defects, including
unhealthy indoor molds and water intrusion defects.
311. The units in fact had design defects, serious safety shortfalls including
the lack of appropriate fire safety systems, construction and/or maintenance defects
which caused severe water intrusion and extensive mold growth and dangerous air
quality issues, all existing at the time the lease was entered into and these defects
were omitted in the representations made by Defendants.
312. Defendant HACA made the affirmative representation to all Plaintiffs
at the time of lease inception that “HACA is obligated to…comply with the
requirements of all applicable building and housing codes materially affecting health
and safety….” At the time of that representation, Defendant HACA was on notice
from the City of Annapolis, since at least July 2016, that the HACA Properties were
102

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 103 of 111

not in compliance with the City’s Fire Safety Code as it pertained to “multiple
dwelling rental unit” as defined by the City Code.
313. This misrepresentation that the HACA Properties were of a particular
standard was made to every tenant of the HACA Properties at lease inception and
their renewal amounted to unfair and deceptive trade practices.
314. The City of Annapolis failed to enforce their own policy and City Code
to advise the consumer tenants of the HACA Properties that the units were not
licensed for occupancy. The City of Annapolis failed to enforce their own policy
and City Code to enforce fines and penalties on HACA. The fact that these units
were not licensed amounted to a material fact, and its omission deceived the
consumer tenants of the HACA Properties.
315. As a proximate and direct result of Defendants unfair and deceptive
trade practices in violation of the MCPA, Plaintiffs have suffered economic harm
and loss, including but not limited to, medical bills, rent paid to Defendant HACA,
loss of personal property/contents of unit due to damage, costs of testing and
reporting of moldy conditions, mental and emotional anguish, costs of relocation,
damages due to loss of employment related to relocation, and costs of intermittent
remediation of properties.
TENTH CAUSE OF ACTION
(BREACH OF CONTRACT – DAMAGES)

103

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 104 of 111

Defendant Beverly Wilbourn, Defendant Housing Authority of the City of
Annapolis, and Defendant Housing Authority of the City of Annapolis Board of
Commissioners
316. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
317. Plaintiffs entered into valid written contracts for the lease of real
property with Defendant HACA.
318. Under those contracts, Defendant HACA obligated itself to:
a. Maintain the unit and the development in decent, safe, and sanitary
condition;
b. Comply with the requirements of all applicable building and
housing codes materially affecting health and safety and all
applicable U.S. Department of Housing and Urban Development
regulations;
c. Make necessary repairs to the units within a reasonable time;
d. Keep the development’s buildings, facilities and common areas, not
otherwise assigned to tenants for maintenance and upkeep, in clean
and safe condition;
e. Maintain in good and safe working order and condition, electrical,
plumbing, sanitary, heating, and ventilation and other facilities and

104

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 105 of 111

appliances, including elevators, supplied or required to be supplied
by HACA; and
f. Provide reasonable accommodations for a disabled Tenant or any
other household member.
319. Defendant HACA has breached the contracts by:
a. Failing to provide decent, safe, and sanitary conditions;
b. Failing to allow City inspectors to complete inspections of the
HACA properties as required by the relevant housing code,
specifically Chapter 17.44.010 of the City Code;
c. Failing to correct the City Code violations discovered by the initial
City Inspections in 2016;
d. Failing to properly remediate unsanitary conditions in the attics
and ventilation systems of the dwellings; and
e. Failing to properly remediate mold conditions in the apartments.
320. Further, Defendants refuse to act in a manner consistent with the terms
of the contracts which they entered into by:
a. Maintaining a clean and healthy living environment;
b. Actively inspecting the HACA units and common areas for unhealthy
indoor molds;

105

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 106 of 111

c. Remediating the units and common areas for mold that has been or
reasonably should be discovered;
d. Conducting regular maintenance of the ventilation systems in the
HACA properties; and
e. Otherwise refusing to act consistent with the terms of the contracts.
321. As stated, instead of complying with the terms of the lease agreements
with tenants, Defendant HACA has sought to hide the conditions and hire
unqualified third-party inspectors instead of inspectors employed by the City of
Annapolis to falsely represent that the apartments are safe and habitable.
322. As a result of Defendant HACA’s breach, Plaintiffs have suffered
economic losses including, but not limited to, money paid for rent, and money paid
to inspect unhealthy indoor molds and water intrusion.
ELEVENTH CAUSE OF ACTION
(BREACH OF CONTRACT – SPECIFIC PERFORMANCE)
Defendant Beverly Wilbourn, Defendant Housing Authority of the City of
Annapolis, and Defendant Housing Authority of the City of Annapolis Board of
Commissioners
323. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
324. Plaintiffs seek specific performance of the lease agreements to include
the provision of a safe and habitable residence that is licensed and inspected by the
City.
106

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 107 of 111

TWELFTH CAUSE OF ACTION
(BREACH OF WARRANTY OF HABITABILITY)
Defendant Beverly Wilbourn, Defendant Housing Authority of the City of
Annapolis, and Defendant Housing Authority of the City of Annapolis Board of
Commissioners
325. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
326. A reasonable inspection by HACA would have revealed defective
conditions related to water intrusion, mold, contaminated ventilation, and other
defects in the HACA Properties.
327. At least as early as July 2016, Defendants knew that the HACA
Properties were in violation of the Fire Safety requirements of the City of Annapolis,
after which time they requested that City Inspectors no longer inspect HACA
properties for violations.
328. Defendant HACA thereby breached the warranty of habitability in that
it knew or should have known of dangerous conditions upon the units which
Plaintiffs leased.
329. Defendant HACA continued to collect monthly rent from Plaintiffs
despite their lack of a City-issued rental licenses though the defective and dangerous
conditions of the units rendered them unfit for habitation in violation of state and
local housing codes which require among other things, healthy conditions free of
water intrusion and properly installed fire detection systems.
107

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 108 of 111

330. Plaintiffs paid rent, and continue to pay rent, and have been subjected
to physical eviction demands despite Defendant HACA’s knowledge of this breach
of the implied warranty.
THIRTEENTH CAUSE OF ACTION
(NEGLIGENCE)
Against all Defendants
331. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
332. Defendants had a duty recognized by the law which required
conformance to a certain standard of conduct for the protection of others against
unreasonable risks.
333. Defendants failed to conform to that standard through a breach of that
duty.
334. Defendants’ breach was the proximate cause of actual damage to
Plaintiffs that resulted in damages to include monetary loss as well as physical injury
and emotional pain and suffering.
FOURTEENTH CAUSE OF ACTION
(GROSS NEGLIGENCE)
Against all Defendants
335. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.

108

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 109 of 111

336. Defendants through their actions expressed a reckless disregard for the
consequences to the life or property of Plaintiffs and made no effort to avoid those
consequences when there was a clear duty to act.
337. Defendants’ breach was the proximate cause of actual damage to
Plaintiffs that resulted in damages to include monetary loss as well as physical
injury and emotional pain and suffering.
FIFTEENTH CAUSE OF ACTION
(Tort – Civil Conspiracy)
Against all Defendants
338. Plaintiffs repeat and reallege the foregoing paragraphs as if fully set
forth herein.
339. Two or more of the Defendants or their agents agreed to and did
wrongfully direct the City Inspector’s Office of the City of Annapolis, in violation
of City Code and State Law, to refuse to inspect the apartments of Plaintiffs, because
the Plaintiffs were tenants of the Housing Authority.
340. As a result of the conspiracy Plaintiffs have suffered monetary and nonmonetary damages.

109

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 110 of 111

PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray that the Court grant them the following relief:
A.

The Court should issue an order granting Plaintiff’s request for

declaratory relief, finding that the Defendant’s actions violate the FHA.
B.

The Court should enter a permanent injunction and all other

affirmative relief necessary, enjoining Defendants and their affiliates, subsidiaries,
agents, employees, and representatives from continuing the illegal conduct described
above, and further directing Defendants to take all affirmative steps necessary to
remedy the effects of its past illegal conduct. Such affirmative relief should include,
but not necessarily be limited to, the elimination of any and all policies which allow
the Housing Authority of the City of Annapolis to be treated differently than any
other landlord in the City of Annapolis, and to ensure that the displacement of
African Americans from the City is stopped and policies are put in place to
affirmatively further fair housing for this protected class within the City limits of the
City of Annapolis.
C.

As a part of any permanent injunction or other affirmative relief,

the Court should oversee the implementation of a plan by which the City of
Annapolis and the Housing Authority of the City of Annapolis are required to
enforce and comply with the City Code regardless of the race of the tenants.

110

 Case 1:19-cv-01442-CCB Document 1 Filed 05/16/19 Page 111 of 111

D.

As a direct, legal, and proximate result of the defendants’ acts

and/or omissions, Plaintiffs have sustained, and will continue to sustain, economic
damages to be proven at trial. As a further result of Defendants’ acts and/or
omissions, Plaintiffs have suffered physical harm and emotional distress, resulting
in damages in an amount to be proven at trial.
E.

The Court should enter a judgment for punitive damages to the

Plaintiffs, in an amount to be proved at trial before a jury.
F.

The Court should award Plaintiffs their reasonable attorneys’

fees, costs, and expenses.
G.

The Court should grant such other relief as it deems just and

equitable.
DEMAND FOR JURY TRIAL
Pursuant to Fed. R. Civ. P. 38(b), Plaintiffs demand a trial by jury of all
issues in this case.
WISE & DONAHUE, PLC
By:

111

/s/ P. Joseph Donahue
P. Joseph Donahue, Esquire
Bar Number: 06245
18 West Street
Annapolis, Maryland 21401
Telephone: 410-280-2023
Fax: 410-280-0905
Email: pjd@wisedonahue.com
Attorneys for Plaintiffs

 Ward1 


mun-M blur-l ??13 MME

 

Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 1 of 37

Exhibit B

Public Housing
Public
Housing
Transition Team
Transition Team
Mayor Michael John Pantelides, 2014 Citizen Advisory Transition Team

Adopted October 27, 2014 
Public Housing

1

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 2 of 37

Exhibit B

EXECUTIVE COMMITTEE MEMBERS:
Bob Burdon
Rick Morgan
Vienna Laurendi
Leslie Stanton
Leslie Stanton

LEGAL & ADMINISTRATIVE ASSISTANCE PROVIDED BY:
Jacalyn Bierman
Ashley Leonard, Esq.

Adopted October 27, 2014 
Public Housing

2

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 3 of 37

Exhibit B

COMMITTEE CHAIR: Deneice F. Fisher
COMMITTEE CO CHAIR:
COMMITTEE CO‐CHAIR:
Dennis Conti
COMMITTEE MEMBERS:
Sheryl Banks

Sandra Chapman

Trudy McFall
y

Adopted October 27, 2014 
Public Housing

3

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 4 of 37

Exhibit B

Timeline Key
ONGOING

Continuation of existing activity.
Continuation of existing
activity

IMMEDIATE

Commencement within 3 months.

SHORT‐TERM

Commencement within 3‐12 months.

MEDIUM‐TERM

Commencement within 1‐2 years.

LONG‐TERM

Commencement after 2 years.

Adopted October 27, 2014 
Public Housing

4

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 5 of 37

Exhibit B

Abbreviations Used
AAC

Anne Arundel County, Maryland

AACC

Anne Arundel Community College

AAWDC

Anne Arundel Workforce Development 
Corporation

ADOT

Annapolis Department of 
Transportation

APD

Annapolis Police Department

CDBG

Community Development Block Grant

HACA

Housing Authority of the 
City of Annapolis
y
p

MD

Maryland (i.e. State of)

RFP

Request for Proposal (i.e. bid)

Adopted October 27, 2014 
Public Housing

5

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 6 of 37

Exhibit B

HOUSING AUTHORITY 
OF CITY OF ANNAPOLIS
ISSUES 1 3
ISSUES 1‐3

Adopted October 27, 2014 
Public Housing

6

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 7 of 37

Exhibit B

HACA: ISSUE 1
HACA appears to be in serious financial condition with grim prospects for
maintaining financial viability. HACA owes the City for unpaid reimbursements.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should conduct its 
own independent assessment of
own independent assessment of 
the financial health of HACA and 
collectability of unpaid 
reimbursements.

Finance Director

Immediate

Adopted October 27, 2014 
Public Housing

7

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 8 of 37

Exhibit B

HACA: ISSUE 2
The condition of HACA properties is in serious decline. The latest available HUD score
for their physical condition is 25 out of 40. Residents say the condition and
maintenance
i
off their
h i units
i are their
h i biggest
bi
problems.
bl

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. Per State code unless an 
exception is made the City
exception is made, the City 
should begin inspecting HACA 
units under the City’s rental 
licensing program that applies to 
all other rental housing in City
all other rental housing in City.

DNEP Director

Immediate

2. The City has an obligation to 
protect health and safety of 
public housing residents, as they 
do other City renters, and should 
work with HACA to phase in City 
inspection of HACA properties.

DNEP Director

Immediate

Adopted October 27, 2014 
Public Housing

8

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 9 of 37

Exhibit B

HACA: ISSUE 2, CONTINUED
The condition of HACA properties is in serious decline. The latest available HUD score
for their physical condition is 25 out of 40. Residents say the condition and
maintenance
i
off their
h i units
i are their
h i biggest
bi
problems.
bl

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

3. HACA should take on more 
responsibility from APD for
responsibility from APD for 
banning list and policies (make 
stronger), and for lease
enforcement, as well as rules for 
allowing residents to have
allowing residents to have 
“onsite” guests who are on the
banned list.

City Manager

Immediate

4. HACA should check with its 
insurance company to make sure 
HACA is in compliance with all 
fire safety regulations, especially 
those for smoke alarms.

DNEP Director

Immediate

Adopted October 27, 2014 
Public Housing

9

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 10 of 37

Exhibit B

HACA: ISSUE 3
It is necessary for HACA to participate as promptly as possible in redeveloping their
remaining six properties through public/private partnerships.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should encourage 
HACA to replace or rehabilitate to
HACA to replace or rehabilitate to 
the maximum degree possible all 
existing low income units, 
providing one for one 
replacement and to consider
replacement, and to consider 
collaboration with public/private 
partnerships.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

10

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 11 of 37

Exhibit B

OUTSIDE SERVICE 
PROVIDERS FOR HACA
ISSUES 4 9
ISSUES 4‐9

Adopted October 27, 2014 
Public Housing

11

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 12 of 37

Exhibit B

OUTSIDE SERVICE PROVIDERS: ISSUE 4
HACA appears to have done a good job in recent years of generally increasing
supportive services for its residents, but further improvement and expansion could
be accomplished.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City and HACA should
y
explore funding opportunities 
that exist for programs that help 
public housing residents.

City Manager
y
g

Medium‐Term

2. The City could promote and 
2
The City could promote and
endorse workshops to highlight 
the funding needs of HACA 
residents and emphasize City 
support for such services
support for such services.

Mayor

Medium Term
Medium‐Term

Adopted October 27, 2014 
Public Housing

12

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 13 of 37

Exhibit B

OUTSIDE SERVICE PROVIDERS: ISSUE 5
Some of the HACA residents who may need to use resident services are either not
aware of them or choose not to use them. Case managers may help with this issue.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should encourage 
HACA to transfer some funding 
from its administrative costs to 
support resident services and 
resident case managers.

Mayor

Medium‐Term

2. The City should work
y
with 
HACA to ask AAC to assign case 
managers specifically to HACA.

Mayor
y

Medium‐Term

3. The City should encourage 
HACA to pursue all available
HACA to pursue all available 
private contributions and grants 
to fund case workers.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

13

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 14 of 37

Exhibit B

OUTSIDE SERVICE PROVIDERS: ISSUE 5, CONTINUED
Some of the HACA residents who may need to use resident services are either not
aware of them or choose not to use them. Case managers may help with this issue.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

4. The City should encourage 
HACA to consider case workers to 
be either HACA employees or 
assigned by outside jurisdictions.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

14

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 15 of 37

Exhibit B

OUTSIDE SERVICE PROVIDERS: ISSUE 6
It appears there are many services on site and in the community. Perhaps HACA
could do better job of providing information on them and encouraging participation.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should encourage
HACA to use technology to 
communicate better, such as the 
Internet or social media.

Mayor

Medium‐Term

2. The City should encourage 
HACA to provide and post a 
HACA to
provide and post a
public calendar monthly that lists 
daily services and activities 
available to each resident.

Mayor

Medium‐Term

3. The City should encourage 
3
Th Ci h ld
HACA to recruit volunteers to 
help with outreach to residents 
to supplement its own staff.

M
Mayor

M di
Medium‐Term
T

Adopted October 27, 2014 
Public Housing

15

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 16 of 37

Exhibit B

OUTSIDE SERVICE PROVIDERS: ISSUE 7
HACA needs to capitalize more on the potential for private contributions and public
grants for resident services and volunteers to educate residents on those services.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should encourage 
HACA to add a development
p
officer to reach out and secure 
private funding, and foundation 
and public grants for HACA 
service programs.
p g

Mayor

Medium‐Term

2. The City should encourage 
HACA to consider private and 
foundation grants and 
contributions as a viable source
contributions as a viable source, 
but a new and talented
fundraising staff person would be 
needed by HACA.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

16

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 17 of 37

Exhibit B

OUTSIDE SERVICE PROVIDERS: ISSUE 8
HACA, and its staff, need to always provide first class support (responsive and
helpful) for the groups and volunteers who work to help the residents.

RECOMMENDATIONS
1. The City should encourage
HACA to consider honoring and 
g
thanking these groups in some 
formal way each year, such as 
thank‐you events or newsletter 
articles about these groups.
g p

RESPONSIBLE PARTY

TIMELINE

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

17

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 18 of 37

Exhibit B

OUTSIDE SERVICE PROVIDERS: ISSUE 9
Community room space is reportedly scarce sometimes leaving willing groups with
inadequate space for their on‐site programs.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. As HACA properties are 
redeveloped, the City should 
p
y
encourage HACA to insist on 
generous community space being 
provided.

Mayor

Medium‐Term

2. The City should provide as 
2
The City should provide as
much space as possible in 
buildings it owns for services and 
office spaces for groups willing to 
give on‐site services to HACA
give on‐site services to HACA.

City Manager
City Manager

Medium Term
Medium‐Term

Adopted October 27, 2014 
Public Housing

18

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 19 of 37

Exhibit B

CITY PROVIDED 
SERVICES FOR HACA
ISSUE 10
ISSUE 10

Adopted October 27, 2014 
Public Housing

19

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 20 of 37

Exhibit B

CITY PROVIDED SERVICES: ISSUE 10
Interviews were conducted with the City to better understand what services are
currently provided to HACA and where there could be improvement and cost saving.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should encourage 
HACA to partner with AAWDC 
to explore ways to
explore ways to incentivize 
incentivize
local businesses to provide 
vocational training and 
internships to HACA youth.

City Manager

Medium‐Term

2. ADOT should conduct a survey 
2
ADOT h ld
d t
of HACA residents to determine 
the need for transit services to 
areas with high job opportunities.

ADOT Di t
ADOT Director

M di
Medium‐Term
T

3. ADOT should explore 
economical ways of providing 
transportation for HACA 
residents.

ADOT Director

Medium‐Term

Adopted October 27, 2014 
Public Housing

20

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 21 of 37

Exhibit B

CITY PROVIDED SERVICES: ISSUE 10, CONTINUED
Interviews were conducted with the City to better understand what services are
currently provided to HACA and where there could be improvement and cost saving.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

4. The City should encourage 
HACA to explore any electric rate 
reductions it might get by joining
reductions it might get by joining 
the Baltimore Regulatory 
Commission.

Mayor

Medium‐Term

5. The City should make Stanton 
Center more useable and 
accessible to HACA residents.

Recreation & Parks Director

Medium‐Term

Adopted October 27, 2014 
Public Housing

21

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 22 of 37

Exhibit B

ALTERNATIVE & 
ALTERNATIVE
&
ADDITIONAL 
ADDITIONAL
SUPPORT SERVICES
SUPPORT SERVICES
ISSUES 11‐14

Adopted October 27, 2014 
Public Housing

22

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 23 of 37

Exhibit B

ALTERNATIVE & ADDITIONAL SUPPORT SERVICES: ISSUE 11
HACA should expand its efforts to bring partners to the communities that will offer
job development, shadowing and internship opportunities for youth and adults.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should encourage 
HACA to develop
pp
programming 
g
g
around specific partners willing 
to increase their corporate social 
responsibility geared towards the 
needs of residents.

Mayor

Medium‐Term

2. The City should encourage 
HACA to develop and adopt a 
community program that will 
help meet the needs of residents
help meet the needs of residents 
and youths.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

23

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 24 of 37

Exhibit B

ALTERNATIVE & ADDITIONAL SUPPORT SERVICES: ISSUE 12
Anne Arundel Community College (AACC) and Anne Arundel Workforce Development
Corporation (AAWDC).

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should encourage a 
relationship between HACA and 
AAWDC to offer direct basic skills 
and workforce training locally.

Mayor

Medium‐Term

2. The City should encourage 
HACA to continue to utilize
HACA to continue to utilize 
AACC’s outreach efforts to 
address literacy in the AAC.

Mayor

Medium‐Term

3. The City should encourage 
HACA t
HACA to continue to utilize 
ti
t tili
AACC’s established partnership 
with AAWDC that could benefit 
residents of HACA.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

24

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 25 of 37

Exhibit B

ALTERNATIVE & ADDITIONAL SUPPORT SERVICES: ISSUE 13
Bridging the Digital Divide Initiatives.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should encourage 
HACA to be a proactive supporter 
of partnering with low cost 
service providers to initiate Wi‐Fi 
spots in community areas.

Mayor

Medium‐Term

2. The City should encourage 
HACA to continue community 
y
computer centers, but also work 
on making home‐based 
computers available to allow 
p
parents to see and experience 
p
what their child is learning and to 
control that learning 
environment.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

25

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 26 of 37

Exhibit B

ALTERNATIVE & ADDITIONAL SUPPORT SERVICES: ISSUE 14
The condition of the properties suggests that with poor current conditions, ongoing
deterioration and declining HUD maintenance funds, time is not on HACA’s side.
Redevelopment, even under favorable conditions, could take 10‐15 years.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The City should encourage 
y
g
HACA to develop a
comprehensive plan for when, 
how and in what order it will 
make the transition to a public/ 
p
private approach for its 
remaining properties beyond the 
Newtowne 20 property.

Mayor
y

Medium‐Term

2. The City should encourage 
2
The City should encourage
HACA to write less prescriptive
RFPs and be more realistic in 
what it asks.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

26

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 27 of 37

Exhibit B

ALTERNATIVE & ADDITIONAL SUPPORT SERVICES: ISSUE 14, CONTINUED
The condition of the properties suggests that with poor current conditions, ongoing
deterioration and declining HUD maintenance funds, time is not on HACA’s side.
Redevelopment, even under favorable conditions, could take 10‐15 years.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

3. The City should encourage 
y
g
HACA to attract and retain the 
best affordable rental housing 
developers putting forth viable 
proposals in order to implement 
p
p
p
a public/private approach.

Mayor
y

Medium‐Term

4. The City should encourage 
HACA to get better advice to 
guide it through the
guide it through the 
complications of a public/private 
financing environment.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

27

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 28 of 37

Exhibit B

ALTERNATIVE & ADDITIONAL SUPPORT SERVICES: ISSUE 14, CONTINUED
The condition of the properties suggests that with poor current conditions, ongoing
deterioration and declining HUD maintenance funds, time is not on HACA’s side.
Redevelopment, even under favorable
f
conditions, could take 10‐15 years.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

5. The City should encourage 
HACA
HACA  to not overcomplicate the 
li
h
process of redevelopment (ex:
changes in proposed City 
Ordinance O‐3‐14 ).

Mayor

Medium‐Term

6. Instead of increasing number 
of low and moderate income 
units by 67% around Newtowne 
20, the City should encourage
HACA to ensure that none of 
existing ones are lost and any 
new ones should be in scattered  
areas in the City and AAC.

Mayor

Medium‐Term

Adopted October 27, 2014 
Public Housing

28

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 29 of 37

Exhibit B

ALTERNATIVE & ADDITIONAL SUPPORT SERVICES: ISSUE 14, CONTINUED
The condition of the properties suggests that with poor current conditions, ongoing
deterioration and declining HUD maintenance funds, time is not on HACA’s side.
Redevelopment, even under favorable conditions, could take 10‐15 years.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

7. The City should encourage 
HACA to create extensive 
i
involvement and communication 
with residents effected by any 
public/private partnerships for 
redevelopment, including 
d l
i l di
temporary/permanent relocation 
and help with returning to the 
redeveloped community.

Mayor

Medium‐Term

ALSO SEE THE ECONOMIC 
DEVELOPMENT TRANSITION 
TEAM REPORT’S ISSUE NO. 3.

Adopted October 27, 2014 
Public Housing

29

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 30 of 37

Exhibit B

OPERATIONS BETWEEN
HACA AND THE CITY
ISSUES 15 19
ISSUES 15‐19

Adopted October 27, 2014 
Public Housing

30

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 31 of 37

Exhibit B

HACA‐CITY OPERATIONS: ISSUE 15
Changes need to be made to HACA’s enabling MD State legislation (i.e. Title 13).

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. Reduce the term of the 
Commissioners from the current 
five years to three years.
five years
to three years

Mayor

Immediate

2. Increase the number of HACA 
residents required on the Board 
of Commissioners from the 
current two to three.

Mayor

Immediate

3. Change current requirement 
that one of the Commissioners is 
“a tenant of an Annapolis 
p
Authority property for seniors” to 
simply “a tenant who is a senior”.

Mayor

Immediate

Adopted October 27, 2014 
Public Housing

31

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 32 of 37

Exhibit B

HACA‐CITY OPERATIONS: ISSUE 15, CONTINUED
Changes need to be made to HACA’s enabling MD State legislation (i.e. Title 13).

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

4. Require four of the seven
Commissioners to have expertise 
in areas like affordable housing
in areas like affordable housing 
finance and development, 
construction/maintenance, 
property management, and 
business management
business management.

Mayor

Immediate

Adopted October 27, 2014 
Public Housing

32

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 33 of 37

Exhibit B

HACA‐CITY OPERATIONS: ISSUE 16
Until HACA’s MD State legislation is amended per Issue 15, the following should take
place in the short term:

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. City Housing and Community 
Development Committee  should 
conduct an independent review 
d t i d
d t
i
of HACA’s annual audit, its annual 
and 5‐year plans, and its overall 
financial health.

Finance Director

Ongoing

2. The City should appoint 
Commissioners who have 
expertise in areas like affordable 
housing finance and 
development, construction/ 
maintenance, property 
management, and business 
management.

Mayor

(present results to 
City Council by July
City Council by July 
1st of each year)

Adopted October 27, 2014 
Public Housing

Medium‐Term

33

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 34 of 37

Exhibit B

HACA‐CITY OPERATIONS: ISSUE 17
There are concerns about the financial stability of HACA, and the possibility of HACA
becoming insolvent within the next two years.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. HACA should pay the City any 
outstanding balance on its
$36 000 annual payment for APD
$36,000 annual payment for APD 
support, and make future 
payments in a timely manner.

Finance Director

Ongoing

2. The City should immediately 
conduct an independent review 
of HACA’s financial situation.

Finance Director

Immediate

Public Works Director

Short‐Term

3. The City and HACA should 
investigate feasibility of HACA 
feasibility of HACA
using the City’s refuse pickup 
contract to achieve reduced 
rates.

Adopted October 27, 2014 
Public Housing

34

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 35 of 37

Exhibit B

HACA‐CITY OPERATIONS: ISSUE 18
Application of normal City Code provisions for rental properties.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. City should pass a resolution 
that either explicitly exempts or 
does not exempt HACA from
does not exempt HACA from 
complying with City Code 
provisions normally required of 
other rental properties.

DNEP Director

Immediate

2. If HACA not exempted
f
d (which 
( hi h
is recommended), City and HACA 
should develop and implement a 
plan for phasing in the inspection 
of all HACA units, including 
f ll HACA i i l di
annual rental license payments 
from HACA to the City.

DNEP Director
i

Immediate
di

Adopted October 27, 2014 
Public Housing

35

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 36 of 37

Exhibit B

HACA‐CITY OPERATIONS: ISSUE 19
Cooperative Agreements between HACA and the City.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

1. The Cooperative Agreements 
between HACA and the City 
should be revised to include all
should be revised to include all 
current agreements and 
practices, such as the policing 
agreement and clarifications on 
what services can or cannot be
what services can or cannot be 
offset PILOT payments.

City Attorney

Short‐Term

2. The Cooperative Agreements 
should then be amended going 
f
forward to represent all future 
d
ll f
agreements between HACA and 
the City.

City Attorney

Short‐Term 
& Ongoing

Adopted October 27, 2014 
Public Housing

36

 Case 1:19-cv-01442-CCB Document 1-2 Filed 05/16/19 Page 37 of 37

Exhibit B

HACA‐CITY OPERATIONS: ISSUE 19, CONTINUED
Cooperative Agreements between HACA and the City.

RECOMMENDATIONS

RESPONSIBLE PARTY

TIMELINE

3. As part of the Cooperative 
Agreements, HACA should 
provide City each year with a 
City each year with a
copy of the appropriate HUD 
form that calculates a housing 
authority’s required annual PILOT 
payment as well as any required
payment, as well as any required 
PILOT payments

Finance Director

Short‐Term
& Ongoing

Adopted October 27, 2014 
Public Housing

37

 Case 1:19-cv-01442-CCB Document 1-3 Filed 05/16/19 Page 1 of
1
Exhibit
C

City of Annapolis

FOR CITY USE ONLY

Zoning
Approved by
Date approved
Rental License #
Rental District

Department of Planning and Zoning
145 Gorman Street Fl 3
Annapolis, MD 21401-2529

1

2

3

4

Permitting@annapolis.gov • 410-260-2200 • Fax 410-263-9158 • TDD use MD Relay or 711 • www.annapolis.gov

Rental Operating License Application
A property owner must obtain a license prior to operating a rental facility within the City of Annapolis. License application and rental
operating license are non-transferable. Application must include fee of $100.00 per unit. Property must be inspected for compliance
of the City’s Code and International Property Maintenance Code before the license will be issued.
Rental Property Address

Unit #

Property Tax ID #

Complex/Hotel Name
Property Owner Information

Property Management or Authorized Agent* Information

Name

Name

Company

Company

Address

Address

City

State

Day phone

Zip

City

Cell

Day phone

E-mail

State

Zip

Cell

E-mail

* The Property Management or authorized agent will be the person that we contact regarding renewals, inspections, complaints and
any violations.
Description of Property (Please check only one)
Single Family Dwelling

Two Family Dwelling

Multi Family Dwelling

Yes

Hotel

Number of units requested on this application

Total number of dwelling units in the entire building
Is the building owner occupied?

Apartment Hotel

No

Year Built

Does the unit have AC electric power supplied smoke alarms? (City Code Section 17.40.440)
Yes
No
***Must have smoke alarms installed on each ceiling or wall outside of each separate sleeping area in the immediate vicinity of
bedrooms, in each sleeping room, and each story of the dwelling unit (International Property Maintenance Code 704.2)***
Maryland Lead Certification Requirements
All owners of residential rental properties in Maryland constructed prior to 1978 must comply with the State’s lead law (Title 6, Subtitle 8
of the Environmental Article). Properties built prior to 1950 must provide a copy of the Maryland Department of the Environment
(MDE) lead certificate. Properties built between 1950 and 1978 must provide a copy of MDE lead certificate, if new tenant as of
January 1, 2015. We cannot process your application until this section is completed and lead requirements are met. If you have
questions call MDE at 410-537-4199.
MDE Tracking Number

Lead Certificate Number

Tenant Move in Date

Copy of Certificate Included)

Yes

No

Required Customer Information Booklet
Owner is required to provide the Customer Information Booklet for Rental Operating License and Property Maintenance prepared by
the Department of Planning and Zoning to new tenants. (City Code Section 18.04) Copies are available on our website
www.annapolis.gov or by visiting our office.
Owner/Agent Certification
The applicant hereby certifies and agrees that: (1) they are the owner or the duly authorized agent of the owner to make this application; (2) they have
read all of the information above set forth and declare under penalty of perjury that the foregoing is true and correct; (3) the license, if issued, may be
declared void should said information be false; (4) they will comply with the ICC Code and the Charter and Code of the City of Annapolis, which are
applicable hereto; (5) they agree to inspections by the Department of Planning and Zoning and the Fire Department to determine if the property is in
compliance with the provisions of the ICC Code and the Charter and Code of the City of Annapolis; (6) they will notify the Department of Planning and
Zoning within 24 hours if there is a change of ownership or in the agents who are listed above.

Applicant Signature
Fee Submitted $

Date
. Checks made payable to City of Annapolis and mailed to the address above.

 Case 1:19-cv-01442-CCB Document 1-4 Filed 05/16/19 Page 1 of
1
Exhibit
D
R-31-15
Page 1
1
2
3
4
5

..Title
Rental Unit Licenses - For the purpose of waiving fees associated with the licensure and
inspection of HACA residential rental units.
..Body
CITY COUNCIL OF THE

6

City of Annapolis

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46

Resolution 31-15
Introduced by: Alderwoman Finlayson
Referred to
Economic Matters
Finance Committee
Housing and Human Welfare
A RESOLUTION concerning
Rental Unit Licenses
FOR the purpose of waiving fees associated with the licensure and inspection of HACA
residential rental units.
WHEREAS the Housing Authority of the City of Annapolis (“HACA”) provides housing to
hundreds of Annapolis citizens and their families; and
WHEREAS the City of Annapolis and HACA desire to ensure that the residents of HACA
housing are afforded safe and habitable housing; and
WHEREAS City Code Chapter 17.44 requires the City to license and inspect all rental housing
units in the City; and
WHEREAS the cost of such licensure, inspection and associated fees could encumber HACA
with tens of thousands of dollars of expenses.
NOW THEREFORE BE IT RESOLVED BY THE ANNAPOLIS CITY COUNCIL that the
fees associated with the licensure and inspection of HACA residential rental units are hereby
waived.
AND BE IT FURTHER RESOLVED BY THE ANNAPOLIS CITY COUNCIL that this
Resolution shall take effect on the date of its adoption.
EXPLANATION
CAPITAL LETTERS indicate matter added to existing law.
Strikethrough indicates matter stricken from existing law.
Underlining indicates amendments.

 Case 1:19-cv-01442-CCB Document 1-5 Filed 05/16/19 Page 1 ofExhibit
1
E
FISCAL IMPACT NOTE
Legislation No:

R-31-15

First Reader Date: 12-7-15
Revised Note Date: 1-4-16

Legislation Title: Rental Unit Licenses

Description: For the purpose of waiving fees associated with the licensure and inspection of HACA
residential rental units.
Analysis of Fiscal Impact: This legislation waives the fees associated with the licensure and
inspection of HACA residential rental units as required by City Code Chapter 17.44. The current fee
structure, section 17.44.040 of the City Code, includes a $100.00 fee per annum for an operating
license for rental unit and rooming house. According to HACA, there are currently seven hundred
and ninety (790) HACA residential rental units within the City of Annapolis. Based on the number of
units, the net fiscal impact would be $79,000.

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 1 of 146

Exhibit F

CITY OF A~NAPOLIS
PROPERTY MAINTENAi\'CE CORRECTION l'\OTJCE RENTl 605-020
PROPF:RTY ADDRESS:

BLOOMSBURY SQUARE APARTMENTS

PROPERTY OWNER:

Annapolis Housing Authority
c/o Zena Saunders
101 Bloomsbury Square
Annapolis. MD 2140 I

DATE OF INSPECTION: May 5-6, 20 l 6
li'iSPECTIO:S TYPE:
A!\NAUT.
MARY EY!RICK. ADA\1 KNIGHT, STEVE !\~DREWS & HENRY GUTIERREZ
INSPECTOR:
VIOLATION(Sl

No.

Code Ref.

Unit

l.

JPMC 305.3

-7.,_.,

2.

~.,
IPMC 403.2 3,-

3.

IPMC 603.1

4.

IP::v!C 403 .2 319

BATl!ROOM-VENTFA:-.:S -CLEAN OUT-CLOGGED

5.

IPMC 504.1 313

2:-cu FLOOR- BA TI!ROOM (BOTH) - SHOWERffUB - RECAULK AREAS

6.

lPMC 305.3 309

KITCHEN - WALL AT LAUNDRY ROOM DOOR/TRIM - WATER DAMAGE- CUT OUT - REPLACE

7.

IPMC 305.3 307

MASTER BATHROOM - WALL - HOLES- REPAIR- PREPARE AND PAINT

8.

IPMC 305.4 307

MASTER BATHR.00\1 - FLOOR AT TUB- WATER DAMAGE - WEAK - REPLACE

9.

IPMC 305.4 307

2"n FLOOR IIALLW A Y - BATHROOM - FLOOR - WATER DAMAGE - WEAK - REPLACE

323

LIVING R00.\1- CEILING - DRYWALL SEAM - DEFECTIVE- REPAIR- PREPARE A!\D PAINT
BA Tl !ROOMS - VENT FANS - CLEA'K - COMPLETE!. Y CLOGGED
UPSTAIRS - COLD AIR RETCRN VENT - CLEAN OUT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 2 of 146

Exhibit F

IPMC 305.3 307

LIVING R00'.\1- ·CEILING··· WATER DMAGE- I.ARGE AREA - DRYWALL REPLACE- PREP ARE AND I'AII\T

IPMC 704.2 316

HALLWAY - SMOKE DETECTOR - PROVrDE HARDWIRED

IPMC 403.2 316

HALLWAY·· BAT! !ROO:vl - VENT FAN - DEFECTIVE· REPAIR/REPL'\CE

IPMC 104.2 314

NO E\:TRY - DOG-ALL DOGS MUST BE CRATED OR REMOVED FOR INSPECTION

IPMC 305.3 312

KITCIIE?-i - CEILING- STAIN - REPAIR - PREPARE AND PAINT

!PMC 305.3 312

1'1 FLOOR-CEILING - STAIN·· REPAIR-PREPARE AND PAINT

IP:V!C 305.1 310

KITCHEK -GARBAGE DISPOSAL- STUCK- REPAIR/REPLACE

17.

IPMC 305.3 308-A BATHROOM-CEILING- WATER SPOT -REPAIR-PREPARE AND PAINT

18.

IP:VlC 504.1 304

BATHROOM - TOILET SEAT - REPLACE

19.

IPMC 304.13 304

I'' FLOOR- Wf.\DOW -AIR COMING N AROUND WINDOW-SEAL

20.

!PMC 305.3 300-A BATI!ROOM- CEILI:\"G- WATER SPOTS-REPAIR- PREPARE AND PAINT

21.

!PMC 305.3 300-B BATHR00:\-1 - CEII.l\:G - WATER SPOTS - REPAIR - PREPARE AND PAINT

22.

IPMC 605.1 300-B KITCIIEN - LIGHT - DEFECTIVE- REPAIR/REPLACE
ll'MC 304.7 316

EXTERIOR- GUTTER- LOOSE- SECURE

24.

IPMC 304.14313

WINDOWS - FRONT - SCREE:\S- PROVIDE

25.

!PMC 704.1 311

SPRINKLER IIEADS- PAINTED OVER-MUST BE SERVICED BY LlCE>lSED CONTRACTOR FOR SPRIK'KLERS

26.

IP'.v!C 704.2 3 I 1

SMOKE DETECOTRS - BOTH LEVELS - BEEPING - REPLACE BATTERIES

27.

IPMC 305. I 31 I

KITCJ IE:-: - POOR HOUSEKEEPING - TENANT'S RESPONSIBILITY

28.

!PMC 504.1 311

BATHR00\11 - S!IOWERfl"UB DIVERTER- LEAKING - REPAIR/REPLACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 3 of 146

Exhibit F

29.

IPMC 304.14 307

WI\DOWS. SCREENS-TOR:\ - REPLACE

30.

IPMC 704. I ~05-8 SPRl:\KI.ER I IE/\DS- PAINTED OVER- \1lSI BE SERVICED BY L!CE'.\SED CO>ITRACTOR FOR SPRI".'KI.ERS

3 I.

IP1v1C 305. l 305-B KITCH!-:'.\ - WAS! 11:\G MACHl:S:E - DRAl'.'J PA'- CR..-\CKED- REPL\Cl'

32.

!P\1C 603.1 305-8 KITCHE:S: ·· STOVE- RIG! IT FRO:S:T Bl."R:S:ER

33.

IPMC 704.1 305-A SPRINKLER l !EADS- PAIX!D) OVER-'.vlUST BE SERVICED BY UCE>1SED COl\TRACTOR FOR SPR!\:K! .ERS

34.

!!':VIC 305.1 305-A K!TCl!E;\i - WAS! !ING MACl!l:\E PAN · CRACKED- REPLACE

35.

IP:v1C 604.2 305-A BATHROOM . GFCI

36.

IPMC 704.1 30 !

SPRl'\KLER l !E:\DS- P,\I'.',JTED OVER-:V1L"ST BE SERVICED BY L!C!~SED CO'.\TRACTOR fOR SPRl'.\KI.ERS

37.

IPl\1C 702.3 215

BEDROOM- DOORS·· KEY LOCK· RE\10VE - i'iOi" PER\1JTI"ED

38.

IP\1C 304.7 213

ROOF - DRIP EDGE- Fi\l.LI1'<i OFF - REPAIR

39.

lPMC 403.2 209

2:-:D FLOOR - BATHROOM - VENT FAN · DEFECTIVE - REP AIR/REPL1\CE

40.

!!'MC 603.J 201-A FURNACE· >/EEDS :VL\J:-,.;TE\:ANCE A):0 REPAIRS :V1ADE

41.

IP\!C 504. l 2 I 9-B KITCHEN - FAUCET

42.

Il'\lC 604.~ 219-A KITCHEt-,; · ot:TLETS - '\O POWER (BY W:\J.L SWITCH :\REA)- REPAIR'REPI.ACE

43.

IP:VIC 402.3 213

I si FLOOR- BATllROO:VI ·· VENT FAN - CLOGGED

44.

IPMC 305. l 213

KITCHEN -GARBAGE DISPOSAL- PROVIDER\ ;13131,R GROMET

45.

!!'MC 305.1 215

LAli'.'\DRY ROO!vl - REMOVE PORTABI.EDIS!lWASl IER

46.

Il':VfC 603.1 2 I 5

K!TCHE'.\ - STOVE - NOT WORKING- REP:\!RiREPI.ACE

DEFECTIVE - REPAIR 'REPI..A.Cl'

PAINTED OVER·· REPLACE

LOOSE

:v!\JST RE\1AIN GIT!

REPAIR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 4 of 146

Exhibit F

47.

IPMC 702.3 215

JsT BEDROOM - DOOR- LOCK- REMOVE- NOT PERMITTED

48.

IPMC 305.6 215

MECHANICAL ROOM - CHECK LOCK ON DOOR - DEFECTIVE

49.

IPMC 305.3 207

2"° FLOOR HA.LL WAY -CHECK FOR LEAK-REPAIR- PREPARE AND PAINT

IPMC 605.3 207

i"° FLOOR HALLWAY - PROVIDE MISSING LIGHT GLOBE

51.

IPMC 305.1 21 I

KITCHEN -REFRIGERATOR- PA.1'-1 CRACKED ON PA'-/ - REPAIR/REPLACE

52.

IPMC 304.7 211

ROOF - DRIP EDGE - DEFECTIVE - REPAIR/REPLACE

53.

IPMC 305.3 I J 1-B BATHROOM-CEILING- WATER LEAK- REPAIR- PREPARE AND PAINT

54.

IPMC 604.3 111-A KITCHEN -Ol.iTLET TO RIGHT OF SINK-REVERSE POLARITY -REPAIR

55.

IPMC 604.3 J 1I-A LIVING ROOM- CHECK OUTLET TO RIGHT OF TV STAND-NO POWER

56.

IPMC 603. I 113

57.

[PMC 305.1

58.

IPMC 305.I 113-D FUR:'\'ACE ROO:Vl- WATER LEAK IN CEILING AROlJND HOT \VATER HEATER AREA- REPAIR

59.

!PMC 704.1

60.

IPMC 604.3 113-E BATHROOM- GFCI - DEFECTIVE - REPAIRIR.EPLACE- Ml,ST REMAIN GFCI

61.

IPMC 603.1 113-F Fl.iR:"\iACE AREA - CHECK CONDENSATION LINE & PUMP - REPAIR

62.

IPMC 305.4 I 09-A FUR:'\/ACE ROOM - FLOOR - LEAK- REPi\.IR

63.

IPMC 305.4 109-A FURA,'\/CE ROOM- MOLD ON FLOOR-REPi\.IR-CLEAN AND SANITIZE

64.

IPMC 504.1

65.

IPMC 704.2 109-A SMOKE DETECTOR- LOW DECIBEL- REPLACE- MUST RElvlAIN ELECTRIC

I ST FLOOR - DUCT - SHOWING DIRT

113-C FURNACE ROOM - CEILING - HOLE - REPAIR

0

2" & 3RD FLOOR HALLWAY - E:VlERGENCY LIGHTS- DEFECTIVE- REPAIR/REPLACE

109-A KITCHEN-SINK-LOW WATER PRESSl.iRE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 5 of 146

Exhibit F

109-A KITCf!E'>; -1:l.ECTRlCAL OLTLET - Dl'FECTIVE Rl'PAl!~REPL/\CE

66.

11':v!C 6043

67.

IP\,!(' 304.7

BCll.Ol'.JG 312 & 314 - ROOF RlDGE VE'.JT · REPAlR - Bl 'ILDl'.\G PER\1IT WJ!.1. BE REQURED

68.

lP\·IC 704.1

C0\-1\!l''-:ITY CE'-:TER ,\REA - EXIT I.IGHT & B,\CKl.'P LIGHTS '-:OT \\'ORK!'.\G - REPAIR 1REPL\CE

69.

IPMC 603. l

GAS \IETERS - CO'.\'-:ECTlO'-: TO BUILDNCi- '.\iEED TO BE SLE!:VED OR H:\RDPIPED - WORK \1l."S[ BE
[)O'-:E BY l.lCE:--:SED PU 'MBER'G:\S Frn·1·:R - PER\l!TS WILL BE REQl'IRED

70.

lP'.\1C 403.5

DRYER VE'.\TS- RE\10VE EXCESS Ll>!E A'.\D CLE,\'.\ OLT VE:--.:TS

71-

!P\fC 403.~

BAlllROOl\1 - vi::-;T FA'-:S ... \LI. CLOGGED- CLEA'-: Ot:T Tl [ROL!Gl!Ot:r CO!IIPLEX

72.

ll'\IC 704.2 I 704.3 Al.I. UNITS
PROV[J)E i'LECTRIC l!ARDW[RED S'.\10KE DETECTORS I'.\ ALI. SLEE!'l:S.:G ROOMS ..
LHTRlC,\l. PER\IIT WILL BE REQL'IRED

73.

IJ>\.JC 304.14

ALI. l''-:ITS - Wl'-:DO\\'S

74.

IP\,!C 308.3

Al.I. l:;-s;rrs .. ALL TRJ\SI I CJ\l\S Ml ;sT l!A VE LIDS WIT! l ADDRESS 0\: E,\Cl l CJ\'.\: PER CITY CODE

75.

ll'MC 504. l

/\LL lJN[TS-1 lOT W J\TER 1!E./\TER EXPANSlO!'-,J TANKS-SECURE WIT! I STRJ\PP[NG- Pl.LcMBC\'(i PER\HTS
REQljlRED

76.

IPMC 305.3

ALL ELECTRIC METER ROOMS - I !OJ.ES I\: CE!l.ll\GS - Fil.I. HOLES

77.

!RC

J\Ll. C°NITS ·· PROVIDE CO DETECTORS ON THE LEVEL WHERE SI.El'PIN(i R00\1S ARE LOCATED

315.1

SCREE:--.:S - l'ROVIDE

ALL ELECTRICAL, J,fECHAlV/CAL, BUILDING AND PLUMBING WORK WILL REQUIRE PER.11-1/TS TO DO THE WORK AND FINAL
INSPECTIONS ON THESE ITE"JS WILL BE CONDUCTED BY THE CITY OF ANNAPOLIS INSPECTORS FOR TIIAT TRADE - ANY
QUESTJOSS, PL£4.SE FEEL FREE TO CO.\'TACT l'S AT 410-263-7946

REINSPECT/ON SCHEDULED ON SEPTEBl'.JER /9-2fJ. 2016 AT 9:30 A.M.

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 6 of 146

Exhibit F

CITY OF ANNAPOLIS
PROPERTY '.\1AINTENANCE CORRECTION NOTICE RENT1605-033
PROPERTY ADDRESS:

EASTPORT TERRACE APARTMENTS

PROPERTY OWNER:

Annapolis I lousing Authority
cl(} Raylyne R. Shaw
1217 \'iadison Street
Annapolis, MD 21403

DATE OF INSPECTION: May 12. 2016
11\SPECTION TYPE:
A:,,.JNAUL
l;"t;SPECTOR:
:\1ARY EMRICK. ADA:\1 KNIGHT. STEVE A:\'DREWS & HENRY GUTIERREZ
VIOLAT!ON(Sl
No.

Code Ref.

Unit

PRESIDENT STREET
1.

lPMC 104.2 1101

UNIT CljRREXTLY VA CANT - NO GAS TN THE UNIT

j

JPMC 704.2 I 101

lsr BEDR00:\1- SMOKE DETECTOR- NOT SOUNDING- REPLACE

3.

IPMC 305.6 1101

BATHROOM - DOOR- OFF III?\GES - REPAIR

4.

IPMC 603.1 1102

MECHANlCAL ROOM - HOT \VA TER HEATER - VENT STACK - LEANING - SECURE TO CEILING

5.

IP.:viC 305.3 1102 BATHROOM - WALL - :\10LD - REPAIR - PREPARE A)JD PAINT

6.

IP:vtC 305.3 1102

BA TH ROOM - WALT. AREA BY TUB SURROUND - CRACKED - REPAIR - PREPARE AND PA.NT

7.

IPMC 604.3 110:2

BATIIROOM-SWlTCH PI.ATE-CRACKED- REPLACE

8.

IPMC 603.l 1102 MASTER BEDROOM - VENT PIPE - PROVIDE BLAKK

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 7 of 146
9.

lPMC 704.2 1 ! 02

ALL BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

10.

IPMC 604.3 1102

IJVl~G ROOM · SWITCH PLATE AT DOOR- CRAKCED - REPALCJ-::

IL

IPMC 305.3 1103

KlTCHE~ - \VALL BY REAR DOOR- CO:v1PLETE REPAIR·· PREPARE AND PAINT

12.

lPMC 305.3 1103

KITCHEN - PLASTER -- FLAKING - REPAIR - PREPARE AND PAINT

13.

IPMC 504.l 1103

KIT CI IE?\ - SINK FAtCET - PROV IDE /\ERATOR

14.

IPMC 603.l 1103

KITCHEN - STOVE - REAR BURNER- DEFECTIVE-REPAIRfREPLACE

15.

fPMC 605.3 1103

KITCHEN - LIGHT FIXTURE - PROVIDE GLOBE

16.

IPMC 604.3 1103

STAIR \VAY - 3 WAY SWITCH AT TOP OF STAIRS - NOT WOR.Kl"KG -- REPLACE

17.

lPMC 605.3 1103

2KD

18.

IPMC 504.l 1103

BATRHOOM - TUB SURROUND - RECAULK

19.

fPMC 504.1

20.

lPMC 305.3 1104

KITCHEN - WALL BEHIND WASHER - HOLE - REPAIR - PREPARE AKO PAINT

21.

IPMC 504.1 1104

KITCHEN - SlNK f Al'.CET -DRIPPING- REPAIR

22.

fPMC 704.2 1104

2KD

23.

IPMC 603.1

1104

KITCHEN - STOVE- MAULFL~CTIONJNG- REPAIR/REPLACE

24.

IPMC 605.1

1104

BEDROOM - LIGHT FIXTURE- NOT WORKING -REPAIR/REPLACE

25.

IPMC 605.3 1104 BEDR00:\1 -LIGHT FIXTURE - PROVIDE GLOBE

26.

IPMC 305.3 1105

27.

lPMC 305.3 1105 KITCHEN - REAR WALL AT WINDOW - HOLE - REPAIR - PREPARE AND PAINT

1104

BEDROOM - LIGHT FIXTURE - PROVIDE GLOBE

KITCHEN - SJ:\lK - CLOGGED - REPAIR IMMEDIATELY

FLOOR - SMOKE DETECTOR - LOOSE- SECURE TO CEILING

KITCHEN - CEILING - FALLING DOWN - REPAIR IMMEDI/\TELY - PREPARE AND PAP.\T

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 8 of 146

28.

IP:'vlC 305.1 1105

KITCHEN - BACKS PI.ASH - RECJ\ULK

29.

IPMC 604.3 1105

KITCHEN - GFCI - DEFECTIVE - REPLACE - MCST REM.A.JN GfCI

30.

IP:vfC 603.1 1105

KITCI lEN - STOVE - RlGl ff SIDE BURNERS - DEFECTIVE- REPAIR/REPLACE

31.

IPMC 305.6 l l05

1i;r BEDR00\11 - DOOR - PROVIDE HARDWARE

"")
,)

.....

IPMC 305.6 1105

1ST BEDROOM - DOOR -- JA;.v1B BCSTED - REPLACE

.,.... .
.)

IP:v1C 305.6 1105

2~n BEDROOOM - DOOR - JAMB BCSTED - REPLACE

34.

IPMC 702.3 1105

2:-:n BEDROOM - DOOR - DEADBOLT - REMOVE

35.

IPMC 403.2 l 105

BATHROOM- LIGHT/FAN FIXTURE-- fALLING DOWN - SECCRE & CLEAN

36.

IP:MC 504.1 1105

BATHROOM - Tl:B FACCET - DRIPPING- REPAIRJR.EPLACE

37.

lP;vtC 305.4 ]105

BATHR00\1- FLOOR AREA AT TCB -RECAULK

38.

IP~C 504.1 1105

BATHROOYl - TLB SL"RROUND - RECAULK

39.

lPMC 305.l. · 1105

BATHR00\1- SOAP DISH & TO\VEL BAR - PROVJDE

40.

IPMC 305.3 1105

UV~G ROOM - WALL AT WfNDOW - HOLES - REPAIR - PREPARE AND PAINT

41.

IPMC 309.1 110j

EXTERMt\ATE - ROACHES

42.

IPMC 704.1

43.

lPMC 504.1 1106

BATHROOM - TUB SURROUND - REC AlJLK

44.

IPMC 605.3 1107

HALLWAY - LIGHT FIXTURE - PROVIDE GLOBE

45.

IPMC 603.l 1107 KITCHEN - STOVE - RIGHT SIDE BURNERS - DEFECT[VE - REPAIR/REPLACE

1106

LOW BATTERY CHIRP -- PROVIDE BATTERlES IN S:MOKE DETECTORS

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 9 of 146

46.

IPMC 304.1

1181-1184-RETAINNGWALL-LEAND\G-REPAIR

IPMC 704.2 1181

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS & CO DETECTOR ON 2NF FLOOR AREA

IPMC 504.l 1182 KITCHEN - SINK FAUCET - DRIPPING - REP AIR
,

IPMC 505.4 1182

MECHA.NICAL ROOM-HOTW.-1...TER HEATER-REPLACE

1P:V1C 604.3 1182

KITCHEN - LIGHT FIXTURE - COVER/GLOBE - PROVIDE

IPMC 605.1

1182

DO\VNST.AJRS BEDROOM - LIGHT FIXTURE - SHORT - REPAIR

52.

IPMC 305.1

1182

BEDROOM- NEEDS TO BE RENOVATED

53.

IPMC 604.3 1182

1sr FLOOR- BEDROOM - LIGHT FIXTURE - SHORT - REPAIR IMMEDIATELY

54.

IPMC 305.5 1183

STAIRS - HANDR.A.lL - REATTACH - SECURE

IPMC 605.3 1183

ST.AJRSVv'A Y - LIGHT FD..'TURE AT TOP - PROVIDE GLOBE

lPMC 704.2 1183

LOW BATTERY CHIRP - PROVIDE BATTERIES FOR SMOKE DETECTORS

IPMC 305.3 1184

KITCHEN - WALLS - DEFECTIVE- REPAIR - PREP ARE i\.ND PAINT

IPMC 305.l

61.

Exhibit F

1184

HOGSEKEEPING - THROUGHOUT UNIT - TENANTS ADVISED ON SITE

IPMC 305.3 1184

LIVING ROOM- WALL- PLASTER DEFECTIVE-REPAIR- PREPARE A..~l) PAINT

IPMC 605.3 1184

KITCHEN - LIGHT FD..'TlJR.E- PROVIDE GLOBE

IPMC 305.3 1184

KITCHEN - CEILING-ACCESS PAt'\JEL- MOLD-REPAIR-PREPARE A1':l) PAINT

IPMC 603.1

LNING ROOM- THER.MOSTAT - DEFECTIVE- REPLACE

1184

IPMC 604.3 1184

2:-.ao BEDROOM- OUTLET BY BED - DEFECTIVE - REPLACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 10 of 146
64.

IP\.1C 702.1 1184

65.

IP\1C 504.1 1184 BATHROOM- TCB SURROUND-RECAULK

66.

lPMC 305.3 1184 BATHR00\1- CEIU!\"G- REPAIR-PREPARE A7'D PAINT

67,

IPMC 403.2 1184 BATHR00:\1 - VENT FAN/UGI IT f!XTURE - CLEAN OUT

68.

IPMC 605.1 1184 STAIRWAY - WIRE MOLlLDJNG- LOOSE- SECURE

:;RD

Exhibit F

BEDROOM - AC UNIT IN ROOM - CA]'(NOT BE USED IN WINDOW - BLOCKS :'VIEA'.'\S OF EGRESS

MEDGAR EVERS STREET

69.

IP~1C 305.I

REAR EXTERIOR AREAS OF MEDGAR EVERS STREET - DEBRIS, TIRES, ETC REMOVE

70.

IPMC 403.2 1134

BATHROOM- VENT FAN/LIGHT FIXTURE-fALLING DOWN - REPAIR

71.

IP\ifC 305.3 1134 BATHROOM-CEIUNG-REPAIR-PREPARE AND PAI:\TT

72.

IPMC 305.3 1134 2:-;l) FLOOR - HALLWAY - REPAIR- PREPARE AND PAINT

73.

IP:'vfC 305.3 1134 STAIRWAY -UPPER WALL-HOLE ·-REPAIR-PREPARE AKO PAINT

74.

IPMC 603.1 1134 MECHANICAL ROOM - HOT WATER HEATER VENT - BIRD I~SlDE AUVE

75.

IP\1C 704.1 1135

LOW BATTERY CHIRP-PROVIDE BATTERIES FOR SMOKE DETECTORS

76.

IPMC 605.3 1135

2~° FLOOR - HALLWAY - LIGHT FI.X"llJRE - PROVIDE GLOBE

77.

IPMC 604.3 1135

ST,AJRW AY - 3 WAY SWITCH - DEFECTIVE - REPLACE

78.

lPMC 704.1 1135

1sr FLOOR- ELECTRIC SMOKE DETECTOR - DEFECTIVE - REP AIR

79.

IPMC 504.1 1135 BATl IROOY! - TOILET RUNS CONTINUOUSLY - REPAIR

80.

JPMC 305.3 1136 KITCI IE)J - CEILING - REP AIR - PREPARE AI\iD PAfNT

81.

lPMC 603.1 1136 KITCI IE"'.\; - STOVE -- KNOBS - PROVIDE

 ---------·---

Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 11 of 146

82.

IPlvfC 604.3 1136

LIVING ROOM - LIGHT FIXTURE- PROVIDE COVER

83.

IPMC 305.4 1136

BATHROOM - FLOOR - DEFECTIVE -REPLACE

84.

IPYIC 604.2 1137

NO ELECTRIC IN THE l.JNIT

85.

IPMC 702.1

86.

lPMC 304.15 1138

ENTRAl'..rCE DOOR - J MOLD - REPLACE

87.

IPMC 504.1

1138

EXTERIOR- FRONT WATER FAUCET - REP AIR

88.

IPMC 305.1 1138

KITCHEN - COUNTEROP EDGING - REATTACH

89.

IPMC 305.6 1138

2:-,;o BEDROOM - DOOR - STRIKE PLATE - MISSING - PROVIDE

90.

IPMC 504.1 1138 BATHROOM- TUB SURROlJND- RECAULK

91.

IPMC 704.2 1139

92.

IPMC 305.3 1140 LIVING ROOM - CEILING - REPAIN'T

93.

IPMC 305.3 1141

94.

IPMC 305.3 1142 KITCHEN - WALL BEHIND WASHNG M.6..CHlNE-REPAJR-PREPARE AND PAINT

95.

IPMC 605.1

1142

BATHROOM - LIGHT FIXTURE - DEFECTIVE - REP AIR/REPLACE

96.

IPMC 30.53 1143

MECHANICAL ROOM- HOLES - REPAIR- PREPARE Al'\JD PA.INT

97.

IPMC 702.3 1143

BOTH BEDROOM DOORS - KEY LOCKS - REMOVE - NOT PER.i\11TTED

98.

IPMC 305.3 1143

HALLWAY - WALL AT DOORS - DEFECTIVE - REPAIR - PREPARE AND PAINT

99.

IPMC 605.2 1144

KITCHEN - GFCI - DEFECTIVE - REPLACE MUST REMAIN GFCl

1137

PL Y\VOOD \\t1ND0W FOR AC lJNIT - REMOVE

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS & CO

1sT FLOOR - ALL CEIL:i};GS - PEELING PAIXT - REP AIR - PREPARE At",jD PAINT

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 12 of 146
BATHR00'.\1 - GFCI - DEFECTIVE - REPLACE :Vll'ST REMAIN GFCl

100.

lPMC 604.3 1144

101.

IPMC 603.1

ICC.

IPMC 603.3 1145

103.

IP:VIC 605.1

104.

lP'v1C 305.6 1145

MECHAKICAL ROOM - DOOR - DEFECTIVE

105.

IP?v!C 304.15 1145

ENTR,."''\iCE DOOR- LOOSE - REPAIRiREPLACE

106.

IPMC 604.3 1146

BATHR00'.\-1 - GFCI - DEFECTIVE - REPLACE MUST REMAIN GFCI

107.

IPMC 304.15 1147

ENTRANCE DOOR-J MOULDING-REPLACE

109.

IPMC 704.2 1147

1sr FLOOR- ELECTRIC SMOKE DETECTOR- DEFECTIVE - REPLACE

110.

IPMC 304.15 1148

REAR DOOR- WEATHER STRIPPING-PROVIDE

111.

lPMC 704.2 1149

1sr FLOOR- ELECTRIC SMOKE DETECTOR- REMOVE

112.

IP:V!C 403.2 1149

BATHROOM- VE?sff FA1'\i/LIGHT FIXTuRE- CLOGGED-CLEAN OUT

113.

IPMC 605.1 1149

BATHROOM-REMOVES?vlALLHEATER

114.

IPMC 504.I 1150

EXTERJOR-WATERFAUCET-REPLACE

115.

IPMC 605.3 1150

LIVING ROOM - LIGHT FIXTURE - PROVIDE GLOBE

116.

IPMC 603.1 1150

KITCHEN - STOVE - RIGHT FRONT BUR.'\iER - DEFECTIVE -REP AIR/REPLACE

] Ji.

IPMC 305.1 1150

KITCHEN - CABINET DR.A.. WER- MISSING- PROVIDE

118.

IPMC 704.2 1150

2~° FLOOR- ELECTRJC SMOKE DETECTOR - DEFECTIVE - REPLACE

119.

IPMC 403.2 1150

BATHROOM - VE"'"T FAN/LIGHT FIXTURE- CLOGGED - CLEAi'\i Olff

1145

1145

\1ECHANlCAL ROOM - FRESH AIR VENT - RE:V!OVE TAPE
MECH.ANIC.t..L ROOM - STORAGE & FLA:V!\1ABLES - REMOVE- NOT PER.\1ITTED
:V!ECHA"l\i!CAL ROOM - HOT \VATER HEATER - RECEPTICAL -

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 13 of 146
110.

JPMC 704.2 1150

121.

IPMC 305.4 ]150 2~° FLOOR ... CABLE WIRE-· SECURE - TRIPPNG HAZARD

122.

IPMC 305.l 1151

123.

lPMC 605.1

124.

lPMC 704.2 1151

ALL BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

125.

lPMC 305.3 1151

BATHROOM - CETLJ:.:'G - REPAIR - PREPARE A~D PAINT

126.

lPMC 603.3 1151

MECIIA."'\lCAL ROOM - CLOTHES AND DEBRIS - REMOVE - NOT PER;V[ITTED

127.

IP~v1C 603.3 1151

YIECHANJCAL ROOM - HANGERS ON WATER AND GAS Lil\.ES - REMOVE

128.

IPMC 505.4 1152

MECHANICAL ROOM - BOT WATER HEATER - FLCE - REPAIR

129.

IPMC 305.3 1]53 KITCHEN - CEIU~G- PEELING PAI~T - REPAIR- PREP/\.RE AND PAINT

130.

IPMC 704.2 1153

1151

Exhibit F

ALL BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

HOUSEKEEPI}.;G- THROUGI IOUT

MECHANIC Al. ROO\if - ELECTRIC AL BOX - SECURE

I s-r FLOOR- ELECTRIC SMOKE DETECTOR - REYIOVED - REPLACE

FREDERICK DOUGLAS STREET
131.

IPMC 305.3 1108 Y1ECHANICAL ROOM - HOLE BEHIND HOT WATER HEATER - REPAIR - PREPARE AND PAINT

132.

IPMC 603.1 1l 08

KITCHEN - STOVE·- ::-JOT WORKING - REPAIR/REPLACE

133.

IPMC 605.1 1108

ELECTRICAL ISSUES THROUGHOUT - REPAIR

134.

IPMC 304.15 1108 FRONT DOOR- KNOB- BROKEN -REPLACE

135.

IPMC 605.3 1108 LIGHT FIXTURES - THROUGHOUT - PROVIDE GLOBES

136.

IPMC 704.2 1108

lsT FLOOR-ELECTRIC SMOKE DETECTORS- DErECTIVE- REPLACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 14 of 146

Exhibit F

137.

IP:'vlC 505.4 1108

HOT \V ATER l IEATER --- VC\:T PIPE l'\EEDS TO BE SECCRED - REPAIR

138.

IPMC 305.3 1108

REAR BEDROOM- CEILI>iG -REPAIR -- PREPARE AND PANT

139.

IPiv1C 605.2 1108

KlTCI !EN·- GFCl - DEFECTIVE - REPLACE MUST RE:vtAIN GFCI

140.

IPMC 704.2 1109 LOW BATTERY CHIRPS - PROVIDE BATTERIES

141.

IPMC 603.l 1109 KITCHE'.\l - STOVE- RIGHT FRONT&LEFT REAR BCRNERS - DEFECTfVE - REPARJ/REPI.AC

142.

IPMC 504.l

143.

IPMC 403.2 1l09

BATHROOM- VENT FAN - CLOGGED - Cl.EAN OUT

144.

IPMC 305.4 ]109

1:-.T BEDROOM·· FLOOR TILES - DEFECTIVE --REPLACE

145.

IP~C 305.6 1109

i'D BEDROOM - DOOR- HOLE - REPLACE

146.

IPMC 305.3 1109

2~D BDROOYl - CEILI::-.:G - REP AIR - PREPARE AND PAl),iT

147.

IP:\1:C 603.1 1110

KITCHEN - STOVE - LEFT FRO).;T BLJR:-,.:ERS- DEFECTIVE - REPAIRJREPLACE

148.

lPMC 305.l 1110

KITCHEN -· REF RIG ERATOR - BOTTO:V1 SEAL · - DEFECTIVE - REPLACE

149.

IPMC 604.3 1110

KITCHEN -SWITCH PLATE - CRACKED- REPLACE

150.

IPMC 704.2 1110

1sT & 2~o FLOOR- ELECTRIC SMOKE DETECTORS - REMOVED - PROVIDE

151.

IP~C 504.l

152.

IPMC 305.3 1110 BATHROOM - WALLS - MOLD - REPAIR - PREPARE A:--.JD PAINT

153.

IPMC 504.1 1110 BATHROOM- SINK- CRACKED- REPLACE

154

IPMC 505.4 1111

I!OT WATER HEATER - VENT PIPE - SECURE

155.

IPMC 603.1 1112

KITCHEN - STOVE -2 BURNERS - DEFECTIVE - REAJR/REPLACE

l 109

BATHR00:\1-SINK- FACCET ··LOOSE

1110 BATHROOM - TUB - RUSTED - REPLACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 15 of 146

156.

lPMC 604.32 1112

KITCI !EN - GFCl AT SNK- DEFECTIVE-REPLACE MCST RPvfAlN GFCI

157.

IPMC 603.1

KITCHEN - STOVE - RIGHT FRONT BURNER - DEFECTIVE-· REPAIR/REPLACE

J58.

!PMC 305.3 1113

KITCHEN-WALL Ar Wl:>iDOW-REPAIR- PREPARE AND PAJ)JT

159.

IPMC 605.3 1113

KITCHEN - LIGHT FIXTCRE ·- PROVIDE GLOBE

160.

IPY!C 305.3 1113

KITCHEN -CEIL!NG-PEEL~G PAINT- REPAIR-PREPARE AND PAINT

161.

IPMC 305.3 1113

l.lV!NG ROOM - CEILING - PEELING PAl:>JT - REP AIR - PREPARE AND PA!NT

162.

!P'.v!C 704.2 1113

2'D FLOOR - ELECTRIC SMOKE DETECTOR - DEFECTIVE-· REPLACE

163.

!PMC 504.1 1113

BATHROOM-Sl'.\JK FAUCET Kl\OB- LOOSE- REPAIR

164.

IPMC 305.3 1113

BATHROOM -FLAKING PAINT-REPAIR-PREPARE Al\D PAINT

165.

IPMC 504. l 1113

BATHROOM-TOILET-LEAKING AT BOTI"OM-CHECK WAX RING- REPLACE

166.

IPMC 305.3 1113

STAIRWAY-HOLE-REPAIR-PREPARE ~"'JD PAINT

167.

lPMC 304.151114

FRONTDOOR-LOOSE-REPAlR

168.

IPMC 604.3 1114

BATHROOM - GFCl- DEFECTIVE- REPLACE MUST REMAIN GFCI

169.

IPMC: 605.3 1115

KITCHEN - LIGHT FIXTURE- PROVIDE GLOBE

170.

IPMC 305.3 1115

KITCHEN- CEIL!NG-I!OLE- REPAIR-PREPARE AND PAINT

171.

IPMC 504.1 1115

KITCIIE'.',l-fAUCET-PROV!DEAERATOR

172.

IPMC 603.3 · 1115

MECHA'.',IICAL R00:\1-REMOVE HANGERS ON GAS/WATER LINES

173.

IPMC 504.1

BATHR00:\1 -TOILET -LOOSE- SECURE

1113

1115

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 16 of 146

Exhibit F

174.

!Plv1C 504. l 1115

BATHROOM- TUB- RECAULK

175.

IPMC 402.3 111 5

MASTER BEDROO:V1 & i' 0 BEDROOMS- LIGHT FIXTURES- PROVIDE GLOBES

176.

IPMC 305.4 1115

STAIRS-2ND STEP- NOSING- DEFECTIVE- REPLACE

177.

IPMC 704.2 1116

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS & CO DETECTOR ON i'° FLOOR AREA

178.

IPMC 305.3 1117

KITCHEN - CEILING - REP AIR - PREPARE A?-iD PAINT

179.

IPMC 504.1

BATHROOM- REMOVE WASHING MACHINE FROM SHOWER

180.

IP:v!C 702.1 1118

AC UNIT IN WINDOW - REMOVE- BLOCKS EGRESS

181.

IPMC 304.141118

SCREEN DOOR - HOLES IN SCREEN - REP AIR/REPLACE

182.

IP:VIC 704.2 1118

lsT & 2"° FLOOR- ELECTRIC SMOKE DETECTORS- REMOVED- REPLACE

183.

IPMC 704.2 1118

LOW BATTERY CHIRPS - PROVIDE BATTERIES

184.

IPMC 605.3 1118

BATHROOM - LIGHT FIXTURE- PROVIDE GLOBE

185.

IPMC 305.3 1118

KJTCHEN - CEILING - FLAK.ING PAINT - REP AIR- PREPARE A~1) PAINT

186.

!PMC 305.3 1118

K!TCHE:'i - COUNTERTOPS - RECAULK

187.

IPMC 704.2 1119

1sT FLOOR- ELECTRIC S:V10KE DETECTOR- REMOVED - PROVIDE

188.

IPMC 304.15 1120

BOTH SCREEN DOORS- REPAIR

189.

IPMC 604.3 1120

REAR BEDROOM - OUTLET - DEFECTIVE - REPLACE

190.

IPMC 504.1 1120

WASI-IING MACHINE - REMOVE

191.

IPMC 305.6 1120

REAR BEDROOM- DOOR- HOLE - REPLACE

192.

IPMC 605.3 1121

KITCHEN - LIGHT FIXTURE- PROVIDE GLOBE

1117

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 17 of 146
i93.

IPMC 604.3 . I 12 I

1'T FLOOR - BEDROOM - LIGHT SWITCH- SHORT

194.

IPMC 605.3 1121

I sr FLOOR - LIGHT FLXTURE - PROVIDE GLOBE

195.

IPMC 305.4 I 121

KITCHEN - FLOOR TILES - REPLACE

196.

IPMC 305.1

I 121

KITCHEN - R.A.NGE HOOD - RUSTED - REPLACE

197.

IPMC 604.3

I 121

THROUGHOUT - OUTLETS&. SWITCHES - PAINTED OVER- REPLACE

198.

IPMC 304.4 1121

2''° FLOOR - ALL FLOOR TILES - REPLACE

199.

IPMC 604.3 1121

BATHR.OOM - LIGHT ABOVE SINK - DEFECTIVE -RE PAIR/REPLACE

200.

IPMC 504.1

BATH ROOM - TUB &. TOILET - RECAULK

201.

!PMC 403.2 1121

BATHR.OOM - VENT FAN - COVER - PROVIDE

202.

IPMC 304.14 1121

WINDOWS - SCREENS - PROVIDE

203.

IPMC 605.3

ALL BEDROOMS - LIGHT FLXTURES - PROVIDE GLOBES

204.

IPMC 604.3 1121

3RD BEDROOM- OUTLET - SHORT - REPLACE

205

IPMC 305.6 1121

3RD BEDROOM - DOOR JA.Iv1B - BUSTED- REPLACE

206.

IP:-V!C 305.6 1122

2''° FLOOR- BATHROOM- DOOR JA.l\1B- BR.OKEN - REPLACE

207.

IPMC 305.3 1122

2'° FLOOR BATHROOM - MOLD - REP AIR - PREP..'\RE AND PAINT

208.

IPMC 305.3 1122

BEDROOM - CEILING - REP AIR- PREPARE A.t'\JD PAINT

209.

IPMC 604.3 1123

LIVING ROOM- OUTLET - DEFECTIVE- REPLACE

210.

!PMC 305.I

KITCHEN - DR.A WER FRONT - BROKEN - REPLACE

1121

I 121

1123

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 18 of 146
211.

IPMC 605.3 1113

KITCHEN - LIGHT FIXTURE - PROVIDE GLOBE

212.

IPMC 603.1 1123

KJTCHEN - STOVE - FRONT BUR.'\!ERS - DEFECTIVE - REP AIR!REPLACE

213.

IPMC 603.1 1123

Y1ECHA..1'\IICAL ROOM- FURi"'lACE & HOT WATER HEATER VENT- REPLACE

214.

IPMC 403.2 1123

2~0 BATHROOM - VENT FAN - DEFECTIVE - REPLACE

215.

IPMC 504.l 1123

2:---o BATHROOM - TOILET - LOOSE- REPAIR

216.

IPMC 305.6 1123

REAR BEDROOM - DOOR - REPLACE

217.

IPMC 305.6 1123

REAR BEDROOM - DOOR FR.A.ME - REPLACE

218.

IPMC 704.2 1124

1ST FLOOR- ELECTRIC SMOKE DETECTOR- HANG NG - SECURE

219.

IPMC 605.1 1124 STAIRS - 3 WAY S\\ITICH - REPLACE

220.

IPMC 305.3 1124 KITCHEN - CEILING - COMPLETE REP AIR- PREPARE AJ'\ID PAINT

121.

IPMC 305.3 1124 BATHROOM - FLA.KING PA.INT - REP AIR- PREPARE Al\TD PAINT

222.

IPMC 403.2 1124 BATHROOM - VENT F.A.i'J - CLOGGED - CLEAN OUT

__::,_
1r

IP1'.1C 605.3 1124 2~ 0 BEDROOM - LIGHT FIXTURE - PROVIDE GLOBE

224.

lPMC 704.2 1125 BEDROOM - SMOKE DETECTOR- PROVIDE

.,r
--'·

IPMC 304.13 1126 2><D FLOOR - BATHROOM WINDOW - REPLACE

226.

IPMC 605.1 1126 2~ 0 BEDROOM - LIGHT BROKEN - REPLACE

227.

IPMC 305.3 1126 DRYWALL REP.I\JRS - THROUGHOUT - REPAIR - PREPARE .A..t'\JD PA.INT

228.

IPMC 504.1 1127 BATHROOM- TUB - RECAULK

229.

IPMC 605.1 1127 BATHROOM - LIGHT .t-\BOVE SINK - DEFECTIVE - REP AIRJREPLACE

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 19 of 146
KITCHEN - RODE:,,;T - HOLE· REPAIR- EXTERMINATE

230.

IPMC 309.4 1128

231.

IPMC. 604.3 1128 KITCHEN - GFCl - DEFECTIVE - REPLACE

,.,... . .,

.)_.

IP~1C 305.3 1128

BATHROOM - CEILING - REPAIR - PREPARE AND PArNT

?""
_.).).

IPMC 704.2 1128

1sT & 2:,.;D

234.

IPMC 704.2 1128

ALL BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

?"-.J:>.

IPMC 305.3 1129 KITCI IEN - PEELING PAINT - REPAIR- PREPARE AND PAP.-:"T

236.

IPMC 305.3 1129

LIVf\'G ROOM- PEELING PAINT-REPAIR- PREPARE AND PAD\T

237.

lPMC 305.l 1]29

POOR HOUSEKEEPING- TENANT'S RESPONSIBILITY

238.

IPMC 305.l

KITCHEN - CAB1NET FRO~TS - BROKEN - REPLACE

239

IPMC 309.4 1130

240.

·IP:vfC 504.1

241.

IPMC 605:3 l 130

242.

iPMC 305.1 1130 BATHROOM - TOWEL BAR - PROVIDE

243.

IPMC 702.3 1130

1:;r BEDROOM-DOOR- KEY LOCK- RE\10VE- NOT PERMITTED

244.

IPMC 702.3 1130

MIDDLE BEDROOM - DOOR LOCKED FRO:vt INSIDE - PROVIDE ACCESS

245.

IPMC 305.3 1130

LIVING ROOM - HOLES IN WALL BY \'VINDOW -REPAIR - PREPARE AND PANT

246.

IPMC 704.2 1130

ALL BEDROOMS - PROVIDE ELECRIC SMOKE DETECTORS

247.

IPMC 304.i51131

FRONTDOOR-JMOCLDING-R.EPi\lR

1130

FLOOR- ELECTRIC S~OKE DETECTORS-REMOVE- PROVIDE

EXTERMINATE - ROACHES

1130 BATHROOM - TCB- RECACLK
BATHROOM - LIGHT FIXTURE- PROVIDE GLOBE

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 20 of 146

Exhibit F

248.

IP\1C 704.2 1131

LOW BATIERY CHIRP-PROVIDE BATTERIES

249.

IP:'v1C 3 05.1 1131

KITCHEN - BACKSPLASH - RE CAULK

250.

IPMC 305.3 1131

MECl-L~NlCAL ROOM- FLAKING PAINT - REPAIR - PREPARE AND PANT

251.

IPMC 604.3 1132

ELECTRICAL ISSUES THROUGHOUT UNIT

..,-..,

_)_.

IPMC 603.l

1133

KITCHEN - STOVE LEFT REAR BURNER- DEFECTIVE - REP AIR'REPLA..CE

253.

IPMC 605.1

1133

KlTCHEN - STOVE HOOD & LIGHT - DEFECTIVE - REPLACE

254.

IPMC 305.3 1133

15r BEDROOM- PEELING PAINT -REPAIR-PREPARE AND PAINT

,-_)).

IPMC 505.4 1154

MECH.A..;'\JICAL ROOM- HOT WATER HEATER - VENT PIPE - REPLACE

256.

lPMC 104.2 1155

TENAJ.'\IT S1CK - PRO\i1DE ACCESS UPON REINSPECTION DATE

257.

IPMC 603.3 1156

MECHANICAL ROOM- STORAGE- REMOVE NOT PER.;v1ITTED

258.

IPMC 605.3 1156

2"° FLOOR- LIGHT FIXTURE -

259.

IPMC 304.14 1156

FRONT \VINDO\VS- SCREENS- PROVIDE

260.

IPMC 704.2 1157

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS & CO DETECTOR THROUGHOUT

261.

IPMC 603.1 1158

KITCHEN - STOVE - BUR..'\JERS - DEFECTIVE - REPAIR/REPLACE

262.

lPMC 305.1 1158

KITCHEN - STOVE- RANGE HOOD - RUSTED - REPLACE

263.

IPMC 305.1

KITCHEN-CABINET EDGING-REATTACH

265.

IPMC 305.1 1158

POOR HOUSEKEEPING - TENANTS RESPONSIBILITY

266.

IPMC 305.3 1158

KITCHEN - WALLS & CEILING AT STOVE AREA-GREASE-TEN.A.NT NEEDS TO CLE.l\J'\l"

267.

IPMC 305.3 1158

1sr BEDROOM- CHIPPING PAIN'T -REPAIR-PREPARE A1'\JD PAINT

1158

PROVIDE GLOBE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 21 of 146

Exhibit F

2~D FLOOR - LANDING- FLOOR TILES - DEFECTIVE - REPLACE

268.

IP'.v!C 305.4 1158

269.

IP:v1C 504.1

270.

lPMC 403.2 1158

271.

IPMC 504.1

272.

!PMC 305.3 1158

HALLWAY - WALL .. CRACK- REPAIR - PREPARE AND P.I\INT

273.

!PMC 305.3 1158

I ST BEDROO:'v1 - WALL - CRACK - REPAIR - PREP ARE Al\D PAINT

274.

IPMC 304.15 J l 59

STORM DOOR- CLOSURE - PROVIDE

275.

IPMC 305.3 1160

KITCHEN - CEILING ACCESS PANEL- FALLING DOWN -- SEC{;RE- PREPARE AND PAINT

276.

IPMC 403.2 1160

2N >FLOOR- BATHROO:'vl- VE:'\T FA."i - DEFECTIVE- REPAIR/REPLACE

277.

IPMC 704.2 1161

BEDROOM- PROVIDE ELECTRIC S:'v!OKE DETECTORS

278.

IPMC 304.10 I \62

EXTERIOR CONCRETE STAIRS- DEFECTIVE AT RAIL- REPAIR

279.

!PMC 309.l 1162

EXTER.\11!\ATE -A:'\TS

280.

ll'MC 604.3 1162

BATHROOM - SWITCH Pl.ATE- CRACKED-· REPLACE

281.

IPMC 704.2 1162

BEDROOM - PROVIDE ELECTRIC SMOKE DETECTOR

282.

IPMC 704.2 1162

HALLWAY - ELECTRIC SMOKE DETECTOR- DEFEC11YE - REP! .ACE

283.

lPMC 604.3 1162

LIVING ROOM- SWITC! I PLATE COYER- CRACKED- REPLACE

284.

IPMC 603.1

KITCHEN - STOVE 1.Efl" FRONT & REAR RIGHT Bl;RNERS - DEFECTIVE - REP AIR/REPLACE

285.

!PMC 704.2 1163

1158

1158

ll63

B,\THROOM - TUB - RE CAULK
BATHROOM - VE:,JT FAN/LIGHT FIXTURE - CLEAN & SECURE
BATHROOM - Tl.!B AT FLOOR- RECAULK

1

I sr FLOOR- ELECTRIC SMOKE DETECTOR - REMOVED - PROVIDE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 22 of 146

Exhibit F

286.

IP\1C 604.3 l 16~

ST.-\IRW:\ Y - 3 \\":\ Y I.I(;iJT S\\'ITCH - DEFECTIVE - REPL\CE86

287.

IP\-lC 305.~ 116..i

BEDROOM ·· CEILING MOLD

288.

IP\1(' 605J 1164

BACK LEFT BEDROO:V1 - LIO HT FIXTl:RE - COVER MISSJ\'(i - PROVIDE

289.

IPMC 309. l 1164 EXTER!\·111':ATE · RODENTS

290.

IPMC 603.J 1165

KlTCHE}.: ·· REAR RIGHT BURNERS - DEFECTIVE -REPAIR/REPLACE

'.!91.

IPMC 4023 1166

BAT! JR00'.\1- VENT FJ\;'\/L!GHT FIXTURE -CLOGGED - Cl.EA:\ OCT

~9:!.

1p:,.,1c 305.3 1166

BATHROOM - Cl-:II.Th:G - REPAIR - PREPARE A.'.\:D PAI:'\'T

:!93.

IP~1C 504.1

BATIJR00:-.1- Tl ·3 _ RECACLK

294.

IP~lC 70-+.2 J166

1<;T BEDROO:.V1 -- PROVIDE ELECTRIC SMOKE DETECTOR

295.

IP!\1C 305.3 1166

('r BEDROOM ... CRACK 1N WALL -- REPAIR- PREPARE A~D PAINT

296.

IPMC 704.2 1166

2~0 BEDROO:V1 -- PROVIDE ELECTRIC SMOKE DETECTOR

297.

IPMC 704.2 1166

31tD

298.

IP.\1C 3053 l 167 KITCHEN· CEIU"\:G - PEELli\G PAIKT- REPAIR-PREPARE :\~D PAI:-.:T

::!99.

1p:,..1c 605.1 1167 EXTERIOR UGI IT POLE - :-..-USSl:'\G COVER- PROVlDE

300.

IP~1C 704.::? 1168 BEDR00\1S-PROVIDE ELECTRIC SMOKE DETECTORS & CO DETECTOR 0~ .2:-:D FLOOR AREA

301.

TP~R' 305.3 1169 KITCHE~ - HOLES OVER STOVE 1ti~HVAC Dl.:CT & GAS PIPING · REPAIR- PREPARE A;\JD PAJNT

302.

lPMC 305.3 1169 KITCHE~ - DRYWALL-PATCH AT SINK -- REPAIR - PREPARE AND PAINT

303;

IPMC 604.3 1169 STAIRS .. 3 WAY SWITCH ·· REPAIRiREPI.ACE

304.

IPMC 605.3 1I 69

1166

Rl:PAIR PREPARE :\ND PAI:\T

BEDR00\4 ··· PROVIDE ELECTRIC SMOKE DETECTOR

BATI iROOM - UGI IT FIXTURE · PROVIDE GLOBE

 Exhibit F

Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 23 of 146

305.

!PMC 403.2 1169

BAT! !ROO:VI - VENT FI\J\i/l.J<il !T - ( "J.OGOED

306.

ll''.\1C 504. l

! 169

BAT! !ROo:,..1 - Tl :s - RECAU.K

307.

11':VlC 504.1

1169

BAT! IR00\·1- TOILET·· PROVIDE FXSCl T!Ol\ Pl.ATE - REPLACE

308.

!P\IC 305.3 1169

B,\Tl !R00\-1-C!:!Ll);(j - FL,\Kl:-SG PAl:\T - REPAIR

309.

!P\1C 30-l. l-11169

BATl !R00\·1 ·· WINDOW - SCREEN

310.

!Pl\·K 305.1 1169

BAT!IROO:"v!

311.

!!'MC 603.1

MECI !AN ICAL ROO:"vl - FURNACE VOLTAGE WIRE- EXPOSED - REPAIR IMMEDIATELY

312.

!PMC 305.3 1170

KITCHE>,; - CEILING - REP AIR - PREI\PRE AND PA!:\T

313.

!P\1C 504.1 1170

K!TCI 11-:N

31-1.

IP'.\·!C 504.1 1170

B,\Tl !RO< >\1 -

315

11':VlC 50-1. l 1170

B.-'.TI lR00\-1- TOlLET - LOOSE - SECURE TO FLOOR

316

IP:VlC 702.1 1171

BEDROO:VI

317.

ll'MC -103.2 1171

BATIJROO:V1 - VE:'\T FA:,,J/LJGIIT- DEFECTIVE - RE!'i\lR!REPLACE

J 18.

IPMC 504.1 1171

B.i\Tl!ROOM -TUB - RECAl;LK

3 l 9.

IPMC 704.2 1171

BEDROOMS - PROV!DE ELl:CTRIC SMOKE DETECTORS & CO DETECTOR ON 2"° FLOOR ARE:\

320.

IPMC 704.2 1172

BEDROO:V1S PROVIDE ELECTRIC S:VIOKE DETECTORS & CO DETECTOR ON 2~u fLOOR AREA

32 I.

IP'.'v!C 704.2 1173

I si FLOOR - ELECTRIC S\10KE DETECTOR - RE.\10VED- REPLACE

__
'""

lP.\IC 305.3 1173

BATl!ROOM -CUL!'.\(, - DEFECTIVE- REPAIR· PREPARE A'iD PAl:'\T

_,

,

1170

VA:--IITY CABl:\ET

SINK FAt:cET

n ·B -

CLEAN Ol T

PREPARE AND P,\lNT

PROVIDE
REATTACH BASE id CABINET TO DOOR

DEFECTIVE

REPAIR

REP,\IR'Rl:PL\("E

Rl'C..\\ "LK

WINDOW - AC l :NIT - REMOVE - BLOCKS .\ll'A:'\S OF EGRESS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 24 of 146

Exhibit F

7>23.

IP\lC 30-l.2 1173

EXTERIOR SOFFIT SIDl;\G - \11SSJ;\G

32-L

IP:\K" ?,05.1 117>

EXTERIOR

..._,_,_
...,-

IP~K 704.~ 1174

BEDR00\,1S - PROVIDE ELECTRIC SMOKE DETECTORS & CO DETECTOR 0~ 2:-:n FLOOR AREA

326.

IPMC 305J 1175 KITCJIE~ ·· WALL BELOW Wl);DOW- PEELI~Ci PAINT- REPAIR- PREPARE AND PAINT

327.

IPMC 305.3 1176 STAIR.WAY - HA;',iDRA(L - DEFECTIVE -· REPAIR

328.

IP~K 604.3 1176 ELI:('TRIC SWITCJliOt;TLETS ·· ·1·11ROUGIIOCT -PA!'.\:TED ()VER·· REPl.ACE

329.

IP\1C 603. l 1176

I.IVNG R00\-1 - lHER'\10STA T - REPLACE

330.

IP~lC 305.3 1176

KIT("HE>,; - ACCESS N CEJLl~G-- DEFECTIVE·- REPAIR- PREPARE A:'\D PAl~T

331.

TP~-1(" 305.13 1176 KITCHE~ - HOOD RANGE FA~ - PROVIDE COVER

.., ... __
.,::,

IPMC 704.2 1176 15T FLOOR - SMOKE DETECTOR- REMOVED - REPLACE

')

HOC ·sEKEEPlNO · · TRASJ 11'.'\ REAR Of Bl "ILDl;\G BEi IND l :NIT

333. . IPMC 504.1 1176 BATIIR00\.1-TOILET - LOOSE AND COCKED - REPAIR·· CHECK WAX RI":\G
334.

IP'.\K' 402.3 1176 2sD FLOOR - HALLWAY - L!(iHT FIXTCRE ·· PROVIDE GLOB!:

335.

IP:V1C 504.1 1176 BAT! IR00\·1- TUB - RECAULK

336.

lP.\i1C 305.4 1176

:rD FLOOR -

337.

I.P~lC 605.3 1176

f' 1 BEDROOM -

338.

IP:vlC 702.1 1176

(~T BEDROOM ··· AC UNIT lN WINDOW-· RE:'v'.IOVE- BLOCKS \·1Ei\.NS OF EGRESS

339.

IPMC 604.3 1176 2'-1> BEDROOM - OUTLET - BROKl~N - REPLACE

340.

1Pl'v1C' 305.4 1176

1sT FLOOR · TILE FLOOR - DEFECTIVE - REPI ,ACE

341.

JPMC 505.4 1177

Ml:CHANICAL ROO.:V1 ... HOT WATER HEATER PIPE - REPLACE

FU >OR TH .ES - THROl."GIIOl:T - DEf ECTIVE - RE Pl .:\CE
I.IGHT FIXTCRE

PROVIDE GLOBE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 25 of 146
342.

Exhibit F

IPMC 605.1 1177 2:-;n FLOOR - HALL \"/A Y LIGHT - DEFECTIVE - REPAIR/REPLACE
IP:vlC 605. l 1178

BEDROOMS - BOTH - LIGHT - PROVIDE

344.

IPMC 603.1 1178

KlTCHEN - STOVE- RIGHT REAR BURJ'\JERS -DEFECTIVE - REPAIR/REPLACE

345.

IPMC 305.3 1178

BATHROOM - CEILING- REPAIR- PREPARE AND PAINT

346.

IPMC 704.2 1179 BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS & CO DETECTOR ON 2ND FLOOR ,\REA

347.

IPMC 305.3 1180 BATHROOM - CEILING - FLAKING PAINT - REPAIR - PREPARE AND PAINT

348.

IPMC 403.2

ALL BATHROOM - VENT FANS - ALL CLOGGED - CLEAJ\l OUT THROUGHOUT CO!v1PLEX

349.

IPMC 704.2/704.3

.A.LL u"NITS - PR0\11DE ELECTRIC HARDWIRED SMOKE DETECTORS rN ALL SLEEPING ROOMS .~'\JD ALL
LEVELS - ELECTRICAL PER.i\1IT WILL BE REQUIRED

350.

IRC

ALL UNITS - PROVIDE CO DETECTORS ON THE LEVEL OF THE SLEEPIGN ROOMS

351.

IPMC 304.14

ALL UNITS - WINDOWS - SCREENS - PROVIDE

IPMC 505.4

ALL lJNITS - HOT WATER HEATER FLUE PIPES NEED TO BE SECURE TO CEILING - PLUi'vfBING PERMITS
REQUIRED

353.

IPMC 605.2

LAUNDRY - GFCI FOR WASHING MACHINES

354.

IPMC 403.5

LAUNDRY - PROVIDE SCREENS IN DRYER VENTS

355.

IPMC 603.1

LOUVERS OVER FRESH AIR IN"TAKE - REMOVE

356.

NFPA 10.11.6.1 &2 GRILLS ON E\.'TERIOR-MUST BE USED 15FTAWAY FROM THE DWELLfNGS

. 35i.

315.I

IPMC 605.2

ALL BATHROOMS & KITCHEN AREAS - PROVIDE GFCI OUTLETS AT AREAS BY SINKS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 26 of 146

Exhibit F

ALL ELECTRICAL, MECHA.VICAL, BUILD!l\/G AND PLV.MB!lVG WORK H-'ILL REQUIRE PERMITS TO DO Tl/£ WORK ASD FJSAL
I~VSPECT/0.\'S O:'i THESE ITE.11S WILL BE CO.\'DL7CTED BY THE CITY OF ASSAPOLIS INSPECTORS FOR THAT TRADE -ASY
QUEST/Ol•{S, PLE4SE FEEL FREE TO CONTACT US AT 410-263-7946

REISSPECTION SCHEDULED Q;Y OCTOBER 17-18, 2016. AT 9:30A.Jf.

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 27 of 146

Exhibit F

CITY Of A?\NAPOLIS
PROPERTY MAINTENANCE CORRECTION NOTICE RE:'.'lT1605.069
PROPERTY ADDRESS:

HARBOUR HOUSE APARTMENTS

PROPERTY OW~"ER:

Annapolis Housing Authority
c/o Ray lyne R. Shaw

121 7 Madison Street
Annapolis. MD 21401
DATE OF INSPECTION: May 16-19. 2016
INSPECTION TYPE:
ANNAUL
INSPECTOR:
MARY EMRICK, ADAM K\lGHT. STEVE ANDREWS & HENRY GUTIERREZ
VIOLATION(S)
· No.

Code Ref.

Unit

COMldUNlTYIRECREATION CENTER BUILDING
L

IPMC 605.1 OFFICE CORRIDOR - l sT FLOOR

2.

IPMC 305.3 MULTI-PURPOSE ROOM - CEII JNG - TILES STAINED - MAY 1KDICIATE ROOF LEAK OR CONDENSATfON LIN"E REPAIR - CHECK ROOF FOR POSSIBLE LEAKS

:, .

..,

JPMC 605.l ZONE ROOM - REAR E\1ERGENCY UGHT -NOT WORKING- REPAIR/REPLACE

4,

IPMC 605.l MAlN OFFICE - NO EMERGENCY LIGHTING - PROVIDE

5c

IPMC 605.1 STAIR TOWER TO 2~D FLOOR - EMERGENCY LIGHT - NOT \VORK~G - REPAIR/REPLACE

6.

lPMC 605.l GREEN ROOM AT TOP OF STAIRS - EMERGENCY LIGHT - KOT WORKING - REP AJR/REPLACE

7.

IPMC 605.l SECONDARY EGRESS UGHTfNG TO STAIRS (2:-JI) FLOOR) NOT WORKING- REPAI.R/REP!.ACE

8,

IP:v1C 605.1

2'.'JD

EMERGENCY LIGHT AT END OF HALL- NOT WORKING - REPAlRiREPLACE

FLOOR AREA- EXIT UGHTING ONLY -- NO EMERGENCY LIGHTING - PROVIDE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 28 of 146
1012 PRESIDEl\T STREET
9.

IPMC 704.2 B2

HALL \VAY - ELECTRIC SMOKE DETECTOR - NOT SOUNDI1'JG - REPLACE

10.

IPMC 704.2 B3

FRONT BEDROOM - PROVIDE ELECTRIC SMOKE DETECTORS

I I.

IPMC 704.2 BI

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

12.

IPMC 704.2 Al

MASTER BEDROOM - SMOKE DETECTOR- NOT SOlJNDING - REPLACE

13.

IPMC 704.2 A.2

BOTH BEDROOMS - SMOKE DETECTORS - NOT SOUNDING- REPLACE

14.

IPMC 704.2 A3

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

15.

IPMC 704.2 A4

VACANT - REHAB - PROVIDE ELECTRIC SMOKE DETECTORS IN BEDROOMS

16.

IPMC 704.2 A4

VACAt~T - REHAB-PROVIDE COMBINATION SMOKE AND CO DETECTOR

17.

IPMC 704.2 S4

BEDROOM- SMOKE DETECTOR - NOT SOu'NDING - REPLACE

18.

IPMC 604.3 S3

KITCHEN - BASE CABfi\JET AT SINK - DOOR - BROKEN - REPA.IRIR.EPLACE

19.

IPMC 305.3 S3

LIVING ROOM - WALL-HOLE AT BALCONY DOOR-REPAIR-PREPARE :-\i'\JD PAINT

20.

IPMC 504.1 S2

KITCHEN - SINK - FAUCET - LOOSE- REPAIR/REPLACE

21.

IPMC 304.15 Sl

SCREEN DOOR - REPLACE

22.

IPMC 604.3 SI

KITCHEN - GFCI AT SINK- DEFECTIVE - REPLACE - MUST REM.A.IN GFCI

7~
_.).

IPMC 704.2

3RD FLOOR COMMON AREA - SMOKE ALARM BROKEN - REPLACE

1006 PRES1DE1VT STREET
24.

IPytC 104.2 B 1

VACANT - GAS SHUT OFF IN UNIT

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 29 of 146

Exhibit F

25.

IP\K 704.2 Bl

HALI.WAY·· 1-:JJ::CTRIC S.\10KE DETECTOR

26.

IP\tC 704.2 Bl

Bl:DR00\1 'S - PROVlDF ELECTRIC S\10KI-: DETECTORS

27.

IP\·1(' 704.2 B2

BOTH BEDROOMS - S\10KE DETECTORS -- \OT SOC'.\:1.)1:\G - PROVIDE ELECTRIC S\10KE DETECTORS

28.

IP\1(' 504.1

KITCIIE~ - Sl~K - LEAK!\'G l::'\DER:'JE.'\Tli · REPAIR

29.

IP:v1C 704.2 B3

ALL BEDROOMS - PROVIDE f.LFCTRIC SMOKE DETECTORS

.:;o.

IP.\lC 704.2 t\ l

.-\I.I. BEDROOI\1S - PROVIDE ELECTRIC S\.IOKE DETECTORS

31.

IP\'IC 604.3 A2

BATHROOM

_, ......

IP\1C 70-L2 r\2

I L\U .\\'A Y

.).).

........

IMC

BEDROO:vtS · PROVIDE ELECTRIC SMOKE DETECTORS

34.

IP\1C 704.2 A4

BEDROO:.V!S - S\.10KE DETECTORS -

35.

IPMC 704.2 S4

LO\\' BATTERY CHIRP - PROVIDE BA TTERJJ:S f-OR S;v1QKE DETECTORS

36.

!Pl\1C 50-l-.1

£3.-\THR00\.1 ·· TOILET SE:\T - BROKE;\ - REPL:\CT

37.

JPMC 305.6 S4

BEDROO>.il · DOOR KNOB - BROKE"N' - REPLACE

38.

IP'.\1(' 704.2

S3

HAI.I.WAY - ELECTRIC S;v10Kl: DETECTOR - HA:"\Gl'.'\G -SECTRE TO CE!l.l'.\G

39.

IPMC 704.2

s .,. .

LOW BAITERY CHIRP

40.

IP\lC 70..J..2 S"'.)

41.

JJ>MC 704.2 S?

-+:!.

IP\1C 603.1

43.

lPMC 704.2 SI

.... ...,

B2

704.2 A3

S-l-

.

Sl

~OT SOl!J\DL\G

REPLACE

GFCI- LOOSE- REPAIR
ELECTRIC S\fOKE DETECTOR - '.\:OT SOl."'.'\Dt\°G - REPLACE

:-:or SOl.""'.\°DI:'.\(, -

PROVIDE ELECTRIC S:\10KE DETECTORS

PROVIDE BATTERIES FOR SMOKE DETECTORS

1'T BEDR00\-1 - SMOKE DETECTOR - KOT SOL"~DI~G · REPL:\CE

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTOR~
KITCHE~ - STOVE- LEFT REAR BUR.,ER - DEFEC'J'I\"E - REPAIR.iREPI.A(T
LOW BATTERY CHIRP -- PROVIDE BATTERIES FOR SMOKE DETECTORS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 30 of 146
44.

IPMC 305.3 SI

BA THR00\1 - CEILING - PEELING PAINT - REPAIR - PREPARE AND PAINT

45.

IPMC 304. 15

ENTRANCE DOOR - ADJUST - DOESN'T SJ IUT COMPLETELY -ALARM SOl~DS

Exhibit F

1II51l1ADISON STREET
46.

1P\1C 302. l

TRASH N EXTERIOR WINDOW WELL AREA - RE1\·10VE

47.

fPMC 304.3 Bl

ENTR.t\:\CE DOOR - PROVIDE CNlT ~UMBER ON DOOR

48.

IPMC 704.2 Bl

I ST BEDROOM - SMOKE DETECTOR - NOT SOL1'Dl1';G - PROVIDE ELECTRIC S:v10KE DETECTOR

49.

IPMC 304.3 B2

ENTRANCE DOOR - PROVJDE ONIT NUMBER ON DOOR

50.

IPMC 603.1 B2

KITCHEN - STOVE - HOOD VENT - DEFECTIVE - REPAIR/REPLACE

51.

lPMC 704.2 B2

2:-.:D BEDROOM - SMOKE DETECTOR- NOT SOUNDf\"G - PROVIDE ELECTRIC SMOKE DETECTOR

52.

IPMC 605.1 B3

KlTCHEN - STOVE- HOOD & LIGHT-DEfECTIVE- REPAIR/REPLACE

53.

IPMC 704.2 B3

i-:D BEDROOM - SMOKE DETECTOR - NOT SOU!\DING - PROVIDE ELECTRIC S.:V10KE DETECTOR

54.

IPMC 604.3 Al

KITCIIE;( - GFCI - DEFECTfVE - REPLACE - MUST RE~1AIN GFCI

55.

IPMC 704.2 i\ l

HALLWAY - ELECTRIC SMOKE DETECTOR- NOT SOCNDD\G - REPLACE

56.

1P\1C 305.3 Al

BATHR00\1-CEILING-PEELING PAINT- REPAIR- PREPARE AxD PAINT\

57.

IP:vlC 704.2 Al

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

58.

IPMC 704.2 i\3

BOTH BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

59.

IPMC 504.1 A3

BATHROOM - TOH ,ET HANDLE - LOOSE - REPAIR

60.

IPMC 604.3 A3

KITCHEN - GFCI - WIRED TO REFRIGER.A..TOR CIRCUIT - CANNOT DO THIS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 31 of 146
61.

JP:vlC 60-U /\3

KITCHE'.\

62.

fP\K' 704.2 A4

r\J .I. S!\10KE DETECTORS - :,..;oT WORKJ:\(r

63.

IP\1C 704.2 A2

,\LL SMOKE DETECTORS - RE:\10VE PLASTIC COVERJ'.\G

64.

IP\1C 702.3 SJ

BEDR00'.\1

65.

IP:VtC 305.1 Sl

KITCHEN - CABfNET DOOR - DEFECTIVE-·REPAIR!REPLACE

66.

IP:'v1C 305.6

67.

IP\-1C 504.1 SJ

BATI fOOM · TOH.ET - LOOSE- REPAIR

68.

IP\1C 305.3 SJ

BATIIROOM

69.

IP\1:C 704.1

('1' FLOOR JJJ\J.LWAY - FIRE EXTINGUISHER - PROVll)E GLASS COVER

70.

IP\.1C 704.1

:?' 1i FLOOR I i:\LLWA Y - FIRE EXTI'.\Gl"JSHER · PROVIDE

71.

IPMC 704.1

Js r

n.

lPt-:1C 305.5

IIA:'\DRAILS - (>l FLOOR TO 2"r> TO

73.

IPMC 603.1 S2

KITCIIE:\ - STOVE- RIGHT REAR BCR.~ER

7-L

IP'.\1C 704.2 S2

HALLWAY· ELECTRIC S\10KE DETECTOR - RE\110\"E - PROV!l)E

75.

IPMC 704.2 S3

ALL SMOKE DETECTORS - NOT WORKING - PROVIDE ELECTRIC SMOKE DETECTORS

76.

IP\1C 704.2 S4

BEDR00\·1S - PROVlDE ELECTRIC S'.\-tOKF DETECTORS

s,

PROVIDE Rl:GUL/\R <WTLET FOR REFRl(rER.ATOR

DOOR- KEY LOCK - RE~10\'E

PROVIDE ELECTRIC S\fOKF DETECT( )RS

:--.:OT PFR'.\·1ITTED

KlTCIIEN - CLOSET DOOR-REPArR

CEILI~G - REPAIR ·- PREPARE AND P,\I'.\T

FLOOR - FIRE ALARM WIRE

REA TTACI I - IIANG!'.'JG
3RD

FLOOR - REPLACE - C:\}..;:,;-OT GRIP
DEFECTJYE-REPAIR/REPLACE

1125 MADISON STREET

77.

1P\1C 304.2

Al-A4 EXTERIOR SOFFIT AREA- FALLING DO\\'":\ O'.\ BALCO'.\Y AREA- REPAIR

78.

IPMC 704.2 Bl

l IAI.LWA Y

ELECTRIC -- SMOKE DETECTOR- REMOVE ·· REPLACE

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 32 of 146

Exhibit F

79.

IPMC 704.2 Bl

BOTH BEDROO:v1S - PROVIDE ELECTRIC SMOKE DETECTORS

80.

IP\tlC 305.3 131

2:--;D

81.

IPMC 605.l B1

KITCHEN - STOVE- HOOD LIGHT - DEFECTIVE-REPAIR/REPLACE

82.

IPMC 704.2 B2

HAI.I. WAY - ELECTRIC SMOKE DETECTOR - \!OT SOUNDING - REPLACE

83.

1PY1C 305J B2

BATHROOM - CEILING - REP AIR - PREPARE AND PAINT

84.

1PY1C 704.2 B2

BEDROOM·- SMOKE DETECTOR - :\'OT SOUNDI?\G - PROVIDE ELECTRIC SMOKE DETECTORS

85.

IP\1C 504.l B3

BATHROOM - TUB - MOLD - CLEAN OUT

86.

lPMC 704.2 B3

HALLWAY - ELECTRIC S.:.10KE DETECTOR- REMOVE- REPLACE

87.

IPMC 604.3 B3

MASTER BEDROOM - OCTLET & SWJTCII - PROVIDE COVER PLATES

88.

IPMC 704.2 SJ

BEDROOM - SMOKE DETECTOR - NOT SOU);DING - PROVIDE ELECTRIC SMOKE DETECTORS

89.

JPMC 305.1 SI

POOR IIOUSEKEEPNG-THROUGIIOCT

90.

IPMC 309.1 Sl

EXTERMINATE - ROACHES AND POSSIBLE BED BUGS

9I.

IPMC 305.1 S2

POOR IIOUSFKEEPI::-.rG - THROUGIIOCT

92.

IPMC 704.2 S2

ALL SMOKE DETECTORS - NOT WORKING-~ PROVIDE ELECTRIC SMOKE Dl;;TECTORS

93.

IPMC 304.15 S4

ENTRANCE DOOR - 1IANDJ ,E - LOOSE -REPAIR

94.

lPMC 704.2 S4

ALL SMOKE DETECTORS - ~OT WORKING - PROVIDE ELECTRIC SMOKE DETECTORS

95.

TPMC 704.2 S3

ALL BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

96.

IPMC 305.4 A4

KJTCHE;-.; & BEDROOM - FLOOR TILES - CRACKED - REPLACE

BEDROOY1 ·- WALL~ HOLE·-· REPAIR - PREPARE A:\'D PAINT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 33 of 146

Exhibit F

97.

IPMC 305.3 Al

BATHROOM - WAI J_ - HOLE - REPAIR -- PREP!\RE A~D PAINT

98.

IPMC 305.3

2:--o FLOOR- COMMO\' HALLWAY - HOLE- REPAIR - PREPARE AND PAl:\T

99.

IP\1C 704_2 A.2

BEDROOMS - SMOKE DETECTORS - NOT SOUNDING - PROVIDE ELECTRIC S.MOKE DETECTORS

100.

IPMC 305_3 A2

BATHROOM-CEILI~G-FLAKING PAINT-REPAIR-PREPARE A~D PAl1\T

lOJ.

IPMC 704_2 A3

ALL SMOKE DETECTORS - NOT WORKING - PROVIDE ELECTRIC SMOKE DETECTORS

102.

IPMC 305.3 A3

BATHROOM -CEILING - MOLD- REPAIR- PREPARE /\ND PAl:JT

103.

IPMC 305.3 A3

BATHR00~1 - CEILING - HOLE - REPAIR - PR EA PRE A)JD PAINT
1135 NL4DlSON STREET

104.

lPMC 605.1

1ST FLOOR - LIGHT FIXTURE - BROKEN COVER- REPl .ACE

105.

IPMC 704.2 Bl

BOTH BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

106.

IPMC 704.2 B2

FRONT BEDROOM - SMOKE DETECTOR - BROKEN - REPLACE- PROVlDE ELECTRIC S:\10KE DETECTOR

107.

IRC

108.

JPY!C 305.3 B2

BATHROOM -CEILING- REPAIR-PREPARE AND PAINT

109.

IPMC 304.3 B3

E:\TRANCE DOOR- PROVIDE CNJT ~CMBER

110.

IPMC 704-2 83

1s-r BEDR00.\1 - NO SMOKE DETECTOR - PROVIDE ELECTRJC SMOKE DETECTOR

111.

IPMC 305.6 B3

1ST BEDROOM - DOOR KNOB - PROVIDE

1 l 2.

IPMC 402.3 A1

BATHROOM-VE:\'T FAN-DEFECTIVE-REPAIR/REPLACE

·113.

IPMC 704.2 Al

2:--D BEDROOM - NO SMOKE DETECTOR - PROVIDE ELECTRIC SMOKE DETECTOR

114.

IPMC 704.2 A2

REAR BEDROOM - SMOKE DETECTOR- ~OT SOUNDING- PROVIDE ELECTRIC S\10KE DETECTOR

315. 1 B2

HALLWAY · NO CO DETECTOR - PROVIDE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 34 of 146

Exhibit F

l 15.

lPMC 605. 1 :\2

KITCEJE\: - LIGHT - DEFECTIVE - REPAIR/REPLACI:

Il6.

IP:"vK 605.1 :\~

Fl .R:\ACE R00\1 -- CABLE \\'IRE TOCCI 11\(, fll:I: PIPE··· RE\10VE

] 17.

JP;1.1C 402.3 l\'2

BAT! IR00\1 · VENT FA\ -- DEFECTIVE - REPAIR/REPLACE

] 18.

IPMC 70-L2 :\3

BJ:DR00\-1S

PROVIDE ELECTRIC S\>10KE DETECTORS

119.

JPMC 704.: A4

BEDROO:vtS

NO SY10KE DETECTORS-· PROVIDE ELECTRIC SMOKE DETECTORS

120.

IPMC 605.l ,-\4

KITCHE'.',; -1 IOOO IJ(jIIT- DEFECTIVE - REPAIR/REPLACE

121.

IPMC 40'23 Sl

BJ\TllROO:V1 - VE:-:-T FA?',; - DEFECTIVE· REPAIR/Rl·'.PLACE

122.

IPMC 604.1 S2

):0 ELECTRIC - VACANT L\:IT

123.

IPMC 305.5

HA>iDR.AII.

124.

IPMC 305.4 S3

KITCIIE):

125.

IPMC 603. 1 S3

KITCHE:\" - STOVE- RIGHT SIDE BUR~ERS - DEFECTIVE- REPAIR/REPLACE

126.

IPJ'v1C 305.3 S3

BATl-lROO:v1

\V;\LI. BY SWITCH .. HOLE·- REPAIR- PREPARE A:--;D PAJ:\lT

127.

JP\1C 704.2 S3

BEDR00>"1S -

:--:o SMOKE DETECl ORS -

128.

IPMC 603.1 S"'.)

Fl.lRI\ACE ROO:Vl - FU JE PIPE - REPLACE

129.

IPMC 305.3 S"'.)

uv1:--:G R00Y1 - WALL BEIIf.'\D E:'TRA:'JCE DOOR CO:l\1PLETE REPAIR - PREPARE A).:D PA!);"f

130.

JPMC 305. I S4

POOR HOUSEKEEPING THROUCil !OCT

13 l.

IPMC 305.l S4-

PROVIDE ACCESS !~SIDE L::\Il -· C:--.:ABLE TO ACCESS DCE TO I IOUSEKEEPI:-:G

132.

lPMC 604.3

3Kll

2:--:D TO 3RD FLOOR - BROKEl\: -- REPLACE

FLOOR TILES - DEFECTIVE REPLACE

PROVIDE ELECTRIC S\10KE DETECTORS

FLOOR COMMO>-J /\REA - LIGHT COVER - PROVIDE

 --

---------------------------------------------------Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 35 of 146

Exhibit F

1145 l',1ADIS0N STREET

133.

lP:v!C 704.2 Bl

I'' BEDROOM -

134.

IPMC 603.1 Bl

FCRNACE R00\1- FLUE PIPE ON EXHACST • RECO~ECT

135.

IP:'.v!C 704.2 B2

i'" BEDROOM- SMOKE DETECTOR- NOT SOU1'iDING- PROVJDE ELECTRIC SMOKE DETECTOR

136.

TPMC 603.l B3

FUR>IACE ROOM- FILTER - WRO'\lG SlZE - PROVIDE AND PUT ON COVER

137.

IPMC 704.2 B3

1' 1 BEDROOM - SMOKE DETECTOR - NOT SOUND!NG - PROVIDE ELECTRIC SMOKE DETECTOR

138.

!PMC 704.2 Al

BEDROOM - NO SYIOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

139.

IPMC 305.5

2"r, FLOOR - HANDRAIL - FROM 2"° FLOOR TO I s-r FLOOR- REPLACE

140.

fPMC 704.1

2"D FLOOR- FIRE EXTINGUISHER- REMOVED - PROVIDE

141.

IPMC 305.3

z"n FLOOR- COMMO:' IIALLW A Y -

142.

!PMC 704.2 A2

FRONT BEDROOM - SMOKE DETECTOR- J\OT S0l.ND!1'G - PROVIDE ELECTRIC S'.'v10KE DETECTORS

143.

IPMC 603.1 A3

KJTCHEJ\ - STOVE- LEFT FRONT BURNER- DEFECTIVE-REPAIR/REPLACE

144.

IPMC 605.1

KITCHEN - LIGHT- DEFECTIVE- REPAIR/REPLACE

145.

IP.Y!C 603.l i\3

THERMOSTAT - PROVIDE COVER

146.

IPMC 704.2 /\3

BEDROOM - NO SMOKE DETECTOR- PROVJDE ELECTRIC SMOKE DETECTOR

147.

IPMC 704.2 A3

HALT.WAY - ELECTRIC SMOKE DETECTOR- NOT SOUNDING-REPLACE

148.

JPMC 304.15 A3

SCREEN DOOR- HANDLE- PROVIDE

149.

IP:v!C 305.3

150.

IPMC 605.3 A.3

A3

l'w

SMOKE DETECTOR - NOT SOUNDl'\lG - PROVIDE ELECTRIC SMOKE DETECTOR

HOLE IN WALL ··REPAIR-PREPARE A>ID PAINT

I .JVING ROOM - WALL - PREPARE AND PAINT
LIVING ROOM - LIGHT COVER- PROVIDE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 36 of 146
] 51.

IPY!C 304.15 A4

SCREE?\ DOOR - HAKDLE - PROVIDE

152.

TPMC 604.3 A4

KITCHEN -ALL Gfcrs PAINTED OVER- REPLACE- :\1CST REMAN GFC[

153.

lPMC 305.4 SI

FLOORING - THROUGHOUT - REPLACE

154.

IPMC 402.3 SI

BA TI IR00~1 - VENT FAN - DEFECTIVE -- REPAIR/REPf ,ACE

155.

IPMC 704.2 Sl

BEDR00;1.1S - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

156.

IPMC 704.2 S2

VACA~T - REHAB - PROVlDE ELECTRIC SMOKE DETECTORS & CO DETECTOR

157.

IPMC 704.2 S3

VACA:\fT - REHAB~. PROV1DE ELECTRIC SMOKE DETECTORS & CO DETECTOR

158.

IPMC 603. t S4

Ft;R~J\CE ROOM - FLCE PIPE - CRACKED AT JO TNT - REPLACE

159.

JPMC 304.7

REAR GLTTER - REATTACH

Exhibit F

1155 MADISON STREET
160.

1PMC 305.l

BASEMEtrr-HALLWAY AREA-TRASH/LAUNDRY UNDER UPPER STAIRS-REMOVE

161.

IPMC 704.1 ·

BASEMEl\T - FIRE EXTINGUISHER - REMOVED - PROVIDE

162.

IPMC 604.3 Bl

KITCHEN - GFCI TO RlGHT Of SlJ\K- DEfECTlVE - REPLACE MUST REMAN GFCI

163.

IPMC 704.2 B2

HJ\LLWA Y - ELECTRIC SMOKE DETECTOR- NOT SOUNDING ·· PROVIDE ELECTRIC SMOKE
DETECTOR

l 64.

IPMC 704.2 B2

2:-:D BEDROOM -SMOKE DETECTOR- NOT SOUNDING-PROVIDE ELECTRlC SMOKE DETECTOR

165.

IPMC 305.3 B1

BATHROOM -ACCESS PANEL & VENT- RUSTED- REPLACE

J66.

IPMC 402.3 B3

BATHROOM - VE>lT FAN-· DEFECTIVE- REPAIR/REPLACE

167.

IPMC 704.2 Sl

BEDROOMS ·-NO SMOKE DETECTORS~ PROVIDE ELECTRIC SMOKE DETECTORS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 37 of 146

Exhibit F

BATHR00:0 - TOILET - LOOSE - REPAIR

168.

IPMC 504.l

169.

fPMC 604.3 SI

BATHROOM - GFCI - DEFECTIVE - REPLACE - MlJST RE:vIAJ:,..; GFCI

170.

IP:'v1C 504. l S2

BATHROOM -TOILET- LOOSE- REPAIR

I 71.

IPMC 704.2 S2

HALL Vo/A Y - ELECTRIC SMOKE DETECTOR - REMOVED - PROVIDE ELECTRIC SMOKE DETECTOR

172.

IPMC 704.2 S2

BOTH BEDROOMS - SMOKE DETECTORS - NOT SOUNDING - PROVIDE ELECTRIC SY10KE DETECTORS

173.

IPMC 704.2 SJ

BEDROOM - SMOKE DETECTOR - NOT SOUNDI~G - PROVIDE ELECTRIC S?1.10KE DETECTOR

174.

IPMC 604.3 S3

LIVING ROOM - OCTLET ON LEFT WALL BY TV - DEFECTIVE - REPLACE

175.

IPMC 603.l S3

KITCHEN - STOVE - LEFT FRONT BURNER- DEFECTIVE -REPAIR/REPLACE

176.

IPMC 304.6 S3

PORCI I - CEILNG - COLI .A PS ING - REP AIR IMMEDIATELY

177.

IPMC 704.2 S4

BEDROOM - SMOKE DETECTOR - REMOVED - PROVIDE ELECTRIC SMOKE DETECTOR

SJ

178 .. IPMC 704.2 Al

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

179.

IPMC 305.3 A2

HALLWAY -WALLATBATHROOM-HOLE-REPAIR-PREPAREAND PAINT

180.

IPMC 704.2 A3

BEDROOM/S - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

181.

IP~C 604.3 A3

BATIIROOM - GFCI - DEFECTIVE - REPLACE - MUST REMAl:--J GFCI

182.

IPMC 704.2 A4

BEDROOM - SMOKE DETECTOR - NOT SOUNDI~G - PROVIDE ELECTRJC S\10KE DETECTOR

183.

IPMC 504.1 A4

BATHROOM - TOILET - RUNS CONTlNUOUSLY - REP AIR

184.

IPMC 603.1 1\4

KITCHEN - STOVE - LEFT FRONT BURNER - DEfECTIVE - REP AIR!REPLACE

185.

IP:viC 704.1

3RD

FLOOR EXTINGU1SHER- PROVIDE GLASS COVER

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 38 of 146
186.

IP:.1C 305 .4

BnLDII\'G E).JTR..i\?-;CE ·- FLOOR TILES - DEFECTIVE - REPLACE

187.

IPMC 304.15

BASEME:,;T - STORAGE ROOM ·- DOOR REPAIR - PROVIDE EGRESS DOOR

188.

IPMC 504.l

BASEMENT - UTIT .ITY ROOM - LEAK - \V ATER ALL OVER FLOOR- REPAIR

189.

IPMC 605.1

BASE!v1E~T - UTILITY ROOM - PROVIDE EMERGENCY LIGHTS

Exhibit F

1165 M4.DJSON STREET

190.

IPMC 704. I

2:-.;l) FLOOR- EXTNGC!SHER- REMOVED - PROVIDE

191.

IPMC 704.l

MAN I,EVEL - FIRE LIXE SYSTEM - JUNCTION BOX - BURNED - :\'O COVER - REPAIR - PROVIDE
COVER

192.

IPMC 305.J

BASEMENT - COMMON HALLWAY AREA - BAGS OF TRASH - REMOVE

193.

IPMC 304.15

ENTRANCE DOOR-GLASS DOOR- SIDE PANEL - BROKEN - REPLACE GLASS

194.

TPMC 704.2 Bl

BEDROOY!S - PROVIDE ELECTRIC SMOKE DETECTORS

195.

IPMC 604.I B2

NO ELECTRIC - OCCUPIED - TENANT HAS BEEN GIVEN 72 HOURS TO HA VE ELECTRIC BACK ON

196.

IPMC 305.3 B3

MASTER BATHROOM - <::ETI.rNG - REPAIR- PREPARE AND PAINT

197.

IPMC 504.l B3

HALLWAY-·BATHROOM-SINK-FALUNG OFF WALL-SECLRE

198.

IPMC 704-2 B3

MASTER BEDROOM - SMOKE DETECTOR - NOT SOUNDING- PROVIDE ELECTRJC SMOKE DETECTOR

199.

IPMC 605.l

200.

lPMC 604.3 B3

KITCHEN - GFCI TO LEfT OF SINK - DEFECTIVE - REPLACE MUST REMAIN GFCI

201.

IPMC 704.2 A1

HALLWAY - ELECTRIC SMOKE DETECTOR- REMOVE- PROVIDE ELECTRJC SMOKE DETECTOR

202.

JPMC 704.2 Al

BEDROOM - NO SMOKE DETECTOR- PROVIDE ELECTRIC SMOKE DETECTOR

B3

KITCHEK - STOVE HOOD - DEFECTIVE - REP /\IR/REPLACE

------------------·

-·-·

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 39 of 146
203.

IJ>\1( 704.2 t\2

Bl:DR00\1S

204.

IP\·1C 70--t.2 1\3

Bl·:DROO:v1

205.

1P:V1C 60--t.3 i\4

K!TCJ !EN - CiFCI - PAINTED OVER - REPLACE- MUST REMAIN GFCI

206.

IP\·1C 704.'.?. Sl

BEDR00:\.1 -

207.

IPMC 704.2 s..,-

I 1/\LLWA Y - ELECTRlC SMOKE DETECTOR · HA?\GING- SECl "RE

208.

!P\t1C 402.3

209.

IPMC 704.2 S2

210.

IP\1C 704.2

211.

IPMC 305.1 S4

KITCIIE:-J - BASE CABl'.\/FT - SINK - DOOR · BROKE?\- REPAIR/REPLACE

212.

IP:'.'v1C 704.2 S4

LO\\' BATTERY CHIRP

213.

IPMC 704.2 S4

HALLWAY - ELECTRIC S:,.,10KE DETECTOR·· HANGI:-.:G-SECCRE

114.

IP\1C 305.4

3rn FLOOR · STAIR\\',\ Y -- TREADS - LOOSE

s...,

.s-'..

PROVIDE ELECTRIC SMOKE DETECTORS

:-:o S).10KE DETECTOR -

PROVIDE EI.E< "TR[C S\10KE DETECTOR

:,:o SMOKE DETECTOR - PROVIDE ELECTRIC S\10KE DETECTOR

B:\THR00\1 - VE:>iT FAT\ -DEFECTIVE - Rl:PAIR,Rl:PLACE
BEDROOM - :t\O SMOKI: DETECTORS- PROVIDE ELECTRIC SMOKE DETECTORS

BEDR00\1

~O S\10KE DETECTOR PROVIDE ELECTRIC S\.tOKE DETECTOR

PROVIDI: BATJ'FRIES

I I 75 Il,fADISON STREET
2] 5.

IP\1C 305.3 Bl

KITCHE~

216.

lPMC 604.3 Bl

B/\TIIROOM

217.

IP\,1C 402.3

BATI IR00\1 . VENT FA:-,; - DEFECTIVE - REPAIRiREPL:\CE

218.

lPMC 305.3 Bl

Bl\THROOYI -CEILINO - WATER DA::vlACiE - REPAIR-·· PREPARE A"t'\D PAl;\JT

219.

IPMC 305.1 Bl

B.I\TIIROO~t - VA~lTY CABINET - DEFECTIVE- REPLACE

220.

IPMC 504.l

I} I

Bl

WALL BEIII\lD ST0\'1: -- HOLE - REPAIR - PREPARI: ,\:-:D P:\l:-,;T
UGI!'r SWITCH - BROKEN··· REPAIR

BATHROOM · TUB - RECAULK & REGROCT

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 40 of 146

Exhibit F

221.

JP:MC 305.l B2-

LIVING R00:.-1 - AC UNIT

222.

IPYiC 704.2 B2

MASTER BEDR00\1 - NO SMOKE DETECTOR - PROVIDE ELECTRIC SMOKE DETECTOR

223.

lPMC 604.3 B2

BATHROOM - GFCI - DEFECTIVE - REPLACE - MUST REMAIN GFCT

224.

IPMC 702.3 B3

MASTER BEDROOM - DOOR - KEY LOCK - REMOVE NOT PER\1TTTED

225.

IPMC 704.2 83

ALL SMOKE DETECTORS-ADA SY10KE- KOT WORKING - REP/\.IR/REPLACE

226.

IPMC 305.1 B3

KITCHEN - STOVE /\REA - GREASE /\LL OVER WALLS - CLEA!'\

227.

IPMC 603.l B3

KJTCHE:'.\' - STOVE - EXHACST FAN - COVER - PROVIDE

228.

IPMC 604.3 BJ

KlTCHEN -· STOVE- GFCI - PAINTED OVER- REPLACE MUST RE:'v1AIN GFCl

229.

IPMC 704.2 Al

FIRST BEDROOYl - SMOKE DETECTOR - MISSf>lG - PROVIDE ELECTRJC SMOKE DETECTOR

230.

IPMC 305.1 Al

AC UNIT - NOT SEALED - REPAIR

231.

lPMC 704.1

3RD FLOOR - SMOKE DETECTOR N CORRIDOR - PROVIDE

r?
_.)_.

IPMC 704.2 A2

2,,;l) BEDROOM-SMOKE DETECTOR-NOT WORKlJ\G-PROVIDE ELECTRIC SMOKE DETECTOR

_.,.,,
?"' ...

IP;\1C 704.2 A2

1sT BEDROOM - SMOKE DETECTOR - MISSING - PROVIDE ELECTRIC SMOKE DETECTOR

234.

IPMC 304. I 5 A2

SCREEN DOOR - PROVIDE SCREEN

?
... ~
_..,:,,

IPMC 704.2 A3

BOTH BEDR00:\1S - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

236.

IPMC 603.1 A4

KITCHEN - STOVE - RANGE HOOD - NOT WORKING - REP AIR/REPLACE

237.

IPMC 304.15 A4

SCREEN DOOR- PROVIDE SCREEN

238.

IPMC 305.3 A4

FURNACE ROOM- CEILING- DRYWALL -DEFECTIVE- REPAIR

CANKOT BE CSED 11' \VI~DOW - 2\JD MEANS Of EGRESS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 41 of 146

Exhibit F

239.

IPMC 603.1 A4

Fl7R~ACE ROOM·- DEBRIS (LEAVES ETC) CLEAN OuT

240.

IPMC 704.2 S 1

VACANT - REHAB ·· NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS AND CO
DETECTOR

241.

IPMC 704.2 S2

2ND

242.

IPMC 504.I S2

KITCHEN - Sf.'\K ·- FAUCET - LOOSE- REPAIR

243.

IPMC 603.l S2

FURNACE ROOM - DEBRIS·- CLEA!\" OUT

244.

IPMC 304.15 S3

SCREE~ DOOR - PROVIDE SCREEN

245.

IPMC 603.l S3

KITCIIEX - STOVE - RIGHT REAR BURNER- DEFECTIVE- REPAIR/REPLACE

246.

IPMC 603.1 S3

FURNACE ROOM-FLUE FROM LO\VER UNIT DISCONNECTED-REPAIR

247.

lPMC 603.l S3

FCR..'-:ACE ROO:vl - DEBRIS - CLEAN OCT

248.

IPMC 305.3 S4

BATHROOM - CEILING -REPAIR- PREPARE A.~D PAINT

249.

IPMC 6043.3 S4

BATHROOM - GFCI - REPLACE - MUST REMAIN GFCI

250.

JPMC 504.1 S4

BATHROO~-SIKK-RECACLK AT WALL

BEDROOM - SMOKE DETECTOR- !\OT SOlJKD1NG - PROVIDE ELECTRIC SMOKE DETECTOR

1185 MADISON STREET
251.

IPMC 304.15

ENTRANCE DOOR-SPRING ARM - BROKEN~ REPAIRJREPLACE

252.

IPMC 704.2 Bl

HALLWAY - ELECTRIC SMOKE DETECTOR - REMOVE - PROVIDE ELECTRIC SMOKE DETECTOR

253.

IPMC 704.2 Bl

ALL 3 BEDROOMS - SMOKE DETECTOR-· NOT SOU:\'DrNG - PROVIDE ELECTRIC SMOKE DETECTORS

254.

IPMC 504.l B2

BATHROOM - HOTWATER SIDE- LOW WATER PRESSURE

255.

IPMC 304.14 B2

WINDOW - SCREENS - PROVIDE

 ------------------

-----------------------

Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 42 of 146

Exhibit F

256.

IPMC 304.15 B2

SCRl·l:N DOOR

;.57.

JP\1C 3053 B:2

Ll\.1:--.JG ROO:Vt -- WALL .-\RE/\ BY \\'!;\DOW

:258.

IPMC 704.1

COMMON I IALL WAY AREA - FIRE EXTINGUSHER - REMOVED - PROVIDE

259.

IP).K' 704.2 B3

PROVIDE ELECTRIC S:vlOKE DETECTORS I~ BEDROO:v1S

260.

IP:V1C 704.1

1~1 FLOOR- FIRE EXTI~GUISI IER - MISSING - PROVIDE

'.::61.

IP:v1C 704.::: Al

3w BEDROO:V1 - S\10KE DETECTOR- ~OT WORKI~G ... PROVlDE ELECTRIC SMOKE DETECTOR

262.

IPMC 704.1 J\2

BEDROOMS --PROVIDE ELECTRIC SMOKE DETECTORS

263.

JPMC 304.3 A3

E'.\TRA'.'\CE DOOR - PROVTDF U!\ff "\'C~1BER 0~ DOOR

264.

IPMC 704.3 A3

J.., 1 BEDROOM -· SMOKE DETECTOR -NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTOR

265.

fP\1C 605.l A3

CLOSET - LIGHT - '.\:OT WORKI:--.:G - REPAIR/REPLACE

266.

IPMC 304.15 A4

E~TRANCE DOOR - PROVIDE UNIT NUMBER ON DOOR

"267.

JP\-1C 704.2 A-t

BEDR00\1S -· PROVIDE ELECTRIC SMOKE DETECTORS

268.

IPMC 704.2 Sl

(H & 3Ro BEDROOM - S\10KE DETECTORS -· NOT SOlJNDlNG ... PROVIDE ELECTRIC SMOKE DFTECTOR

:269.

IP}>1C 60-L:; Sl

:?."1> BATHR00\,1-GFCJ - REPI .ACE- \H:ST RF\1Ai\ GFCI

270.

IPMC 305.4 Sl

BOTH BA Tl !ROOMS ·- TI lRESHOI.D - REPAIR

27J.

IP\1C 604.~ S1

1st B/\THROO:'v1 - GfCJ - REPLACE- ;1.1t"ST RE!v1Al~ CiFCI

272.

IPMC 604.3 Sl

KITCHEN

STOVE - LEFT rROXr BURNER - DEFECTIVE -REPAIR/REP! .ACE

273.

lP\1C 604.3 Sl

KITCHE~

GFCI - DEFECTI\/E - REPLACE

274.

IP\1C 30-US S1

E~TRANCE DOOR KNOB & LATCH - REPAIR

PROVIDE

HOLE

Rl:PAIR

PREPARE A\D PAIJ\T

~1CST RE~1Al:( GFCI

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 43 of 146

Exhibit F

275.

lPMC 704.2 S"...

VACANT - REHAB - PROVIDE ELECTRIC SMOKE A~D CO DETECTOR

276.

IPMC 504.1 S3

BATilROOM - TOILET - RUNS CONTIKUOUSL Y - REPAIR

277.

IPMC 305.3 S3

BATHROOM - CEILNG - FLAKING PAINT -REPAIR- PREPARE AND PAll'\T

278.

IPMC 704.2 S4

BEDR00\1S - SY10KE DETECTOR - NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTOR

279.

fPMC 305.4 S4

LIVNG ROOM - FLOOR - DEfECTIVE - REPAIR

2SO.

IPMC 605.3 S4

DINING ROOM - LIGHT GLOBE-PROVIDE

1195 MADISON STREET
281.

IPMC 603.1

BASEMENT - UTILITY ROOM - GAS LINE HA:'JGING OFF WALL - SECURE

282.

IPMC 305.3

BASEMENT- UTILITY ROOM- WALL IN COR:-lER- MOLD- REPAIR

283.

IPMC 605.l

BASEMENT - UTILITY ROOM - EMERGENCY BACKUP LIGHTS -- PROVIDE

284.

lPMC 305.4

STAJRS - BASEMENT TO l ST FLOOR- I sr TO 2:--:o - CONCRETE NOSING - DEfECTIVE- REPAIR

285.

IPMC 603.1

B1

KITCHEN - STOVE- BOTTOM DRAWER- DEFECTIVE- REPAIR/REPLACE

286.

IPMC 305.3 Bl

BATHROOM - WALL & CEILING - MOLD - REPAIR - PREPARE AND PAINT

287.

IPMC 504.1 B1

BATHROOM - SINK - RECAULK AT WALL

288.

fPMC 305.3 BJ

HALI.WAY - WALL BY BJ\THROO:V1 - HOLE - REPAIR- PREPARE AND PAI~T

289.

IPMC 704.2 Bl

BOTH BEDROOMS - SMOKE DETECTORS - NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTOR

290.

lPMC 704.2 B2

HALLWAY - ELECTR1C SMOKE DETECTOR - NOT SOU:\DING - PROVIDE ELECTRIC SMOKE
DETECTOR

291.

fPMC 605.1 B2

HALLWAY - WIRES I IAN GING OUT Or BOX - REPAIR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 44 of 146

Exhibit F

292.

fP:\1C 504. l 82

WASJIJ:\G MACHINE - IN UNIT - NO f!OOK UP

293.

IPMC 604.3 B2

DIKING ROOM - OUTLET - BROKEN - REPLACE - PROVIDE COVER PLATE

294.

IPYIC 704.2 B3

BOTH BEDROOMS - SMOKE DETECTORS - NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTORS

295.

IPMC 302.9

STAIRWAY WALL AREA - COMMO:J AREA- GRAFFITI -CLEAN UP

296.

IPMC 305.1 Al

KITCHE:\l -CABI>JET LNDER SINK- REPLACE

297.

IP~C 605.1 Al

CLOSET - Lf GHT - BROKEN - REPLACE

298.

IPMC 603.1 A2

KITCHEN - STOVE - LEFT REAR BCRNER- DEFECTIVE -REPAIR/REPLACE

299.

JPMC 704.2 A2

BOTH BEDROOMS - SMOKE DETECTOR- NOT SOCNDING - PROVIDE ELECTRIC SMOKE DETECTORS

300.

JPMC 305.3 A2

BATHROOM - PEELING PAINT - REPJ\lR - PREPARE AND PAI.XT

30I.

IPMC 704.2 A3

2:-:n BEDROOM - SMOKE DETECTOR -- NOT WORK.C\G - PROVIDE ELECTRIC SMOKE DETECTOR

302.

IPMC 305.3 A3

BATIIROOM - PEELING PAIKT - REPAlR - PREPARE AND PAINT

303.

IPMC 704.2 A4

BEDROO:M - S\10KE DETECTOR - NOT WORKING - PROVIDE ELECTRIC SYIOK.E DETECTOR

304.

IPMC 704.2 S1

BEDROO:M - S:'vlOKE DETECTOR .. NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTOR

305.

IPMC 704.2 S2

BEDROOM - SMOKE DETECTOR - NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTOR

306.

IPMC 305.3 S2

BATHR00:\1-CEILIN'G-FLAKI::.JG PAINT-REPAIR- PREPARE AND PAINT

307.

JPMC 704.2 S3

LOW BATTERY CHIRP- PROVIDE BATTERIES

308.

IPMC 504.1 S4

KITCHEN - SINK - TRAP - LEAKING - REPAIR

309.

IPMC 704.2 S4

BEDROOM - SMOKE DETECTOR - REMOVE - PROVIDE ELECTRIC SMOKE DETECTOR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 45 of 146
310.

IPMC 504.1 S4

BATHROOM - SINK - RECAULK

31 L

IPMC 305.4 S4

DIN1NG ROOM - FLOOR - REPAIR

Exhibit F

1205 ,'v!ADISON STREET

312.

IPMC 304.14 Bl

WINDOW - SCREENS - PROvlDE

313.

IP?v1C 603.1 Bl

FURJ"\JACE ROOM - FLUE PIPE - RUSTED..:. REPLACE

314.

IPMC 603.3 Bl

FUR.J"\JACE ROOM - OLD CABLE EQulPME~"T - CAP OFF

315.

IPMC 305.3 Bl

BATHROOM - CEILING - CHIPPING PAINT - REP.AJR - PREP ARE A1'(D PAINT

316.

IPMC 504.1 Bl

BATHROOM - TUB - RECAULK

317.

IPMC 504.1 B1

BATHROOM - SHO\VER AREA - SOAP DISH - PROVIDE

318.

IPMC 305.1 Bl

BATRHOOM- SINK- SOAP DISH - PROVIDE

319.

IPMC 402.3 Bl

BATHROOM- VENT FAl'-r- DEFECTIVE - REPAIR/REPLACE

320.

IPMC 704.2 Bl

1sT BEDROOM- SMOKE DETECTOR - NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTOR

321.

IPMC 704.2 Bl

HALL \VAY - ELECTR1C SMOKE DETECTOR- NOT SOUNDI?-,;G - PROVIDE ELECTRIC SMOKE
DETECTOR

~)?

IPMC 504.l B2

BATHROOM- TUB - RECAULK

~?~

j_:).

IPMC 305.3 B2

BATHROOM - CEILING - MOLD - REPAIR - PREPARE AND PAINT

324.

IPMC 603.3 B3

FUR.NACE ROOM - CABLE BOX STUFF - REMOVE

.:)_).

~7-

IPMC 603.1 B3

FURNACE ROOM- CLEAN OUT LEAYES A}ID DEBRJS

326.

IPMC 704.2 B3

HALLWAY- ELECTRIC SMOKE DETECTOR- REMOVED - PROVIDE ELECTRIC SMOKE DETECTOR

.J--·

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 46 of 146

Exhibit F

327.

IPMC 704.2 B3

1Sl BEDROOM - SMOKE DETECTOR- NOT SOUNDI~G- PROVIDE ELECTRIC SMOKE DETECTOR

328.

IPMC 603.1 B3

TI IERMOSTAT - COVER - PROVIDE

329.

IPMC 305.3 B3

LIVING ROO!vl- WALL- REPAIR- PREPARE AND PAINT

330.

IPMC 305.3 B3

BATHROOM - ACCESS PANEL - RUSTED - REPAIR - PREPARE AND PAfNT

331.

IP\1C 305.3 B3

BATHROOM - WALL AT TCB - DEFECTIVE - REP AIR

. ..,

XJ-.

')

IPMC 305.1 B3

BATHROOM - TOWEL RAR- PROVIDE

;j.):J.

" .., "

IPMC 504.1 B3

BATHROOM -- TUB - CLEAN AND RECACLK

334.

IP\.1C 504. l BJ

BATHROOM - TOILET - LEAKING - CIIECK WAX RING - REPAIR

335.

IP>-'fC 604.3 B3

KITCHEN~ GFCI- PAINTED OVER - REPLACE MUST REMAIN GFCI

336.

IPMC 304.3 B3

ENTRANCE DOOR - PROVlDE UNIT :-JU~BER ON DOOR

337.

fPMC 305.5

HA~DR<\II. - l sT FLOOR TO 2:-:o FLOOR - WOOD - REPLACE

338.

IPMC 704.2 A1

2><n BEDROOM - SMOKE DETECTOR - NOT SOU~DING - PROVIDE ELECTRIC SMOKE DETECTOR

339.

IPMC 305.3 Al

HALLWAY - WALL - REPAIR - PREPARE AND PAINT

340.

IPMC 305.3 J\l

l sr BEDROOM - FLOOR & WALL - REPAIR

341.

IPMC 305.3 Al

BATHROOM- PEELING PAINT-REPAIR-PREPARE AND PAINT

342.

TPMC 305.4 Al

LIVING ROOM- FLOOR - DEFECTIVE -REPAIR

343.

IPY!C 704.2 A?.

BOTH BEDROOMS - SYiOKE DETECTOR - NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTORS

344.

IPMC 603.1 A2

KITCHEN - STOVE - RA;\JGE HOOD - MISSir--:G - PROVIDE

345.

IPMC 305.3 A2

BATHROOM- WALL & CEILING-MOLD- REPAIR- PREPARE AND PAl).;T

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 47 of 146

Exhibit F

346.

IP!\1C 604.3 :\3

KITCH£~

347.

IP\.1C 603. l A4

Fl "R:\'ACE R00;-.1- BIRD'S :\'EST - REYIOVE - CLEA~ OCT A:\'D PROVIDE SCREE:\"

348.

IPMC 704.:! SI

S:VtOKE DETECTORS .. TlIROl.:GHOL:T - ~OT \l:ORKI:'\G -· PROVIDE ELECTRIC SMOKE DETECTORS

349.

IPMC 604.J SI

K[TCIIE:\'-<iFCI & Ol:TJ.ETS-REPLACE-GFCI l\·1l"ST REMA£~ GIT[

350.

IP\.1C 605.1 SJ

KITCIIE>:" - LIGHT- DEFECTIVE -- REPAIR/RF.PLACE

351.

'.\JFP /\ I 0.11.6 S l

GRILL ON BAI.CO~Y - !\OT PERMITTED TO BE STORED OR USED 0:\ TIIJS LEVEL

352.

IP:V1C 305.l

353.

IPMC 305.3 S::?.

BATllROOf\·1- PEELING PANT-REPAIR-· PREPARE A?--iD PAI:'\T

354.

IP:'v1C 504.1 S2

BATI JR00!\1- TOILET - RLJNS CONTIXUOl_"SI.Y - REPAIR

355.

lP:-VfC 305.1 S2

AC

356.

IP\.tc 304.15 S2

SCREE\: DOOR - PROVIDE SCREE:'\

357.

IP:V1C 704.2 S'>

3S8.

IP~v1C 603.1

359.

IPMC 704.2 S3

BEDR00\.1S .. PROVIDE ELECTRIC SMOKE DETECTORS

360.

JP;-.·1C 603.1 S4

K!TCHE~- STOVE - R!Gl lT REAR Bl.!R'.'.\:ER ·· DEFECTIVE- REPAIR/REPLACE

361.

IPMC 704.2 S4

IIAI.L WAY - ELECTRIC SMOKE DETECTOR -- REMOVED - PROVIDE ELECTRIC SMOKE DETECTOR

362.

IP~1C 305.3 S4

BATIIR00:\-1- PEEUKG PAI:'\T

363.

IPMC 402.3 S4

BATHROO:vt - VENT FAN -DEFECTIVE-. REPAIR/REPLACE

S2

-

s.,"~

(iFCT- DEFECTIVE

REPLACE-· '.v1lJST REMAP.\ GIT!

KITCHEN - :2 CABINET DOORS · BROKEN- RIGHT OF REFRIGERATOR - REPAIR-.. REPI.ACE

c;s.;rr - SEAL AROC;\:D L:-JIT

I.OW BATTERY CHIRP- PROVIDE BATTERIES

Fl.:RNACE R00\.1- BIRD·s :\"EST

REMOVE & CLEAN OUT - PROVIDE SCREE~

REPAIR - PREPARE A1'D PAI>,;T

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 48 of 146
J64.

:--.:FPA I 0.11.6 S4

Exhibit F

GAS GRILL 0:\ BALCO~Y . Rl-:l\10VE- ~OT PER\t1ITTFD TO t:SE OR STORE 0\: TI !IS LEVEL
1215 .HAD/SO.\" STREET

365.

IPMC 302.1

EXTERIOR - BASE:V1E~T UTIUTY ROOM ACCESS ··· CllAIR CCSHIO~S & DEBRIS - REMOVE

366.

JP'.\1C 605.1

CTII.ITY R00\1 - E:V1ERGENCY EXIT UGI IT - PROVIDE

367.

lPMC 305.3

LTILITY ROOM- Wi\l.L-MOLD - REPAIR

368.

IP\lC 504.1 Bl

KITCHE:\ -- Sl>JK - FAlTET - DRIPPNG

369.

IP'.'vlC 704.2 B2

BOTH BEDROOMS -- NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

370.

IP\1C 305.1

KITCHE:\'- CABI\:ET DOOR- DEFECTIVE (.ILST :\'EEDS TO BE GLCEO)

371.

IPMC 504.1 B3

372.

IP\.1C 60-l.3

373.

IPMC 704.2 B3

MASTER BEDROOM- S>1IOKE DETECTOR - NOT SOCl\DING - PROVIDE ELECTRIC SMOKE DETECTOR

374.

lP\1C 704.2 Al

BEDR00'.\1S - PROVIDE ELECTRIC S~10KE DETECTORS

375.

lPMC 702.3 A2

IsT BEDROOM - NO ACCESS - KEY LOCK 0:--! DOOR - PROVIDE ACCESS - REMOVE KEY I.OCK

376.

IP\1C 305.6 A2

BEDR00'.\1 - DOOR - I IOI .E - REPI .ACE

377.

JPMC 704.2 A2

21'D

378.

IP\tC 305.6 A3

H:\LLWAY - CLOSET DOOR

379.

IP\>1C 305.6 A3

Isr BEDROOY!- DOOR - 1!OLE - REPLACE

380.

ll'\1C 309.1

381.

IP\1C 305.3 J\4

B2

83

:\4

REPAIR

KITCHEN- SINK - FAUCET -DRIPPING- REPAIR

KITCH£:,.;-- GFCJ - PAI:\TED OVER - REPL,\CE ;vlCST RE'.\1AIN GFCI

BEDROOM - NO S:'v10KE DETECTOR

PROVIDE ELECTRIC SMOKE DETECTOR

PAINT

EXTER?v1I:-:ATE - ROA Cl l A?\D '.\1ICE T\"FESTATION PROBLEM

1.!Vf>JG ROOM - WALL- HOLE· REPAIR-· PREPARE A;,;D PAJ~T

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 49 of 146

Exhibit F

382.

IPMC 604.3 A4

BATHR00\1- GFCI - DEFECT[Vl: -REPL/\CF - \1CST REMAN (iFCI

383.

IP\IC 704.~ Sl

S'.\10KE DETFCTORS - TIIROl-GI !OCT - ~OT \\'ORKJr--;G - PROVIDE ELECTRIC S\·10KE DETECTORS

384.

IP\1C 305.3 Sl

BATHROQ!\,1- PEELING PANT

385.

IP:VfC 6053 SI

BATHROOM- LIGHT GLOBE - PROVIDE

386.

IP\1C 504.1 SI

KITCIIEN - FAL~CET - DRIPPING - REPAIR

387.

IP\1C 704.2 S2

BEDROOJ\-1- :--:o SMOKE DETECTOR - PROVIDE ELECTRIC S1\.10KE DETECTOR

388.

IPMC 704.2 .S"'.)

BEDROOMS - PROVIDE ELECTRIC S.\10KE DETECTORS

389.

1P\1C 704.2 S4

BEDR00\1 -- SMOKE DETECTOR - l\1ISSING - PROVIDE ELECTRIC S:-V10KE DETECTOR

390.

IPMC 504.l

BATHR00\1- TUB - RECAULK

391.

JPMC 304.15 S4

S4

REPAIR- PREPARE A~D PAI~T

SCREE>-: DOOR- BUGS CO~f\:G 11\ THROUGH SCREE?\ - REPAIR

1 I 50 MADISON STREET
392.

IPMC 305.3

t:TILlTY R00\1- CEIL1:'\G - HOLES·- REPAIR

393.

IJ>MC 604.3 Bl

KITCIIE~~ (iFCI - PAI\:TED OVER - REPLACE :\1l'ST REMAIN CiFCI

394.

IPMC 605. l Bl

KITCHEN ·PANEL-PAINTED OVFR - OPEN CP

395.

IPMC 305.1 BI

KITClIEN~ DR/\ \YER FRO'.\JT- PROVIDE

396.

IPMC 305.3 Bl

BATHR00\>1 -CEIIJNG ·· LEAKING fROM UPSTAIRS-REPAIR - PREPARE A'.'JD PAl~T

397.

IPMC 504.1 Bl

BATHROO\I -TOILET··· Rl'.?\S CONTNl'Ot:SLY - REPAIR

398.

IPMC 704.2 Bl

I l/\1.LWA Y -- ELECTRIC SMOKE DETCTOR - LOW DECIBEL-· REPLACE - \llvST REMAIN ELECTRIC

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 50 of 146

Exhibit F

399.

TPMC 704.2 Bl

ALL 3 BEDROOMS - :\"O S>llOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

400.

IPMC 704.2 82

BOTI J I3EDROO:V1S- SMOKE DETECTORS - NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTORS

401.

IRC

HALLWAY- PROVIDE CO DETECTOR - MISS1:\"G

402.

IP:vIC 504.1 B3

KITCl !EN - SINK - LEAKING UNDERNEATH - REPAIR

403.

IPMC 704.2 B3

I sr BEDROOM - SMOKE DETECTOR - NOT SOUNDING- PROV IDE ELECTRIC SMOKE DETECTOR

404.

IPMC 305.3 Al

BATHROOM -CEII .ING- PEELf:\G PAINT - REPAIR - PREPARE AND PAINT

405.

IP:\ttC 402.3 AI

BA TI IROOM - VENT FAN - DEFECTIVE - REPAIR/REPLACE

406.

IPMC 604.3 A2

KITCHEN -GFCf RIGHT Of SINK- DEFECTIVE- REPLACE MCST REMAIN GFCI

407.

IPMC 704.2 A3

BOTH BEDROOMS - SMOKE DETECTORS - NOT SOl-2\DTNG - PROVIDE ELECTRIC SMOKE DETECTORS

408.

IPMC 305.1 A3

BEDROOM - POOR HOUSEKEEPING

409.

lPMC 704.2 J\4

LOW BA TIER Y CHIRP - PROVIDE BA TTERJES

410.

IPMC 704.2 A4

BEDROOM~ SMOKE DETECTOR - NOT SOCKDING - PROVIDE ELECTRIC SMOKE DETECTOR

411.

IPMC 504.l SI

KITCHEN - SIKK - FAUCfT - DRIPPING - REPA[R

412.

IPMC 603.1 Sl

KITCHEN - STOVE- LEFT REAR BURNER - DEFECTIVE- REPAIR/REPLACE

413.

IPMC 604.3 Sl

KITCHEN - GFCI ..::·REPLJ\CE - MUST REMAlN GFCI

414.

JPMC 704.2 Sl

BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

415.

IPMC 704.2 SJ

HALLWAY - ELECTRIC SMOKE DETECTOR - COVERED WITI I BAG - REMOVE BAG

416.

IPMC 704.2 S2

BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

417.

IPMC 305.3 S2

BA TIIROOM- FLAKING PAfNT - REPAIR-PREPARE AND PA!Kf

3 I 5.1 B2

·~

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 51 of 146
418.

IPMC 704.2 S3

BEDROOMS - :-JO S:V10KE DETECTORS-·· PROVIDE ELECTRIC SMOKE DETECTORS

419.

IPMC 603.1 S3

KITCIIE?\- STOVE- RIGHT SIDE BURNERS - DEFECTIVE -REPAIR/REPLACE

420.

IPMC 603 .1 S4

KITCHE>J - STOVE - LEFT REAR BURNERS - DEFECTIVE - REP AIR/REPLACE

Exhibit F

I 140 MADISON STREET
421.

lPYl:C 305.3

f.AUNDR Y ROOM -·WALLS & CEiLING - I JOLES - REPAIR

422.

IPMC 605.1

LAUNDRY R00\.1-EMERGE~CY BACKUP LIGHTS- DEFECTIVE- REPAIR/REPLACE

423.

IP:\1C 504. I

lTTIUTY ROOM- SEWAGE BACKUP - CLEAN FLOORS - CRUSTED OVER THROtJGHOliT

424.

IPMC 504.1

UTlLITY ROOM - SEWER CLEAN UP CAP- PUT CAP BACK ON LINE

425.

IP.\1C 605.1

UTILITY ROOi\-1- EMERGE1\'CY BACKUP LIGHTS- DErECTIVE- REPAIR/REPLACE

426.

IPMC 305.4 Bl

BATHROOM - FLOOR - TENANT KEEPS HA YING A WATER ISSUE- WATER SEEPING IN - NOT SURE ff
THIS 1S RELATED TO UTILITY ROOM BACKUP- CHECK AND MAKE :--,;ECESSARY REPAIRS

427.

IPMC 305.1 BI

POOR l!OUSEKEEPING-THROUGHOCT-TENANT.CLAIMS ITS Dl:E TO WATER ISSUE

428.

lPMC 704.2 82

BEDROOMS -- PROVIDE ELECTRIC SY10KE DETECTORS

429.

IPMC 605.3 B3

DINING ROOM - LIGHT GLOBE- PROVIDE

430.

IPMC 504. l B3

KITCHE:\l- Sl:\K~ FAUCET-DRIPPING- REPAIR

431.

IPMC 305.3

3RD

FLOOR COM\10N AREA-CEILING- REPAIR

432.

IPMC 704.I

3RD

FLOOR - FIRE EXTINGUISHER - PROVIDE GLASS COVER

433.

IPMC 704.2 SI

HALLWAY- ELECTRIC SMOKE DETECTOR -1 IAN GING- SECURE

434.

IPMC 704.2 S2

HALLWAY - ELECTRIC SMOKE DETECTOR- NOT WORKING - PROVIDE EU:CTRIC SMOKE DETECTOR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 52 of 146

Exhibit F

435.

IP\1C 704.2 S2

BEDR00'.\1

436.

IP\1C 404.5 S2

OVERCRO\\'Dl~G · BED [~ UVI~G ROO:'v1 - REMOVE :t,.:OT APPROVED BEDR00\1

437.

IPMC 704.2 S"'.,

HALL\VAY -- ELECTRIC SMOKE DETECTOR-NOT SOCNDING~PROVIDE ELECTRIC S:v10KE DETECTOR

438.

TP~1C 704.2 S3

BEDR00:V1S - :,..:o S\tOKE DETECTORS- PROVIDE ELECTRIC' S:'v10KE DETECTORS

439.

1Pl\.1C 704.2 S4

BEDR00\1S

440.

IPMC 704.2 Al

ALL S:V!OKE DETliCTORS - THROl."GIIOCT - :\OT SOl.l>-JDD.:G PROVIDE ELECTRIC S:'v10KE DETECTORS

441.

lP:-.,1C 504. I Al

KlTCHE:-.: · SINK - FAUCET HANDLE- DEFECTIVE - REPAIR/REPLACE

442.

1PY1C 504.1 A2

KITCHEN - SINK- LEAKING-REPAIR

443.

IP\1C 504.1 A2

BATHROOM - COLD WATER ·· :\OT WORKI~G - REPAIR

444.

IP:-..1C 504.1 A2

BATHROOM ·-TOIi.ET SEAT-BROKE?\'-REPLACE

445.

IP:\1C 504. J

446.

1P:V1C 704.2 /\2

BEDROOM - SMOKE DETECTOR - NOT WORKING - PROVIDE ELECTRlC SMOKE DETECTOR

447.

IP\.1C 704. l

2:-.D

448.

IP:'vlC 704.2 /\3

JIALLWAY -ELECTRIC SMOKE DETECTOR-NOT WORKING - PROVIDE ELECTRIC SMOKE DETECTOR

449.

IP\.lC 704.2 A3

BEDROOM - S~10KE DETECTOR

450.

1P:V1C 603.1

KITCHEN - STOVE··· RIGHT REAR BURNER - DEFECTIVE - REPAIRiREPLACE

451.

IP'.'v1C 305.4 A3

FLOORC'\G - THROUGJ lOUT - CRACKED·· REPLACE

452.

lPY1C 305.1 /\4

KITCHEN- REFRIGERATOR HA~DLE- BROKE~ - REPAIR/REPLACE

A2

A3

S\10KE DETECTOR ·DEFECTIVE-PROVIDE EU:C:TRJC S:v10KE DETECTOR

:--.:o S:v10KE DETECTORS -

PROVIDE ELECTRIC SMOKE DETECTORS

BATHROOM - TCB - NOT DRAI~ING - REPAIR

fLOOR ·· HALL\V/\ Y · FIRE EXT1:'.\Gl.lSIIER-RE\-10VED ·· PROVIDE

~OT \VORKI~G - PROVIDE ELECTRIC S'.\10KE DETECTOR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 53 of 146

Exhibit F

I 130 MADISON STREET

453.

IPMC 309.1 B3

EXTERMINATE - ROACHES

454.

IPMC 604.3 B3

DINING ROOM-· OCTLET COVER PLATE·~ PROVIDE

455.

lPMC 704.2

456.

lPMC 305.3 83

1ST BEDROOM - PREPARE A~D PAINT

457.

IPMC 305.3 B3

UVING ROOM & DINING ROOM- \VALL- PREPARE AND PAI~T

458.

IPMC 704.2 B2

MASTER BEDROOM - SMOKE DETECTOR- NOT SOlJNDP..:G - PROVIDE ELECTRIC SMOKE DETECTOR

459.

IPMC 603.1

460.

IPMC 305.3 Bl

BATHROOM - VENT & ACCESS PANEL- RUSTED- REPAIR- PREPARE AND PAfNT

461.

IP~·1C 704.2 Bl

1ST BEDROOM - SMOKE DETECTOR -NOT SOUNDING.- PROVIDE ELECTRIC SMOKE DETECTOR

462.

lPMC 704.2 81

HALLWAY - ELECTRIC SMOKE DETECTOR- NOT SOUNDI)IG - PROVIDE ELECTRIC S:v10KE
DETECTOR

463.

IPMC 704.1

3RD f LOOR COMMON AREA - CABLE CHIME - REAITACH TO WALL

464.

IPMC 704.2 Sl

2ND

465.

TPMC 305.3 SI

BATHROOM - FLAKING PJ\.INT - REPAIR - PREPARE AND PAINT

466.

IPMC 704.2 S2

BEDROOMS - SMOKE DETECTORS - MISSING- PROV1DE ELECTRIC SMOKE DETECTORS

467.

IPMC 704.2 S3

ALL 3 BEDROOMS - S:v10KE DETECTORS - NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTORS

468.

IPMC 305.3 S3

BATHROOM - FLAKING PANT - REPAJR - PREPARE AND PAINT

469.

IPMC 504.1 S3

BATHROOM - TOILET-LOOSE- REPAIR

B3

82

BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC S~OKE DETECTORS

KITCHEN - STOVE - RA~GE HOOD - RUSTED- REPLACE

BEDROOM - SMOKE DETECTOR - NOT SOU!\DlNG - PROVIDE ELECTRIC SMOKE DETECTOR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 54 of 146

Exhibit F

-+70.

IP>1IC 604.3 S3

BATHROOM - GFCI - DEFECTIVE - REPLACE - MCST REMAIN GFC!

471.

IPMC 704.2 S4

BEDROOM - SMOKE DETECTOR-1\0T SOCN'DJXG- PROVIDE ELECTRIC S}.10KE DETECTOR

472

IP:v!C 704.2 A1

BEDROOM - SMOKE DETECTORS - PROVIDE ELECTRIC S\10KE DETECTORS

473.

IPMC 704.:2 A2

MASTER BEDROOM - S:v10KE DETECTOR- ~OT WORKI"KG~ PROVIDE ELECTRIC SMOKE DETECTOR

474.

IPMC 604.3 A2

KITCHEN - GFCI TO LEFT SIDE OF SINK - DEFECTIVE - REPLACE MUST REMAIN GFCI

475.

IPMC 704.2 J\3

l sT & 2)\ 0 BEDROOM - NO SMOKE DETECTORS - PROVfDE ELECTRfC SMOKE DETECTOR

476.

IPMC 604.3 A3

KITCHEN - GFCI TO LEFT OF SIKK · DEFECTIVE -REPLACE - MUST REMAIN GFCI

477.

IPMC 704.2 A4

HALLWAY - ELECTRIC SMOKE DETECTOR - RFMOVF.D - PROVIDE ELECTRIC SMOKE DETECTOR

478.

JPMC 704.2 A4

BEDROOM - SMOKE DETECTOR - :--:or WORKING - PROVIDE ELECTRIC S~OKE DETECTOR

I 120 l'i4ADISON STREET
479.

IPMC 305.3

UTILITY ROO~ - HOLE BEHl):D ENTR.i\.NCE DOOR- REPAIR

480.

IP~C 704.2 Bl

l ST BEDROOM - SMOKE DETECTOR - KOT SOL"NDING - PROVIDE ELECTRIC SMOKE DETECTOR

481.

IPMC 305.3 B1

HALLWJ\ Y-WALL-REPAIR-PREPARE AND PAINT

482.

IPMC 305.6 BJ

KITCHEN -CLOSET DOOR - CI UPPING PA!:-JT - REPAIR - PREPARE AND PANT

483.

IPMC 504. l B2

BATHROOM - TUB WALL- RECAULK & REGROUT

484.

IP:vtC 305.3 B2

BATHROOM - CEILING - REPAIR - PREPARE AND PAINT

485.

IPMC 704.2 B2

MASTER BEDROOM - SMOKE DETECTOR - )JOT SOUNDI1':G - PROVIDE ELECTRIC SMOKE DETECTOR

486.

IPMC 704.2 B3

HALLWAY - SMOKE DETECTOR (BAn·ERY OPERATED) - NEEDS TO BE PUT BACK AS ELECTRIC

487.

IP\1C 305.1 S1

KITCHE:,J - BACKSPLASH - REPAIR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 55 of 146

Exhibit F

-t88.

IPMC 704.2 Sl

LOW BATTERY CHIRP - PROVIDE BA TTERJES

489.

IPMC 305.3 S1

BATHROOM - FLAKING PAJ}..;T- REPAIR - PREPARE AI\D P/\l?\T

490.

IPMC 305.3 SI

BATI IROO:vi - W/\LL- COY!PLETE REPAIR- PREPARE A~D PAINT

491.

IPMC 304.15 S2

ENTRANCE DOOR - HOLE- REPAIR

492.

IPMC 704.2 S2

2~D BEDROOM- SMOKE DETECTOR - NOT SOUNDING - PROVlDE-ELECTRIC SMOKE DETECTOR

493.

IPMC 305.3 S2

BATHROOM- FLAKING PAINT-REPAIR-PREPARE AKO PAINT

494.

IPMC 603.1 S2

FUR:--!A~CE R00:\1- HVAC NOT WORKING- REPAIR

495.

IJ>MC 704.2 S3

ALL BEDROOMS - NO S:vfOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

496.

lPMC 704.2 S4

LOW BATIERY CHIRP-PROVIDE BATTERIES

497.

IPMC 604.3 Al

KJTCHE:'.\J - GFCI LEF OF SINK - DEFECTIVE - REPLACE - MUST REMAIN GFCI

498.

IPMC 704.2 Al

BEDROOM - S:\10KE DETECTOR- NOT \VORKING- PROVJDE ELECTRIC SMOKE DETECTOR

499.

IPMC 305.3 Al

BA THR00:\1- CEILING - REPAIR - PREPARE AND PAINT

500.

IPMC 604.3 A2

KITCHEN - GFCI TO RIGHT SIDE OF SINK- DEFECTIVE - REPLACE MUST REMAIN GFCJ

501.

IPMC 704.2 A2

2~n BEDROOM - SMOKE DETECTOR - NOT WORKI?\G - PROVIDE ELECTRIC SMOKE DETECTOR

502.

IPMC 604.3 A3

KITCHEN - GFCI TO RIGHT OF SINK - REPLACE - MUST REMAlx GFCI

503.

IPMC 604.3 A3

BATHROOM - GFCI - REPLACE - MUST REMA~ GFCI\

504.

IPMC 504.l A3

KlTCHEN - SINK FAUCET - LEAKING - REPAIR/REPLACE

505.

IPMC 704.2 A3

1sr BEDROOM - SMOKE DETECTOR - NOT SOlNDING - PROVIDE ELECTRfC SMOKE DETECTORS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 56 of 146

Exhibit F

506.

IPMC 305.3 A3

BATI fROOM - CEIL NG - DNv1AGED - REPAIR - PREPARE A \"D PAINT

507.

lPMC 704.2 A4

BEDR00.\1- SMOKE DETECTOR - LOW DECIBEL - PROVIDE ELECTRIC SMOKE DETECTOR

508.

lPMC 603.1 A4

KITCHE:-J -STOVE I.EFT SIDE BURNERS-DEFECTIVE- REPAIR/REPLACE
1110 MADISON STREET

509.

IPMC 304.15

UTILITY ROOM - BROKEN INTO - REPLACE LOCKS & REPAIR DOOR

510

IPMC 504.1

GTJLITY ROOM - SEWER CLEA:-: OUT CAP - PROVIDE

511.

IPMC 305.3

STORAGE ROOM - \VALLS & CEILINGS- HOLES - REPAIR

512.

IPMC 704.2 B2

HALT.WAY - SMOKE DETECTOR (BATTERY OPERATED) PROVIDE ELECTRIC SMOKE DETECTOR

513.

IPMC 504.1 B2

KITCHEN - FAUCET - LEAKING - REPAJR/REPLACE

514.

JPMC 305.3 B2

KITCIIEN-WALLAT SINK-REPAIR-PREPARE AND PAINT

515.

1PMC 305.3 B2

KITCHEN - WALL BEHIND STOVE - GREASE - CLEAN

516.

TPMC 704.2 B3

ALL BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

517.

IPMC 305.3 B3

BA TI IROOM - WALL - DEFECTIVE - REPAIR - PREPARE AND PAINT

518.

IPMC 504.1

519.

IMC

520.

IPMC 305.3 B3

BATHROOM - WALLS & CEILING- LEAK FROM UPSTAIRS - REPAIR - PREPARE AND PAINT

521.

IPMC 704.2 S4

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

. 522.

IPMC 704.2 S2

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

523.

IPMC 402.3 S3

BATHROOM- VENT FAN - NOT WORKING- REPAIR/REPLACE

83

504.1 B3

BATHROOM -TOILET-RUNS CONTINLOUSLY - REPAIR
BATHROOM - TUB- RECAULK

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 57 of 146

Exhibit F

524.

IP\1C 605.3 S3

Bi\TIIROO?vl -LIGIIT GLOBE--PROVJDE

525.

IP\1C 704.2 S3

2:-,;l) BEDROO:Vl - SMOKE DETECTOR - REMOVE - PROVIDE ELECTRIC SMOKE DETECTOR

526.

lPMC 305.1 S 1

POOR HOUSEKEEPING - MOVING OUT PER TENANT
1100 MADISON STREET

527.

IPMC 304.10

EXTERIOR- ALL BALCOJ\:IES-RUSTED AND CHIPPING PArNT-REPAIR-PREPARE AND PAJ;-.JT

528.

IPMC 305.3

UTJLTTY ROOM - WALI, & CEILING - MOLD - REPAIR

529.

IPMC 605.3

LTILITY ROOM - UGI IT COVER - PROVIDE

530.

TPMC 304.15 Bl

ENTRANCE DOOR- PROVIDE UNIT NUMBER 0:-! DOOR

53 L

lPMC 604J Bl

KITCHEN - ELCTRICAL OUTLET (WORKING ON) - DEFECTIVE- REPAIR

532.

IPMC 604.3 Bl

LIVING ROOM -ELECTRICAL OUTLET-DEFECTIVE - REPAIR

533.

IPMC 504,l BJ

BATHROOM- TUB-RECAULK

534.

IPMC 604.3 Bl

I ST BEDR00:-1 - OUTLET BY BED - DEFECTIVE

535.

IPMC 704.2 Bl

HALLWAY - SMOKE DETECTOR - LOW DECIBEL - PROVIDE ELECTRIC SMOKE DETECTOR

536.

IPMC 305.1 Bl

BATHROOM- SOAP & TOOTH BRLSH HOLDER -- PROVIDE

537.

IPMC 504.1 Bl

BATHROOM - TUB - SHOWER DIVERTER - PROVIDE

538.

IPMC 704.2 B2

BOTH BEDROOMS - :'JO SMOKE DETECTORS -PROVIDE ELECTRIC SMOKE DETECTORS

539.

JPMC 305.3 B2

HALLWAY - WALL BY BATHROOM - HOLE - REPAIR - PREPARE AND PAINT

540.

1PMC 604.3 B2

1sr BEDROOM -OUTLET - COVER PLATE - PROVJDE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 58 of 146

Exhibit F

541.

IPY!C 603.I B2

KTTCHE~ -STOVE- RANGE HOOD FAN·· DEFECTIVE-REPAIR/REPLACE

542.

IPMC 704.2 B3

l !ALL WAY - ELECTRIC SMOKE DETECTOR ... REMOVE- PROVIDE ELECTRIC SMOKE DETECTOR

543.

IPMC 504. l B3

BATHROOM- TOILET SEAT - DEFECTIVE - REPLACE

544.

lPMC 7042 B3

BOTH BEDROOM - SMOKE DETECTORS - NOT SOUNDING - PROVIDE ELECTRIC SMOKE DETECTOR

545.

IPMC 305.1 B3

KITCHEN -CABINET DRJ\ WER - PROVlOE

546.

lPMC 603.1 B3

FURNACE ROOM - REMOVE TRASH & DEBRlS - CLEAN OUT

547.

IPMC 603.1 Sl

KITCHEi\ ... STOVE- RIGHT REAR BURNER- DEFECTIVE-REPAIR/REPLACE

548.

lP\1C 504.1 SI

KITCHEN -FAUCET-REPLACE

549.

IPMC 704.2 S2

I s-r BEDROOM- SMOKE DETECTOR- NOT WORKING - PROVIDE ELECTRIC SMOKE DETECTOR

550.

IPMC 704.2 S3

l sT BEDROOM - SMOKE DETECTOR - rs;oT WORKING- PROVIDE ELECTRIC SMOKE DETECTOR

551.

IMC

BATHROOM- FLAKI:'.'JG PAINT- REPAIR - PREPARE Al\'D PAfNT

552.

IP:MC 603.1 S3

KITCHEN- STOVE - LEFT REAR BURNER - DEFECTIVE - REP AIR/REPLACE

553.

IPMC 604.3 S3

BATHROOM - GFCl - NO POWER - REPLACE :V1UST REMAIN GFCI

554.

IPMC 603.l S4

KITCHEN- STOVE - LEFT FRONT BURNER - DEFECTIVE -REPAlR/REPJ .ACE

555.

lPMC 704.2 S4

BEDROOM - SMOKE DETECTOR - NOT WORKING - PROVIDE ELECTRIC SMOKE DETECTOR

556.

rPMC 603.I AI

KITCHEN- RA.~GE I IOOD - NOT WORKING - REPAIR/REPLACE

557.

TPMC 704.2 Al

2~ 0 BEDROOM- SMOKE DETECTOR- LOW BATTERY CHIRP -PROV[DE BATTERIES

558.

IPMC 704.2 A2

BOTH BEDROOMS - SMOKE DETECTOR - NOT WORKP.-JG- PROVIDE ELECTRIC SMOKE DETECTOR

559.

IPMC 305.3 A2

BATHROOM- CEfLING-REPAIR- PREPARE Al\'D PAINT

305.3 S3

.

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 59 of 146
560.

IP!v1C 305.3 A2

FURKACE ROOM - CEILING - REPLACE

561.

1PMC 603.1 A2

FURNACE ROOM- LEA YES - DEBRIS - CLEAN OUT

562.

JP~C 604.3 A3

KIT CJ IEX - GFCI TO RlGHT OF SINK - NOT WOR.KINGw REPLACE MCST REYIAN Gf CI

563.

IPMC 604.3 A3

BATHROOY! - GFCI ... NOT WORKING - REPLACE MOST REMAIN Gf.CJ

564.

IPMC 704.2 A3

lsr BEDROOM -NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTOR

565.

IPMC 704.2 A4

ALL BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

Exhibit F

960 MADISON STREET

566.

IPMC 304.15

UTILITY ROOM- UNLOCKED - NEEDS TO BE SECURED

567.

IMC

UTILITY ROOM -EMERGENCY BACKUP LIGHT- DEFECTIVE- REPAIR/REPLACE

568.

IPMC 104.2 Bl

PROVIDE ACCESS - DOG NOT CRATED

569.

lPMC 605.3 82

Dl::,,JING ROOM - LIGHT - GLOBE - PROVIDE

570.

IPMC 704.2 B2

BOTH BEDR00\1 - SMOKE DETECTORS - NOT SOu'"'.\DTNG - PROVIDE ELECTRIC SMOKE DETECTORS

571.

IPMC 704.2 B2

HALLWAY - ELECTRIC SMOKE DETECTOR - NOT SOUNDING - PROVIDE ELECTRIC SMOKE
DETECTOR

572.

IPMC 305.3 B2

HALLWAY~ WALL - HOLE - REPAIR - PREPARE AND PAINT

573.

IPMC 305.3 B2

BATRHOOM- VENT & PANEL - RUSTED - PREPARE A~D PAINT

574.

IPMC 305.3 B2

BA TRHOOM- WALL - REPAIR - PREP ARE AND PAINT

575.

IPMC 504.1 B2

RATHROOM - SHOWER TILES - DEFECTIVE - RE?AIR/REPLACE

576.

IP:VlC 504. l B2

BATHROOM- SJ lOWER - NO DIVERTER- PROVIDE

605.1

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 60 of 146

Exhibit F

577.

IPMC 304.14 B2

\VINDOWS -·· SCREENS & BLINDS

578.

IP\,1C 305.3 B3

BATHROOM- WALL & CEILING- MOLD - REPAIR- PREPARE Al\'D PAINT

579.

IPMC 305.3 B3

BA TH ROOM- CEILING- FLAKI).JG PAINT - REPAIR - PREPARE AND PAfNT

580.

IPMC 704.1

3RD

581.

JPMC 104.2 Sl

1\'0 ENTRY - TENA-~T SICK

582.

IPMC 305.3 S2

BATHROOM- CEILIKG - REPAIR - PREPARE AND PAINT

583.

IPMC 504.1 S2

BATHROOM-TOILET- RUNS CO>JTJNUOVSLY - REPAIR

584.

IPMC 704.2 S2

BEDROOMS - NO SMOKE DETECTOR - PROVIDE ELECTRIC SMOKE DETECTOR

585.

[PMC 704.2 S3

BEDROOM - SMOKE DETECTOR - DISCONNECTED - PROVIDE ELECTRJC S110KE DETECTOR

586.

IPMC 504.l S3

KITCHEN - SINK f ACCET - LOOSE- REPAIR

587.

IPMC 704.2 S4

HALLWAY - ELECTRIC SMOKE DETECTOR - NOT SOUNDING-PROVIDE ELECTRIC SMOKE DETECTOR

588.

TPMC 704.2 Al

BEDROOM - NO S\10KE DETECTOR - PROVIDE ELECTRlC SMOKE DETECTOR

589.

!PMC 704.2 Al

HALLWAY - ELECTRIC SMOKE DETECTOR - NOT SOUNDING - PROVIDE ELECTRIC SMOKE
DETECTOR

590.

IPMC 305.3 Al

HALLWAY - DRYWALL - PATCH - PREPJ\RE AND PAJNT

591.

IPMC 305.6 Al

MASTER BEDROOM- DOOR-BROKEN-REPLACE

592.

JPMC 702.3 Al

MASTER BEDROOM- DOOR- KEY LOCK- REMOVE NOT PERMITTED

593.

IPMC 704.2 A2

BEDROOM - NO SMOKE DETECTOR-PROVIDE ELECTRJC SMOKE DETECTOR

594.

IMC

KITCHE>i- REFRIGERATOR - PLUGGED INTO GFCI OCTLET -PROVIDE REGULAR OUTLET

605.1 A3

FLOOR- SMOKE ALARM CAGE-· REPLACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 61 of 146

Exhibit F

595.

IP~C 504.l i\3

BATI [ROOM - TUB - RE CAULK

596.

IPMC 504.1 A4

KITCHEN- SINK FAUCET - DRIPPIKG- REPAIR

597.

IPMC 603.1 A4

KITCHEN - RA~GE HOOD - NOT WORKING- REPAIR/REPLACE

598.

IPMC 704.2 A4

BEDROOM - SMOKE DETECTOR -NOT WORKING~ PROVIDE ELECTRIC SMOKE DETECTOR
950 MADISON STREET

599.

lPMC 704.1

UTILITY ROOM - EXIT LIGHT - DEFECTIVE - REPAIR/REPLACE

600.

IPMC 305.3

UTILITY ROOM -CEILING- \'!OLD - REPATR

601.

IPMC 605.I

CTTLITY ROPOM - EMERGENCY BACKUP UGI IT - DEFECTIVE - REP AIR/REPLACE

602.

IPMC 304.3 Bl

ENTRA.i'\f CE DOOR - PROVIDE UNIT NUMBER ON DOOR

603.

IPMC 704.2 82

ALL BEDROOMS - SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

604.

IPMC 704.2 83

ALL BEDROOMS - SMOKE DETECTOR - PROVIDE ELECTRIC SMOKE DETECTORS

605.

lPMC 704.2 SJ

ALL SMOKE DETECTORS -NOT WORKING· PROVIDE ELECTR1C SMOKE DETECTOR

606.

IPMC 704.2 S2

ALL BEDROOMS - SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

607.

lPMC 605.1

HALLWAY - LIGHT - DEFECTIVE - REPLACE

608.

IPMC 704.2 S3

SMOKE DETECTORS - LOW BATTERY Cl IIRP - PROVIDE BATTERIES

609.

IPMC 704.2 S3

2t--:D

610.

IPMC 305.3 S3

BATHROOM- PREPARE A.t'JD PAINT

611.

IPMC 402.3 S3

BATl IR00\-1- VENT FAN- DEFECTIVE - REPAIR/REPLACE

S3

BEDROOM - SMOKE DETECTOR - MJSSfNG - PROVIDE ELECTRIC SMOKE DETECTOR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 62 of 146

Exhibit F

612.

IPMC 604.3 S4

KITCHE:-J- GFCJ - PAL\'TED OVER

613.

UdC

KfTCHEN - LEFT SIDE BURNERS -- DEFECT1VE-REPAIR/REPLACE

614.

TPMC 605.3 S4

BATHROOM - LIGHT GLOBE - PROVIDE

615.

JPMC 704.2 A 1

HALLWAY- ELECTRIC SMOKE DETECOR-NOT SOUNDING-PROVIDE ELECTRIC SMOKE DETECTOR

616.

IPMC 603. J A2

KITC1 IE\! - STOVE -RIGI IT REAR BLRNER - DEFECTIVE - REPAIR/REPLACE

617.

IMC

BEDROOM - NO SMOKE DETECTOR - PROVIDE ELECTRIC SMOKE DETECTOR

618.

IPMC 704.2 A3

HALLWAY- ELECTRIC SMOKE DETECTOR- NOT WORKING PROVIDE ELECTRIC SMOKE DETECTOR

619.

IPMC 704.2 A3

2~l) BEDROOM - SMOKE DETECTOR -- NOT WORKING..:. PROVIDE ELECTRIC SMOKE DETECTOR

620.

IP:MC 305.3 A3

KITCIIEN- WAU. BY KITCIIE:l\" -HOLE-REPAIR-REPAIR-PREPARE AND PAl?\T

621.

IPMC 704.2 A4

BEDROOM - NO SMOKE DETECTOR - PROV1DE ELECTRIC SMOKE DETECTOR

622.

IPMC 604.3 A.4

BATHROOM- GFCI - NOT WORKING - REPLACE - MUST REMAIN GFCI

603.l S4

704.2 A2

REPAIR MUST REMAIN GFCI\

940 MADISON STREET
623

JPMC 305.3

UTILITY ROOM-CEILll\G-HOLE ··:REPAIR

624.

!PMC 605.1

UTILITY -ROOM - NO EMERGENCY BACKUP LIGHT - PROVIDE

625.

IPMC 604.3 Bl

DINl"i\'G ROOM - OUTLET - COVER PLATE CRACKED - REPLACE

626.

IPMC 604.3 B 1

1sr BEDROOM - OUTLET - PLATE COVER - PROVIDE

627.

IPMC 604.3 Bl

LIVING ROOM - OUTLET AT WTNDOW - DEFECTIVE- REPLACE

628.

IPMC 305.3 B 1

BATHROOM- CEILING- WATER DAMAGE- REPAIR- PREPARE Ar--;D PAINT

629.

IPMC 305.1 Bl

BATHROOM - TOILET PAPER HOLDER - PROVIDE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 63 of 146

Exhibit F

630.

IP\1C 305.1 Bl

BA Tl IROOM - SOAP DISI ! IN SHOWER - PROVIDE

631.

lPMC 704.2 Bl

BEDROOM - NO SMOKE DETECTOR- PROVIDE ELECTRIC SMOKE DETECTOR

632.

IPMC 604.3 B1

MASTER BEDROOM - OUTLET - COVER PLATE - PROVIDE

6.).)
....... .

IPMC 704.2 B2

HALLWAY- ELECTRIC SMOKE DETECTOR- :\'OT SOCNDING-PROVIDE ELECTRIC SMOKE DETECTOR

634.

IPMC 704.2 B2

ALL SMOKE DETECTORS ARE ADA - NOT SOVNDING- REPAIR/REPLACE

635.

IPMC 702.3 B2

l ST BEDROOM - DOOR- DEADBOLT - REMOVE - NOT PER:\i!ITTED

636.

IPMC 304.15 B2

i'0 BEDROOM - DOOR HA~DLE - LOOSE -REPAIR

637.

IP:VfC 305.1

638.

IPMC 504.1 B2

BATHROOM- SINK- RECAULK AT WALL

639.

IPMC 305.l B2

KITCHEN - RANGE HOOD - CHIPPING PAINT - REPLACE

640.

IP:vf C 305 .3 B3

lsT BEDROOM-WALL-DEFECTIVE-REPAIR-PREPARE AND PANT

641.

IPMC 305.4 B3

BEDROOM- FLOOR- DEFECTIVE- REPAIR

642.

IPMC 603.1 Sl

KITCHEN - STOVE - LEFT SIDE BURNERS - DEFECTIVE - REPAIR/REPLACE

643.

IPMC 704.2 Sl

HALLWAY-ELECTRIC S~10KE DETECTOR-\!0 POWER-REPAIR/REPLACE

644.

lPMC 704.2 S2

HAI .L WAY - ELECTRIC SMOKE DETECTOR- NOT SOUNDfNG- PROVIDE ELECTRIC SMOKE DETECTOR

645.

IPMC 305.l S2

KITCHEN- CABINET DOOR BY REFRIGERATOR- DEFECTIVE - REPAIR/REPLACE

646.

IPMC 603.l S2

KITCHEN- STOVE LEFT FRONT BURNER - DEFECTIVE -REPAIRJREPLACE

647.

IPMC 604.3 S3

KITCHEN - GFCI - REPLACE - MUST REMAIN GFCI

B2

BA Tl IROOM - LIGHT BULB - DEFECTIVE - REPLACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 64 of 146

Exhibit F

648.

IPMC 704.2 S3

LOW BAITERY CHfRP- PROVIDE BAITERIES

649.

lRC

NO CO DETECTOR N CNIT - PROVIDE

650.

IPMC 305.3 S3

BATHROOM-CEILJ~G- REPAIR,- PREPARE AND PAINT

651.

IP.MC 704.2 S4

IIALLWA Y --ELECTRIC SMOKE DETECTOR·. ~OT SOUNDING-PROVIDE ELECTRJC SMOKE
DETECTOR

652.

IPMC 603.1 S4

KITCHEN- STOVE - RIGHT FRONT BURNER- DEFECTIVE - REPAIR/REPLACE

653.

IPMC 305.4 S4

KITCHEN - FLOOR - REPAIR

654.

fPMC 603.l Al

KITCHEN -STOVE- LEFT REAR BUR.\ER-DEfECTIVE-REPAIR/REPLACE

655.

IPMC 704.2 Al

BOTH BEDROOMS - SMOKE DETECTORS - NOT WORKING- PROVIDE ELECTRIC SMOKE DETECTOR

656.

IPMC 704.2 A2

2>Jr> BEDROOM - SMOKE DETECTOR - NOT WORKING- PROVIDE ELECTRIC SMOKE DETECTOR

657.

IP.'.\1C 702.3 A2

BOTH BEDROOMS - DOORS - KEY LOCKS - REMOVE - :'.'JOT PERMITTED

658.

IP~C 305.3 A3

BATHROOM - CEILING- VERMIN - REPAIR

659.

IPMC 304.14 A3

\VIN DOWS - PROVIDE SCREENS

660.

IPMC 604.3 A3

KITCHEN - GFCI LEFT WALL - HOT/NEUTRAL REVERSE - REPLACE - MUST REMAE\ GFCl

661.

JPMC 704.2 A3

ALL SMOKE DETECTORS - NOT WORKl>JG - PROVIDE ELECTRIC SMOKE DETECTORS

662.

JPMC 704.2 A4

HALLWAY - ELECTRIC SY10KE DETECTOR - LOW DECIBEL - REPLACE MCST REMAIN ELECTRIC

315.J S3

910 ,WAD/SON STREET

663.

IPMC 704.2

1sr FLOOR- HALLWAY - SMOKE DETECTOR - LOOSE - REPAIR

664.

IPMC 704.2 B 1

HALLWAY -ELECTRIC SMOKE DETECTOR- REMOVED - PROVIDE ELECTRIC SMOKE DETECTOR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 65 of 146

Exhibit F

665.

IPMC 704.2 Bl

1s-r & 2~n BEDROOM··- SMOKE DETECTOR · DEFECTIVE - PROVIDE ELECTRIC SMOKE DETECTOR

666.

IPMC 704.2 Bl

.v1ASTER BEDROOM - SMOKE DETECTOR ·· NOT SOC1'DING - PROVIDE ELECTRIC SMOKE DETECTOR

667.

IPMC 304.3 Bl

ENTRANCE DOOR - PROVIDE UJ\IT NC'MBER ON DOOR

668.

IPMC 504.1 B2

LIVING ROOM - WASHfNG MACHINE · RE:vlOVE PER MANAGEMEKT

669.

IPMC 605.l

670.

·IPMC 704.2 B2

MASTER BEDR00\1 - SMOKE DETECTOR - DEFECTIVE - PROVIDE ELECTRIC SMOKE DETECTOR

671.

IPMC 304.15 B3

ENTRANCE DOOR - PROV1DE lJ?\"IT NUMBER ON DOOR

672.

IPMC 603.1

673.

IPMC 305.6 B3

BATHROOM - DOOR JAMB - BlJSTER - REPLACE

674.

IPMC 305.3 BJ

HALLWAY- WALL AT BATHROOM - HOI .E - REP i\lR - PREP ARE AND PAINT

675.

IPMC 604.3 B3

Bi\ TIIROOM - SWITCH PLATE -CRACKED - REPLACE.

676.

IPMC 305.3

BASEMENT - COMMO:'.'J HALLWAY - DEFECTIVE - REPAIR - PREPARE A1':D P!\l!\T

677.

IPMC 704.1

BASEMEKT - COMMON AREA - FIRE EXTINGUISHER - REMOVED - PROVIDE

678.

IPMC 702.3

UTILITY ROOM - )JO KEY - SOMETHING BROKEN OFF IN LOCK - REPAIR - PROVIDE ACCESS

679.

lPMC 704.2 Sl

ENTIRE UNIT - SMOKE DETECTORS - MISSING- PROVIDE ELECTRIC SMOKE DETECTORS

680.

IPMC 704.2 Sl

HALLWAY - ELECTRIC SMOKE DETECTOR- NOT SOUNDING -PROVIDE ELECTRIC SMOKE DETECTOR

· 681.

IPMC 704.2 S2

i'u BEDROOM - SMOKE DETECTOR - DISCONNECTED - PROV1DE ELECTRIC SMOKE DETECTOR

682.

IPMC 504.I S2

KITC:HEN - SINK FAUCET - PROVIDE AERATOR

683.

IPMC 704.2 S3

HALLWAY -- ELECTRIC SMOKE DETECTOR - REMOVED·- PROVIDE ELECTRIC SMOKE DETECTOR

B2

83

HALLWAY - LIGHT- DEFECTIVE- REPAIR/REPLACE

BATHROOM - GFCI - DEfECTIVE - REPLACE - ML'ST REMAfl'.:' GFCI

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 66 of 146

Exhibit F

684.

IP.\1C 305.3 S3

BATl !ROOM - CEILING - DEFECTIVE - REPAIR - PREPARE A'.\"D PAINT

685.

TPMC 402.3 S3

BA TH ROOM - VE~T FAN - DEFECTIVE - REPAIR/REPLACE

686.

IPMC 704.2 S3

BEDROOMS - NO BEDROOM SMOKE DETECTORS- PROVIDE ELECTRIC SMOKE DETECTOR

687.

IPMC 604.3 S4

KITCHEN - GFCI TO LEFT OF SIN'K- NOT WORKTNG - REPLACE- MUST REMAll\" GFCl

688.

IPMC 704.2 J\1

BEDROOMS - PROVIDE ELECTRIC S~OKE DETECTORS

689.

IPMC 704.2 J\2

2:-:o BEDROOM - SMOKE DETECTOR - NOT WORKING - PROVIDE ELECTRIC SMOKE DETECTOR

690.

IPMC 504.1 A3

BATHROOM- nm- RECAULK\

69L

TPMC 704.2 A3

BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTOR

692.

lPMC 304.14 A3

WINDOWS - S.CREENS PROVIDE

693.

JPMC 605.1/704.2

A3

694.

IPMC 704.2 A4

HALLWAY - ELECTRIC SMOKE DETECTOR - NOT WORKING - PROVIDE ELECTRIC SMOKE DETECTOR

695.

lPMC 305.4 A4

KITCHEN - FLOOR AT REFRlGERATOR- REPAIR

HALI.WAY - LIGHT-REPAIR- PROVIDE ELECTRIC SMOKE DETECTORS

920 MADISON STREET
696.

IPMC 604.1 BI

NO ELECTRIC IN UNIT - V ACAl'JT ACCORDING TO RESIDE:\"TS NEXT DOOR

697.

TPMC 704.2 B2

BEDROOMS - PROVIDE ELECTRIC SMOKJ: DETECTORS

698.

IPMC 305.3 B3

MASTER BEDROOM - WALL - DEFECTIVE - REPAIR - PREP ARE AND PAINT

699.

TPMC 605.3 B3

IIALLWA Y - LIGHT GLOBE- PROVIDE

700.

IPMC 305.3 B3

BATHROOM-CEILING- FLAKTNG PAINT- REPAIR- PREPARE AND PAINT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 67 of 146

Exhibit F

701.

lPMC 603. l B3

KITCHEN - STOVE - LEFT FRONT BUR;-JER- DEFECTIVE- REPAIR/REPLACE

702.

IPMC 305.3 B3

KITCHEN - WALL AT STOVE- DEFECTIVE - REPAIR - PREPARE AND PAG\T

703.

IPMC 704.2 Sl

SMOKE DECTORS - THROUGHOCT - NOT WORKf.'.JG - PROVIDE ELECTRIC S\10KE DETECTOR

704.

lPMC 603.1

705.

IPMC 304.14 SI

WINDOW - SCREENS - PROVIDE

706.

IPMC 704.2 S2

BEDROOM - SMOKE DECTORS - NO BATTERIES - PROVIDE ELECTRIC SMOKE DETECTOR

707.

IPMC 305.3 S2

BATHROOM -CEILING- REPAIR - PREPARE ANO PAINT

708.

IPMC 603. l S2

FURNACE ROOM- BIRD'S NEST - RE:V10VE- PROVIDE SCREENS

709.

IPMC 603.1 S2

FURNACE ROOM - FLUE PIPE - RUSTED - REPLACE

710.

IPMC 305.3 S2

FURNANCE ROOM- CEILING BY FLUE PIPE- HOLE- REPAIR

711.

IPMC 704.2 S3

VACANT - NO POWER- REHAB- PROVIDE ELECTRIC SYlOKE & CO DETECTORS

712.

IPMC 704.2 S4

SMOKE DETECTORS - >JOT WORKING - PROVIDE ELECTRJC SMOKE DETECTORS

713.

lPMC 604.3 S4

KTTCHE:;\- GFCI TO RIGB OF STNK - REPLACE - MUST REMAIN GFCI

714.

IPY!C 704.2 i\l

BEDROOMS - PROVIDE ELECTRIC SY10KE DETECTORS

715.

IPMC 704.2 A2

BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

716.

IPMC 305.1 i\3

POOR HOUSEKEEPING - THROCGHOUT

717.

IPMC 305.3 A3

IIALLWAY-WALL BY 15T BEDROOM-HOLE-REPAIR-PREPARE AND PAI>JT

718.

IPMC 604.3 i\3

OUTLET COVER - PROVIDE

719.

IPMC 305.3 A3

ls,- BEDROOM-- WALLS-PREPARE AND PAINT

SI

FURNACE ROOM - BIRD'S NEST - REMOVE- CLEAN OCT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 68 of 146

Exhibit F

720.

IP~C 704.2 A3

1sT BEDROOM - SMOKE DETECTOR- KOT WORKING - PROVIDE ELECTRIC S:\IIOKF. DETECTOR

721.

IPMC 305.1 A4

KITCHNE- CABNET FRONTS - PROVIDE

722.

lPMC 604.3 A4

BATHROOM - GFCI- NOT WORKING - REPLACE MUST REMAIN GFCI

723.

IPMC 304.14 A4

WINDOWS - PROVIDE SCREEKS
930 lefADJSON STREET

724.

IPMC 305.l

CTILITY ROOM- WATER SEEPAGE INTO THE FLOOR FROM THE BLOCK WALLS-REPAIR

725.

IPMC 304.15 Bl

ENTRANCE DOOR- PROVIDE UNIT NUMBER 0~ DOOR

726.

IPMC 704.2 B1

ALL BEDROOMS - PROVIDE ELECTRIC SMOKE DETECTORS

727.

JPMC 305.1 Bl

MASTER BATHROOM - SINK - SOAP DISI I - PROVIDE

728.

IPMC 704.2 B2

1sr BEDROOM - S:\IIOKE DETECTOR- NOT SOUNDING - PROVIDE ELECTRIC S'.MOKE DETECTOR

729.

IPMC 305.3 B2

BATHROOM-CElI.lNG- FLAKING PAINT-REPAlR-PREPARE AND PAINT

730.

IPMC 305.1 B2

BATHROOM - SOAP DISH - PROVIDE AT SINK

731.

IPMC 504.l B2

BATHROOM - TUB - RECAULK

732.

fPMC 704.2 B3

HALLWAY -- ELECTRIC S:\10KE DETECTOR - REMOVE - PROVIDE ELECTRIC SMOKE DETECTOR

733.

IRC

734.

IPMC 704.2 B3

BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

735.

IPMC 604.3 B3

KITCHEN - GFCI AT SINK - OPEN GROUND- REPLACE- MCST REMAIN GFCI

736.

IPMC 603.1

315.1 B3

B3

KO CO DETECTOR IN THE UNIT - PROVIDE lN HALL Wi\ Y AREA

FURNACE ROOM - DEBRIS - REMOVE - PROVIDE SCREENS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 69 of 146

Exhibit F

737.

1PMC 504.1 S1

BATHROOM - TOILET TANK LID - BROKN- REPLACE

738.

IPMC 402.3 SI

BATRH00\1- VENT FAN - NOT WORKNG - REPAIRJREPLACE

739.

IPMC 604.3 SI

1ST BATl IROOM - GFCl - REPLACE - MUST REMAIN GFCI

740.

IPMC 604.3 Sl

KITCHE:-.J - GFCI - REPLACE - MUST REMAIN GFCI

741.

lPMC 305.1 S1

KITCHE;-,.I -CABNET DOOR - BROKEN - REPAIR/REPLACE

742.

IPMC 603.1 SJ

FURNACE ROOM - CLEAN OUT DEBRIS

743.

IPMC 603.i S2

FVR.."i\CE ROOM - FLUE PIPE- RCSTED- REPLACE

744.

lPMC 603.1 S2

FUR);'ACE R00\1- BIRD'S NEST - REY10VE - CLEAN OUT - PROVIDE SCREEN

745.

fPMC 704.2 S3

BEDR00\1 - >JO S).10KE DETECTOR - PROVIDE ELECTRIC SMOKE DETECTOR

746.

lPMC 603.1 S3

FUR~ACE ROOM - BIRD'S NEST - REYIOVE - CLEA~ OUT - PROVIDE SCRRE:--J

747.

IPMC 704.2 S3

LOW BATTERY CHIRP- PROVlDE BATTERIES

748.

IPMC 704.2 S4

LOW BATTERY CHIRP-PROVIDE BATTERIES

749.

IPMC 704.2 S4

BEDROOM - NO SMOKE DETECTOR - PROVIDE ELECTRIC SMOKE DETECTOR

750.

IPMC 603.1 S4

FURNACE ROOM - BIRD'S NEST - REMOVE - CLEAN OUT - PROVIDE SCREE~

751.

IPMC 304.14 Al

LIVING ROOM - SCREEN - MISSING - PROVIDE

752.

1PMC 604.3 Al

LIVING ROOM - OUTLET MISSING COVER PLATE - PROVIDE

753.

IPMC 504.1 Al

BATHROOM - TOILET - BROKEN - REPAIR/REPLACE

754.

IPMC 704.2 Al

HALL W/\ Y - ELECTRIC SMOKE DETECTOR- NOT WORKING - PROVIDE ELECTRIC SMOKE DETECTOR

755.

IPMC 704.2 Al

ALL BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 70 of 146

Exhibit F

756.

1P\1C 305.3 A 1

2'1) BEDR00\1 - \\.:\I.I. - I IOT.E ··· REPAIR - PREP:\RE A:,..:J) PAl\:T

757.

IP!\.1C 704.2 :\2

BEDR00\1 - NO S\:10KE DETECTOR

758.

IPMC 504.1 t\2

BATHROOM - TOIi.ET SE/\ T - DEFECTIVE

759.

IPMC 304.14A~

WINDOWS - SCREENS - MISSING - PROVIDE

760.

IPMC 504.1 A3

BATHROOM

761.

IPMC 305.3 A3

BAfHR00\.1 - CE!l .J::\G- REPAIR - PREPARE A);D PAINT

762.

IP).,lC 50..J..l l\3

BATIIROO:-Vt

763.

NFPA

A3

764.

IP\1C 305.1 A3

AIR CONDITIONING BOX - BROKE~ - REPA[R1REPLACE

765.

IPMC 704.2 /\4

BEDROOM · NO SMOKE DETECTOR - PROVIDE ELECTRIC S\10KE DETECTOR

766.

IPMC 402.3

BATHR00\1 - VE:\"T FANS - ALL CLOGGED - CLEAN OUT Tl IROCGHOUT COMPLEX

767.

IPMC 704.2/70..J..3

ALL L:\"ITS · PROVIDE ELECTRIC 1IARDWIRED SMOKE DETECTORS IN ALL SLEEPTNG R00\1S -··
ELECTRIC\!. PER\1lT WILL BE REQl TIRED

768.

IRC

ALL l.l:'\ITS - PROVIDE CO DETECTORS ON THE LEVEL OF TIIE SLEEP~G ROOMS

769.

IP:VlC 304.14

ALL UNITS - WINDO\VS - SCREENS - PROVIDE

770.

IPMC 302. l

EXTERIOR - GROlJNDS - CLEAN UP TRASI I THROUGBOCT COMMON AREAS

771.

IPMC 302. l

INTERIOR· CO.Ylr-.·10N HALL \Vi\ YS -NEED TO BE CLEA'.':ED DAILY IN ,-\I.L BlHLDINGS

77'2.

:,..:FPA 10.11.6.1&2

BALCO'.':Y - (iRlLl.S - >JOT PER\fffTED TO BE CSED ON ANY LEVEL ABOVE GROCND LEVEi.

773.

:-:FPA 10.11.6.1&2

GROl"'.':D LEVEL - CiRIU.S-· CAN BE STORED O\" PATIO AREA BUT\-1CST BE CSED 15FT FRO~vt BUILDINGS

10.11.6

315.1

PROVJOE

ELECTRIC S\10KE DETECTOR

REPLACE

SINK AT WALL - RECAULK

TU3 -- N"EEDS TO I !AVE PORCEL:\I~ P.-\l\"T OR REPLACED

(,RILL():( BAI.CONY - NOT Pl~R\1ITlED O\" THIS LEVEL - REMOVE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 71 of 146
774.

IP;v1C 604.3

Exhibit F

ALL KITCIIE~- REFRIGER.-\ TORS RC;\\T\G O:'\ GFCI -);OT TO CODE PROVIDF REGU.AR Ol "TLETS FOR
THE REFRJGERATORS

All. ELECTRJC4L. MECHAl\'/CAL, BC:ILDiiVG ASD PLCJ,fBING WORK WILL REQCIRE PERMITS TO DO THE WORK A..ro..JJ Ffi'\/AL
INSPECTIONS OlV THESE ITEMS WILL BE CONDUCTED BY TIIE CITY OF ANNAPOLIS INSPECTORS FOR Tl/AT TRADE -ANY
Ql "EST/0.1\"S, PLEASE FEEL FREE TO COSTA CT US AT 410-263-7946

REINSPECT/ON SCHEDULED ON OCTOBER 31-NOVEMER 4, 2016.AT 9:30 A.M.

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 72 of 146

Exhibit F

CITY OF A:'i:'\APOLIS
PROPERTY '.\IAI:'iTE:'iA:'iCE CORRECTIO:'i :'iOTJCF. RE:'iTl605-019
PROPERTY ADDRESS:

701 GLE:'iWOOD STREET

PROPERTY OW:'\F.R:

A\~Al'OL!S l IOCSING ,\Fri IORITY
C.O /.E\A S/\C";s;DERS
701 Cil.E\WOOD STRl:ET
A'\'\APOI.lS. :',1[) 21401

DATE OF I:\"SPECTIO:'i: :';1AY 2-4.2016
l'.\SPECTIO:'i TYPE:
A\~Al;L
I!'>SPECTOR:
\1.-\RY E\1RICK. /\DA:';1 K\!Cil IT. VER'\O\ BROOKS. STEVE ANDREWS & Hl-:1':RY Gl TIERREi'.
VlOLATION(S)

\:o.

Code Re[

\."nit

I.

JP\lC 604.3 802

KITCI IE\ - REFRIGERATOR· CA:-S\"OT Bl: PL\ ·c;GED 1:-.:TO (if Cl Ol"TLFI - PRO\'IDE Ot:TI.ET

11'\lC 504.1 802

BATIIR00\1- TOILET - \OT \\'ORKI\G - REP,\IR l\1T\1EDL\TEL Y

3.

IP\1C 305.6 802

CLOSET DOORS AT ELECTRICAL PANEL - DEFECTIVE -REP.\IR/REP!.:\CE

4.

IP!\!C 305.6 802

CLOSET DOOR K\OBS · DEFFCTIVl'-REPAIRiREPLACE

5.

ll'MC 605.1 802

MISSING 1.IGHT -· BY !!ALL WAY CLOSET ARE,\ - PROVIDE

6.

IP\lC 603.l 805

KITCH ES - STOVE ··LEFT FRO\T BURNER - DEFECTIVE - REPAIRiREPI.ACE

7.

IP'.vlC 504.1 805

B:\Tl !ROOM - SI 10\\'ER - DIVERTl:R - DEFECTIVE - REPLACE

8.

11'\IC 305.3 805

BATI!ROOt-1- TILE WORK- DEFECTIVE - REPAIR

9.

11'\!C 603.1 806

KITCl!EN · STOVE - REAR RIGHT BUR\FR- DEFECTl\'E- REPJ\JR/REPI.ACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 73 of 146

Exhibit F

iO.

IP:V1C 704.2 808

BEDR00?'-.1/S - PROVIDE HA.RDWlRED SMOKE DETECTORS - ELECTRJCAL PERMIT REQUIRED

I 1.

IPMC 603.1 809

KITCHEN - RJGHT FRO:'-iT BL'R.c"ER- DEFECTIVE -REPAIR/REPLACE

12.

IPMC 604.3 809

ELECTRJCAL OUTLETS - PAINTED OVER- REPLACE

13.

IPMC 704.2 810

BEDROOM!S - PROVIDE HARDWIRED SMOKE DETECTORS- ELECTRJCAL PERJ\1IT REQUIRED

14.

lPMC 305.1 813

KITCHEi\ - REFRJGERA.TOR- DOOR SEAL- DEFECTIVE- REPAIR/REPLACE

15.

IPMC 704.2 813

BEDROO:Vt'S - PROVIDE HARD\vlRED SMOKE DETECTORS - ELECTRJCAL PER.c'vl!T REQUIRED

16.

lPMC 704.2 815

BEDROO:VVS- PROVIDE HARDWIRE_D S:\10KE DETECTOR- ELECTRJC:\L PER.c\1IT REQUIRED

17.

IPMC 604.3 817

KITCHEN - GFCI - PAINTED OVER- REPLACE- MUST REM.~ GFCI

18.

IPMC 305.1 817

KITCHEN-DR.c.\\VERFRONTS-PROVIDE

19.

IPMC 304.13.2(817) WINDOWS - WILL ;\'OT STAY OPEN 0'.'J THEIR 0\\,"?-iER - REPLACE

20.

IPMC 603.l 818

KJTCHE:'-i - STOVE - REAR RIGHT BURNER - DEFECTIVE -REPAIR/REPLACE

2 l.

IPMC 305.3 818

CEILING AREAS - DRYW ..c\LL - PAI:-(T - THROUGHOUT

22.

!PMC 604.3 819

KITCHEN & BATH - GFCJ"S - TRJPPING- REPLACE- MUST REMAI:'-i GFC!"S

-J.

IPMC 603.1 700

KJTCHEN - STOVE- RIGHT SIDE BUR.c"\:ERS - DEFECTIVE -REPAIR/REPLACE

24.

IPMC 604.3 700

KJTCHEN - GFCI - DEFECTIVE -REPLACE - MUST REMAI:'-i GFCI

..,-

_)_

IPMC 304.2 700

EA'TERIOR- STUCCO CEILING- DEFECTIVE- REPAIR

26.

IPMC 504. l 700

BATHROOM - SHOWER/TUB - REGROUT

27.

IPMC 603.1 705

KITCHEN - STOVE- LEANS TO ONE SIDE- LEVEL STOVE

28.

IPMC 604.3 705

KITCHEN - GFCI - PAINTED OVER - REPLACE - MUST RE:Vi.\l?-J GFCI

..,,

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 74 of 146

K\OB

Exhibit F

29.

11''.\lC 305.6 705

InTlIR00\1

1.1\E:,( CLOSET

LOOSE - SECLRI'

30.

IP'.\IC 504.1

705

BATJ !ROO'v!

TOILET RC\S CO\TJ:\l-OCSI.Y - REP.-\IR

31.

JP\lC 305.3 705

BATllR00!-.1

WALL & CEIL!'.\:(i /\BOVE SHOWER- WATER DAMAGE - REPAIR

J--

,.,.

J!'MC 504.1 705

BAT! !ROOM ·- SHOWER- DIVERTER- DEFECTIVE

33.

IP'.\>IC 504.1 705

BATJ IR00'.\1 - SHOWER DIVERTER- DEFECTIVE - PLCMB!NG PER\11TS REQUIRED

34.

IP\1C 304.10 705

BA!.CO\Y - CO);CRETE - DEFI·:CrIVE - REPAIR

35.

IP\IC 304. I 4 705

BAI.CO'-:Y SCREE:\ DOOR - SCREE'-: TOR\ - REPAIR·RFPL\CE

36.

ll'\IC 30..\.15 705

lt\l.CONY SCREEN DOOR

37.

!!'MC 504. J 708

BATllROOM -TUB-REC!\ULK

38.

IPMC 504. l 708

B.-\TI !R00:\1 · TOILET · Rl');S CONTT:\1.'01.SL Y - REPAIR

39.

Il'\!C 305.3 708

B.-\TI !R( )OM - WALL & CEIL!:\G AROl '\D SI JOWER I IL\D - \\.A!ER D:\\L\GI·: - RU'.-\IR - PREPARE AND
PAINT

40.

11'.\.!C 504. i 708

BAT! !ROOM- SECL'RE SINK TO WALL & RECA\ ILK ALO~G Tl !IS AREA

..\1.

IP\.1C 704.2 708

BEDROO'.\J/S

42.

lP\.IC 304.12 708

B..\I.CO:\Y - RAl!.1\"G - LOOSE - SECtRE

..\3.

!J>l'v1C 504.1 708

KITCI!E\" - Sl\"K - FACCET- DRIPPI);G -· REPAIRIREPL\CE

44.

IPMC 305.3 707

BATI!ROOM - WALi. &. CE!Lf\"G - REP!\IR-· l'REPARE AKD PAINT

45.

IPMC 504.1 707

BATl!R00\1 -Sl!OWER/TlJB- RECAUI.K

46.

l!''.\1C 50..\.1 707

KITCl!E'-: - SI:>JK FAl.:CET

PREPARE A\D PAINT

SPRT:\G .-\RM·· DEFECTIVE - REPLi\CE

PROVIDE IIARDWIRED S\10KE DETECTOR

DRIPS

RFPAIR.'REPL!\CE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 75 of 146

47.

IP\lC 70-..2 712

BEDROO\,JiS

1ST

48.

IP'.\lC 70-t.2 71.,

BEDR00\1·S

PROVIDE lL\RD\\'lRfl) S\10KE DETECTOR

-.9.

IP\IC 305.3 715

KlTCllE\ - \V.-\Ll. - VOlD

50.

IPMC 704.2 715

BEDR00\11S

51.

lPMC 604.3 716

BATl!R00\1 ·- PROVIDE GFC'l OUTLET- ELECTRIC/\!. PERMIT REQL:lRI'D

52.

11'\lC 603.1

53.

!P\JC 604.~ 719

B,\Tl!R00\·1- Ol"TLET P,\I\TFD OVER - PROV!])E GFCl - El.ECTRlC\l. PER:\11T REQL'IRED

54.

IP\1C 603.1 720

KITCI IE:,;

55.

IP\1C 604.3 722

KITCI !EN --Ol :TI.ETS - PAl:'-:TEJ) OVI'R- REPLACI; -PROVIDE UF(TS BY SINK ARE/\ · ELECTRICAL PERMIT

718

KITCI IE:,;

S\-10KE DE !"ECTOR

Exhibit F

NOT\\ ORKI\G -PRO\"IDE ll.-\RD\VIRFD S\10KE DETl:CTOR

REPAIR - PREPARE A\D PAl:--JT

PROVIDE II,\RDW!RED SMOKE DETECTOR

STOVE -- REAR R!GllT B\jRNER · DEFECTIVE - Rl'P.-\IR.'Rl'PLACE

STOVE - LEFT REi\R Bt:RNER -- DEFECTIVE -REPAIR.'REPLACE

lffQURFD
56.

IP\lC 305.3

\lAlNTEN.-\CE CLOSET IN C0\1\10\ AREA -- HOLES I\ CE!LI\G- REl'AlR \\'!Tl! flRE RATED DRY\\ ALL

57.

IP:v1C 305.1 600

POOR HOUSEKEEPING - TE:S:A:'-:T"S RESPO\SIBlLITY

58.

IP:V1C 704.1

59.

IP\1C 604J 600

KlTCI !EN - POWER STRIP&. EXTE\SION CORDS - REMOVE

60.

IP:\lC 504.1 600

B.-\Tl !R00\1- WALL TILES - DEFECTIVE AT BOTT0\1 EDGE - RFPAJR.'RI-:PLACE

61.

IPMC 50-..1 600

B,\TIIR00'.\1 · TOILET RCNS CO\TINCOCS!.Y - REPAIR

(1].

IPMC 504.1

BAT! !ROOM - TUB - RECAl.l.K

63.

lPMC 305.1 600

BATllR00\1- WALL & CEil.ING AREA

6-..

!Pt-.1C 604.3 603

KITCJ IE:,; - GFCI - DEFECTIVE - REPLACE- '.\lt'ST RE\1A!\' GFCI

600

600

FIRE SL'PPRESSION Ll\E- WE RE\10VED !!ANGER - CANNOT PUT Tlll'.'JGS ll/1\:Gli\'G OK THESE PIPES
\OT PER:VllTfED - PROVIDE OUTLETS

WORKING ON- REPAIR-- PREPARE AND PAINT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 76 of 146

65.

lP\lC :io4.15 603

66.

IP\1C 30-1.13.1 (607) W[;\l)O\\'S - \\'ILL :\OT OPE)';· FIRE I 1'\ZARD - REPLACE

F'sTR,\'-:('l: DOOR - RI·:PI..-\CE

IP\1C 30-1.15 607

Fi':TRJ\;\CE DOOR - Sl'AL -- DEFECTIVE - PROVIDE

8.

ll':V1C 305.1 612

KITCIIE\' - SINK .. LOOSE

.

!P:VlC 704.'.'. 61'.'.

BEDROOMIS - PROVIDE HARDWIRED SMOKE DETECTORS

IP\1C 60-U 613

KITCI lE:\ - Gl'Cl - REPLACE - 'v1l."ST RE\1AI!\ GIT!

IP\!C 305.3 613

Ll\'I\'G R00\1 AREA - VOID I\' W,\I.L - REPAIR - PREPARE A:\D l'Al\'T

IP:VlC 605.l 613

BEDR00\1 - WIRE \10t;LD1:\'Ci -· COVERED

IPMC 504.1 613

BAT! !ROOM -- TOil.ET Rl.'\'S CONTl\'COCSLY - REPAIR

JP:-.1C 605.3 613

I .!GI IT - l'ROVlDE GLOBE

JP\1C 605.1 615

KITC'I IE:-1 - REFRJ(iER,\TOR PI.l1GGED !:\TO GFCI- PROVIDE REGl."LAR QI 'Tl.ET

IP:-.-!C 305.l

POOR HOl 'SEKC:EPI'.\Ci-TE\':\\T"S RESPO:\SIBll.lTY - PIIOTOS TAKE\

616

Exhibit F

SECL:RE TO WAI.I.

ll'\1C 603. l 617

KIT('! !EN - STOVE - BL;R;\l:RS - WILL :\OT UGI IT - REPA!R'REl'l.ACE

78.

!PMC 305.3 618

BA TJIROOM

79.

IP\1C 305.l 618

POOR HOL:SEKEEPING- TENANT'S RESPONSIBILITY - PHOTOS TAKE!'-'

80.

!Pf\lC 604.3 619

BATHROOM ..-6 WAY EXTE:\SJO;'J FR0\1 BATl!R00:-.1 TO LJV!'.\G ROO:'vl- RE\10\'E -- :\OT PER\l!TlTD

81.

IP\1C 603.1 620

KITCIIE:\ - STOVE - BL"l{:\ERS- NOT \\'ORKI:\Ci-REPAJR•REPL\CE

lQ.

IPMC -103.1 611

B.-\ T!lROOM

:V10!.DiMILDEW - CLEAN

VE:\T - NOT WORKI'.\G - CLEAN AND REPAIR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 77 of 146

Exhibit F

S3.

IPMC 304 .. 15 62]

STOR}vl DOOR - M!SSlNG WrNODW SECT!O;'i - PROVIDE

84.

IPMC 305.1 503

POOR HOUSEKEEPING- TENANT'S RESPOi\'S!BILITY - STOR..-\GE Oi\' BALCONY Ai'iD THROUGH OCT

85.

!PMC 704 . 2 503

BEDR00'.\1/S - PROVIDE HARDWIRED SMOKE DETECTOR

86.

!PMC 702.3 503

BEDR00'.\1 - DOOR- KEY LOCK- REMOVE -NOT PERMITTED

87.

IP'.'v1C 603.1 504

K!TCHEi\' - STOVE - RJGHT FR0"1T Bt.:R..,ER- DEFECTIVE - REPAIR/REPLACE

88 .

!PMC 605.2 505

BATHR.OOM - PROVIDE GFC! OUTLET

89.

IPMC 605 . 3 506

L!Vf.\:G ROOM AR.EA - PROVIDE LIGHT GLOBE

90.

!P:'>1C 305.3 506

BATHROO:\'l - CE!LlNG- REPAIR- PREPARE AND PAli\'T

91.

IPMC 604.3 509

BATHROOM - PROVIDE GFCI - OUTLET PA11'TED OVER- ELECTRICAL PER..Vf!T REQUIRED

92.

IPMC 603.1 513

KITCHEN - STOVE - REAR LEFT BURNER- DEFECTIVE - REPAIR/REPLACE

93.

rp:,_,rc 504.1 514

BATHROOM- SHOWER- DIVERTER - DEFECTIVE- PLUMBING PERMIT REQUIRED

94.

IP:VlC 605.1 515

KITCHEN - REFR.JGER.ATOR PLUGGED lNTO GFCI- PROVIDE REGULAR OUTLET

95 ..

IP:--.1C 50-U 516

BATHROOM - SHOWER AREA - :--:O WATER PRESSURE

96 .

IP:--.1C 305.1 517

BATHROOM - CEILING - WATER DA!vL..\GE - REPAIR- PREPARE Al"\JD PAINT

97 .

!PMC 702 . 1 517

HA.LL \VAY - PROVIDE 36.... CLEAR PATH AT ALL TIMES

98 .

IPMC 603 . l 518

KITCHEN - VENT - FALLING OCT OF CEILING - PATCH - REPAIR - PREPARE AND PA.INT

99.

!PMC 603.l 519

KITCHEN - STOVE - R.JGHT FR.ONT BURNERS - DEFECTIVE -REPAIR/REPLACE

100 .

IPMC 504 . l 520

KITCHEN - FAUCET - RUST COMES OUT OF \VATER LIN'E - REPAIR- WATER

101.

IPMC 305.3 522

KITCHEN- VENT-FLAKING PAINT-REPAIR-PREPARE AJ."iD PAL"-JT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 78 of 146

Exhibit F

102.

[P'vfC 403.2 522

BATHROOM-· VE))T - CIIA'sGE OUT TO CONTI'sCOL:SL Y OPEN

103.

!P\1C 304.18.2 (522JBEDROOM - WINDOW - WON'T STAY OPEN BY ITSELF - REPAIR/REPLACE

104.

IP\1C 704.1 522

FIRE SUPPRESSION LINE- RE\,10VE CABLE WIRE 01' THIS·· NOTlllNG SHOL:Ll) BE ON THESE LINES

105.

IPMC 404.5 522

TENANT \"FEDS TO BE MOVED INTO A TWO BEDROOM t:NIT

106.

IPMC 305.1 401

POOR l!Ol;SEKEEPl>lG- GREASE ll\' KITCHEN AREA -- CLEAN WAI.LS & STOVE AREA.S

l 07.

IPMC 603.1 402

KITCHEN · STOVE- RIGHT REAR BURNER- DEFECTIVE-· REPAIR/REPLACE

108.

!PMC 309.1 402

EXERMINATE- ROACHES

109.

IP:'v1C 605.2 402

BATHROOM - PROVIDE GFCI

110.

!PMC 305.3 402

BATHROOM - WALL & CEILING AREA· WATER DAMAGE- REPAIR- PREPARE AND PAINT

I I l.

IP\1C 305.3 402

BATHROOM- WALL AT TOILET - WATER DAMAGE-- REPAIR- PREPARE AND PAINT

1 J2.

JP\1C 605.2 403

K[TCHEN - PROVIDE GFC[ OUTLET AT SI:\K AREA- ELECTRJCAL PER'vfIT REQUIRED

I 13.

[P\,!C 504.1 405

BATHROOM - I.OW WATER PRESSURE

J 14.

[P\1C 603.l 406

KITCHEN - STOVE-GAS SHUT OFF - REPAIR

115.

IPMC 305.3 409

BATHROOM- DRYWALL-REPAIR- PREPARE AND PAINT

116.

IPMC 305.l 409

BATllROOM - SHOWER CLJRTAJN ROD- REPLACE

l I 7.

lP'.'vfC 605.I 408

KJTCllEN- STOVE-RUNNING OFF Of EXTENSION CORD-PROVIDE OUTLET-REMOVE CORD.

118.

IPMC 504.l 408

BATHROOM- TOILET RU'.\ CONTINUOUSLY -REPAIR

119.

lPMC 504.1 411

BATHROOM-REGROUTTlLE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 79 of 146

Exhibit F

120.

IP'v1C 603.1 411

KITCHEN - STOVE - REAR LEFT BUR,'\JER - DEFECTIVE - REPAIR/REPLACE

121.

IP\1C 704.2 412

BEDROOM/S - PROVIDE HA.RD WIRED SMOKE DETECTORS

122.

!PMC 504.1 412

BATHROOM-REGROUT TILES IN SHOWER

123.

!PMC 504.l 414

BATHROOM - SHOWER DIVERTER- DEFECTIVE -REPLACE - PLUMBING PER.MIT REQUIRED

124.

lPMC 504.l 413

KITCHEN - SINK CLOGGED- REPAIR !MMED!ATELY

125.

!PMC 304.15 413

ENTR.A.NCE DOOR - REPLACE

126.

!PMC 305.3 413

BATHR00\1- MOLD- REPAfR- PREPARE A'\JD PAINT

127.

IPMC 604.3 416

KITCHEN - GFCI - PAINTED OVER - REPLACE - MUST REMA.IN GFCI

128.

IP\1C 605.2 416

BATHROOM- PROVIDE GFCI

129.

IPMC 305.3 417

BATHROOM- WALL & CEILING- WATER DAMAGE-REPAIR-PREPARE AND PAINT

130.

IPMC 504.1 417

BATHROOM-TOILET RlTNS CONTlNUOCSLY -REPAIR

131.

!PMC 605.2 417

BATHROOM-PROVIDEGFCI

132.

IPMC 304.13 419

WINDOWS - DEFECTIVE - REPLACE

133.

IPMC 504.1 419

BATHROOM- TOILET SEAT -REPLACE

134.

IPMC 305.3 419

BATHROOM-MOLD-REPAIR-PREPAREANDPA!NT

135.

1PMC 403.2 421

KJTCHEN&BATHROOM-'lENTS-BLOCKEDOFF-REPAfR

136.

IPMC 305.6 422

CLOSET DOOR & HA.1'\JDLES -DEFECTIVE- REPAIR/REPLACE

137.

IPMC 504.l 300

KITCHEN-SINK-PROVIDE AERATOR

138.

lPMC 504.1 300

BATHROOM-HA"-:DICAP GRIP BARS-LOOSE-COMING OUT OF TILES-REPAIR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 80 of 146

.mo

Bc\Tl IR00\1- SI 10\\TR CO\TROI. K\OB - LO( >SE - REPAIR REP! .ACE

!39.

JP\lC ~0-1.1

1-10.

11'\lC 3053 302

BAT! IR00\1- VE\T - CO\ll\G 0\ 'l OF CEIL!\(i - REPAlR A\D FIX CE!IJ\(i ARL\ .

1.\ 1.

IP\-!C 50-1. I 302

B,\TI !R00\-1- SI 10\VER,TCB FAlTET - DR!PPI\G - REPAIR

142.

IP\1C 3053 303

R\TllROOM-CFl!J'-!Ci ·- PEl'll\(i PANT - PREPARE /\\D PAI>IT

143.

fl'MC 604.3 303

K!TC! IE\

OUTLET

1-14.

IP:vJC 305.l 304

KITCI JEN

CABINET DRAWERS - NEED FRO\TS

l-15.

IP\1C 603.l

KITCIIEN · STOVE- m;RNERS - DEFITTIVE - REPAIRJREPL\CE

1-16.

IP'vlC 305.1 30-1

B:\Tl!ROOM - TO\\"EL BAR

1-17.

IP:VIC -103.2 30-1

BATIIR00\1- VE:--:T - DEFECTIVE - REP:\lR'REPLACE

1-18.

IP'v!C 50-1.1 30-1

B..\TIIROOM-Sl!OWER/fl'B · REC:\U.K

149.

11':VlC 605.2 304

BATHR00\1- GFCI - PROVIDE- El.ELCTRIC AL PERMIT \VII.I. I3E REQl ilRF:D

150.

fP\1C 305.6 304

HALLWAY --CLOSET DOOR KNOBS·· PROVIDE

J 51.

IP'v!C 704.2 308

BEDROOM/S - SMOKE DETECTOR - PROVIDE

152.

IPMC 605.2 308

B,\TI IROOM- GFCI- PROVIDE

153.

IP\1C 304. l 5 308

STOR\-1 DOOR - PROVIDE H/\\DLE

l 5-1.

lP\1C 605.2 311

B,\TI lR00\1- GFCI - PROVIDE - ELECTRICAL PER:\·IIT REQCIRED

155.

IPMC 604.3 311

KlTCllE::S:- GFCI

156.

IPMC 305.3 31 J

BAT! IROO'v! - CEILI::S:<i - DEFECTIVE - REPAIR - PREPARE A'.\"D PAINT

30-1

Exhibit F

DEFECTIVE

PROVIDE (iFCl

ELECTRICAL PERMIT \VILL BE REQPIRED

\1ISSI\G · PROVIDE

PAl::S:TED OVER - REP:\LCE- :Vll.'ST REJ\·!AIN GFCI- ELECTRICAL PER\-!IT REQCIRFD

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 81 of 146

Exhibit F

157.

IPMC 504.1 311

B..\THR00\1 - TLB- :-,;EEDS PORCELAJ":\ PAINTED OR REPLACED

158.

lPMC 403.2 311

13,\THROOM - VE:,."T- COVERED· REMOVE COVER.ll\G

159.

IPMC 504.1 311

BAT! !R00\1 - TOILET SEAT - DEl'ECTIVE- REPLACE

160.

IPMC 305.1 312

HOCSKEEPING -· THROCGHOUT

161.

IPMC 604.3 312

WALL OUTLETS - COVERED WITH PAPER - REMOVE - l\1AKE SCRE OCTLETS AREl\'T PAINTED OVER REPLACE

162.

IPMC 305.3 314

BATIIROO:V1-CE!Ll:S:G-PEELf.\!G PAINT-REPAIR-PREPARE AND PANT

163.

!PMC 605.2 314

BATHROO:V1 - GFCI - PROVIDE - ELECTRlCAL PERMIT REQUIRED

164.

IPMC 604.3 316

BATIIR00'.\1 & KITC!IE>l - GFCI'S - TRIPPING - REPLACE - MUST REMAIN GFCI - ELECTRlCAL PERMIT

165.

ll'MC 605.2 317

KITCHEN -GFCI - PROVIDE ON ALL COl:'NTER AREAS- ELECTRICAi. PERMIT REQUIRED

166.

IPMC 309.1 322

EXTERMINATE- ROACHES

167.

lPMC 305.3 322

BATI !ROOM - CEILI:\"G BY VENT - DEFECTIVE - REPAIR- PREPARE AND PAINT

167.

IP.MC 304.12 322

BALCONY - HANDRAIL - REATTACH

169.

IPMC 104.2 321

TENANT SICK-PROVIDE ACCESS UPON REINSPECTIO:S: DATE-CHECK SMOKES & GFCl'S

170.

IPMC 504.1 320

BATHROOM - LOWER WATER PRESSURE- CHECK OUT

171.

IPMC 605.2 317

KITCHEN -GFCI - PROVIDE

172.

IP!v!C 603.1 313

KITCHEN - STOVE- RlGHT SIDE BURNERS - DEFECTIVE -REPAIR/REPLACE

173.

IPMC 504.I 313

BATHROOM-SHOWERCORNERS-RECAULK

174.

IPMC 504.1

BATHROOM - RE CAULK TOILFT AT FLOOR AREA

313

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 82 of 146

Exhibit F

175.

lP!\1C 305.3 218

BA THR00'.\1 . CE[LNG - DEFECTIVE - REPAlR - PREPARE AND PAl'sT

176.

IPMC 104.2 213

1\0 ENTRY - KEYS NOT WORKNG - PROVIDE ACCESS UPO's REINSPECTION

177.

IPMC 305.1 215

KlTCJ lE"! - COU'\TERTOPS AT BACKSPLASH -RECAULK

[ 78.

IPMC 504.l 215

KITCHEN - SINK . LEAKING AT TRAP- REPAIR/REPLACE

179.

!PMC 504.1 215

BATHROOM - PROVJDE SHOWER DIVERTER

180.

IPMC 603.1 217

KITCIIE'\ - STOVE LEFT FRO'.\T BUR..'\ER- DEFECTlVE-REPAIRJREP!.ACE

181.

IPMC 603.1 200

K[TCIIEN" - STOVE-· REAR I.EFT BURNER ··DEFECTIVE-REPAIR/REPLACE

182.

IP\1C 305.] 200

KITCHEN - COIDffERTOPS AT BACKSPLASH AREA - RECAULK

l 83.

ll'MC 305.6 200

I !Al .L W/\ Y - CLOSET - KS OBS - PROVIDE

184.

IPMC 403.2 200

BATHROOM- VEl\T - FALLING OCT- REPAIR-PREPARE AND PAJ:\T

185.

IPMC 604.3 201

KITCHE;\ - WALL OCTLET -PAJ?,;TED OVER- REPLACE

186.

lP:V!C 604.3 201

HALLWAY·· OUTLET- PAJ'\TED OVER- ELECTRJCAL PERMIT REQliIRED

187.

!PMC 305.1 203

KJTC!IE"l - CABINET - LOOSE- SECURE TO WALL

188.

IPMC 604.3 203

KITCHEN -- GFCI - LOOSE & REVERSE POLARITY - REPLACE & SECCRE

189.

IPMC 604.3 203

UGI IT COVER CRACKED - REPLACE

190.

IPMC 305.6 203

HALLWAY - CLOSET DOOR KNOBS - PROVIDE

191.

lPMC 605.2 203

BATHROOM-GFCI - PROVIDE- ELECTRICAL PERMIT REQUIRED

192.

IPY!C 704.2 203

BEDROOM/S - SMOKE DETECTOR- PROVIDE- ELECTRICAL PERMIT REQUIRED

193.

IPMC 704.1 203

FIRE SUPPRESSJO~ LINE - CITY REMOVED COAT HANGER- DON'T USE FOR HA~GING ITEMS

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 83 of 146

Exhibit F

\\",\l .I. BY RITRtC,F.RATOR - It .LEGAi. 0\ 'TLET SCRE\\ ED !\TO Ol :TLET - RE\10\T

19-t.

IP»1C 60-l.3 ::os

Kll"CI !E\:

]95.

JP\1C 70-l.1 205

FIR!; Sl."PPR!:sst<r\ 1.1\:F- RE\10VE DRL\\•1 C,\TC!ll'R A\!) CIIRIST'.\1:\S Ll(il!TS

196.

IPMC 704.2 205

BEDROO\!•S- SMOKE DETITTOR ·· PROVIDE ·· I IARD\V!RED - ELECTRICAi. l'ER'.\1lT REQURU)

197.

JPMC 304. l ~ 205

STOR\1 DOOR - SCREE\ TOR:\' - REPLA( 't-:

198,

ll'MC 605.2 209

BAT! !R00\1- GFIC- PROVIDE - ELECTRICAi. PERMIT REQUIRED

199.

JPMC' 305.1 208

K!TCI IE\ . CABINET DRAWERS - OFF TRACK - RFl'AIR/REPLACE

200.

IPMC 305.-t 208

FOYER AT REAR DOOR -- TILES - DEFECTIVE - REPLACE

201.

IP'.\!C 50-l.l 211

BAT! lROO\·! - TOILET RC:--:s co:,.;T[\COLSLY --REP:\lR

202.

IP'.\!C 30-t.15210

RE:\R DOOR - \\'EATl !ER STRIPPJ\:G - LOOSE - REP:\!R

203,

ll'\1C -t03.2 210

B,\TI JR00\1

204.

IP\K' 305.1 210

KlH'l-lE\: · CABJ\:ET l·XO::S:TS- DEFECTJVE-REPA!Rd{EPL\CE

205.

IPMC 604.3 210

K!TCHE\: - GFCI - PAJ'trED OVER · REPLACE MCSl RF:-.1AL\' GF!C - ELECTRICAi. PER:V1JT Rl:QlJJRED

206.

IP\1C 604.3 210

BATI !ROOM - Gl:CI - PROVIDE - El .EC'l'RICAL PERMIT RE QC IRED

'J.07,

IP\1C 605.2

FRO;,,.;T ENTR..\:--;CE TO BUI.Dl\"G · ELECTRIC Al, OUTLETS - MCST BE :VIADE OFCTS & WEATI !ER Tl(il IT
PROVIDE TO COVER Tl lEM - ELECTRICAL PERMIT REQCIRED

208.

IP\1C 304. 12

FRONT ENTRA::-,JCE- ADA I !A:---JDRAILS - J.OOSE - SECURE

209.

JPMC 403.5

LAUNDRY ROOM AREA-DRYER VENTS- SCREWS IN PIPING-REMOVE

210

IPMC 403.5

LAU:--JDRY ROOM AREA - DRYER VENTS - COUPLED WRO!\G DIRECTION

2 I I.

IP\-IC 3053

PROVIDE SEPARATION IN WALL BY PlP!\:(i T!lROUGII \VALL- CO\IPCTER ROOM & Roo:-.1 TO WORKS] !OP

\'E:\T - F:\Ll.l:\G DOW::S:

REPAIR - PREPARE ,\\:D P...\I'.',;l

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 84 of 146

:;o.i. J 8.2

Exhibit F

Al.I. \\'[\DOWS ARE RFQl 'IRED TO BE RFl'l.A(TD- SEALS :\RE BROKE\. WO\'T SI!\ ·r OR ST.·\ Y OPE?\

212.

IP\1C

213.

IP\1C 704.2704J

.!\LL BEDR00\-1S .!\RE REQURl·.D TO 11:\VE FLECTRIC 11.-\RD\\.IRED S\lOKE DElTCTORS
ELECTRICAi. PER!\lIT TO DO Tl IE WORK

214.

IP\1C (,05.2

ALL BAT! I00\1S & KITCHE:\S ARE REQURED TO I I:\ VE GF(TS PRO\'IDED

215.

IP\!C 604.3

C0\1\IO>J AREAS 0:\ AU. LEVELS - El.ECTRlC:\L Ol "TLETS · PAl'-TED OVER · REPLACE

216.

IP\-!C 402.3

,\LL BATllR00\1 & KITCJIE\ VENTS - :\FED TO BE Cll:A:\ED A>JD OR REPL\CED

217.

11'\!C 403.4

1\LL C0\1\-!0l\ AREA VE:\TS · CLEAN AND SECl :RE TO WALL

218.

!RC

219.

IPMC 304.14

315.1

\ll:Sr l't·u.

PROVIDE EITHER A COMBl"!ATION S\10KE & CO DETECTOR OlITSIDE OF SLEEPING AREAS OR SI:\OLI'
U:\ITS FOR BOTH OL;TSIDE THE SLEEP!\G ,\REA
ALL WINDOWS - PROVIDE SCREE:\S

CITY OF A:\NAPOI.IS WOl'l.D RI·:C0\-1:'v!E:,;I) TIIAT ALL E:'v!EROE:,;CY STAIRWAY EXIT DOORS l lA \'F ADA IIA:\DLES !:\STEAD OF
REGl.'LAR DOOR K'\OBS (ilVEl\ Tl IE ,\CiE OF RFSIDF:\TS I\ TIIE Blll.l)l\(j A'.\D l!EAI.Tll JSSl.T.S 11\ C,\SE OF E\·lER(iE:\CY Tl IEY
\1A Y '\OT BF ABLE TO GRIP Tl lE Cl "RRENT DOOR K:---JOBS

ALL ELECTRICAL, MECHAl\'JC4l, BUILDl.'\'G A,'VD PLl'MBli'VG WORK Ifill REQL"JRE PER.HITS TO DO THE WORK ASD Fl.\'.4L
REINSPECT/ON WILL BE CONDUCT/:,"']) BY TllE CITY OF ANNAPOLIS INSPECTORS FOR THAT TRADE-ANY QUESTIONS PLEASE
FEEL FREE TO COSTACT l'S WITH QUESTIOXSAT 4/0-263-7946

REINSPECT/ON SCHEDULED ON SEPTEll-tBER 7-9, 2016, AT 9:30 A.-11

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 85 of 146

Exhibit F

CITY OF ANNAPOLIS
PROPERTY MAINTENANCE CORRECTION NOTICE RENT1607-014
PROPERTY ADDRESS:

NEWTOWNE 20 APARTMENTS - 78 UNITS

PROPERTY OWNER:

Annapolis Housing Authority
c/o Latounzia Buchanan
1386 Tyler Avenue
Annapolis, MD 21403

DATE OF INSPECTION: July 6-7, 2016
INSPECTION TYPE:
ANNAUL
MARY EMRICK, ADAM KNIGHT, STEVE ANDREWS, HENRY GUTIERREZ & BRUCE MURRELL
INSPECTOR:

VIOLATION(S)
No.

Code Ref.

Unit
BROOKE COURT

1.

IPMC 605.2 800-A KITCHEN - GFCI- DEFECTIVE-REPLACE- MUST REMAIN GFCI AT ALL TIMES

2.

IPMC 605.2 800-A BATHROOMS - GFCI- DEFECTIVE- REPLACE- MUST REMAIN GFCI AT ALL TIMES

3.

IPMC 704.2 800-A 3RD BEDROOM- NO SMOKE DETECTOR- PROVIDE

4.

IPMC 305.3 800-B WALLS - THROUGHOUT - HOLES - REPAIR- PREPARE AND PAlNT

5.

IPMC 704.2 800-B 1sTFLOOR-ELECTRIC SMOKE DETECTOR-HANGING-SECURE TO CEILING

6.

IPMC 504.1 800-B KITCHEN -FAUCET-LOOSE- SECURE

7.

IPMC 605.2 800-B KITCHEN - GFCI - LOOSE - SECURE

8.

IPMC 603.1 800-B KITCHEN - STOVE - RIGHT REAR BURNERS - DEFECTIVE- REPAIR OR REPLACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 86 of 146

Exhibit F

9.

IPMC 305.3 800-B KITCHEN-CEILING-HOLE-REPAIR-PREPAREANDPAINT

10.

IPMC 305.6 800-B ALLBEDROOMDOORS-HOLES-REPLACE

11.

IPMC 305.6 800-B ALLBEDROOMS-CLOSETDOORS-OFFTRACK-REPAIR

12.

IPMC 305.3 800-B BATHROOM-WALL TILES - DEFECTIVE- REPLACE

13.

IPMC 305.3 802-A FURNACEROOM-CEILING-HOLE-REPAIR

14.

IPMC 704.2 802-A 1ST FLOOR- ELECTRIC SMOKE DETECTOR- LOW BATTERY CHIRP - PROVIDE BATTERIES

15.

IPMC 704.2 802-A 2ND FLOOR- ELECTRIC- SMOKE DETECTOR-NOT WORKING- REPLACE MUST REMAIN ELECTRIC

16.

IPMC 305.3 802-B KITCHEN - CEILING- HOLE- REPAIR- PREPARE AND PAINT

17.

IPMC 305.3 802-B 2NDFLOORHALLWAY-PEELINGPAINT-REPAIR-PREPAREANDPAINT

18.

IPMC 104.3 802-C DOG NOT CRATED-PROVIDE ACCESS UPON REINSPECTION

19.

IPMC 304.8 804-A EXTERIOR-SOFFIT AREA-FALLING DOWN-REPAIR

20.

IPMC 704.2 804-A ENTIRE UNIT NEEDS TO BE DONE-VACANT

21.

IPMC 704.2 804-B SMOKE DETECTORS-LOW BATTERY CHIRP-PROVIDE BATTERIES

22.

IPMC 605.3 804-B 2ND FLOOR- HALLWAY - LIGHT GLOBE - PROVIDE

23.

IPMC 305.3 804-B 2ND BEDROOM - CEILING- FLAKING PAINT - REPAIR- PREPARE AND PAINT

24.

IPMC 304.13 804-B 3RD BEDROOM - WINDOW - HARD TO SHUT- REPAIR

25.

IPMC 304.13 804-B LIVING ROOM- WINDOW - HARD TO CLOSE- REPAIR

26.

IPMC 305.3 806-A BATHROOM-MOLD-REPAIR-PREPAREANDPAINT

27.

IPMC 704.2 806-B 1sT FLOOR- SMOKE DETECTOR - REMOVED - PROVIDE ELECTRIC SMOKE DETECTOR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 87 of 146

Exhibit F

28.

IPMC 603.2 806-B FURNACE ROOM - STORAGE- REMOVE - NOT PERMITTED TO USE FOR STORAGE

29.

IPMC 305.1 806-B KITCHEN - COUNTERTOP & BACKSPLASH- DEFECTIVE- REPLACE

30.

IPMC 504.1 806-B KITCHEN - WASHING MACHINE - REMOVE

31.

IPMC 305.1 806-B POOR HOUSEKEEPING-THROUGHOUT-TENANT'S RESPONSIBILITY

32.

IPMC 702.4 806-B FRONT BEDROOM -AC UNIT IN WINDOW - REMOVE

33.

IPMC 302.9 806-C EXTERIOR- GRAFFITI ON SIDE OF BUILDING- CLEAN AND REMOVE

34.

IPMC 305.3 806-C LAUNDRYROOM-MOLD-REPAIR-PREPAREANDPAINT

35.

IPMC 605.3 806-C LIGHT GLOBES - THROUGHOUT -PROVIDE

36.

IPMC 704.2 806-C SMOKE DETECTORS - THROUGHOUT - LOW BATTERY CHIRP - PROVIDE BATTERIES

37.

IPMC 504.1 806-C BATHROOM-TUBFAUCET-LEAKING-REPAIR

38.

IPMC 108.2 806-C ENTIREUNITNEEDSRENOVATION

39.

IPMC 304.7 808-A ROOFING- SHINGLES FALLING OFF FRONT OF BUILDING-REPAIR

40.

IPMC 704.2 808-A 1sr &2NDFLOOR-ELECTRIC SMOKEDETECTORS-NOTWORKING-REPLACEMUSTREMAINELECTRIC

41.

IPMC 704.2 808-B 1sr FLOOR- SMOKE DETECTOR-NOT WORKING- REPLACE MUST REMAIN ELECTRIC

42.

IPMC 305.1 808-B KITCHEN - CABINET DOOR- REPLACE

43.

IPMC 305.4 808-B KITCHEN-FLOORING-DEFECTIVE-REPLACE

44.

IPMC 305.1 808-B BEDROOM-PEELINGPAINT-REPAIR-PREPAREANDPAINT

45.

IPMC 504.1 808-B BATHROOM-SINKFAUCET-LEAKING-REPAIR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 88 of 146

Exhibit F

46.

IPMC 305.6 808-B REAR BEDROOM- NO DOOR- PROVIDE WITH HARDWARE

47.

IPMC 704.2 808-B SMOKE DETECTORS -THROUGHOUT- NO WORKING- PROVIDE ELECTRIC SMOKE DETECTORS

48.

IPMC 108.2 808-C VACANTUNIT-NEEDSCOMPLETERENOVATION

49.

IPMC 504.1 810-A HOT WATER HEATER- SHUT DOWN -NOT HOOKED UP CORRECTLY -PLUMBING PERMIT REQUIRED

50.

IPMC 603.1 810-A FURNACE-GAS VALVE-PAINTED-REPLACE

51.

IPMC 704.2 810-A 1sTBEDROOM-SMOKEDETECTOR-PROVIDE-MUSTBEMADEELECTRIC

52.

IPMC 304.3 810-B ENTRANCELETTERING-PROVIDE

53.

IPMC 704.2 810-B 1ST FLOOR- SMOKE DETECTOR- NOT WORKING- REPLACE MUST REMAIN ELECTRIC

54.

IPMC 704.2 810-B 2ND BEDROOM - SMOKE DETECTOR- NOT WORK.IGN - REPLACE MUST BE ELECTRIC

55.

IPMC 304.15810-B SCREENDOOR-REPLACESCREEN

56.

IPMC 305.1 810-C KlTCHEN-BAKCSPLASH-REPAIR/REPLACE

57.

IPMC 504.1 810-C BATHROOM-TUB OVERFLOW COVER-PROVIDE

58.

IPMC 305.3 810-C 3RDBEDROOM-COMPLETEWALLREPAIR-PREPAREANDPAINT

59.

IPMC 305.3 810-C HALLWAY-COMPLETE WALL REPAIR-PREPARE AND PAINT

60.

IPMC 304.13 810-C 2ND BEDROOM- WINDOW -REMOVE CARDBOARD AND PROVIDE PLYWOOD

61.

IPMC 702.4 812-A FRONT BEDROOM WINDOW -AC UNIT-REMOVE-BLOCKS EGRESS

62.

IPMC 604.3 812-A KlTCHEN - 6 WAY PLUG- REMOVE

63.

IPMC 305.6 812-A LIVINGROOM-CLOSETDOORHINGE-REPAIR

64.

IPMC 603.1 812-A FURNACEROOM-GASLINE-PAINT-REPAIR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 89 of 146

Exhibit F

65.

IPMC 704.2 812-A FRONT BEDROOM- SMOKE DETECTOR- NOT WORKING- REPLACE MUST BE ELECTRIC

66.

IPMC 305.3 812-A FRONTBEDROOM-PEELINGPAlNT-REPAlR-PREPAREANDPAlNT

67.

IPMC 305.3 812-A BATHROOM- CEILING- COLLAPSING- REPAIR IMMEDlATELY - MADE AWARE OF THIS

68.

IPMC 605.3 812-A 2ND FLOOR HALLWAY - LIGHT GLOBE MISSING-PROVIDE

69.

IPMC 305.3 812-A 2NDFLOORHALLWAY-PEELINGPA1NT-REPA1R-PREPAREAND PAINT

70.

IPMC 702.4 812-B FRONT BEDROOM-AC UNIT IN WINDOW -REMOVE- BLOCKS EGRESS

71.

IPMC 304.3 812-B UNIT NUMBER ON EXTERIOR-PROVIDE

72.

IPMC 305.5 812-B 2ND FLOOR- HANDRAlL-DEFECTNE-REPLACE

73.

IPMC 704.2 812-B 2ND BEDROOM- SMOKE DETECTOR-NOT WORKING-REPLACE MUST BE ELECTRIC

74.

IPMC 108.2 812-C BOARDED- VACANT UNIT-NEEDS RENOVATION

75.

IPMC 605.3 814.A KITCHEN -LIGHT COVER-MISSING-PROVIDE

76.

IPMC 603.1 814-A FURNACEROOM-GASVALVE-PAlNTED-REPAIR!REPLACE

77.

IPMC 504.1 814-A HOT WATER HEATER- VENT PIPE-NOT INSTALLED PROPERLY -NEEDS PLUMBING PERMIT

78.

IPMC 504.1 814-A HOT WATER HEATER- PRESSURE RELIEF VALVE-NOT INSTALLED PROPERLY - PLUMBING PERMIT

79.

IPMC 305.3 814-A BATHROOM-PEELINGPAlNT-REPAlR-PREPAREAf.ll)PAlNT

80.

IPMC 605.2 814-A BATHROOM- GFCI- DEFECTNE- REPLACE MUST REMAIN GFCI

81.

IPMC 704.2 814-A REAR BEDROOM- SMOKE DETECTOR- NOT WORKING- REPLACE MUST BE ELECTRIC

82.

IPMC 304.15 814-B SCREENDOOR-HANDLE-DEFECTNE-REPLACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 90 of 146

Exhibit F

83.

IPMC 604.3 814-B 1sT FLOOR TO 2ND FLOOR- EXTENSION CORDS - NO OUTLETS WORKING- REPAIR IMMEDIATELY TRIPPING BACK TO BREAKER- GET LICENSED ELECTRICIAN

84.

IPMC 305.3 814-C UTLITYROOM-FLAKINGPAINT-REPAIR-PREPAREANDPAINT

85.

IPMC 605.3 814-C UTILITY ROOM-PROVIDE LIGHT FIXTURE- NOTHING THERE

86.

IPMC 605.3 814-C LIVING ROOM- LIGHT GLOBE- MISSING-PROVIDE

87.

IPMC 304.13 814-C 2ND BEDROOM- WINDOW -REMOVE CARDBOARD AND PROVIDE PLYWOOD

88.

IPMC 603.1 816-A FURNACE-GAS VALVE PAINTED OVER-REPAIR/REPLACE

89.

IPMC 704.2 816-A 2ND FLOOR- SMOKE DETECTOR- NOT WORKING- REPLACE MUST REMAIN ELECTRIC

90.

IPMC 704.2 816-A FRONT BEDROOM - SMOKE DETECTOR- NONE- PROVIDE ELECTRIC SMOKE DETECTOR

91.

IPMC 305.3 816-A BATHROOM-PEELINGPAINT-REPAIR-PREPAREANDPAINT

92.

IPMC 305.3 816-A BATHROOM-WALLS-MOLD-REPAIR-PREPAREANDPAINT

93.

IPMC 305.3 816-A BATHROOM-WATERLEAKFROMTUB-REPAIR

94.

IPMC 704.2 816-A ALL BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

95.

IPMC 704.2 816-B 2ND & 3RD BEDROOM- SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

96.

IPMC 305.3 816-B 2NDFLOOR-HALLWAY-PREPAREANDPAINT

97.

IPMC 605.3 816-C EXTERIOR-MlSSINGLIGHTCOVER-PROVIDE

98.

IPMC 305.3 816-C 3RDBEDROOM-MOLDBYCLOSETDOORANDCORNER-REPAIR-PREPAREANDPAINT

99.

IPMC 304.14 816-C WINDOW SCREENS-PROVIDE

100.

IPMC 304.13 816-C ALL BEDROOMS - WINDOWS - HARD TO OPEN - REPAIR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 91 of 146

Exhibit F

101.

IPMC 605.2 816-C KITCHEN - GFCI-PROVIDE TO LEFT OF STOVE

102.

IPMC 305.1 816-C KITCHEN-BACKSPLASH-REPLACE

103.

IPMC 403.2 816-C BATHROOM- VENT FAN -CLEAN-CLOGGED

104.

IPMC 305.1 805-A POOR HOUSEKEEPING THROUGHOUT - TENANT'S RESPONSIBILITY

105.

IPMC 108.2 805-B VACANT & BOARDED - NEEDS FULL REHAB

106.

IPMC 605.3 805-C FRONT ENTRANCE - LIGHT GLOBE- PROVIDE

107.

IPMC 305.4 805-C ENTRANCE FOYER- FLOOR TILES - MISSING- PROVIDE

108.

IPMC 704.2 805-C SMOKE DETECTORS - LOW BATTERY CHIRP - REPLACE BATTERIES

109.

IPMC 603.1 805-C KITCHEN - STOVE - RIGHT FRONT & LEFT REAR BURNERS - NOT WORKING - REPAIR/REPLACE

110.

IPMC 504.1 805-C KITCHEN - SINK- FAUCET HANDLES - BROKEN - REPLACE

111.

IPMC 309.4 805-C EXTERMINATE-ROACHES

112.

IPMC 305.1 805-C KITCHEN - COUNTERTOP - BACKSPLASH - REPLACE

113.

IPMC 403.2 805-C BATHROOM-LIGHTNENTFAN-DEFECTIVE-REPLACE

114.

IPMC 305.3 805-C 3RD BEDROOM - CEILING- CHIPPING PAINT - REPAIR- PREPARE AND PAINT

115.

IPMC 604.3 805-C HALLWAY - SWITCH - DEFECTIVE - REPLACE

116.

IPMC 305.3 805-C KITCHEN - WALL- HOLE IN WALL BY DOOR TO RIGHT- REPAIR- PREPARE AND PAINT

117.

IPMC 704.2 803-A 1sT BEDROOM- SMOKE DETECTOR- DEFECTIVE- MUST BE MADE ELECTRIC

118.

IPMC 108.2 803-B VACANT & BOARD - COMPLETE REHAB

119.

IPMC 304.3 803-C ENTRANCE - PROVIDE ADDRESS ON EXTERIOR OF BUILDING

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 92 of 146

Exhibit F

120.

IPMC 603.1 803-C KITCHEN-STOVEKNOBS-MlSSING-PROVIDE

121.

IPMC 605.2 803-C KITCHEN - GFCI- REPLACE

122.

IPMC 504.1 803-C KITCHEN - TRAP LEAKING - REPAIR/REPLACE

123.

IPMC 403.2 803-C BATHROOM - VENT SYSTEM- CLEAN

124.

IPMC 305.3 803-C HALLWAY - HOLE IN WALL- REPAIR- PREPARE AND PAINT

125.

IPMC 305.3 803-C WALL BEHIND FRONT DOOR- HOLE - REPAIR- PREPARE AND PAINT

126.

IPMC 305.3 801-A 2NDBEDROOM- WALL & CEILING- CRACKING-REPAIR-PREPARE AND PAINT

127.

IPMC 305.1 801-B KITCHEN - BASE CABINET - REPLACE

128.

IPMC 305.3 801-B 1sTBEDROOM-CEILING-COLLAPSING-REPAIRIMMEDIATELY

129.

IPMC 605.2 801-C BATHROOM-GFCI-REPLACE

130.

IPMC 504.1 801-C BATHROOM-TUB SURROUND-RECAULK

131.

IPMC 704.2 801-C BOTH HALLWAY SMOKE DETECTORS - ELECTRIC - REPLACE MUST REMAIN ELECTRIC

132.

IPMC 305.3 801-C 3RDBEDROOM-CEILING-FLAKING&BUBBLINGPAINT-REPAIR-PREPAREANDPAINT

BETSY COURT
133.

IPMC 603.1 800-A FURNACE ROOM - GAS VALVES - PAINTED OVER- REPLACE WHEN UNIT CHANGED OUT

134.

IPMC 504.1 800-B FURNACE ROOM- HOT WATER HEATER- NO PERMIT & HOOKED UP WRONG- PERMIT REQUIRED

135.

IPMC 305.3 800-B FURNACE ROOM-CEILING-DEFECTIVE-REPAIR-PREPARE AND PAINT

136.

IPMC 305.3 800-B LIVINGROOM-CEILING-LEAK-REPAIR-PREPAREANDPAINT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 93 of 146
137.

IPMC 305.3 800-B LIVINGROOM-WALL-RETAPESEAM-PREPAREANDPAINT

138.

IPMC 304.14 800-C WINDOW SCREENS-REPAIR ORE REPLACE SCREENS

139.

IPMC 403.2 800-C BATHROOM- VENT- CLEAN OUT

140.

IPMC 304.13 800-C 1ST BEDROOM - BROK.EN WINDOW - REPLACE

141.

IPMC 605.3 800-C FRONT DOOR & HALLWAY AREA - GLOBE MISSING- PROVIDE

142.

IPMC 605.2 800-C BATHROOM & KITCHEN - GFCI- REPLACE

143.

IPMC 603.1 800-C KITCHEN - STOVE- RIGHT REAR BURNER- DEFECTIVE - REPAIR/REPLACE

144.

IPMC 605.3 800-C KITCHEN - LIGHT - NOT WORKING- REPAIR/REPLACE

145.

IPMC 605.3 800-C UTILITY ROOM- MISSING LIGHT - PROVIDE

146.

IPMC 704.2 802-A BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

147.

IPMC 305.l 802-B KITCHEN - POOR HOUSEKEEPING-TENANT'S RESPONSIBILITY

148.

IPMC 603.1 802-B KITCHEN - STOVE - LEFT REAR BURNER- DEFECTIVE -REPAIR/REPLACE

149.

IPMC 305.1 802-B KITCHEN - CABINETS FRONTS - REPLACE

150.

IPMC 305.1 802-B KITCHEN - CEILING- CLEAN - GREASE

151.

IPMC 305.3 802-B FURNACE ROOM - HOLES IN CEILING - REPAIR

152.

IPMC 504.1 802-B HOT WATER HEATER- PRESSURE RELIEF VALVE-NOT INSTALLED PROPERLY

153.

IPMC 704.2 802-B BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

154.

IPMC 504.l 802-B BATHROOM- SINK- CLOGGED- MANAGEMENT MADE AWARE ON SITE

155.

IPMC 305.3 802-B ALL BEDROMS & BATHROOMS - PEELING PAINT- REPAIR- PREPARE AND PAINT

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 94 of 146

Exhibit F

156.

IPMC 108.2 802-C BOARDED AND VACANT- COMPLETE REHAB NEEDED

157.

IPMC 704.2 804-A 1ST FLOOR- SMOKE DETECTOR- REMOVED-PROVIDE ELECTRIC SMOKE DETECTOR

158.

IPMC 305.1 804-A POOR HOUSKEEPING-TENANT'S REPSONSIBILITY

159.

IPMC 704.2 804-A 1ST BEDROOM- SMOKE DETECTOR-NOT WORKING- REPLACE WITH ELECTRIC SMOKE DETECTOR

160.

IPMC 704.2 804-B GOOD (STILL NEEDS ELECTRIC SMOKE DETECTORS AND CO DETECTORS)

161.

IPMC 304.14 804-C WINDOW SCREENS-REPLACE MISSING OR TORN

162.

IPMC 704.2 804-C SMOKE DETECTORS - PROVIDE MISSING BATTERIES - THROUGHOUT

163.

IPMC 305.3 804-C BATHROOM-FLAKING PAINT- REPAIR-PREPARE AND PAINT

164.

IPMC 305.3 804-C BATHROOM-MOLD-REPAIR-PREPARE AND PAINT

165.

IPMC 304.7 823-A EXTERIOR- WATER GETTING BEHIND SHINGLES - REPAIR OR REPLACE

166.

IPMC 305.4 823-A BATHROOM- FLOORING- WEAK- REPLACE SUB-FLOORING

167.

IPMC 704.2 823-A 1sT BEDROOM - SMOKE DETECTOR- NOT WORKING - REPLACE WITH ELECTRIC SMOKE DETECTOR

168.

IPMC 704.2 823-A BOTH BACK BEDROOMS - SMOKE DETECTORS - NOT WORKING- PROVIDE ELECTRIC SMOKE
DETECTORS

169.

IPMC 704.2 823-A MASTER BEDROOM - SMOKE DETECTOR- NOT WORKING- PROVIDE ELECTRIC SMOKE DETECTOR

170.

IPMC 108.2 823-B VACANT & BOARDED - NEEDS COMPLETE REHAB

171.

IPMC 108.2 823-C VACANT & BOARDED - NEEDS COMPLETE REHAB

172.

IPMC 108.2 821-A VACANT-WORKING ON REHAB DURING INSPECTION WILL NEED ELECTRIC SMOKES, CO & GFCI'S

173.

IPMC 305.1 821-B KITCHEN-CABINETFRONT-LOOSE-REPAIR

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 95 of 146

Exhibit F

174.

IPMC 305.6 821-B 15TFLOOR-CLOSETDOORKNOB-PROVIDE

175.

IPMC 504.1 821-B HOTWATERHEATER-PRESSURERELIEFVALVE-NOTTO CODE

176.

IPMC 605.2 821-B BATHROOM- GFCI- DEFECTIVE- REPLACE

177.

IPMC 604.3 821-B BATHROOM- LIGHT SWITCH- BROKEN - REPLACE\

178.

IPMC 305.3 821-B BATHROOM-PREPAREANDPAINT

179.

IPMC 304.13 821-C WINDOW SCREENS - MISSING OR TORN - REPAIR/REPLACE

180.

IPMC 305.3 821-C 2NDBEDROOM-FLAK.INGPAINTUNDER WINDOW-REPAIR-PREPARE AND PAINT

181.

IPMC 304.13821-C 2NDBEDROOM-WINDOW-LEAK.ING-REPAIR

182.

IPMC 108.2 819-A VACANT & BOARDED - NEEDS COMPLETE REHAB

183.

IPMC 605.2 819-B KITCHEN - GFCI- WON'T RESET - REPLACE-MUST REMAIN GFCI

184.

IPMC 305.3 819-B ALL BEDROOMS-CEILINGS-DRYWALL-REPAIR-PREPARE AND PAINT

185.

IPMC 704.2 819-C OK (WILL STILL NEED ELECTRIC SMOKE DETECTORS & CO)

186.

IPMC 108.2 817-A VACANT & BOARDED- NEEDS COMPLETE REHAB

187.

IPMC 108.2 817-B VACANT & BOARDED - NEEDS COMPLETE REHAB

188.

IPMC 108.2 817-C VACANT & BOARDED - NEEDS COMPLETE REHAB

189.

IPMC 108.2 815-A VACANT & BOARDED - NEEDS COMPLETE REHAB

190.

IPMC 704.2 815-B MASTER BEDROOM-NO SMOKE DETECTOR- PROVIDE ELECTRIC SMOKE DETECTOR

191.

IPMC 504.1 815-B BATHROOM-LEAK-LEAK.ING INTO KITCHEN -REPAIR-PREPARE AND PAINT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 96 of 146

Exhibit F

192.

IPMC 305.3 815-B KITCHEN-WALL-WATERLEAK-REPAlR-PREPAREAND PAINT

193.

IPMC 605.3 815-B 1ST FLOOR- LIGHT GLOBE- PROVIDE

194.

IPMC 108.2 815-C VACANT & BOARDED- NEEDS COMPLETE REHAB

195.

IPMC 304.6 813-A EXTERIOR- CABLE CORD FOR DISH NETWORK- REMOVE-NOT PERMITTED BY MANAGEMENT

196.

IPMC 704.2 813-A 2ND BEDROOM- SMOKE DETECTOR- MISSING- PROVIDE ELECTRIC SMOKE DETECTOR

197.

IPMC 704.2 813-A 2ND BEDROOM- SMOKE DETECTOR- MISSING- PROVIDE ELECTRIC SMOKE DETECTOR

198.

IPMC 605.2 813-A KITCHEN - GFCI TO RIGHT OF SINK-DEFECTIVE- REPLACE MUST REMAIN GFCI

199.

IPMC 304.8 813-B EXTERIOR- SOFFIET AREA- DEFECTIVE- REPLACE

200.

IPMC 403.2 813-C BATHROOM-VENTFAN-NOTWORKING-REPAIR/REPLACE

201.

IPMC 603.1 813-C KITCHEN - STOVE- LEFT REAR BURNER- DEFECTIVE -REPAIR/REPLACE

202.

IPMC 704.2 813-C ALL ADA ALARMS ON SMOKE DETECTORS - HAVE CHECKED

203.

IPMC 305.3 811-A FURNACE ROOM- CEILING- LEAK-REPAIR- PREPARE AND PAINT

204.

IPMC 605.3 811-A DINING ROOM- LIGHT GLOBE - PROVIDE

205.

IPMC 704.2 811-A 1sT BEDROOM- SMOKE DETECTOR- NOT WORKING- PROVIDE ELECTRIC SMOKE DETECTOR

206.

IPMC 504.1 811-A KITCHEN - FAUCET - LEAKING - REPAIR/REPLACE

207.

IPMC 504.1 811-A BATRHOOM-FAUCET-LEAKS-REPAIR/REPLACE

208.

IPMC 604.3 811-A EXTERIOR LIGHT- SHORT-REPAIR/REPLACE

209.

IPMC 304.15 811-B SCREEN DOOR-KNOB-DEFECTIVE-REPLACE

210.

IPMC 305.1 811-B POOR HOUSEKEEPING- THROUGHOUT-TENANT'S RESPONSIBILITY

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 97 of 146

Exhibit F

211.

IPMC 304.14 811-C WINDOW SCREENS - TORN OR MISSING - REPAIR/REPLACE

212.

IPMC 403.2 811-C VENT COVERS THROUGHOUT-REPAIR/REPLACE

213.

IPMC 305.3 811-C BATHROOM - WALLS - FLAKING PAINT - REPAIR- PREPARE AND PAINT

214.

IPMC 604.3 809-A LIVING ROOM - LIGHT- DEFECTIVE- REPAIR/REPLACE

215.

IPMC 309.4 809-A FURNACE ROOM - DEAD MICE - REMOVE

216.

IPMC 605.2 809-A KITCHEN - GFCI - REPLACE

217.

IPMC 305.3 809-A BATHROOM-CEILING-REPAIR-PREPARE AND PAINT

218.

IPMC 403.2 809-A BATHROOM-VENTFANT-CLEAN

219.

IPMC 305.5 809-A INTERIOR HANDRAIL- BROKEN - REPLACE

220.

IPMC 604.3 809-A EXTENSION CORDS - THROUGHOUT - REMOVE - TRIPPING HAZARD

221.

IPMC 604.3 809-A ELECTRICAL OUTLETS - DEFECTIVE- THROUGHOUT - REASON FOR CORDS

222.

IPMC 305.5 809-B INTERIOR HANDRAIL - DEFECTIVE- REPAIR/REPLACE

223.

IPMC 704.2 809-B ALL BEDROOMS - NOT SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

224.

IPMC 108.2 809-C VACANT & BOARDED - NEEDS COMPLETE REHAB

225.

IPMC 108.2 807-A VACANT & BOARDED-NEEDS COMPLETE REHAB

226.

IPMC 304.8 807-A FRONT AC COVER (BOX) FALLING OFF FRONT OF BUILDING- REATTACH

227.

IPMC 104.3 807-B NO ACCESS-KEY LOCKS CHANGED

228.

IPMC 108.2 807-C VACANT & BOARDED- NEEDS COMPLETE REHAB

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 98 of 146

Exhibit F

229.

IPMC 704.2 805-A 1sr FLOOR- SMOKE DETECTOR- NOT WORKING- PROVIDE ELECTRIC SMOKE DETECTOR

230.

IPMC 305.1 805-A FURNACE ROOM- FURNITURE BLOCKING ACCESS - REMOVE - CANNOT BLOCK

231.

IPMC 704.2 805-B OK (NEED TO VERIFY IF THIS HAS ELECTRIC SMOKE DETECTORS & CO)

232.

IPMC 704.2 805-C OK ( NEED TO VERIFY IF THIS HAS ELECTRIC SMOKE DETECTORS & CO)

233.

IPMC 704.2 803-A BEDROOMS - NO SMOKE DETECTORS - PROVIDE ELECTRIC SMOKE DETECTORS

234.

IPMC 403.2 803-A BATHROOM - VENT FAN - NOT WORKING- REPAIR/REPLACE

235.

IPMC 504.1 803-A BATHROOM-SINK-REATTACHTOWALL

236.

IPMC 108.2 803-B VACANT & BOARDED - NEEDS COMPLETE REHAB

237.

IPMC 704.2 803-C SMOKE DETECTORS-LOW BATTERY CHIRP-PROVIDE BATTERIES

238.

IPMC 605.3 803-C HALLWAY - LIGHT GLOBE - BROKEN - REPLACE

239.

IPMC 305.6 803-C BEDROOMS - DOORS - HOLES - REPLACE

240.

IPMC 604.3 803-C 2ND BEDROOM - OUTLET COVER PLATES - MISSING- PROVIDE

241.

IPMC 605.2 803-C BATHROOM- GFCI - DEFECTIVE- REPLACE

242.

IPMC 305.3 803-C HALLWAY - FINISH WALL REPAIR- PREPARE AND PAINT

LAUNDRY ROOM & COMMUNITY CENTER AREAS
243.

IPMC 604.3 EXTERIOR-ELECTRIC BOX ON OUTSIDE- SECURE

244.

IPMC 403.5 DRYER VENTS- SCREWS IN PIPING- REMOVE

245.

IPMC 603.2 MECHANICAL ROOM- REMOVE STORAGE

246.

IPMC 603.2 MECHANICAL ROOM - CEILING COLLAPSING- REPAIR- PREPARE AND PAINT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 99 of 146

Exhibit F

247.

IPMC 605.2 LAUNDRY ROOM- WASHER- PROVIDE GFCI'S

248.

IPMC 702.1

EXIT LIGHTS - DEFECTIVE - REPLACE

249.

IPMC 702.1

EXIT LIGHT AT FAR SIDE-REPLACE

250.

IPMC 702.1 EMERGENCY BACK UP LIGHTS - NOT WORKING- REPLACE

251.

IPMC 504.1 BATHROOM-TOILET-LOOSE-SECURETOFLOOR

252.

IPMC 704.2/704.3

ALL UNITS - PROVIDE ELECTRIC HARDWIRED SMOKE DETECTORS IN ALL SLEEPING ROOMS AND ALL
LEVELS - ELECTRICAL PERMIT WILL BE REQUIRED

253.

IRC

ALL UNITS - PROVIDE CO DETECTORS ON THE LEVEL OF THE SLEEPING ROOMS

254.

IPMC 304.14

ALL UNITS - WINDOWS - SCREENS - PROVIDE

255.

IPMC 505.4

ALL UNITS - HOT WATER HEATER- PRESSURE RELIEF VALVES- MUST EXTEND TO 6" ABOVE FLOORNOT INTO WALLS ETC - PLUMBIN PERMITS MAY BE REQUIRED

256.

NFPA 10.11.6.1 &2 GRILLS ON EXTERIOR-MUST BE USED 15FT AWAY FROM THE DWELLINGS

257.

IPMC 605.2

ALL BATHROOMS & KITCHEN AREAS - PROVIDE GFCI OUTLETS AT AREAS BY SINKS

258.

IPMC 304.2

EXTERIOR WOOD TRIM - REPLACE ROTTEN - PREPARE & PAIN1\

259.

IPMC 305.1

EXTERIOR- COMMON AREAS & GROUNDS - NEED TO BE CLEANED AND PICKED UP DAILY

315.1

ALL ELECTRICAL, MECHANICAL, BUILDING AND PLUMBING WORK WILL REQUIRE PERMITS TO DO THE WORK AND FINAL
INSPECTIONS ON THESE ITEMS WILL BE CONDUCTED BY THE CITY OF ANNAPOLIS INSPECTORS FOR THAT TRADE -ANY
QUESTIONS, PLEASE FEEL FREE TO CONTACT US AT 410-263-7946

REINSPECT/ON SCHEDULED ON OCTOBER 20-21, 2016, AT 9:30 A.M.

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 100 of 146

Exhibit F

\VILLIAM F. BECKER
PROPERTY MAI;-.;TENANCE CORRECTION NOTICE #RENT1605-070
PROPERTY ADDRESS:

ROBINWOOD

PROPERTY OWNER:

Annapolis Housing Authority
c/o Ms. Buchanan
1217 Madison Street
Annapolis. MD 21401

DATE OF Jl\SPECTIOI'\: May 9-11.2016
INSPECTION TYPE:
A1's'NUAL
INSPECTOR:
:--1ARY EMRICK. ADA'v! KN"IGHT. STEVE ANDREWS & HENRY GUTIERREZ

VIOLATION(S)
No.

Code Ref.

Unit

1.

IPMC 603.l

ALL UNITS

ALL SCREENED FRESH AIR INTAKES ARE NOT TO CODE. MECHANICAL PERMITS WILL
BE REQUIRED. MOST ARE BROKEN AND INFESTED WITH BIRD NESTINGS.

2.

IPMC 402.3

ALL l.J'NITS

BATH VEJ\i1S ON EXTERIOR LOUVERS BROKEN. BIRDS NESTING CAUSING FIRE
HAZARD - REPLACE

3.

!Pl\·1C 302.1

ALL UNITS

GENER.t.,.L CLEAN-UP -REMOVE ALL TR.t.,.SH ON GROUNDS THROUGHOUT

4.

IPMC 704.2

ALL UNITS

ALL BEDROOMS MUST HAVE HARDVvlRED SMOKE DETECTORS -PROVIDE

5.

!RC

ALL UNITS

ALL UNITS MUST HA VE C.O. DETECTOR ON LEVEL OF SLEEPING ROOMS -PROVIDE

6.

IPMC 605.3

]301

KITCHEN: LIGHT COVER -PROVIDE

7.

IPMC 603.l

1301

KITCHEN: REAR LEFT BUR.'\.TER ON STOVE DEFECTIVE -REP AIR/REPLACE

8.

IPMC 309.1

1301

INFESTATION OF WATER BUGS SEVERE ISSUE IN BEDS-TERMINATE & PROVIDE CITY WITH
REPORT

315.1

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 101 of 146

Exhibit F

9.

lPl\1C 305.6

1301

HALLWAY: CLOSET DOOR BY ST/\JRS-REPLACE

10.

lPMC 305.3

1301

IIALLWAY:

11.

IPMC 305.3

1301

STAIRWAY: TOP-RAIL !!AS '.v10LD- REPAIR, PREPARE & PAINT (."if.EDS XF.:WWOOD-

2'' 1) FLOOR HAS HOLE-- REPAIR, PREPARE & PAl'.'JT

/',!GMT A'OT!FIED)

12.

IPMC 305.6

1301

DOORS: ALL BEDROO'.vlS, CLOSET. & BATHROOM HAVE MOLD -REPAIR. PREPARE & PAIJ\:T
(it:1TER DAMAGE FRO.H VVETCL071IES Cf ft.>U' PRESSED DOORS SO ALL NEED TO BE
REPL4CED. MGMT NOTIFIED.)

13.

1P\1C 305.3

1301

BATHROOM: 2" 0 - WALL ll/\S HOLE-- REPAIR. PREPARE & PAINT

14.

lPMC 305.1

1301

BATHROOM: 2~ 1>-TOILET PAPER HOLDER-REPLACE

15.

!P;V!C 304.15

1301

FRONT: SCREEN DOOR STICKS-REPAIR/REPLACE

16.

lP:V!C 304.15

1301

E'.\'TRANCE DOOR: BENT-REPLACE (GAP)

17.

IPMC 704.2

1303

BEDROOMS: ALL TI!REE·-SMOKE DETECTORS NOT SOUNDING-REPLACE

18.

IPMC 504.1

1305

FRONT LAW:\! AREA-SEWER CLEAN OUT--PROVIDE CAP

19.

IPMC 305.1

1305

KITCHEN: BACKSPLASH ROTrEN-REPLACE

20.

1P:v1C 305.1

1305

KITCHEN: COUNTERTOP EDGING-- PROVIDE

21.

IPMC 605.3

1305

KITCHEN: LIGHT GLOBE-PROVIDE

22.

IPMC 305.3

1305

DINl:-JG ROOM/K!TCHE::S:: SOl-'f!T AREA-· REPAIR. PREPARE & PAINT

~'
-.J.

IPMC 704.2

1305

BEDROOM:

24.

IPMC 304.13

1307

D[NING ROOM: REAR WINDOW-REPAIR/REPLACE

25.

IPMC 504.1

1307

KITCHEN: SINK LEAKS-REPAIR

3RD __

SMOKE DETECTORS NOT SOUND!;-.iG-REPLACE

2

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 102 of 146

Exhibit F

REPLACE

26.

IP:VIC 704.2

1307

1'r FLOOR: SMOKE Dl:TECTORS 1':0T S0U1'D1'-:G

27.

lPMC 304.13

1307

BATHROOM: 2"D FLOOR-Wl>JDOW- REPAIR

28.

JPMC 704.2

1307

BEDROOM: l ST & 2"n __ SMOKE DETECTORS NOT SOlJ?,.;DJNG-REPLACE

29.

IPMC 305.3

1307

BATl !ROOM: 2:-.D FLOOR-CEILING HAS MOLD-- REP AIR. PREP ARE & PAIKf

30.

!PMC 305.1

1309

KITCHEN: BACKSPLASH ROTTEK-REPLACE

31.

IPMC 704.2

1309

J!ALL WAY: 1' 1 & 2"° FLOOR-- S~10KE DETECTORS DEFECTIVE-REPLACE

")
j_.

JPMC 108.2

131 I

U:'ilT VAC/\l\T & BOARDED

'j j'.

IPMC 504.J

1313

KITCHEN: SINK FAUCET LOOSE-··REPA!R

34.

IPMC 605.3

1313

KJTCHE:'\: LIGHT GLOBE-PROVIDE

35.

IPMC 704.2

1313

BEDROOM: REAR-PROVIDE SMOKE DETECTOR

36.

IPMC 305.6

1313

BATIIROOM: 1si FLOOR---DOOR DRAGS-ADJUST

37.

fPMC 402.3

1313

BATHROOM: I sT FLOOR-VENT FAN DEFECT!VE-REPAIR/REPf ,ACE

38.

IPMC 605.3

1313

HALLWAY: LIGHT FIXTl;RE AT STAIRS-PROVIDE GLOBE

39.

!PMC 305.3

1313

BATHROOM: 2"D-CEIL!NG HAS MOLD-- REPAIR, PREPARE & PAINT

40.

IPMC 604.3

1313

BATH ROOM: 2" 0 -GFCI OlJTLET & COVER PL!\TE BROKEN-REPLACE

41.

IPMC 704.2

13l3

BEDROOM: REAR--S:\10KE DETECTORS l'\OT SOUKD1NG-REPLACE

42.

IPMC 605.1

1313

I!ALLWA Y: 2~n FLOOR--LIGHT DEFECTIVE-REPAIR/REPLACE

43.

!PMC 605.1

1313

BEDROOM: REAR-STROBE HANGJNG-SECC:RE

'

.)

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 103 of 146
44.

IPMC 305.6

1313

BEDROOM: 3Rn_DOOR K>-.:OB-PROV!DE

45.

IPMC 305.6

1315

lsr FLOOR: CLOSET DOOR HAS !!OLE-REPLACE

46.

IPMC 305.3

1315

EATHROOM: 2"n-CEILING-PAl1\T

47.

IP\1C 704.2

1315

BEDR00\1: ls'-SMOKE DETECTOR-PROVIDE

48.

IPMC 704.2

1315

BEDROOM:

49.

IP\1C 305.6

1315

BEDROOM: 2"D DOOR HAS HOLE-REPLACE

50.

IPMC 302.9

1317

GRAFFITI ON BRICK WALL-CLEA:\' & REMOVE

51.

IP\1C 304.14

1317

WINDOW: SCREENS-PROVIDE

52.

IPMC 305.l

1317

KITCHEN: Bi\CKSPLASH-RE-CACLK

53.

IPMC 305.6

1319

BEDROOM: 15T--DOOR HAS HOLE-REPLACE

54.

IPMC 704.2

1319

BEDROOMS: ALL FOUR-·· S:vIOKE DETECTORS NOT SOlJNDING-REPLACE

55.

IP\1C 305.3

1319

EEDROOM: 151-WALL HAS HOLE-- REPAIR. PREPARE & PAINT

56.

!PMC 305.6

1319

SCREEN DOOR: SPRf;\;"G ARM DEFECTIVVE-REPAIR/REPLACE

57.

lPMC 304.14

1319

BATHROOM: 2" 1' FLOOR-WINDOW SCREEN TORN-REPAIR/REPLACE

58.

IPMC 604.3

1321

KITCHEN: ALL STOVE BURNERS DEFECTIVE-REPAIR/REPLACE

59.

IPMC 305.I

1321

KITCHEN: BACKSPLASH ROTTEN-REPLACE

60.

IPMC 305.3

1321

DINI:--:G ROOM: OPENING HEADER WALL-- REPAIR, PREPARE & PAINT

61.

!PMC 305.3

1321

BEDROOM: 4TH_HALLWAY WALL HAS HOLE--REPAIR, PREPARE & PAINT

3RD __

SMOKE DETECTORS NOT SOUNDING-REPLACE

4

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 104 of 146

Exhibit F

62.

IPY!C 305.6

1321

BEDR00\11: 41 "-CLOSET DOOR HAS IIOLE-REPI.ACE

63.

IPMC 305.6

1321

BEDROO'vl: 4rn-DOOR KNOB-PROVIDE

64.

IPMC 305.6

1321

BATHROOM: 2:-.;D FLOOR-DOOR JAMB DEFECTIVE-REPLACE

65.

IPY!C 305.6

1321

BATHROOM: 2:-:n FLOOR-DOOR BROKEN·-NO LOCK--REPLACE

66.

IPMC 305.1

1321

DINING ROOM: SOFFJT AREA LEAK & HOLE-- REPAIR. PREPARE & PAD:T

67.

lP'.'vlC 305.5

1321

ST/'1RS: HANDRAIL LOOSE-SEClJRE

68.

IPY!C 305.6

1321

BEDROOM: 2"' 0 -DOOR HAS HOLES-REPLACE

69.

!PMC 305.6

1321

BEDROOM: 3RD··-CLOSET DOOR HAS HOLE-REPLACE

70.

IPMC 305.3

1321

BEDROOM: 3RD_WALL AT VENT-- REPAIR. PREP.t\.RE & PAJNT

71.

ll'MC 309.1

1323

I1'FESTATION OF ROACHES: EXTERMI1'iATE & PROVIDE CITY WITH REPORT

72.

IP'.'v1C 604.1

t .J. ..,"'
.... .)

NO ELECTRIC IN liN!T-MUST BE TURNED 0:--J IJ\ 72 HOURS OR TENANT MUST VACA TE
UNIT (MAXAGE.'v!ENT .'-iOT!FIED) - ABATED

73.

IPMC 704.2

1325

FLOOR: I sr -SMOKE DETECTOR BATTER MISSING-PROVIDE

74.

!PMC 402.3

1325

BATHROOM: 1ST FLOOR-VENT FAN DEFECTIVE-REI' AIR/REPLACE

75.

IPMC 605.3

1325

BATHROOM: lsT FLOOR: LIGHT GLOBE AT STAIRWAY - PROVIDE

76.

IPMC 504.1

1325

KITCHEN: SINK AERATOR-PROVIDE

77.

IPMC 305.6

1·r
)_)

1~ 1 FLOOR: CLOSET DOOR HAS HOLE-REPLACE

78.

IPMC 704.2

1·r
)_)

2ND

FLOOR: ELECTRIC SMOKE DETECTOR REMOVED-PROVIDE

5

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 105 of 146

Exhibit F

79.

ll'MC 305.1

i:;25

BATHROOM: 2'D FLOOR-TOILET SEAT MISSING-. PROVIDE

80.

ll'MC 504.1

1325

BATHROOM: 2:sD fLOOR--FAUCET DRIPPING-REPAIR

81.

IPMC 305.3

1325

BATHROOM:

82.

IPMC 704.2

1325

BEDROOM: REAR-PROVIDE SMOKE DETECTOR

83.

!PMC 305.6

1325

BEDROOM: 2' 0 ---DOOR BAS HOLE-REPLACE

84.

IPMC 305.1

1325

BEDROOM: 2'D -SOMEOJ\E LEFT FECES O:si FLOOR-CLEA>) lJP

85.

IPMC 305.1

] '1
)~)-

POOR HOUSEKEEPING-CLEAN CP

86.

TPMC 305.3

1327

BATHROO:-vl: IST FLOOR-WALL FLAKING-- REP AIR, PREPARE & PAf!\'.T

87.

!PMC 305.l

1327

KITCHEN: BACKSPLASH ROTTEN-REPLACE

88.

IPMC 305.3

1327

LIVI\:G ROOM: WALL AT SWITCH HAS HOLE- REPAIR. PREPARE & PAINT

89.

IPMC 704.2

1327

2'D FLOOR-ELECTRIC SMOKE DETECTOR DEFECTIVE-REPLACE

90.

IPMC 305.3

1327

BATHROOM: 2:,;n FLOOR CEILING HAS MOLD-- REPAIR. PREPARE & PAINT

91.

IPMC 305.3

1327

BATHROOM: 2:-;D FLOOR-FLAKJ).IG PAmT-- REPAIR, PREPARE & PAINT

92.

IPMC 305.3

1327

BEDROOM: lsr_WALL IlAS HOLD-· REPAIR, PREPARE & PAI'?\T

93.

IPMC 704.2

1327

BEDROOMS: ALL-SMOKE DETECTORS-PROVIDE

94.

IPMC 702.1

95.

IPMC 704.2

1329

BEDROOMS: FRONT & REAR-SMOKE DETECTOR NOT SOUNDNG-REPI.ACE

96.

!PMC 704.2

1330

SMOKE DETECTOR: MISSING HARD WIRE 0:"J 1sT FLOOR-PROVIDE

.,_)

1-r

i"D FLOOR--CEIL!NG HAS !\10LD-- REPAIR. PREPARE & Pi\!NT

BEDROOM: FRO)!T-WINDOW HAS A.IC 1.JNIT TBA T BLOCKS EGRESS--REMOVE

6

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 106 of 146

Exhibit F

FLOOR: :v11ss1:--;G GLOBE ON FLIGHT FIXTCRE-PROV!DE

97.

IPMC 605.3

1330

IS)

98.

IPMC 304. 18

1330

REAR DOOR DOES NOT LOCK PROPERLY-· REPAIR/REPLACE

99.

IPMC 305.1

1330

KITCHEN: MISSING EDGES AND LOOSE EDGES-REPLACE

100.

IPMC 305.3

1330

BATHROOM: CEILING HAS MOLD AND FLAKING PAI1'T-- REPAIR. PREPARE & PAINT

lOL

IPMC 704.2

1330

SMOKE DETECTORS: LOW BATTERIES TIIROUGIIOUT-REPAIR/PROVlDE

l 02.

IP:'v1C 305.6

1330

BEDROOM: 3R 0 -DOOR STICKS AT STRIKE PLATE--REPAIR

103.

1P.'.'v1C 305.l

1331

STOR\,f DOOR: FRONT !IA;'JDLE BROKEK-REPLACE

104.

IPMC 304.14

l 331

WfNDOW: SCREENS HAVE HOI.ES-REPAIRJREPJ.ACE

105.

IPMC 704.2

1331

BJ\THROOM: IST FLOOR-GFCl DEFECTIVE-REPLACE

106.

IPMC 305.1

1331

KITCHEN: BASE CABNET & SINK-REPLACE

107.

IPMC 305.3

133 l

BATHROOM: 2:st) FLOOR-CEILTI\G-- REPAIR. PREPARE & PAINT

108.

JPMC 304.13

1331

BATHROOM:

109.

IP\,fC 704.2

1331

BEDROOM; 151-SMOKE DETECTOR NOT SOUNDING-REPLACE

110.

IPMC 704.2.

1331

BEDROOM: 2ND_SMOKE DETECTOR-PROVIDE

111.

IP'.\1C 704.2

1331

BEDROOM: 3RD_ SMOKE DETECTOR NOT SOli1'DlNG-REPLACE

112.

!!'MC 305.1

1331

KITCHEN: REFRJGERATOR BULB-PROVIDE

I 13.

IPMC 704.2

1332

KITCHEN: GFCI OPEN GROUND-REPAIR/REPLACE

114.

IPMC 702.3

l JJ"' . . ')

BEDROOM: KEY LOCK-REMOVE- NOT PERMITTED

2ND

-WINDOW-REPAIR/REPLACE

7

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 107 of 146
115.

IPMC 704.2

l "7

""-

BEDROOM: NO Slv10KE DF.TECTOR--PROV!DE

116.

IPMC 305.3

1_,.J
"" .......J

BATHROOM: 2"D__ RF.PAIR. PREPARE & PAINT

117.

ll'MC 604.3

1.., .) .)

BATHROOM: 2"D-GFCI PAINTED OVER- -REPLACE

118.

IPMC 402.3

1333

BA TllROOM: l sr FLOOR-VENT FAN DEFECTIVE--REP AIR/REPLACE

119.

!PMC 704.2

1333

BEDROOM: REAR-SMOKE DETECTORS NOT SOCNDING-REPLACE

120.

IPMC 704.2

1333

BEDROO;vl: FRONT-SMOKE DETECTORS NOTSOUND!NG-REPLACE

121.

IPMC702.3

1334

BEDROOM:

122.

IP:\1C 304.13

1334

LIVING ROOM: \V!NDOW CRACKED-REPLACE

123.

!!'MC 304.14

1334

Wll\:DOWS: SCREENS THROCGHOUT

124.

IPMC 305.3

1334

DINING ROOM: CHIPPl:sG PA!NT-- REPAIR, PREPARE & PAl1.\T

125.

IPMC 603.3

1334

CLOTHES HANGING ON GAS Ll>JE-REMOVE

]26.

IPMC 504.l

1334

BATHROOM: 2"D-TUB-RECAULK

127.

!P'v!C 604.3

1334

BEDROOM: MASTER-WALL OUTLET-FIRE DAMAGE-REPLACE

128.

IPMC 304.13

1334

BEDROOM: 2"D-Wl1"DOWS HAVE :\10LD-- REPAIR. PREPARE & PA!);T

129.

IPMC 604.3

1334

BEDROOM: 2~u-OUTLETS OLD-REPLACE

130.

IPMC 704.2

1334

BEDROOM: SMOKE DETECTORS NEED BATTERIES--PROVJDE

131.

IP:vlC 305.1

1335

KITCHEN: BACKSPLASH-RE-CAULK

132.

IP'v1C 305. l

1335

KITCHEN: COll:S:TERTOP EDGING-PROVIDE

"'"I "'1

f

1

-DOOR KEY LOCKS-REMOVE- NOT PERMITTED

.

8

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 108 of 146
133.

lP\1C 305.3

1335

ATTIC ACCESS: PEELING PAJ:\T-- REPAIR. PREPARE & PAINT

134.

11''.vlC 704.2

1335

LOW BATTERY Cl IIRP-·PROVIDE BATTERlES

135.

IP\1C 605 .2

1335

BATl !ROOM: GFCI-RfPLACE

136.

IPMC 305.3

1335

BATH.ROOM: FLAKING PA!KT-- REPAIR. PREPARE & PANT

137.

IPMC 604.3

1336

BATHROOM: Y, BATH--PAINTED GFCI--REP1'\lR

138.

!PMC 604.3

1336

KITCHEN: PAINTED GFCI--REPAIR

139.

IPMC 305.I

1337

K!TCHE\: BACKSPLASH-RECAl.iLK

140.

IPMC 305.l

1337

KITCHEi\: COL'?(TERTOP EDGING-RE-AITACH

141.

IPMC 702.l

1337

STAIRW/1. Y: BOOK SHELF AT BOTTOM OF SL\IRS-REMOVE

142.

IPMC 704.2

1337

BEDROOMS: ALL-- SMOKE DETECTORS NOT SOU:\DJNG-REPLACE

143.

IPMC 504.1

1338

BATHROOM: 1sT FLOOR-SINK LOOSE-REPAIR

144.

IPMC 603.3

1338

KITCHEN: STOVE-FRONT LEFT BURNER DEFECTIVE-REPAIR

145.

IPMC 704.2

1338

I ST FLOOR-SMOKE DETECTOR NOT SOU:\D!KG--REPLACE

146.

IPMC 605.l

1339

KITCHEN: CLOSET BY STOVE-LIGHT r!XTURE LOOSE-REPAIR

147.

!PMC 704.2

1339

BEDROOMS: ALL--SMOKE DETECTORS NOT SOUNDING-REPLACE

148.

lPMC 604.3

i340

KITCHEN: STOVE-·GFCI PAINTED OVER-REPAIR/REPLACE

149.

IPMC 604.3

1340

BATHROOM: !IALF: PAlNTED OVER GFCI-REPAIR/REPLACE

150.

!PMC 604.3

1340

BATHROOM: 2:-:D HALL-- PAINTED OVER GFCI-REPAIR/REPLACE

9

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 109 of 146

Exhibit F

151.

lPMC 704.2

1340

LOW B.i\TTERY CHIRP-REPLACE

152.

lPMC 603.3

1340

STORAGE IN FCR\'ACE CLOSET--REMOVE

153.

IPMC 305.3

1341

BA TIIROOM: REPAINT

154.

IPMC 305.2

1341

IIALL WAY: 2:-:o FLOOR CEILING-RE-ATTACII TO RAFTERS

155.

IPMC 305.3

1341

HALI.WAY: WALL HAS HOLE-- REPAIR. PREPARE & PAINT

156.

IPMC 704.2

1341

BEDROOMS: ALL-- S:'.10KE DETECTORS NOT SOUNDING-REPLACE

157.

IPMC 403.5

1342

KITCI !E::--;: DRYER \1UST VEJ\'T OUTSIDE-REPAIR

158.

IPMC 504.1

1342

BATHROO'v1: 2:-:D TUB-RECAlJLK

159.

IPMC 305.3

1342

BATHROOM: 21' 0 -CEIL!NG & WALL HAVE MOLD--REPATR. PREPARE & PAIN"T

160.

11':v!C 504.1

1342

BATl!ROO:V!: 21' 0 -SJNK DETACHED FROM WALL-REPAIR

I 61.

lP.'.v!C 305.6

1342

BATl IR00\1: DOOR JAMB DEFECTIVE--REP AIR

162.

IPMC 305.6

1343

BATHROO.'.vl: DOOR-- PREPARE & PAINT

[63.

IPMC 704.2

1343

BEDROOM: i' 0 -S:'v10KE DETECTOR J\'OT SOUc'JDING-REPI.ACE

164.

IPMC 305.3

1344

KITCHEN: CEILING HAS WATER DAMAGE-- REPAIR. PREPARE & PAINT

l 65.

IPMC 404.4

1345

LIVl:'<G ROOM: REMOVE COT-CAJ\"J\'OT HAVE BED HERE

166.

lPMC 704.2

1345

BEDROOMS: ALL-SMOKE DETECTORS-PROVIDE

167.

IPMC 108.2

1346

BOARDED: V/\CANT

168.

IPMC 309.l

1346

INFESTATION OF BED BUGS--EXTER.'v!Il\ATE
10

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 110 of 146
169.

!P~1C 309.1

]348

JNFESTATlON Of BED Bl3GS- EXTERMINATE

170.

IPMC 704.2

1349

BEDROOM: 3RD --SMOKE DETECTORS NOT SOCNDTNG-R.EPLACE

171.

IPMC 305.3

1350

STAIRS: LANDING HAS MOLD-- REPAlR. PREPARE & PAINT

172.

IPMC 305.3

1350

BEDROOM: 2~ll & 3RD_WALL DEFECTIVE-- REPAIR. PREPARE & PAINT

\ 73.

lPMC 305.4

1350

BATHROOM: FLOOR TILES DEFECTIVE-REPLACE

174.

Il'MC 305.3

1350

BATHROOM: WALL NEAR TOJLET-LEAK-- REPAIR. PREPARE & PANT

175.

IPMC 305.3

\350

BATHROOM: WALL HAS MOLD-- REPAIR. PREPARE & PAIKT

I76.

IPY!C 305.4

\350

STAIRWAY: 4T 11 STEP UP IS DEFECTIVE-REPAIR

177.

TPMC 305.3

\350

STAIRWAY: WALL HAS HOLE-- REPAIR. PREPARE & PAIJ\:T

178.

IPMC 704.2

1350

BEDROOMS: ALL-- SMOKE DETECTOR NOT SOU'.\DJNG-REPLACE

179.

IPMC 305.l

1350

POOR IIOUSEKEEPING-MvST BE CLEANED

180.

IPMC 305.1

1351

KITCHEN: COUNTERTOP EDGING-PROVIDE

I 81.

TPMC 704.2

135]

BEDROOMS: ALL-- SMOKE DETECTORS NOT WORKING-REPLACE

182.

IPMC 603.l

1352

KITCHEN: STOVE-BCRNER DEFECTIVE-REPAIR/REPLACE

183.

IPMC 504. l

1353

BATHROOM: TOILET LOOSE-REPAIR/REPLACE

184.

IP~1C 704.2

1353

BEDROOM: 2" 0-SMOKE DETECTORS :'JEED BA TTERJES--PROVIDE

185.

ll'MC 704.2

1353

BEDROOMS: ALL-SMOKE DETECTORS-PROVIDE

186.

IPMC 108.2

1353

VACANT: REHAB UNIT

11

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 111 of 146

Exhibit F

. 187.

IPMC' 605.2

1353

BATHROOM & KITCHEN: PROVIDE GFCTS

188.

IP:VlC 605.1

1354

E'.\:TR/\'\CE: RE-ATTACH OUTDOOR LIGHT FIXTURE

189.

!PY!C 605.2

1354

KITCHEN: REPLACE GFC!

190.

IPMC 604.3

1354

LOOSE RECEPTACLES THROUGHOUT UNIT- -REP AIRJREPLACE

I 91.

IPMC 305.6

1354

STAIRWAY: HOLE IN DOOR AT BOTTOM OF STAIRS-REPAIR/REPLACE

192.

IPMC 305.4

1354

HALLWAY: 2ND FLOOR--BROKEN FLOOR TILE-REP AIR/REPLACE

193.

IPMC 604.3

1354

BEDROOM: 2ND-OUTLET SPARKJ'\G-REPLACE

194.

IPMC 305.6

1354

BEDROOM: 2ND····BROKEN DOOR FRAME AND MISSING DOOR STRIKE--RE!'AIR/REPI.ACE

195.

IPMC 305.3

1354

BATHROOM: 2°'u FLOOR-MOLD. MILDEW. FLAKNG PAINT-- REPAIR, PREPARE & PAINT

196.

IPMC 305.l

1354

BATHROOM: 2"ll FLOOR-FLAKING PAll\T ON DOOR-- REPAIR. PREPARE & PAINT

197.

IPMC 504.1

1354

BATHROOM: 2"n FLOOR-TOILET RU)J:\'!NG-REPJ\IR/REPLACE

198.

IPMC 305.3

1355

BATHROOM: 2~l> FLOOR-CEILING HAS MOLD·· REPAIR. PREPARE & PAI:S:T

199.

fPMC 704.2

1355

BEDROOMS: ALL TIIREE-SMOKE DETECTORS-PROVIDE

200.

IP:'v!C 305.5

1355

STAIRWAY: HANDRAILS FLAKING PINT-- REPAIR. PREPARE & PAINT

201.

IPMC 304.14

1356

WINDOWS: PROVIDE SCREENS

202.

IPMC 403.5

1356

KITCHEN: DR YJNG MUST VENT OUTSIDE-REPAIR

203.

IPMC 305.J

1356

BATHROOM: TOILET SEAT DEFECTIVE-REPAIR/REPLACE

204.

IPMC 305.J

1356

BATHROOM: TOWEL BAR-PROVIDE

12

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 112 of 146

Exhibit F

205.

IPMC 504.1

1356

BATHROOM: TOILET 1-IANDLE DEFECTIVE-REPLACE

206.

IPMC 30-U5

1356

SCREEN DOOR HANGS UP-WON'T SHUT-REPAIR/REPLACE

207.

IPMC 704.2

1357

BEDROOM: 151-SMOKE DETECTOR NOT SOUNDING--REPLACE

208.

IPMC 704.2

1358

BEDROOM: 2'' 0 & 3R,'.)-SMOKE DETECTORS NOT SOUNDING-REPLACE

209.

!PMC 305.3

1358

BATHROOM: CEILING HAS MOLD- REPAIR, PREPARE & PAI?>:T

210.

lPMC 504.1

1358

BATHROOM: TOILET LOOSE-REPAIR/REPLACE

211.

IPMC 704.2

1358

HALLWAY: 2"D FLOOR SMOKE DETECTORS NOT SOUND!!'iG--REPLACE

212.

IPMC 704.2

1359

I ST FLOOR-SMOKE DETECTOR HANGING-SECURE

213.

IPMC 604.3

1359

HALLWAY: I 5T FLOOR-LIGHT DEFECTIVE-REPAIR/REPLACE

214.

IPMC 605.2

1359

KJTCHEN: GFCI-PROVIDE

215.

IPMC 603.1

1359

MECHANICAL ROOM: FCRl'\JACE FLUE PIPE-RE-PIPE

216.

IPMC 605.2

1359

BATH.ROOM: 1sT-GFCI-PROVIDE

217.

IPMC 402.3

1359

BATHROOM: I sT_VENT F.tv"i DEFECTIVE-REPLACE

218.

lPMC 305.1

1359

BA TH.ROOM: 2" 0 -TOILET SEAT-PROVIDE

219.

IPMC 305.3

1359

BATH.ROOM: 2" 0 --CEILING DEFECTIVE-REPAIR, PREPARE & PAINT

220.

IPMC 704.2

1359

BEDROOM: REAR-BOTH-SMOKE DETECTORS NOT SOlJNTIING-.REPLACE

221.

IPMC 704.2

1359

HALLWAY: 2ND FLOOR-- SMOKE DETECTORS NOT SOUNDING-REPLACE

222.

IPMC 603.1

1360

KITCHEN: STOVE-RIGHT SIDE DEFECTIVE-REPAIR

13

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 113 of 146

Exhibit F

__ .,'
""'

IPJ\1C 305. l

1360

KITCl!E:s: C<ll ;;,;TERTOP \1ISSll\Cj FDGE

22-t

JP!\1C 70-\.2

1.360

1' FLOOR: S\10KE DETECTOR- PROVl!)I' llARD WIRED

225.

IPMC 30-l.14

1360

BATIIR00\1: RIPPED SCREE:\ 11' WINDOW -REPLACE

116.

IPMC 30~.3

13(,0

HALL \VAY: Ol.'TSIDE OF J' BEDR00\1-1101.E I): WAI.I.-- REPAIR. PREPARE & PAJ):T

127

IPMC 70-l.2

1360

BEDROO:vl: 2"ll-Stv!OKE DETECTOR--REPLACE

128.

JP\1C 305.3

1360

BEDR00\1: 2' 1'

229.

!!'MC 604.3

1360

Ol ;·n.ETS: Tl IROCGHOUT ARE LOOSE-·REPAIR/REPI.ACE

130.

IP'.\1C 305.4

1360

BEDR00\1: 2"1>. REP,\IR FLOOR TILE

231.

lPMC 604.3

1361

BATIIR00\1: I'rFLOOR-GFCI REVERSE POLARITY--REPLACE

232.

IP'.\1C 605.2

1363

KITCHE):: GFCI-PROVIDE

__
.,.,
?"

JPMC 504.l

1363

KITCHEN: SJ;,;K FACCET DRIPP!):G & LOOSE-REPAIR

234.

IP\1C 305. I

1363

KITCIIE):: cot.·:sTERTOP EDGING-PROVIDE

__
?·)).
-

IPMC 305.6

1363

BEDROOM: 2"'··-DOOR IIAS !!Ol.1:-REl'LACE

,.:._, .
"'6

IP\-!(. 70-l.2

1363

BEDR00\.1S: ,\LL--S'.v10KE DETECTORS-· PROVIDE

237.

IPMC 305.l

1364

ENTRANCE DOOR: PA!Nr CHIPl'ED-REPAIR

238.

IP'.\1C 504.1

1364

BATHROO\!: Jsr FLOOR-FAL'CET LEAKJ:s;G WHE?\ Tt:RNED 0):-REl',\IR

239.

IPMC 305.3

1364

BATHROOM:

2-\0.

IP'.\1C 604.3

1365

KITCHE):: Gl'Cl DEFECTIVE-REPLACE

REPAIR ·Rl'PLACE

1

1

-

\VALi. AROUND AIR (0):D!TIO~l'R-SEA!.

1"° FLOOR-WALi. & CEIi.ING !!AVE \10LD-- REPAIR, PREPARE & PAl~ff

14

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 114 of 146

Exhibit F

241.

IP:V1C 104.2

1366

NO E:--:TRY: SCREENS LOCKED-PROVIDE ACCESS UPON NEXT l'\SPECTIO);

242.

IP:VIC 403.5

1367

KITCHEN: DRYER-REMOVE

243.

IPMC 305.6

1367

BEDROOM: 2"ll---CLOSET DOOR HAS HOLE-REPLACE

244.

JPMC 104.2

1368

NO ENTRY: SCREENS LOCKED-PROVIDE ACCESS UPON NEXT IJ\SPECTJON

245.

lPMC 304.7

1368

GUJTERS FALLING OFF: REPAIR

246.

IPMC 605.2

1369

KITCHEN: GFCI - PROVIDE

247.

IPMC 603.1

1369

KITCHEN: STOVE-LEFT FRONT BURNER DEFECTIVE-REPAIRJREPLACE

248.

!PMC 704.1

1370

SMOKE DETECTORS-LOW BATTERY CHIRP THROUGHOUT-REPLACE

249.

IPMC 305.3

1370

HALLWAY: HOLE IJ\ WALL NEAR BATHR00:\1-- REPAIR, PREPARE & PAINT

250.

IPMC 305.1

13 70

KITCHEN: COUNTERTOP BEHIJ\D SINK: RECAlJLK

251.

IPMC 604.3

1370

LOOSE OUTLETS THROUGHOUT-REPAIR/REPLACE

252.

lPMC 603.3

1370

FURNACE ROOM: RE:V10VE STORAGE

., -,

_)j.

IPMC 305.6

[370

FCRNACE ROOM: REPAIR DOORS

254.

IPMC 305.3

1370

BATHROOM: 2Nv FLOOR--MOLD ON CE!Lll\G-- REP,'\IR. PREPARE & PAINT

255.

IPMC 305.6

1370

BEDROOM: lsT_DOOR OFF HINGES-REPAIR

256.

IPMC 704.2

1370

BEDROOM: I si-SMOKE DETECTOR NOT WORKING-REPLACE

257.

IPMC 704.2

1370

BEDROOM: 2"n -SMOKE DETECTOR NOT WORKING-REPLACE

258.

IPMC 305.6

1370

BEDROOM: 2:sD_DOOR HANDLE-REPAIR

15

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 115 of 146
259.

!PMC 704.2

1370

BEDROOM: 3"" -SMOKE DETECTOR NOT WORKl'\G- REPLACE

260.

11':vtC 305.3

1370

BEDROOM: 3RD_SEAL AROUND A/C UNIT

261.

IPMC 104.2

1370

BEDROOM: 4 111- LOCKED-PROVIDE ACCESS UPON NEXT INSPECTJO?\

262.

IPMC 305.I

1371

KITCHE'.'J: CEILJNG-REPAL\IT

263.

lPMC 305.3

1371

BATHROOM: 2" 0 -CEILING HAS MOLD-- REPAIR, PREPARE & PAINT

264.

IPMC 305.3

1371

HALLWAY:

265.

IPMC 704.2

\371

2"D FLOOR: ELECTRIC SMOKE DETECTOR :'.\:OT SOU:sDI::sJG-REPLACE

266.

IPMC 304.14

1372

BEDROOM: SCREEN-REPAIR

267.

IPMC 309.1

1372

INFESTATION-EXTERMINATE

268.

IPMC 704.2

1372

SMOKE DETECTORS: PROVIDE

269.

lPMC 305.3

1372

KITCHE?\: HOLE I:s \VALL-- REPAIR. PREPARE & PAINT

270.

!!'MC 305.3

1372

KITCHEN: MOLD-- REPAIR. PREPARE & PAII\T

271.

IPMC 305.1

1372

POOR HOUSEKEEPING-\1UST CLEAN

272.

IPMC 605.3

· 1372

273.

IPMC 603.l

1372

KITCHEN: STOVE-REAR RIGHT BlJR:\JER DEFECTIVE-REPAIR/REPLACE

274.

IPMC 704.2

1373

BEDROOM: lST-SMOKE DETECTORS NOT SOUNDING-PROVIDE

275.

IPMC 305.l

1373

BEDROOM: 3RD_WALL HAS HOLE-- REPAIR, PREPARE & PAINT

276.

IP\-1C 304.2

1374

EXTERIOR: SIDING ON PORCH-REPAIR

i'm FLOOR CEILING-REPAINT

MISSING LIGHT F!XTURE--PROVIDE

16

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 116 of 146

Exhibit F

277.

IPMC 104.2

1374

:--;o ENTRY: SCREEN DOOR LOCKED-PROVIDE ACCESS UPOI'\ "lEXT 11'\SPECTIO~

278.

IP\1C 704.2

1375

lq FLOOR: ELECTRIC SMOKE DETECTORS NOT SOCNDING-REl'LACE

279.

JP\1C 704.2

1375

BEDROO:V1S: ALL-SMOKE DETECTORS-PROVIDE

280.

lPMC 305.3

1376

KITCHEN: WALL AT BACK DOOR DEFECTIVE-- REPAIR. PREPARE & PAINT

281.

IPMC 304.13

1376

KITCHEN: WINDOW AT BACK DOOR DEFECTIVE-REPAIR/REPLACE

282.

IPMC 305.6

1376

BEDROOM: 1s r-DOOR-REPLACE

283.

IPMC 304.13

1376

BATHROOM:

284.

IPMC 305.3

1376

BATHROOM: 2""-MOLD-- REPAlR, PREPARE & PAINT

285.

IPMC 504.1

1376

BATHROOM: 2"D-RECAULK

286.

IPMC 305.2

1376

BATHROOM: 2" 0 SOBFLOOR ROTTEX-REPLACE

287.

IPMC 305.1

1376

BATHROOM: 2"u TOWEL BAR-PROVIDE

288.

IPMC 305.3

1376

BATHROOM: 2"° FLOOR CETLI:--JG PEELING PAINT-- REPAIR. PREPARE & PAINT

289.

IPMC 305.3

1376

IIALLW A Y: 2"" FLOOR-- REPAIR. PREPARE & PAINT

290.

IP\1C 305.5

1376

HANDRAILS: SPINDLE MISSING-REPLACE

291.

IPMC 309.1

1376

INFESTATIO>I OF MICE: EXTERMINATE & CLEAN UP

292.

IPMC 309.1

1376

MECHANICAL CLOSET: INFESTATION OF MICE-EXTERMINATE & CLEAN UP

293.

IPMC 603.1

1377

KITCHEN: STOVE-RIGHT FRONT BURNER DEFECTIVE-REPAIR/REPLACE

294.

IPMC 305.1

]377

KITCHE>-1: COGNTERTOP EDGING-PROVIDE

i' 0 -WIND0W CRACKED AND OFF TRACK-REPAIR

17

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 117 of 146

Exhibit F

295.

IPMC 305.3

1377

BATHROOM: 2' 1) Fl.OOR-CEIU'sG HAS MOLD-- REPAIR. PREPARE & P/\.ll\T

296.

IP:VIC 305.1

1377

BATHR00\1: 2'n FLOOR-TOILET PAPER HOLDER-PROVIDE

297.

IP:v!C 309.2

1377

GRAFFITI ON BRICK WALL-REMOVE & CLEA~-1..IP

298.

lPMC 304.2

1377

EXTERIOR GABLE VENT-BROKEN-REPAIR/REPLACE

299.

IPMC 704.2

1378

BEDROOMS: 2Nll & 3RD -- SMOKE DETECTORS :-JOT SOUNDI:-JG-REPLACE

300.

IP:-..1C 403.5

1378

DRYER: MUST VENT OUT OR REMOVE

301.

IP!vlC 504.1

1378

BA TIIROOM: TOILET NOT FLUSI!ING-REPAIR

302.

!PMC 305.1

1378

BATHROOM: CEILING HAS MOLD-- REPAIR. PREPARE & PAINT

303.

lPMC 305.3

1378

BATHROOM: WALL TILE FALLl!\G OFF--REPAIR/REPLACE

304.

!PMC 305.3

1378

BEDROOM: ls1-AIR CONDITIONING lNIT-REMOVE

305.

IP\<!C 305.1

1379

KITCHEN: COUNTERTOP EDGE-PROVIDE

306.

!P:-JC 504.1

1379

BA TH ROOM:

2:-JD

FLOOR-TOILET LOOSE-REP AIR

307.

IPMC 305.l

1379

BATHROOM:

2):D

FLOOR-SEAT BROKEN ·-REPLACE

308.

IPMC 704.2

]379

SMOKE DETECTORS: I.OW BATTERY CHJRP-PROVJDE BATTERUES

309.

lPMC 305.1

1379

BATHROOM: 2'° FLOOR-TOWEL BAR & TOILET PAPER IIOLDER--PROVIDE

310.

IPMC 305.1

1380

KITCI !EN: MISSING COCNTERTOP EDGE-REPLACE

311.

IPMC 603.1

1380

KITCHEN: LEFT FRONT BUR.:"IER NOT LIGHT!NG-REPAIR/REPLACE

312.

IP\1C 305.6

1380

STAIRWAY: HOLE IN DOOR AT B01TOM OF STAIRS-REPAIR/REPLACE

18

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 118 of 146

Exhibit F

313.

lPMC 604.3

1380

BATHR00\1: GFC! PAINTED OVER-REPAlRtREPLACE

314.

!PMC 305.3

1380

FLAKINGiPEELl"1G PAINT BY PANEL-- REPAIR. PREPARE & PAINT

315.

lPMC 603.l

1381

KlTCIIEN: LEFT FRONT Bl.!R.;'\JER DEfECTIVE-REPJ\IR/REPLi\CE

3 J6.

IPMC 704.2

1381

1ST & i'D FLOOR: ELECTRIC SMOKE DETECTORS l\OT SOUNDl;s.:G-REPLACE

3 l 7.

!PMC 704.2

1381

BEDROOMS: ALL-SMOKE DETECTORS-PROVIDE

318.

IPMC 604.3

1382

KITCHE:-;: GFCI AT STOVE DEFECTIVE-REPLACE WITH GFCI

319.

IPMC 603.3

1382

GJ\SLINE: REMOVE HANGERS

320.

IPMC 305.l

1382

BATIIROOM: TOILET PAPER HOLDER-PROVIDE

321.

IP\1C 305.3

1382

BATHROOM: WALL TILES-RE-GROUT

322.

IPMC 504.1

1382

BATHROOM: TUB-RECAULK

323.

lPMC 305.6

1382

BATHROOM: DOOR-REPLACE

324.

IPMC 305.5

1382

STAIRWAY LANDING: liPSTAlRS-MOLD & CHIPPED PAINT-- REPAIR, PREPARE & PAI"t\T

325.

IPMC 305.3

1383

DINING ROOM: WALL HAS HOLE-- REPAIR, PREPARE & PAINT

326.

IPMC 305.1

1383

KITCHEN: SINK BASE CAB!:\ET-BROKEK DOOR-REl'A!R/REl'J.ACE

327.

IP:vl.C 305. I

1383

KITCHEN: COUNTEROP EDGING-PROVIDE

328.

lPMC 605.3

1383

MISSING LIGHT GLOBE: PROVIDE

329.

IPMC 704.2

1383

1sT l'LOOR: ELECTRIC SMOKE DETECTORS NOT SOUNDl:\'G-REPLACE

330.

IPMC 704.2

1383

BEDROOM:

3RD __

ELECTRIC SMOKE DETECTORS NOT SOUNDING-REPLACE

19

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 119 of 146

Exhibit F

.3 31.

IPMC 305.1

1384

KITC!IP,: PAJNT

332.

IPMC 305.1

1384

BATHROOM: PAINT

.)_1.).

""

IP:\1C 704.2

1384

BEDROOM:

334.

!PMC 603.1

1385

KITCHEN: STOVE-TWO FRO:\T BUR~ERS DEFECTIVE-REPAIR/REPLACE

335.

fPMC 603.1

1385

KITCH El\: GFCI AT STOVE DEFECTIVE-REPLACE

336.

!PMC 603.3

1385

MECHA2'ICAL ROOM: CLOTHES DRYING ON DUCT WORK-REMOVE

337.

IPMC 702.3

1385

BEDROOM:

338.

IPMC 704.2

1385

BEDROOM: 3RD-SMOKE DETECTOR NOT SOUNDNG-REPLACE

339.

IP1\1C 305.1

1387

KITCHEN: COUNTERTOP EDGING-PROVIDE

340.

!PMC 605.3

1387

HALLWAY: 1s-r & 2"1l FLOOR-LIGHT GLOBE-PROVIDE

341.

IPMC 304.15

1387

FRO:\T DOOR: TRIM MISSING-PROVIDE

342.

JPMC 305.2

1387

FRONT DOOR: FLOOR BEi ll2'D DOOR HAS HOLE-REPAIR

343.

JPMC 305.3

1387

BATHROOM: 2l'D-WALL AT SWITCH HAS I !OLE-- REPAIR. PREPARE & PAINT

344.

IPMC 704.2

1387

BEDROOMS: ALL-- SMOKE DETECTOR NOT SOUNDING-REPLACE

345.

IPMC 704.2

1387

LOW BATTERY CHJRP-PROV!DE BATTERIES

346.

IPMC 305.3

1388

LIVING ROOM: BUBBLE TN CEILING-

347.

IPMC 603.3

1388

FURNACE ROOM: REMOVE STORAGE ITEMS

348.

IPMC 605.2

1388

KITCHEN: REPLACE GFCI OVER STOVE

3R

0

-SMOKE DETECTOR--PROV!DE

i'0 HAS DEADBOLT-REMOVE

20

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 120 of 146

Exhibit F

349.

lPMC 305.l

1388

BEDROOMS: POOR IIOUSEKEEPI:\G-MCST BE CLEANED

350.

IPMC 704.2

1388

BEDROOM: 3"n-MlSSI:\G BATTERY IN SMOKE DETECTOR-PROVIDE

351.

lPMC 305.3

1388

BATHROO:V1: FLAKI'.\"G. PEELING PAINT ON CEILING--REPA!R. PREPARE & PAINT

352.

lPMC 504.1

1388

RATHR00:\1: TUB & SHOWER-RECAlJLK

353.

IPMC 305.1

1388

KITCHEN: BACKSPLASH-RE-ATTACH & CACLK EDGING

354.

IPYlC 304.14

1388

WINDO\V:

355.

IPMC 504.1

1389

KITCHE;\J: Sl>JK FAUCET-REPAIR/REPLACE

356.

!RC

315.1

1389

1

357.

IPMC 704.2

1389

BEDROO:vl: l si -SMOKE DETECTOR NOT SOl.iND!NG-REPLACE

358.

IPMC 704.2

1390

BEDROOMS: "10 SMOKE DETECTORS-PROVIDE

359.

IP:vJC 704.2

1390

1sr FLOOR: SMOKE DETECTOR l\:OT WORK!l\G---REPLACE

360.

IPMC 504.1

1390

BATHROOM: 1sr FLOOR TOILET LOOSE-REPAIR/REPLACE

361.

IPMC 402.3

]391

BATHROOM: ls·i FLOOR-VE"JT FAN DEFECTIVE-REPAIR/REPLACE

362.

JPMC 704.2

1391

BEDROO:vf: 1sT__SMOKE DETECTOR KOT SOUNDING-REPLACE

363.

IPMC 704.2

!391

BEDROOM: 2ND -SMOKE DETECTOR NOT SOUNDING-REPLACE

364.

IPMC 305.6

1391

BEDROOM: 2"n-DOOR JAMB BUSTED-REPLACE

365.

IPMC 704.2

1391

HALLWAY: 2:--JD FLOOR-ELECTRIC S'.'v!OKE DETECTOR NOT SOUNDING-REPLACE

366.

IPMC 704.2

1392

HALLWAY: SMOKE DETECTOR REMOVED-REPLACE

5
T

3RD

BEDROOM- REPAIR/REPLACE SCREEN

fLOOR: C.0. DETECTOR BEEPING-REPLACE

21

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 121 of 146

Exhibit F

367.

IP'.\!C 605.3

1392

KITCHE'.\: l.l(ilIT FIXTl 'RE MISSE\G---REl'I.ACE

368.

lP'.\lC 305.3

1392

KITCHE'\: ('Ell.ll\G lL\S \\'ATER D,\'.\lAGE-- REPAIR. PREPARE & l'Al'\T

:,69.

IPMC 704.2

1392

BEDROOM: SMOKE DETECTOR l\OT WORKING--REl'I.ACE

:,70.

!P'.\·lC l 04.2

1393

'\O E'.\TRY: SCREEK LOCKED- PROVlDE ACCESS l "PO::,.J RE-ll\SPECTIOl\

371.

!l':VlC 301 .2

1393

TRASH AROUND SHIU ,BS & FROC-:T PATIO AREA-CLEAN UP

;tT2.

!!':VIC 304.13

1394

Dl>ill\G R00!\1: WI:\DOW SCREWED SHUT. :\0 LOCKS-REPAIR & PROVJDE LOCK

373.

IPMC 305.1

1394

!STRANCE: FRONT STORM DOOR: PROVIDE HANDLE & l.OCK

374.

IP'.\lC 305.J

139:t

E:\TRA:\CE: PEEP !!OJ.ES HA VE BEE'.\ PAl:\TED-REP:\!R

375.

!PMC 504.1

1394

KITCHEN: SINK DRAll\-REPAIR

376.

!!'\IC 305. l

1394

KITCHE;s:: CABINET ABOVE STOVE-REPA!R/REl'!.ACE

377.

IPMC 704.2

1394

SMOKE DETECTORS Tl!ROUGl!OUT-REl'l.ACE

378.

ll'i\lC 603.l

]394

'.\'11:CHA'.\!CAL ROO'.\I: OLD VENT !'!PE. \\'ATER CO:VJES I'.\- REP,\IR & SEAL

379.

IPMC 403.5

1395

KITCHEN: REMOVE DRYER

380.

IP'.\1C 305. l

1395

HALL \VAY: lsr FLOOR DOOR-REPAIR

381.

IPMC 305.1

1395

POOR HOUSEKEEPING-MUST BE CLEANED

382.

IP'.\K' 704.2

1395

HALLWAY: 2"r, FLOOR-- ELECTRIC S'.\,10KE DETECTOR RE:VlO\'ED-PROV!DE

383.

IPMC 305.3

1395

BATHROOM:

384.

IP'.\1C 305.4

1395

CABLE WIRES ARE TR!PP!:\G llAi'.ARD: SECURE

2r-;D

FLOOR-WALL & CEILING IIAVE MOLD-- REPAIR, PREPARE & PAINT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 122 of 146

Exhibit F

385.

IPMC 304.13

!396

PORCH: WINDO\V SILL TRJM OVER PORCH-REPLACE

386.

IPMC 305. l

1396

TENAi'\JT IS THRO\VING GREASE OUT THE DOOR NEAR GAS METER-PROHIBIT

387.

IPMC 305.1

1396

KITCHEN: BROKEN CABINET DOOR-REPAIR/REPLACE

388.

IPMC 605.2

1396

BATHROOM:

2:<D

FLOOR-REPLACE GFCI

389.

IPMC 305.1

1396

BATHROOM:

2:<D

FLOOR-MISSTING TOWEL AND TOILET PAPER HOLDERS-REPLACE

390.

IP!\1C 305.1

1397

KITCHEN: CABINET CENTER STILE-PROVIDE

391.

IPMC 403.5

1397

KITCHEN: REMOVE DRYER

392.

IPMC 304.14

1397

LIVING ROOM: SCREENS DEFECTIVE-PROVIDE

393.

IPMC 704.2

1397

BEDROOM: 1ST -SMOKE DETECTOR NOT SOlJNDING-REPLACE

394.

IPMC 305.l

1399

SCREEN DOOR DEFECTIVE: REPAIR/REPLACE

395.

IPMC 604.3

1399

KITCHEN: GFCI PAINTED OVER-REPLACE

396.

IPMC 604.3

1399

1ST FLOOR: GFCI PAINTED OVER-REPLACE

397.

IPMC 305.1

1399

POOR HOUSEKEEPING-MUST BE CLEA1'-iED

398.

IPMC 309.1

1399

INFESTATION OF ROACHES-EXTERMINATE & PROVIDE REPORTS TO CITY

399.

IPMC 305.3

1399

BATHROOM: 2'' 0

400.

IPMC 305.1

1399

BATHROOM: 2:,; 0 -TO\VEL BAR-PROVIDE

401.

IPMC

1399

BEDROOM: FRONT-WINDOW H.t\S AIC u'NlT THAT BLOCKS EGRESS-REMOVE

402.

IPMC 305.l

1399

BEDROOM: FRONT-DOOR HAS HOLE-REPA.IR

-

CEILING HA.S CHIPPING PAINT- REPAJR. PREPARE & PAINT

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 123 of 146

Exhibit F

403.

IPMC 504.1

1-\00

BATHROOM: lsT FLOOR-FAUCET DRIPP!)\;G-REPAIR

404.

IPMC 305.3

1400

BATHROOM: 1ST FLOOR-FLAKING/PEELING PAI:'iT- REPAIR. PREPARE & PAINT

405.

IPMC 305.1

1400

KITCHEN: COUNTER TOP EDGES MISSING/LOOSE-REPAIR/REPLACE

406.

IPMC 305.1

1400

GREASE BEING THROVv"N OUT OF BACK DOOR NEAR GAS METER-PROHIBIT

407.

IPMC 309.1

1400

f\T-ESTA TION: THROUGHOUT-ROACHES/BUGS--EXTER.vl!NATE

408.

lPMC 305.6

1400

HALL \VAY: 2ND FLOOR-REPAIR DOOR Ki"\JOB OF HALL CLOSET-REPAIR/REPLACE

409.

IPMC 305.6

1400

STAIRWAY: DOOR AT BOTTOM-HOLES & HINGES-REPAIR/REPLACE

410.

IPMC 704.2

1401

BEDROOMS: ALL-SMOKE DETECTORS NOT SOUNDING-REPLACE

411.

!RC

315.1

1401

NO C.O. DETECTOR-PROVIDE ON LEVEL OF SLEEPING ROOMS

412.

IPMC 305.1

1402

STORM DOOR: SPRING ARM MISSING-PROVIDE

413.

IP\1C 305.3

1402

BATHROOM: 1sT FLOOR - HOLE IN WALL AT TOILET & DOOR-- REPAIR, PREPARE & P.L\INT

414.

IPMC 704.2

1402

I sr FLOOR: SMOKE DETECTOR NOT S01J1'DING-REPLACE

415.

IP:vlC 605.3

1402

Hi'.LL WAY: 1sT FLOOR- GLOBE MISSING-PROVIDE

416.

IPMC604.3

1402

SERVICE PANEL WALL HAS \VATER DAMAGE- REP.A.IR, PREPARE & PAINT

417.

IPMC 305.3

1402

BATHROOM: 2"° FLOOR- WALL AROUND TOILET DEFECTIVE-- REP AIR, PREPARE & PAl;';T

418.

IPMC 305.6

]402

BATHROOM: DOOR VOID-REPAIRIREPLACE

419.

IPMC 702.3

]402

BEDROOM: 1sr_REMOVE LOCK- NOT PERMITTED

420.

IPMC 305.6

1402

BEDROOM: 2" 0 AND 3RD -REPLACE DOORS

24

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 124 of 146

Exhibit F

421.

IPMC 305.3

1402

STAIR LANDI\'G: CIIIPl'ED PAINT-- REPAIR, PREPARE & PAINT

422.

!PMC 305.4

1402

STAJRWA Y: 6TH STEP TREAD-REPAJR/REPLACE

423.

IPMC 305.l

1402

KITCHEN: BASE CABINET-REPAIR/REPLACE

424.

IPMC 504. l

1402

BATHROOM: CAULK TUB AND PROVIDE CONTROL KNOW

425.

JPMC 305.1

1403

I.JVING ROOM: WALL CRACKED-- REPAIR. PREPARE & l'A.l:'.'ff

426.

!PMC 604.3

1403

KITCHEN: GfCI DEFECTIVE-REPLACE WITH GFCI

427.

JPMC 605.1

1403

KITCHEN: LIGHTS NOT WORKING-REPAIR/REPLACE

428.

lPMC 604.3

1403

BATHROOM: lsT FLOOR--GFCI DEFECTIVE-REPLACE

429.

IPMC 305.3

1403

BATHROOM: i' 0 -DOOR-REPAINT

430.

IPMC 305.3

1403

BATHROOM: i'll-W ALL & CE!Lft\G- REP AIR, PREPARE & PAINT

43 l.

WMC604.3

1403

BATHROOM: 2~D - GIT! DEFECTIVE-REPLACE

432.

IPMC 704.2

1403

BEDROOM: FRONT-SMOKE DETECTOR NOT SOCNDING-REPLACE

433.

JPMC 304.15

1404

ENTRANCE DOOR-REPAIR

434.

IPMC 305.3

1404

LIVING ROOM: CEJUNG HAS WATER DAMAGE--REPA!R. PREPARE & PAINT

435.

IP\1C 304.13

]404

BATHROOM: 2"ll 1-'LOOR-WI]';DOW BROKEN--REPLACE

436.

Il'MC 304.13

1405

WINDOW: REAR-BROKEN-REPLACE

437.

IPMC 704.2

1405

SMOKE DETECTORS: LOW BA TIERY CHIRP-REPLACE BAT!"ERIES

438.

!PMC 305.J

1405

KITCHEi\': COU:'.':TERTOP EDGE-REPLACE
?_)

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 125 of 146

Exhibit F

439.

IP:'v!C 305.3

1405

DINING R00'.1-1 AREA: SOFFIT-- REPAIR. PREPARE & PAINT

440.

IP:'v!C 305.3

1405

WAI.LS: THROCGl!OUT Cl\IT---COMPLETE REPAIRS-- REPAIR. PREPARE & PAINT

441.

lP'.v1C 305.1

1405

BATHROOM: 1si FLOOR ·-TOWEL IJOLDER-REPLACE

442.

IPMC 305.l

1405

BATHROOM: 1'1 FLOOR-VENT FAN DEFECTIVE- REPAIR/REPLACE

443.

JP:vtC 605.3

1405

STAIRWAY: TOP LANDING LIGHT GLOBE-PROVIDE

444.

IPMC 704.2

1405

2>:n FLOOR: SMOKE DETECTOR HANGING-SECURE

445.

IPMC 704.2

1405

HARDWIRED SMOKE DETECTORS REMOVED-PROVIDE

446.

IPMC 704.2

1405

BEDROOMS: ALL-- SMOKE DETECTOR NOT SOUNDl\!G-REPI.ACE

447.

IPMC 305.3

1406

KITCHEN/DINING ROOM: HOLE IN WALL BEHIND WASHER-- REPAIR. PREPARE & PAINT

448.

ll'MC 305.1

1406

BEDROOM: DOOR JAMB--REPAIR/REPLACE

449.

IPMC 305.6

1407

BEDROOM: 1' -DOOR KNOB

450.

JPMC 305.6

1407

BEDROOM: 3KD_DOOR HAS HOLE-REPLACE

451.

JP\1C 704.2

1407

BEDROOMS: ALL--S'.v10KE DETECTORS-PROVIDE

452.

IPMC 305.3

1407

BATHROOM: 2:-<D FLOOR-WINDOW SILL DRYWALL DEFECTIVE-- REP AIR. PREPARE & PAINT

453.

IP\1C 305.l

1407

BEDROOM : 151-DR YW ALL-- REP AIR. PREPARE & I' AJNT

454.

IPMC 305.1

1408

HOUSEKEEPING: POOR THROUGHOUT-MUST BE CLEANED

455.

IPMC 504.1

1408

WASHING MACHINE: DRAIN CLOGGED & DISCHARGE ll\CORRECTL Y-REP AJR.

456.

IP'.v1C 305.1

1408

KITCHEN: LIGHT BULB-REPLACE

1

26

PROVIDE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 126 of 146

Exhibit F

457.

lPMC 305.6

1408

BEDROO'v!: 3Rll_DOOR FALLING OFF IINGES-REPAJR

458.

IP:v1C 305.4

1408

CABLE TV: WIRES ACROSS FLOORS--REMOVE/RE-AITAC'H TO WAT.LS

459.

IP:v1C 104.2

1408

BATHROOM: NOT P.\SPECTED-PROVIDE ACCESS

460.

!!'MC 305.3

1408

STAIRWAY: HOLE J\i WALL AT TOP OF STAIRS-- REPAIR. PREPARE & PA!"iT

461.

IP:'vlC 704.2

1408

SMOKE DETECTORS: BATfERY LOW--REPLACE

462.

ll'MC 305.l

1408

COUNTER TOP: EDGE MISSfNG NEAR WASHING MACHINE-REPLACE

463.

IPMC 603.3

1408

FuRNACE ROO:Vl: REMOVE STORAGE

464.

IPMC 305.6

1408

FURNACE ROOM: DOORS--REPAIRIREPLACE

465.

!PMC 305.3

1409

KITCHEN: CEILING & WALL·· REPAIR. PREPARE & PAINT

466.

IPMC 305.3

1409

BA TIIROOM: l $T FLOOR-WALL-· REPAIR. PREPARE & PAINT

467.

IPMC 605.1

1409

KITCHE:-,.1: LIGHTS :-IOI WORKING-REP/\JR/REPLACE

468.

ll'MC 604.3

1409

KITCHEN: GFC! DEFECTIVE-PROVIDE GFCI

469.

IPMC 603.1

1409

KITCHEN: I.EFT BURNERS ON STOVE DEFECTIVE-REPAIR/REPLACE

470.

IPMC 402.3

!409

BATHR00:\1: 1sr FLOOR-VENT FAN DEFECTIVE-REPAIR/REPLACE

471.

!RC

315.1

1409

C.O. DETECTOR DEFECTIVE-REPLACE

472.

JPMC 305.5

1409

STAIRS: HANDRAIL LOOSE--SECURE

473.

JPMC 305.3

1409

BATHROO:Vl: z:-:o FLOOR CEILING-- REPAIR. PREPARE & PArNT

474.

JPMC 704.2

!409

BEDROOMS: BOT!!, FRONT-SMOKE DETECTORS NOT SOU>IDING-REPLACE

27

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 127 of 146

Exhibit F

475.

IPMC 305.4

1409

CABLE CORD--·TRII' HA/.ARD-SECURE

476.

IPMC 702.3

1409

BEDROOM: REAR-DOOR LOCKED-PROVIDE ACCESS Dl;RJ:--:G RE-INSPECTION

477.

IPMC 304.13

1409

BATl !ROOM:

478.

IPMC 305.6

1409

HALLWAY: CLOSET VOOR DEFECTIVE-REPAIR!REPLACE

479.

lPMC 305.3

1410

ENTRA\!CE: WALL JIAS CHIPPED PAfNT-REPAIR, PREPARE & PAINT

480.

IPMC 305.3

1410

BATHROOM: lsr FLOOR-WALL DEFECTIVE--REPAIR, PREPARE & PAINT

481.

IP:vlC 305.1

1410

BATHROOM: I ST FLOOR--TOWEL & TOI LET BARS-PROVIDE

482.

ll'MC 305.3

1410

BA TllROOM: Isr FLOOR-WALL DA:'vfAGE-- REPi\JR. PREPARE & PATNT

483.

IPMC 604.3

1410

BATHROOM: Jsi FLOOR-GFCI DEFECTIVE-REPLACE WITH GFCI

484.

IP:\1C 305. l

14!0

KITCHEN: COUNTER BACKSPLASH DEFECTIVE-REPLACE

485.

JPMC 305.3

1410

KITCHEN: REPAINT WALL & CEILI'.'-iG

486.

IPMC 504.1

1410

BATHROOM: 2:s" FLOOR-TUB-RECAULK

487.

ll':'v1C 305.3

1410

BATHROOM: 2:sD -WALL AT TOILET-- REPAIR, PREPARE & PAINT

488

IPMC 305.3

1410

DI\!L'\!G ROOM: CEII.ft\:G DEFECTIVE-- REPAIR, PREPARE & PAINT

489.

IPMC 604.3

1410

BATHROOM: 2:sD FLOOR---GFCI DEFECTIVE-REPLACE WITH GFCI

490.

lPMC 305.3

1410

HALLWAY: 2:-:D FLOOR-CEILING-- REPAIR. PREPARE & PATNT

49!.

JPMC 603.1

1410

VURNACE ROOM: VENT PIPE-HOLE-REPAIR/REPLACE

492.

IPMC 305.3

1410

BEDROOM: 2~1)-WALL & CEIi.NG HAVE MOLD-- REPAIR. PREPARE & PATNT

2"" FLOOR-W!NVOW TN SHOWER MUST BE TEMPERED GLASS-PROVIDE

28

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 128 of 146

Exhibit F

493.

IPMC 604.3

1410

HALL \VAY: SWITCH PLATE HAS CRA.CK-REPLACE

494.

IPMC 305.1

1411

BATHROOM: 15T FLOOR-TOILET PAPER HOLDER-PROVIDE

495.

!P:v!C 604.3

141 I

BATHROOM: 15T FLOOR-GFCI PA!N"TED OVER-REPLACE

496.

IPMC 704.2

1411

SMOKE DETECTOR: LOW BATTERY CHIRPING IN lJNIT-REPLACE BATTERIES

497.

IPMC 604.3

1412

DINING ROOM: MISSING OUTLET PLATE-REPLACE

498.

IPMC 305.3

1412

BATHROOM: 2"° FLOOR-FLAKING AND PEELING PAINT-- REPAIR. PREPARE & PAINT

499.

NFPAl0.11.6.l

1412

GAS GRILL BEHIND Bl.JILDING-REMOVE

500.

!PMC 305.1

1413

BEDROOM:

501.

IPMC305.6

1415

KITCHEN: COUNTERTOPS-REPLACE

502.

!PMC 603.1

1415

KITCHEN: BURJ"\:ERS ON LEFT SIDE DEFECTIVE-REPAIR/REPLACE

503.

IPMC 704.2

1415

1sT FLOOR: SMOKE DETECTORS NOT SOLTNDING-REPAIR/REPLACE

504.

!PMC 704.2

1415

BEDROOMS: ALL-SMOKE DETECTORS NOT SOl.iNDING-REPA!RiREPLACE

505.

IPMC 304.15

1416

ENTRA.c"iCE DOOR: PANT CHIPPING-PREPARE AND PAINT

506.

IPMC 603.3

1416

DINING ROOM: GAS LINE--REMOVE HANGERS, CA"'-"NOT USE

507.

IPMC 305.3

1416

DINING ROOM:

508.

IPMC 604.3

J.+16

KITCHEN: GFCI PAINTED OVER-REPLACE (MUST REMAIN GFCI)

509.

IPMC 305.1

1416

KITCHEN: BACKSPLASH DEFECTIVE-REPLACE

510.

IPMC 702.3

1416

BATHROOM: l sT AND 2" 0 DOORS HAVE KEY LOCKS-REMOVE

i' 0 -DOOR !-LA..S HOLE-REPLACE

wATER DAMAGE ON wALL AT DOOR-REPAIR. PREP ARE & PAn-rr

29

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 129 of 146

Exhibit F

511.

lPMC 305.3

1416

BATHROOM: WALL AT TOILET HAS \VATER DAJ'vlAGE-REPAiR. PREPARE & PAD:T

512.

IPMC 704.2

1416

BEDROOMS: ALL-SMOKE DETECTORS NOT SOUNDING-REPLACE

513.

IPMC 305.1

1416

BEDROOM: 1sT - DOOR JAMB KICKED IN-REPLACE

514.

!PMC 304.14

1417

WINDOW: PROVIDE SCREENS

515.

!P!\1C 504.1

1417

KITCHEN: SINK LEAKING AT TR.-\P-REP.AJR

516.

IPMC 305.1

1417

KITCHEN: COUNTERTOP EDGE MISSING-PROVIDE

5li.

IPMC 305.3

1417

HALLWAY: WALL-- REPAIR. PREPARE & PAINT

518.

IPMC 305.3

1417

DINING ROOM/KITCHEN: SOFFIT AREA-REPAIR. PREPARE & PANT

519.

IPMC 305.3

1417

DINING ROOM/KITCHEN: \VINDOW SILL-- REPAIR. PREPARE & PAINT

520.

IPMC 704.2

1417

BOTH LEVELS: SMOKE DETECTORS NOT SOUNDING-REPLACE/PROVIDE

521.

IPMC 305.5

1417

STAIRS: TIGHTEN HANDRAIL

__

IPMC 305.6

1417

BEDROOMS: 1ST & 2'' 0 -DOORS BROKEN-REPLACE

)_.)_

-r

IPMC 305.3

1417

BEDROOM: 3RD_HOLES IN \VALL- REPAIR. PREPARE & P.AJNT

524.

IPMC 305.6

· 1417

525.

IPMC 305.3

1417

BATHROOM:

2''° FLOOR-CEILING FLAKING- REPAIR. PREPARE & PAIN1

526.

IPMC 305.3

1417

BATHROOM:

i'° FLOOR-CEILING FLAKING- REPAIR. PREPARE & PAINT

527.

IPMC 504.1

1417

BATHROOM: 2:-.1o FLOOR-TUBISHOWER-RECAULK

528.

IPMC 504.1

14li

BATHROOM: 2ND FLOOR-SINK LOOSE--SECURE

)-77

BEDROOM: 3RD_ CLOSET DOOR BROKEN-REPLACE

30

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 130 of 146

Exhibit F

529.

IPMC 305.3

1418.

STAIRWAY: HOLE IN WALL- REPAIR. PREPARE&. PAINT

530.

IPMC 305.3

1418

BATHROOM: MOLD-- REPAIR. PREPARE&. PAINT

531.

IPMC 305.3

1419

DINING ROOM: CEILING PEELING PAINT- REPAIR, PREP ..\RE &. PAINT

-")
).)

.....

IPMC 403.5

1419

DRYER IN CLOSET-REMOVE

533.

IPMC 305.3

1419

HALLWAY: 2ND FLOOR PEELING PAINT- REPAIR. PREPARE&. PAINT

534.

IPMC 305.3

1419

BATHRROM: 2"D FLOOR PEELING PA!?'lt- REP AIR. PREPARE&. PAINT

535.

IPMC 305.6

1419

BEDROOM: DOOR BROKEN-REPLACE

536.

IPMC 704.2

1419

BEDROOMS: ALL MISSING SMOKE DETECTORS-PROVIDE

537.

IPMC 604.3

1419

HALLWAY: SWITCH--REPAIR

538.

IPMC 309.1

1420

BEDROOM: BED BUGS-PROVIDE COPIES OF PAPERWORK FOR TREATMENT

539.

IPMC 605.2

1421

BATHROOM: 2"° FLOOR GFCI--PROVIDE

540.

IPMC 304.14

1422

WINDOWS: PROVIDE SCREENS

541.

IPMC 704.2

1422

BOTH LEVELS: H.t1.RDWIRED SMOKE DETECTORS DEFECTIVE-REPLACE WITH ELECTRTJC

542.

IPMC 305.4

1422

BATHROOM: I sT FLOOR - FLOOR TILE DEFECTIVE-REPLACE

543.

IPMC 305.6

1422

BEDROOM: 1sT - CLOSET DOORS NEED ADJUSTh1ENT-REP.AJR

544.

IPMC 305.6

1422

BEDROOM: 2ND - CLOSET DOORS - RE-INST ALL

545.

IPMC 305.1

1422

BEDROOM: 3RD - REPLACE DOOR

546.

IPMC 305.3

I422

BATHROOM: 2ND FLOOR-CEILING HAS MOLD&. FLAKING P.AJNT-REPAIR. PREPARE&. PAINT

31

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 131 of 146
547.

!P\IC 704.2

!.\23

BEDROOM: l ' 1

548.

IP\1C 305.6

1-l23

BFDR00\1:

549.

IP'.\IC 604.3

1423

BATllR00\1: 2"n FLOOR ·· CiFC! PAl\:TED OYER- REPLACE (iFCI

550.

!P:-VlC 702.3

1423

BFDR00:\1S: I s·r & 3RD DOORS Iii\ YE KEY LOCKS··· Rl'\IOYE

55 I.

IPMC 704.2

1423

1'' Fl .OOR: S\•IOKE DETECTOR NOT SOUNDING-- -REPLACE

552.

!RC

315.1

1423

1sr FLOOR: CO :--:OT \\'ORKf:-.!Ci- REPLACE

553.

ll':-V1C 605.2

1423

KITCHEN: (iFCI AT STOVE-REPLACE

554.

IP\1C 704.2

1424

BEDROOt,1: FRO'.\:T - S\10KE DETECTORS DEFECTlVE-REPL\CE

555.

IP\1C 704.2

1424

1'' FLOOR - SMOKE DETECTOR REMOVED-PROVIDE

556.

ll''.\1C 305. l

1426

l!OL'SEKEEP!'.\:G: POOR THROl"Cil!OL"T-\IUST BE CI.EA\iED

557.

!P\1C 605.2

1426

BATHROOM: GFCI - PROVIDE

558.

!P\IC 605.2

1426

KITCHEN: GFCI - PROVIDE

559.

lPMC 305.6

1426

MEClIA~lCAI. ROOM: DOOR - REPAlR!RFPI.ACE

560.

IP\!C704.2

1426

1' 1 FLOOR: S\10KE DETECTOR RE:v!OVED · PROVJ!)E

561.

IPMC 504.I

!426

BATHROOM: TOILET BROKEJ\ - REPAIR/REPLACE

562.

ll''.\K 605. l

]426

! !AI.I.WAY: 2"D FLOOR-1.IGHTS \:OT WORKI'\G - REPAIR1REPL\CE

563.

IPMC 305.3

!426

BATHROOM: 2"-D FLOOR - REPAIR. PREPARE & PAINT

564.

lP\·lC 70-!.2

1426

BEDROO\lS: :'-:0':\E OF THE\1 H,\ VE SMOKE DETECTORS - PROVIDE

··

:;RD -

S\10KF DI·: ff.C IOR :--:OT SOU:s;[)J>;(i

DOOR KEEPER

REPI.1\CE

PR.OVID!·:

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 132 of 146

Exhibit F

565.

11'\lC 403 ..5

1426

KITCHEN: DRYER - RE\.10VE

566.

IP\lC 605.2

1426

B/\TIIROOM:

567.

IPMC 605.1

1-126

B/\Tl!ROOM: 2"" FLOOR · LIGHT DEFECTIVE - REPAIR/REPLACE

568.

!P'.\lC 305. l

1426

110!.!SEKEFPl:S:G: POOR Tl !ROl'rn !OCT-- \.1l :sT BF CLEA>JED

569.

ll'MC -+03.5

1427

DRYER: REMOVE

570.

IP:-.K 305.3

1-127

BATHROOM: MOLD-- REPAIR. PREPARE & l':\l);T

571.

IPMC 305.3

1427

BATHROOM: 2"n l'LOOR PEELl:S:Ci PAINT-- REPAIR. PREPARE & PAINT

57'2.

IP\1C 305.3

1427

DI:--.;I'.\"G R00\.1: \\':\LI. c\!EEDS TO BE PAT( ·1 [ED-- REPAIR.. PREPARE & PA!:S:T

573.

!!'MC 704.2

1427

BEDROOM: I sr -SMOKE DETECTOR HAS BEE'.\ REMOVED-PROVIDE

.57-+.

IP\.1C305.6

l-+27

BEDROOM: 2"1l & 3RD DOOR J/\:\1B-REPI.ACE

575.

IPMC 305.6

1428

BATHROOM: ls, FLOOR DOOR - REPAIR/REPLACE

576.

11'\.lC 305.6

1-+28

BATI!R00\.1: 1' 1 FLOOR OOOR K:S:OB · REPAIR 'REPLACE

577.

IPMC 704.2

1428

SMOKE DETECTORS: BATTERY LOW-REPAIR

578.

IP:\!C 603.1

J.+28

KITC'HE's: STOVE-I.EFT FRO);T BlJR);ER DEFECTIVE - REPAlRiREPLACE

579.

IPMC 504.J

1428

KITCHEN: SINK FAUCET DRIPPING-REPAIR

580.

IP\1C 305.3

1-1-28

BATHROOM:

581.

!PMC 603.3

1429

MECHANICAL ROOM: STORAGE-REMOVE

582.

!Pt\ lC 50-+. l

1429

KITCHEN: \\',\SH!:'.\"G :'v1ACHl:'.\E DRA!'.\" 1.1:s;E I.EAKS-REPAIR

2"" FLOOR GFCI -

REPLACT

z"D FLOOR - CEll.1:S:G IJAS FL\Kl:\G l'Al'.\"T - REP,\IR. PREP,\RE & PA!:S:T

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 133 of 146

Exhibit F

5Kt

IP\1( · 60-13

1429

KITCI IE'.\: II.LEGAL 4-W:\ Y PU ·c i AT \\',\SI ll'.\G \!,\Cl ll'.\E-KF.\lOVE

584.

lP!'vlC 504.1

1-129

KITCHEi\: FAl."CET DR!l'Pl>;G

585.

IPMC 504.I

1429

BATIIR00\1: 1"' FLOOR - TOILET RCl\S

586.

IP\1C 70-1.2

1429

2c:t> FLOOR: SMOKE DETECTORS-ELECTRIC-RE}.!OVl'D-PROVIDE

587.

IPMC 305.1

1429

BAT! !ROOM: 2'-D l'LOOR · TOOT! 1!3RUS1 I ! !OLDER--l'ROVIDE

588.

TP\1C 304.15

1430

E'.\TRA>;"CE DOOR: p.,\J'.\T CllIPPl'.'JG--PREPARE AND l'Al'.\T

589.

IP\IC 305.1

1430

BATHROOM: 2"D FLOOR - SOAP DISII MlSSll\G- PROVIDE

590.

IPMC 305.3

1430

B:\THR00\1: 2'-D FLOOR-CEll.ll\G HAS :V\OLD-C\:T OLT DRYWALL. PREPARE & PAl'.\T

591.

IP\1C 304.13.2

1430

BATHROOM: 2"1) FLOOR - \Vll\DOW WILL l\OT STAY OPEJ\:-REPA!R OR REPLACE

592.

TP\lC 702.3

1430

BEDR00\1: J'

593.

!!'MC 305.6

1430

BEDROOM: l ' PROVIDE DOOR l!A;'JDLE AJ\D llARDW ARE

594.

IP\1C 304.15

1-130

SCREEJ\ DOOR: PROVIDE SPRING ARM

595.

IPMC 104.2

1430

POWDER R00\1: PROVIDE ACCESS

596.

!P\!C 305.1

1-131

KITCHE>-1: BACKSPI.:\Sll-REPL\CE

597.

lP:v1C 305.1

1431

B/\Tl !ROOM: 1sr FLOOR-TOILET PAPER I IOI .DER-PROVIDE

598.

ll'\lC 305.3

1-131

BAT!IR00'.1.1: I'' FLOOR-l!OLE I1' WALL BEIIIND DOOR-- REPAIR. PREPARE & PAINT

599.

IPMC 704.2

J 431

SMOKE DETECTORS: BA TIER!ES LOW--REPLACE

600.

IP\IC' 305.6

J-131

BEDROO\,I: 2'-D-HOLE IN DOOR---REPLACE

1

-

REPAIR

REPAIR

RE\10VE DEADBOLT FROM DOOR

1

34

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 134 of 146
601.

!!'MC 305.6

JHI

Bl:DROOM: !' 1 -BOLE I:\ DOOR

602.

IPl\!C 605.2

1-+3 J

B,\Tl!ROOM: 2>-D - PRO\'IDE GFCI

603.

!!'MC 305.3

1431

BATHROOM 2'": CEILI'.\G FLAKING PAINT-- REPAIR. PREPARE & PAINT

604.

!PMC 305.1

143 J

BATHR00\1: 2'-D - TOWEL BAR ·-PROVIDE

605.

JPMC 704.2

1432

BEDROOMS: NO:\E I IA VE S'.'v!OKE DETECTORS - PROVIDE

606.

IP\1C 305.3

1432

B,\THROO'.'vl: CEILJ:\(i !!AS '.'v!OI.D - REPAIR. PREPARE & PAl:--JT

607.

Il'MC 504.1

1432

KITCHEN: FAUCET !IA:s;DLE BROKE>! - REPAIR/REPLACE

608.

JP?\1C 504.1

1-+33

B,\THROO'.'v!: TOILET TA'.':K LID -PROVIDE

609.

IPMC 305.3

1433

KITCHEN: CEILING DEFECTIVE-- REPAIR. PREPARE & PAJ?\T

610.

!!'MC 604.3

1433

KITC!!E'.\:: GFCI AT SI:S.:K DEFECTIVE-- REl'L\CE WIT!! GFCI

611.

IPMC 704.2

1433

S'.'v10KE DETECTORS Tl IROL'Gl !OCT: PROVIDE

612.

!PMC 504.1

1-l33

B,\TIIROO'.'v1: 2'-ll FLOOR TOIi.ET :S.:OT rc:--;cTJO:s;AI.-REPA]RtREPLACE

613.

IPMC 305.3

1433

BATHROOM: PAl1\T

614.

IP:'-,1C 305.6

1433

BEDROOMS: Al.L DOORS-REl'l.,\CE

615.

!PMC 605.l

1433

KITCHEN: LIGHT FIXTCRE-REPl,ACE

616.

IP'.'v!C 505.4

1433

HOT WATER !!EATER-REPLACE

617.

IPMC 504.1

1433

KITCHEN: COLD WATER VALVE FOR WASl!ER--REPI.ACE

618.

IP'v1C 7Q..l..2

1434

BEDROO~·l: I' r - S?\10KE DETECTOR ?\OT SOC'.\:Dl'.':Ci - REPL\CE

35

REPLACE

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 135 of 146

Exhibit F

619.

lPMC 604.3

1434

BATHROOM: BOTH- GFC!"S NOT WORKING- REPLACE WJTH GFCTS

620.

IPMC 305.4

1434

REAR OF BLDG - CABLE WIRE RUNS INTO BATH VENT BOX - REMOVE

62L

IPMC 603.1

1436

FRESH AIR VENT AT REAR WALL: REPLACE

622.

IPMC 305.1

1436

KITC!lE\!: COUNTERTOP EDGE MISSlNG--PROVJDE

623

IPMC 304.!3

1436

Wll\DOWS Tl!ROUGHOCT UNIT: HARD TO OPEN & CLOSE-REPAIR

624.

IPMC 704.2

1436

BEDROOM:

21'D

BEDROOM SMOKE DETECTOR J\OT SOU);Dll\G-REPLACE

625.

IPMC 305.2

1436

BEDR00'.\1:

21'Ll

BEDROOM fLOOR DEFECTIVE-REPAIR

626.

IPMC 304.13

1436

BEDROOM:

3RD -

627.

IPMC 305.3

1436

BATHROOM:

2ND

FLOOR- WALL -COMPLETE REPAIR. PREPARE & PAINT

628.

IPMC 305.1

1436

BATHROOM:

2ND

FLOOR-TOILET PAPER HOLDER- REPAIR/REPLACE

629.

IPMC 504.l

l436

BATHROOM: i'D fLOOR- SHOWER & TUB-RECAULK

630.

IPMC 304.13

1437

FRO>iT WINDOW: HEADER-REPAIR

631.

IPMC 605.2

1437

KITCHEN: GFCrs -ALL-REPLACE

632.

IPMC 603.3

1437

MEC!IANICAL ROOM: STORAGE-REMOVE

633.

lPMC 305.1

]437

KITCHEN: CABINET AT LEFT & RIGHT OF STOVE MISSING CENTER STILE-REPLACE

634.

!PMC 305.1

1437

KITCHEN: COUNTERTOP EDGING-PROVIDE

635.

JPMC 704.2

1437

SMOKE DETECTORS: BOTH HANGING-RE-ATTACH

636.

JPMC 305.3

]437

LIVING R00'.\1: CEILING FLAKING PAINT-- REPAIR, PREPARE & PAINT

Wl>iDOW CRACK AROUND WALL & SILL IS LOOSE-REPAIR

36

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 136 of 146

Exhibit F

637.

lP\1C 305.3

1-137

I ' 1 FLOOR: WALL AT ST,\lRS BJ-:l 11"-:D DOOR llAS !!OLE-- RFJ>AlR. PREPARE & l\\l'(T

638.

IP\IC 305.3

1437

SL\lRWA Y: WALL HAS HOLES-- REPAIR. PREPARE & PAINT

639.

lPl\!C 605.3

1437

l l,\I.LWA Y: LIGHT GLOBE ivllSSl"-:G-PROVlDE

640.

lP:'\K 605.2

1437

BAT! !R00\1: 2"1> FLOOR-GFCI-REPLACE

641.

IP\1C 305.6

1437

BEDROOMS: ALL DOORS HA VE l lOLES-REl'LACE

642.

IPMC 305.3

1437

l !ALLWAY: 2"D FLOOR - WAI.LS l IA VE HOLES-- REPAIR. PREPARE & PAINT

643.

IPMC 604.3

1437

BEDROOM: 2"n·OUTLET BROKE:s;-REPLACE

64-t

1P\1C 305.3

1437

BEDR00:'\1: 3w. WALLS l!AVE llOLES-- RFPAlR. PREPARE & PA!"-:T

645.

lPMC 305.6

1437

BEDROOM:

646.

Jl'\IC 304.15

1439

KITCHEN: REAR DOOR BROKEN - REPLACE

647.

IPMC 305.3

1439

KITCHEN: CEILING WATER LEAK-- REPAIR. PREPARE & PAINT

648.

IP:\!C 603.1

1439

KITCHE;s;: STOVE BCRNERS DEFECTIVE-REPAIR/REPLACE

649.

lP\1C 305.l

1439

KITCl !EN: COUKrERTOPS---REPLACE

650.

IP:'\1C 305.4

1439

STA!RS: TRFADS LOOSE-REPAIR, REPLACE

65 l.

Il'MC 305.3

]439

BATHROOM: REPAIR. PREPARE & PAINT

625.

]l':'\,1C 304.7

J.139

1:xrER!OR: \,IISSING FL:R>!ACE CAP o:,-.; ROOF--REPL\CE

653.

IPMC 304.15

1440

SCREEN DOOR: PROVIDE SPRING ARM

654.

IP\IC 603.1

1440

L!Vl'.\G ROO'.'vl: THERMOSTAT COVER :'\!ISSING-PROV!DE

3RD -

CLOSET DOOR l lAS llOLFS--REPLACE

37

__J

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 137 of 146
1

Exhibit F

655.

ll'J\ 1C 704.2

14-tO

1'

656.

IPMC 605.1

1440

ll:\l.LWA Y: 1' 1 FLOOR - !.!GI IT AT STAIRS D!TECTlVE-REP,\llZIREPL\CI:

657.

IPMC 605.3

14-tO

1!ALI.WAY: 1' 1 FLOOR · l.!GHT- PROVIDE GLOBE

658.

JPMC 305.3

14-+0

ST:\lRWA Y: \VALL HAS IIOLES --REPAIR. PREPARE & PAI~T

659.

IPMC 305.1

1440

BATllROOM: 2"D FLOOR \1IRROR BROKEN-REPL\CE

660.

IPMC 604.3

1440

B,\THR00\1: 2"D FLOOR l.!GHT ! !ANGlNCi O\'ER SINK BROKE'.\:--REPAlR

661.

IPMC 305.3

1440

BAl'HR00\-1:

2"° FLOOR- \VALLS & CE!LI'.\:G-PREPARE & P,\l~T

662.

IPMC 504.1

1440

B,\THR00\-1:

2"° FLOOR - TL:B S! 10\VER DIVERTER DEFECTIVE-REPLACE

663.

IPMC 305.6

]440

BAT! !ROOM: 2"D FLOOR- DOOR BROKF'.':-REPI.ACE

66-t.

IPMC 704.2

1440

BEDROO:VIS: ALL BEDR00\1S S\.10KE DETECTORS \OT SOU:--JDI::-S:G-Rl'PLACE

665.

JPMC 605.3

1440

IlAI.I.WA Y: 2"n FLOOR- UG!IT-PROVIDE GLOBE

666.

IPMC 604.3

1440

1.IVI'.\:G ROOJ\1: Ol'T!.ET INSIDE WALL-·- l'RO\'!DE COVER PLATE

667.

JPMC 305.6

1440

l !ALL WAY: DOOR AT ST AIRS DEFECl!VE----REPI.J\Cl:

668.

!PJ\1C 305.6

14-tO

KITCHE:'\: l !ALL \VAY DOOR AT K!TCI !E'.\: I !AS IIOI.FS-REPI .ACE

669.

IPMC 605.1

1440

KITCHEN: LIGHT FIXTURE DEFECTIVE-REPLACE

670.

IP\IC 305. l

14-tO

J!OUSEKEEPl:-.:G: POOR THR0l'(il!OCT-'.\·1LS[ BE CLEA:,(ED

671.

!PMC 305.3

1440

KITCHEN: WALL BEl!IND WASl!ER HAS 1101.E-REPAlR. PREPARE & PAINT

67'2.

!P\1C 504.1

1440

KITCl!EN: SI'.\:K FA\lCET LOOSE--SECURE

FLOOR S'.\10KE DE !'ECTOR RE:VIOVED--PROVIDE

1

38

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 138 of 146

Exhibit F

673.

IPMC 403.5

1440

KITCHE:-X: PORTABLE DRYER '-:OT PER\1ITl"ED--RE\-10VE

674.

TPMC 603.3

1440

MECHANICAL R00\1: BLOCKED. :'.\iO ACCESS-PROVIDE ACCESS

675.

IPMC 603. l

1440

KITCHEN: STOVE REAR LEFT BURNER DEFECTIVE-REPAIR/REPLACE

676.

!PMC 305.3

1440

KITCHE:-J: CE!LIKG DEFECTIVE-- REPAIR, PREPARE & PAINT

677.

IPMC 605.3

1440

KITCHEN - LIGHT-PROVIDE GLOBE

678.

!PMC 305.6

1440

REAR DOOR: KNOB LOOSE-REP AIR/REPLACE

679.

IPMC 301.2

1440

REARYARD AREA: REMOVE TRASH AND TV STAND

680.

IPMC 704.2

1441

BEDROOMS: ALL MISSING SMOKE DETECTORS--PROVIDE

681.

IPMC 304.13

1442

BATHROOM: WINDOW HAS WATER COMJNG TN ABOVE SEAL-REPAIR/REPLACE

682.

IPMC 504.1

1442

KITCHEN: FAUCET NOT WORKING- REPAIR/REPLACE

683.

IPMC 704.2

1442

SMOKE DETECTORS MJSSf.\G THROUGHOUT: PROVIDE

684.

IPMC 305.3

1442

BATHROOM: MILDEW THROUGJ !OUT • REPAIR. PREPARE & PAINT

685.

IPMC 304.14

1443

Wll\DOWS: SCREEl\S BROKEN-REPLACE

686.

!PMC 305.1

1443

KITCHE>l: COUNTERTOP EDGE MISSJNG-PROV!DE

687.

!PMC 305.3

1443

KITCHE;\: SOFFIT AREA HAS WATER DAMAGE-- REPAIR. PREPARE & PANT

688.

ll'MC 704.2

1443

SMOKE DETECTORS: REMOVED THROUGHOUT-REPLACE

689.

IPMC 305.3

1443

STAIRWAY: AT TOP-WALL-- REPAIR,PREPARE& PAINT

690.

IPMC 305.3

1443

BEDROOM: 3RD -CEILI\!G AND WALL-- REPAIR, PREPARE & PAINT
39

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 139 of 146

Exhibit F

691.

IPMC 604.3

1444

KITCHEN: ILLEGAL JUMP FOR DRYER (PHOTO)-REMOVE

692.

NFPA J0.11.61

1444

KITC!-lE1'i: GRILL

693.

IPMC 604.3

1444

PANEL: PROVIDE BLA'.'JK

694.

JPMC 704.2

1444

llALLWAY:

695.

!!'MC 305.3

1443

BATHROOM:

696.

IPMC 605.3

1445

HALLWAY: 151 FLOOR- GLOBE MISSING-PROVIDE

697.

!PMC 305.3

1445

BATIIROOM: 2:-.D FLOOR- WALL& CEILING IiAS SEVEREMOLD--REPAIR, PREPARE & PAINT

698.

IPMC 305.3

1445

BATHROOM: 2"D FLOOR-WINDOW SILL HAS CHIPPING PAINT-- REPAIR, PREPARE & PAINT

699.

IPMC 305.3

1445

BAI1lROOM: 2"D FLOOR- WALL HAS CHIPPING PAINT-- REPAIR. PREPARE & PAINT

700.

IPMC 604.3

1446

KITCHEJ\": BROKEN SWITCH PL/\TE-REPLACE

701.

IPMC 305.6

1446

KlTCHE:S:: CLOSET DOOR KNOB-PROVIDE

702.

IPMC 605.2

1446

KITCHE~: SINK FAUCET LEAKING AT HANDLE-REPAlR/REPLACE

703.

IPMC 604.1

1446

KITCHE~: GFCI AT STOVE-REPLACE

704.

IP'.\1.C 305.3

1446

KITCIIE~: CEILING FJN!Sl! REPAIR-PREPARE & PAI::S:T

705.

TP'.\1C 305.3

1446

K!TCHE:-S: WALL HAS HOLE-- REPAIR, PREPARE & PAINT

706.

IPMC 305.6

1446

LIVING ROOM: FRONT CLOSET DOOR !!AS HOLE-REPAIRJREPLACE

707.

IPMC 305.3

1446

THROUGHOCT UNIT: COMPLETE DRYWALL REPAIRS -- PREPARE & PAfr..T

708.

IPMC 704.2

1446

l ST FLOOR: S:\10KE DETECTOR RE:\10VED-PROVIDE

z''D FLOOR-SMOKE DETECTOR--REPLACE
z''l> FLOOR-CEILING FLAKING-- REPAIR, PREP /\RE & PAINT

40

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 140 of 146

Exhibit F

709.

IPMC 605.3

1446

HALL \VAY: LIGHT GLOBE MJSS!~G · REPLACE

710.

lPMC 605.1

1446

I !ALL\VAY: LIGHTS :--.JOT WORKl'\:G- · REPAIR

711.

!PMC 604.3

1446

BEDROOM: 2ND - OUTLET AT BED BROKEN-REPLACE

712.

IPMC 305.4

1446

BEDROOM: 2ND - FLOOR TILES MISSING-REPLACE

713.

IPMC 704.2

1446

BEDROOM: 2No - SMOKE DETECTOR BATTERIES-PROVIDE

714.

!!'MC 305.3

1446

BEDROOM: 3w - CEILING AND \VALL REPAIR-PREPARE & PAINT

715.

IPMC 504.1

1446

BATHROOM: 2r-.:o FLOOR- TOILET Rl:N?\ING-REPAIR/REPLACE

716.

IPMC 504.1

1446

BATJ!R00'.1.1: 2:s:D FLOOR - TOILET HANDLE BROKEN-REPAIR/REPLACE

717.

IPMC 305.3

1446

BATI!ROOM: 2NDFLOOR- CEILING HAS MOLD- REPAIR. PREPARE & PAINT

718.

IPMC 304.2

1446

EXTERIOR: SIDING CONDUT HANGING OFF-REPAIR

719.

JPMC 305.l

[+!6

REAR SCREE:--.l :V1ISS!>-!G--PROVIDE

720.

IPMC 504.1

1447

BATIIROO:'vl: 1st FLOOR SINK - RE-ATTACH TO \VALL

721.

!P:v!C 504. l

1447

BATHROOM: 1sr FLOOR TOILET LOOSE- REPAIR

722.

IPMC 305.l

1447

KITCHEN: COUNTER.TOP- REPLACE

T23.

IPMC 305.5

1+!7

STAIRS: BOTTOM HA>IDRA!L LOOSE- REP AIR & SECCRE

724.

!PMC 305.4

]447

STAIRS: TOP TREAD LOOSE - SECURE

725.

IPMC 704.2

1448

SMOKE DETECTORS: THROUGHOUT - PROVIDE

T26.

!PMC 309.l

1448

INFESTAT!ON: ROACHES- EXTERMINATE

41

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 141 of 146

Exhibit F

727.

IP:V1C 605.2

14+8

B;\THROOM & KITCJ !EN - GFCrs - PROVIDE

728.

!RC

315. l

1449

1s I FLOOR: CO DETECTOR NOT WORKING - REPLACE

7'29.

IPMC 704.2

1449

BEDROOM:

730.

!PMC 301.2

1450

REAR YARD: REMOVE TRASH & DEBRIS

731.

JPMC 605.1

1450

EXTERIOR: OPEN CABLE BOX - REMOVE

732.

IPMC 305.l

1451

KITCHEN: COUNTERTOP EDGE-REPLACE

733.

IPMC 402.3

1451

BATHROOM: I sr FLOOR - VENT FAN DEFECTIVE--REPAIRJREPLACE

734.

JPMC 305.3

1451

BATHROOM: lsr FLOOR- WALL AT TOILET DEFECTIVE-- REPAIR. PREPARE & PAINT

735.

!PMC 704.2

1451

BEDROOM: i1' 0

736.

IPMC 704.2

1451

BEDROOM: 3RD - SMOKE DETECTOR NOT SOUNDING-REPLACE

737.

fPMC 305.6

1451

BATHROOM: 2KD FLOOR DOOR--PAINT

738.

!PMC 704.2

1452

BEDROO::VI:

739.

IP'v'!C 704.2

1453

BEDROOM: SMOKE DETECTOR NOT SOUNDING- REPLACE

740.

IPMC 604.3

1+53

KITCHE:\: GFCI NOT WORKING- PROVIDE GFCI

741.

IPMC 305.3

1453

BATHROOM: RE-PAINT

742.

JPMC 504.l

I..\53

BATHROOM: TOILET LOOSE - REP AIR

-743.

lPMC 504.1

1453

K!TCIIEN: SINK IIAS MOLD-REMOVE Al\'D REPAIR

744.

IPMC 604.l

1454

KITCHEN: OUTLET BEllll\D WASHER IS FIRE HAZARD-REMOVE/REPLACE

2~D

& 3RD - SMOKE DETECTORS NOT SOUNDING - REPLACE

-

z:>:D -

SMOKE DETECTOR DISCO>i>JECTED- -REPLACE

BATI'ERY MISSING FROM SMOKE DETECTOR- PROV!DE

42

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 142 of 146

Exhibit F

745.

IPMC 604.1

1454

KITCl!E:-J: GFCI 13EHl>ID STOVE IS HUMMING

746.

IPMC 504.1

1.i54

K!TC! IE:\': PROVIDE SINK AERATOR

747.

!P\1C 603.3

1454

D!NlNG ROOM: GAS UNE--REMOVE HANGERS. CA:'JNOT USE

748.

IPMC 305.3

1454

STAIRWAY: PEELl'\'G PAINT-PREPARE & PAINT

749.

lPMC 404

1454

LIVJ);G ROOM: BED KOT PERMITTED- REMOVE

750.

IPMC 504.1

1454

BATHROOM~ 2:-:n ROOM TUB !!AS SEVERE MOLD-CLEAN & RE\10VE

751.

IP:v!C 305.3

1454

BATHR00:1-1: 2:-;n FLOOR-WALLS & CEJLl;sG-PAINT

752.

IPMC 305.1.1

1454

HALLWAY: 2:-.n FLOOR - CEJLTJ\G COLLAPSING-- REPAIR. PREPARE & PAIJ\:T

753.

IPMC 704.2

1455

LIVING ROOM: SMOKE DETECTOR LOOSE - SECURE

754.

IPMC 104.2

1458

SCREEN DOORS LOCKED-NO ACCESS-PROVIDE ACCESS TO UNIT

755.

JPMC. 604.3

1452

BA1HR00;1,1: GFCI OPE:-.! GROUND- REPLACE WITH GFC!

756.

lPMC 305.1

1457

KITCHEK WALL & CEILING HAS GREASE-CLEAN

757.

IPMC 305.1

1457

HOUSEKEEPING: THROUGHOUT-CLEAN

758.

IPMC 603.3

1457

KITCHEN/DlNING ROOM: GAS LINE--REMOVE HANGERS

759.

IPMC 604.3

1457

BATHROOM: 2:-;D - REMOVE 3-WA Y PLUG

760.

lPMC 605.3

1457

BATHROOM: 2:-;r, - LIGHT GLOBE MISSING-PROVIDE

761.

IPMC 605.2

1457

BATHROOM: 2!-m - PROVIDE GfCl

762.

IPMC 504.1

1457

BATHROOM: 2:-;l) -TUB/SHOWER-RECAUI.K

43

REPLACE

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 143 of 146
763.

IPMC 305.3

1457

BA Tl !ROOM:

764.

IPMC 305.6

1457

BATHROOM: 2" 1)

765.

JPMC 604.3

1457

BEDROOM: MIDDLE-- ELECTRICAL OUTLETS FALUKG OUT-REPAIR

766.

!P'v!C 605.3

1457

HALLWAY: 21':ll FLOOR- GLOBE MISSING-PROVIDE

767.

IPMC 305.4

1457

STAIRS: TREADS AROUND 4rn FR0\1 BO"JTOM STEP-REPLACE

768.

!PMC 305.4

1457

STAIRS: TREADS AROCND 13RH FROM BOTTOM STEP-REPLACE

769.

IPMC 604.3

1457

BEDROOM: MASTER-OUTLETS DEFECTIVE-REPLACE

770.

IP\1C 104.2

1458

SCREE!\ DOORS LOCKED-NO ACCESS-PROVIDE ACCESS TO UNIT

771.

IPMC 704.2

1459

BEDROOM: 2"n - SMOKE DETECTOR- REPAIR/REPLACE

772.

IPMC 605.2

1459

BATHROOM: 2"D FLOOR - GFCI - REPAIR/REPLACE

773.

IPMC 305.6

1459

MECHANICAL ROOM: DOOR BROKEN -REPAIR/REPLACE

774.

IPMC 104.2

1460

SCREEN DOORS LOCKED-NO ACCESS-PROVIDE ACCESS TO UNIT

775.

IPMC 305.4

1462

LIVING ROOM & UPSTAIRS: CABLE WIRE !SA TRIP HAZARD-REMOVE ·

776.

IPMC 305.3

1462

UV!NG ROOM: HOLE AT STAIRS-- REPAIR. PREP ARE & PAINT

777.

IPMC 402.3

1462

BATHROOM: VENT FAN DEFECTIVE-REPLACE

778.

JPMC 603.3

1462

MECHANICAL ROOM: CLOTHES HANGING ON GAS LINE-REMOVE

779.

IPMC 504.1

1462

BATHROOM:

780.

!PMC 605.3

1462

HALLWAY: 2"n FLOOR- LlGl IT GLOBE MISSING-REPLACE

2ND -

-

CEILING-- REPAIR. PREPARE & PAINT
DOOR JAM BUSTED-REPLACE

i'° FLOOR TCB--RECAULK

44

Exhibit F

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 144 of 146

Exhibit F

781.

IP:v!C 704.2

1462

BEDROO:v1S: ALL BEDROOMS· SMOKE DETECTORS NOT SOUND[;\G-REl'LACE

782.

IPMC 305.4

1462

2:-iD FLOOR: CABLE WIRES IN HALLWAY --RE:-.10VE

783.

IPMC 305.3

1464

BATHROOM: 1sr FLOOR- MOLD· REPAIR. PREPARE & PANT

784.

ll'MC 704.2

1464

S:v!OKE DETECTORS: PROVIDE

785.

lPMC 605.2

1466

KITCHEN: GFCI AT STOVE-PROVIDE

786.

IPMC 704.2

1468

J5T FLOOR- SMOKE DETECTOR AND CO NOT WORKING - REPLACE

787.

IPMC 704.2

1468

BEDROOMS: 2:-;D & 3RD SMOKE DETECTORS l\'OT SOl'NDI:-S:G-REPLACE

788.

IPMC 304.15

1468

SCREEN DOOR: REAR BROKEN - REPAIR/REPLACE

789.

IPMC 403.5

1468

DRYER: REMOVE

790.

IPMC 305.3

1468

BATHROOM:

791.

IPMC 305.3

1468

BATHROOM: 2~° FLOOR PEELING PAINT· REPAIR. PREPARE & PAINT

792.

IPMC 604.l

1944

KITCHEN: DRYER OCTLET ILLEGALLY INSTALLED-REMOVE; MUST HIRE LICENSED

2r<P

FLOOR-MOLD - REPAfR. PREPARE & PAINT

ELECTRICIAN AND OBTAD\' ELECTRICAL PERMIT
793.

IPMC 604.1

1944

KITCHEN: SERVICE PANEL MISSING BLA:--:K-PROVIDE

794.

NFPA 10.JJ.6.I

1944

KITCHEN: CANNOT STORE OR USE ELECTRIC GRILL INSIDE-RE:v10VE

795.

IPMC 704.2

1944

HALLWAY: 2~° FLOOR SMOKE DETECTOR LOW DECIBEL-REPLACE

796.

lPMC 309. l

1948

!NFESTA TION OF BED BUGS: EXTERMINATE & PROVIDE CITY WITH REPORT

797.

IPMC 704.2

1998

2:-;D

FLOOR: SMOKE DETECTOR NOT SOCNDING-REPLACE
45

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 145 of 146
798.

IPMC 704.2

1998

Exhibit F

BEDROO:vt: S:v10KE DETECTOR >JOT SOUNDI>IG-REl'I.ACE
COMMUNITY CENTER BUILDING

799.

IPMC 504.l

WATER FOUNTAll\-BROKFN-REPAIR/REPLACE

800.

IPMC 605.J

COMPUTER ROOM: ELECTRICAL PANEL-CLEAR THE AREA/REMOVE

801.

!PMC 603.1

HOT WATER HEATER: COMPUTER ROOM-.FLUE DISCON>IECTED--REPJ\IR

802.

IPMC 305.3

BATHROOM: CEILl:-JG TILES HAVE MOLD-REPAIR/REPLACr:

803.

IP).1C 603. l

STOVE-PROVIDE LANYARD

804.

IPMC 704.!

GIRLS" BATHROOM: ;-JO EMERGENCY LIGHT--PROVJDE

805 ..

IPMC 704.2 /704.3

ALL UNITS - PROVIDE ELECTRIC HARDWIRED SMOKE DETECTORS IN ALL SLEEPING ROOMS & ALL
LEVELS - ELECTRICAL PERMIT WILL BE REQUIRED

806.

!RC

ALL C:-s'ITS - PROVIDE CO DETECTORS ON THE LEVEL OF THE SLEEPIG".'J ROOMS

807.

ll'MC 304.14

ALL UNITS - \'v'INDOWS - SCREEKS - PROVIDE

808.

IPMC 302.!

EXTERIOR - GROUNDS - CLEA:'\ \jp TRASH THROUGHOUT COMYION AREAS

809.

IPMC 302.1

I~TERIOR - COMMON HALLWAYS - NEED TO BE CLEANED DAILY IN ALL BUILDINGS

810.

!RC

ALL UNITS - PROVIDE WINDOW SCREENS ON ALL WI?\DOWS

811.

::-:FPA 10.11.6.1 &2 BALCONY - GRILLS - ~OT PERMITTED TO BE CSED 0:,-i ANY LEVEL ABOVE GROUND LEVEL

812.

l\FPA 10.ll.6.1&2 GROU'.'-1D LEVEL- GRILLS -CAN BE STORED ON PA TIO AREA BUT MUST BE USED 15FT FROM BUILDINGS

315. J

315. !

46

 Case 1:19-cv-01442-CCB Document 1-6 Filed 05/16/19 Page 146 of 146

Exhibit F

ALL ELECTRICAL, MECHA.\'IC-1l, BVILDING AND Pll/!'>18/NG WORK Will REQUIRE PERMITS TO DO THE WORK AND FINAL
INSPECTIONS 0/V THESE ITEMS WILL BE CONDUCTED BY THE CITY OF ANNAPOLIS INSPECTORS FOR Tl/AT TRADE-ANY
QUESTIONS, PLEASE FEEL FREE TO COSTA CT US AT 410-263-7946

RE!l\'SPECTIO.\' SCHEDULED ON OCTOBER 3-6, 2016, AT 9:30 A.M.

47

 Case Document 1-7 Filed 05/16/19 Page 1 dIXhibit 

 

STAFF REPORT AND FISCAL IMPACT NOTE

 

Resolution: R-4l-18

Title: Housing Authority of the City of Annapolis (HACA) Payment in Lieu of Property Taxes
(PILOT) Agreement

Date: August 30, 2018

 

STAFF REPORT

This resolution approves a Payment in Lieu of Taxes (PILOT) on all properties that HACA has an
ownership or control interest, provide the property bene?ts a designated affordable housing market client
base established by income guidelines and involves a ?xed number of units for a ?xed period of time.
This PILOT replaces three previous Cooperation Agreements entered into by the City and HACA dated
March l0, 1950; March 5, 1965, (and amended on January 8, l968,and February 6, 2009,): and
September 28, 1976. All of these Cooperation Agreements allow for the payment by HACA of a
negotiated amount in lieu of all taxes and special assessments on real property owned by HACA, but the
City has not collected any payments under these agreements for years.

While properties owned by HACA are already exempt from property taxes under Section 7?215 of the
Tax Property Article and Section of the Housing Article of the Annotated Code of
Maryland, there have been changes in funding from US. Department of Housing and Urban Development
?that has resulted in public housing authorities like HACA increasingly changing their ownership and
control structures for the affordable housing properties they operate and redevelop. HACA is now
allowed to refinance these properties to allow private ownership, as long as HACA retains some form of
ownership or control interest.

This resolution adopts a PILOT in lieu of any taxes that might be assessed on such properties. The
proposed PILOT is retroactive to July 1, 2018.

Prepared by: Teresa Sutherland, ity Manager

 

FISCAL IMPACT

This resolution has no ?scal impact as HACA properties are not subject to property taxes, and the City
currently does not collect payments from HACA under the existing Cooperation Agreements.

Prepared by: Jodee Dickinson, Finance Director

Fair
Housing
Planning
Guide

Volume 1

 

A US. Department of Housing and Urban Development
'll' Office of Fair Housing and Equal Opportunity

Case 1:19-cv-01442-CCB Document 1-8 Filed 05/16/19 Page 2 of
2
Exhibit
H
Chapter 1: Historical Overview

In its community development (CD) programs, HUD has strongly encouraged:
1.

The adoption and enforcement of State and local fair housing laws

2.

The reduction of separation by race, ethnicity, or disability status.

HUD Community Planning and Development (CPD) programs include:
■

Community Development Block Grant (CDBG)

■

Home Investment Partnership (HOME)

■

Emergency Shelter Grant (ESG)

■

Housing Opportunities for Persons with AIDS (HOPWA).

The CDBG program contains a regulatory requirement to affirmatively further fair housing
based upon HUD’s obligation under Section 808 of the Fair Housing Act. The CDBG regulation
also reflects the CDBG statutory requirement that the grantees certify that they will affirmatively
further fair housing. The HOME program regulation states the statutory requirement from the
Comprehensive Housing Affordability Strategy (CHAS) that the jurisdictions must affirmatively
further fair housing.
Through its CPD programs, HUD’s goal is to expand mobility and widen a person’s freedom of
choice.
The Department also requires CD grantees (those State and Entitlement jurisdictions that
administer the above identified CPD Programs) to document AFFH actions in the CDBG and
CHAS annual performance reports that are submitted to HUD.

Definition of Affirmatively Furthering Fair Housing
The extent of the AFFH obligation has never been defined statutorily. However, HUD defines it
as requiring a grantee to:

1-2

1.

Conduct an analysis to identify impediments to fair housing choice within the
jurisdiction

2.

Take appropriate actions to overcome the effects of any impediments identified
through the analysis

3.

Maintain records reflecting the analysis and actions taken in this regard.

Fair Housing Planning Guide

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 1 of Exhibit
19
I

CHAPTER 19: FAIR HOUSING, ACCESSIBILITY,
AND EQUAL EMPLOYMENT
CHAPTER PURPOSE & CONTENTS
This chapter summarizes the key regulations and requirements of fair housing, accessibility,
and equal employment and contracting laws applicable to CDBG projects.
SECTION

TOPIC

PAGE

19.1

Introduction/Overview of Requirements

19-1

19.2

Fair Housing

19-6

19.3

Handicapped Accessibility

19-8

19.4

Equal Opportunity

19-13

19.5

Recordkeeping and Monitoring

19-16

19.1 Introduction and Overview
The following is a summary of the topics in this section, applicable statutory and regulatory
cites, and other reference materials available from HUD.
Key Topics in This Section

9 Basic Overview
9 Consolidated Plan/Analysis of Impediments
9 List of Applicable Laws

Regulatory/Statutory Citations

Section 109
§570.602

Other Reference Materials on This
Topic

9 Fair Housing Planning Guide website:
http://www.hud.gov/offices/fheo/images/fhpg.pdf

19.1.1

Basic Overview

This chapter summarizes the key regulations and requirements of fair housing and equal
opportunity laws applicable to CDBG projects. To be in compliance, the grantee must adhere to
all the basic tenets of fair housing and equal opportunity regulations. To demonstrate support
for ensuring these tenets, grantees must endorse in attitude and deed all regulations for fairness
in the provision of CDBG funded programs and projects.
Fair housing and equal opportunity laws are like an umbrella, intended to protect individuals
from discrimination in housing, employment, through business opportunities such as
contracting, or through other benefits created by CDBG projects.

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-1

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 2 of Exhibit
19
I
Chapter 19: Fair Housing

19.1.2 Consolidated Plan Requirements
Grantees are required to complete an analysis of impediments to fair housing choice within one
year of the effective date of the Consolidated Plan Rule (February 6, 1995). The analysis is not
required to be submitted as part of the consolidated plan, but the jurisdiction must certify that it
completed the analysis, is taking appropriate actions to overcome the effects of any
impediments identified through that analysis, and maintains records reflecting the analysis and
related actions.

Analysis of Impediments to Fair Housing Choice
In accordance with the Fair Housing Act, the Secretary requires that CDBG grantees administer
all programs and activities related to housing and community development in a manner to
affirmatively further the policies of the Fair Housing Act. As part of the certification to
affirmatively further fair housing that grantees are required to submit with their consolidated
plan, grantees must complete an analysis of impediments to fair housing choice and to take
actions to overcome the effects of any impediments identified through that analysis.
In summary, requirements for the analysis of impediments include:

9 Grantees are to assume the responsibility of fair housing planning by conducting an analysis
to identify impediments to fair housing choice within their jurisdictions;

9 Grantees are strongly encouraged to annually update their analysis of impediments; and
9 Grantees are to take appropriate actions to overcome the effects of any impediments
identified through their analyses, and maintaining records reflecting the analyses and related
actions.

19.1.3

List of Applicable Laws

This chapter is broken down into three broad areas for the applicable requirements: Fair
Housing; Handicap Accessibility; and Equal Opportunity. The fourth section of this chapter is
dedicated toward appropriate record keeping and monitoring. Exhibit 19.1 provides the grantee
with references to the major regulations and requirements covering fair housing and equal
opportunity.
Exhibit 19.1
Federal and State Laws and Regulations
(included amendments)
Title VI of the Civil Rights Act of 1964: This Act provides that
no person shall be excluded from participation, denied program
benefits, or subject to discrimination based on race, color,
and/or national origin under any program or activity receiving
Federal financial assistance.
Title VIII of the Civil Rights Act of 1968 (The Fair Housing
Act): This Act prohibits discrimination in housing on the basis
of race, color, religion, sex and/or national origin. This law also
requires actions which affirmatively promotes fair housing.

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

Fair Housing and
Nondiscrimination

Accessibility

Equal
Employment
and Contracting

X

X

X

19-2

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 3 of Exhibit
19
I
Chapter 19: Fair Housing

Restoration Act of 1987. This Act restores the broad scope of
coverage and clarifies the application of the Civil Rights Act of
1964. It also specifies that an institution which receives
Federal financial assistance is prohibited from discriminating on
the basis of race, color, national origin, religion, sex, disability,
or age in a program or activity which does not directly benefit
from such assistance.

X

Section 109 of Title 1 of the Housing and Community
Development Act of 1974: This section of Title 1 provides that
no person shall be excluded from participation (including
employment), denied program benefits, or subject to
discrimination on the basis of race, color, national origin, or sex
under any program or activity funded in whole or in part under
Title I of the Act.

X

The Fair Housing Amendment Act of 1988: This Act
amended the original Fair Housing Act to provide for the
protection of families with children and people with disabilities,
strengthen punishment for acts of housing discrimination,
expand of the Justice Department jurisdiction to bring suit on
behalf of victims in Federal district courts, and create an
exemption to the provisions barring discrimination on the basis
of familial status for those housing developments that qualify as
housing for persons age 55 or older.

X

The Housing for Older Persons Act of 1995 (HOPA):
Retained the requirement that the housing must have one
person who is 55 years of age or older living in at least 80
percent of its occupied units. The Act also retained the
requirement that housing facilities publish and follow policies
and procedures that demonstrate intent to be housing for
persons 55 and older.

X

The Age Discrimination Act of 1975: This Act provides that
no person shall be excluded from participation, denied program
benefits, or subject to discrimination on the basis of age under
any program or activity receiving Federal funding assistance.
Effective January 1987, the age cap of 70 was deleted from the
laws.

X

Section 504 of the Rehabilitation Act of 1973: It is unlawful
to discriminate based on disability in Federally assisted
programs. This section provides that no otherwise qualified
individual shall, solely by reason of his or her disability, be
excluded from participation (including employment), denied
program benefits, or subjected to discrimination under any
program or activity receiving Federal funding assistance.
Section 504 also contains design and construction accessibility
provisions for multi-family dwellings developed or substantially
rehabilitated for first occupancy on or after March 13, 1991.

X

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

X

X

X

19-3

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 4 of Exhibit
19
I
Chapter 19: Fair Housing

The Americans with Disabilities Act of 1990 (ADA): This Act
modifies and expands the Rehabilitation Act of 1973 to prohibit
discrimination against “a qualified individual with a disability” in
employment and public accommodations. The ADA requires
that an individual with a physical or mental impairment who is
otherwise qualified to perform the essential functions of a job,
with or without reasonable accommodation, be afforded equal
employment opportunity in all phases of employment.

X

Executive Order 11063: This Executive Order provides that no
person shall be discriminated against on the basis of race,
color, religion, sex, or national origin in housing and related
facilities provided with Federal assistance and lending practices
with respect to residential property when such practices are
connected with loans insured or guaranteed by the Federal
government.

X

Executive Order 11259: This Executive Order provides that
the administration of all Federal programs and activities relating
to housing and urban development be carried out in a manner
to further housing opportunities throughout the United States.

X

Section 109 of Title I of the Housing and Community
Development Act of 1974: Requires that no person shall be
excluded from participation in, be denied the benefits of, or be
subjected to discrimination under any program or activity
funded with CDBG funds on the basis of race, color, religion,
national origin, or sex.

X

X

X

X

The Equal Employment Opportunity Act: This Act empowers
the Equal Employment Opportunity Commission (EEOC) to
bring civil action in Federal court against private sector
employers after the EEOC has investigated the charge, found
“probable cause” of discrimination, and failed to obtain a
conciliation agreement acceptable to the EEOC. It also brings
Federal, State, and local governments under the Civil Rights
Act of 1964.

X

The Immigration Reform and Control Act (IRCA) of 1986.
Under IRCA, employers may hire only persons who may legally
work in the U.S., i.e., citizens and nationals of the U.S. and
aliens authorized to work in the U.S. The employer must verify
the identity and employment eligibility of anyone to be hired,
which includes completing the Employment Eligibility
Verification Form (I-9).

X

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-4

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 5 of Exhibit
19
I
Chapter 19: Fair Housing

The Uniform Guidelines on Employee Selection
Procedures adopted by the Equal Employment Opportunity
Commission in 1978: This manual applies to employee
selection procedures in the areas of hiring, retention,
promotion, transfer, demotion, dismissal and referral. It is
designed to assist employers, labor organizations, employment
agencies, licensing and certification boards in complying with
the requirements of Federal laws prohibiting discriminatory
employment.

X

Section 3 of the Housing and Urban Development Act of
1968, as amended: Requires the provision of opportunities for
training and employment that arise through HUD-financed
projects to lower-income residents of the project area, to the
greatest extent feasible and consistent with Federal, State and
local laws and regulations. Also required is that contracts be
awarded to businesses that provide economic opportunities for
low- and very low-income persons residing in the area.
Amendments to Section 3 in 1992 included requirements for
providing these opportunities in contracts for housing
rehabilitation, including lead-based paint abatement, and other
construction contracts.

X

The Vietnam Era Veterans’ Readjustment Act of 1974
(revised Jobs for Veterans Act of 2002): This Act was
passed to ensure equal employment opportunity for qualified
disabled veterans and veterans of the Vietnam War.
Affirmative action is required in the hiring and promotion of
veterans.

X

Executive Order 11246: This Executive Order applies to all
Federally assisted construction contracts and subcontracts. It
provides that no person shall be discriminated against on the
basis of race.

X

24 CFR Part 85 (the Common Rule): This rule provides that
the grantee shall take affirmative steps to encourage
contracting with small minority and female owned business
enterprises when possible as sources of supplies, equipment,
construction, and services.

X

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-5

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 6 of Exhibit
19
I
Chapter 19: Fair Housing

19.2 Fair Housing
This section of the chapter reviews the requirements grantees must follow to be in compliance
with the Fair Housing Act when using CDBG funds.
The following is a summary of the topics in this section, applicable statutory and regulatory
cites, and other reference materials available from HUD.
Key Topics in This Section

9 Prohibited Discrimination
9 Fair Housing Activities

Regulatory/Statutory Citations

Section 109
§570.602

Other Reference Materials on This
Topic

9 CPD Notice 05-09 and 00-09
9 Fair Housing and Equal Opportunity Website:
http://www.hud.gov/offices/fheo/index.cfm
9 Uniform Federal Accessibility Standards website:
http://www.access-board.gov/ufas/ufas-html/ufas.htm
9 The Fair Housing Act Design Manual: A Manual to Assist Designers
and Builders in Meeting the Accessibility Requirements of The Fair
Housing Act

19.2.1

Prohibited Discrimination

Grantees should be aware that fair housing provisions apply to the locality as a whole and not
just those activities that are CDBG funded; and that implementing fair housing activities is an
essential part of the CDBG responsibilities. No person shall be subjected to discrimination
because of: race, color, religion, sex, disability, age, familial status, or national origin.
Fair housing actions should increase housing opportunities and affirmatively promote fair
housing throughout the entire housing market at all income levels. These activities may include
independent actions by the grantee or cooperative ventures with housing related industries,
such as mortgage lenders, home builders, and local non-profits working in housing. The
grantee is expected to take progressive actions to further fair housing with each CDBG project.
The grantee must assure that all CDBG-funded activities undertaken as part of the project are
conducted in a manner which will not cause discrimination on the basis of race, color, religion,
sex, disability, familial status, or national origin. Segregated facilities, services, or benefits and
different treatment are prohibited.
The grantee should take care to ensure the following:

9 Access to any advantage arising out of the project is not:
– Denied solely on the basis of race, color, religion, sex, disability, familial status, or national
origin; or
– Offered for the enjoyment of a segment of the population in such a way as to intentionally
exclude any member of these protected groups.

9 Selection of sites and locations for facilities and improvements do not have an exclusionary
or discriminatory effect.

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-6

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 7 of Exhibit
19
I
Chapter 19: Fair Housing

9 Evaluation criteria and administrative practices do not have a discriminatory effect.
9 Affirmative action is used to overcome the effects of past discrimination.
9 A Fair Housing Poster is displayed in a prominent place at the office of the grantee where
applications for assistance are being taken.

19.2.2

Fair Housing Activities

The Fair Housing Act provides that, in connection with the design and construction of multifamily housing, the public use and common areas must be accessible and usable by persons
with handicaps, all doors must be designed to be wide enough for wheelchair accessible, and all
premises should be of adaptive design (e.g., reinforcements within a bathroom to allow
installation of grab bars).
Grantees undertaking housing projects and activities must ensure fair housing rules are
followed in the provision of housing services and assistance. Opportunities for purchase or
rental, terms and conditions, advertising and marketing information, and availability of real
estate services should not discriminate.
Some examples of possible actions to ensure fair housing are listed below.

9 Developing and implementing a fair housing resolution;
9 Marketing information concerning housing services and activities should be disseminated
through agencies and organizations that routinely provide services to protected groups;

9 Criteria for selecting recipients of housing services or assistance should be evaluated for any
discriminatory effect;

9 Policies guiding the provisions of relocation housing and services for persons displaced by
housing activities should be evaluated for discriminatory effect; and

9 Legal documents used by grantees and lending institutions should be reviewed and revised if
necessary to eliminate any discriminatory intent or practice.
It is important for grantees to understand both the Fair Housing Amendment and Section 504.
The Fair Housing Amendment requires that a landlord must allow a tenant to make reasonable
modifications to a unit paid for by the tenant. Section 504 provides that the landlord is
responsible for making reasonable accommodations. Finally, the accessibility logo should be
used in housing projects where units are available for the disabled.

19.2.3

Affirmative Marketing

9 Grantees must adopt affirmative marketing procedures and requirements for all CDBGassisted housing with five or more units.

9 Requirements and procedures must include:
–  Methods for informing the public, owners and potential tenants about fair housing laws
and the grantee's policies (for example, use of the Fair Housing logo or equal opportunity
language);
–  A description of what owners and/or the grantee will do to affirmatively market housing
assisted with CDBG funds;

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-7

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 8 of Exhibit
19
I
Chapter 19: Fair Housing

–  A description of what owners and/or the grantee will do to inform persons not likely to
apply for housing without special outreach;
–  Maintenance of records to document actions taken to affirmatively market CDBG-assisted
units and to assess marketing effectiveness; and
–  Description of how efforts will be assessed and what corrective actions will be taken
where requirements are not met.

19.3 Handicapped Accessibility and Section 504
The following is a summary of the topics in this section, applicable statutory and regulatory
cites, and other reference materials available from HUD.
Key Topics in This Section

9
9
9
9
9

Regulatory/Statutory Citations

Section 109
§570.614

Other Reference Materials on This
Topic

9 CPD Notice 00-10
9 Fair Housing and Equal Opportunity Website:
http://www.hud.gov/offices/fheo/index.cfm
9 CPD Notice 05-10

19.3.1

Programs
Housing
Facilities
Other Accessibility Rules
Self Evaluation and Transition Plan

Program Accessibility

Communication is an important component of program accessibility. Disabilities involving
impairments to hearing, vision, speech or mobility may affect communication. Members of the
community who have disabilities must be able to access and enjoy the benefits of a program or
activity receiving CDBG funds; therefore, varied approaches may be required to assure effective
communication and information dissemination.
Specifically, the grantee must be receptive to the requests and needs of the disabled person(s)
within the community when determining which auxiliary aids or services are necessary. For the
purposes of Section 504 compliance, the target population includes: the hearing impaired,
visually impaired, mobility impaired, developmentally disabled, and those persons requiring inhome care or institutional care. Grantees must furnish auxiliary aids and services, as
necessary, which may include:

9 For persons with hearing impairments:
–  Qualified sign language interpreters;
–  Note takers;
–  Telecommunication devices for deaf persons (TDDs);
–  Telephone handset amplifiers;

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-8

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 9 of Exhibit
19
I
Chapter 19: Fair Housing

–  Assertive listening devices (devices that increase the sound in large group settings);
–  Flashing lights (where aural communication is used, such as warning bells);
–  Video text displays (devices that display text that is simultaneously being spoken can be
used where a public address system provides information);
–  Transcription services; and
–  Closed and open captioning.

9 For persons with vision impairments:
–  Qualified readers;
–  Written materials translated into alternative formats (e.g., Braille, audio tape, large print);
–  Aural communication (e.g., Bells or other sounds used where visual cues are necessary);
and
–  Audio description services (i.e., through a headset, a narrator describes what the visually
impaired person cannot see).
The grantee must ensure effective communication with persons with all types of disabilities in all
activities. Where the grantee communicates with applicants and beneficiaries by phone, a TDD
is required or an equivalent system must be available.
Please note that grantees are not required to take any action that would result in a fundamental
alteration in the nature of a program or activity or undue financial and administrative burdens.

19.3.2

Housing

Section 504 also includes accessibility requirements for new construction and substantial
rehabilitation of multi-family rental housing. Section 504 provides that no otherwise qualified
individual shall, solely by reason of his or her disability, be excluded from participation in
(including employment), denied program benefits, or subjected to discrimination under any
program or activity receiving Federal funding assistance. Section 504 also contains design and
construction accessibility provisions for certain new multi-family dwellings developed for first
occupancy on or after March 13, 1991.
For the purposes of compliance with Section 504, “accessible” means ensuring that program
and activities, when viewed in their entirety, are accessible to and usable by individuals with
disabilities. For housing purposes, accessible means a dwelling is on an accessible route and
adaptable inside.

9 The following requirements apply to both Federally assisted newly constructed multifamily
rental housing containing five or more units and substantial rehabilitation of multi-family
rental housing with fifteen (15) or more units. A rehabilitation project is considered
substantial when the rehab costs will be 75% or more of the replacement cost of the
complete facility;
–  A minimum of five percent of total dwelling units (but not less than one unit) accessible for
individuals with mobility impairments;
–  An additional 2% of dwelling units (but not less than one) accessible for persons with
hearing or vision impairments; and

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-9

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 10 ofExhibit
19
I
Chapter 19: Fair Housing

– All units made adaptable that are on the ground level or can be reached by an elevator.

19.3.3

Facilities

“Facility” is defined under Section 504 as any portion of a building, equipment, roads, walkways,
parking lot or other real property. “Accessible” for non-housing purposes means that a facility or
portion of a facility can be approached, entered and used by individuals with physical
handicaps.
Non-housing programs, as well as existing facilities in which they are situated, must be readily
accessible to and usable by persons with disabilities. Accessibility programs will be determined
once again under self-evaluation. The focus of program access is providing programs in the
most integrated setting possible. Providing separate or different programs is illegal unless
necessary to achieve equal opportunity.
Methods of improving program access in existing facilities can include the following:

9 Relocating programs to accessible facilities or accessible portions of facilities;
9 Acquiring or building new facilities;
9 Selectively altering facilities;
9 Changing operating policies and procedures;
9 Assigning aides to assist beneficiaries;
9 Adding or redesigning equipment or furnishings; and
9 Conducting home visits.

19.3.4 Special Requirements for Grantees with 15 or More
Employees
There are two additional requirements for Section 504 compliance for grantees (called
“recipients” under 504 to include public agencies, instrumentalities, and public and private
entities including nonprofits) with fifteen (15) or more full or part-time employees:

9 Designation of responsible employee and adoption of grievance procedures:
–  At least one person must be designated to coordinate 504 and related compliance efforts.
The agency coordinator should be designated in writing and identified in any written
notices.
–  A grievance procedure must also be adopted incorporating due process standards and
allowing for prompt local resolution of any complaints of discrimination based on disability.
Existing grievance procedures can often be adapted to satisfy this requirement.
–  Any individual or authorized representative who believes that they have been denied
opportunities or treated differently due to their race, color, national origin, sex, age
disability, religion and familial status may file a complaint. The complaint may be filed with
the grantee or HUD.

9 Notification to participants, beneficiaries, applicants and employees of their nondiscriminatory
provisions. In summary, the grantee must provide notice regarding the following:

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-10

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 11 ofExhibit
19
I
Chapter 19: Fair Housing

–  Grantees must publish in a newspaper of general circulation the notice “Policy of NonDiscrimination on the Basis of Disability Status.”
–  Grantees must include the same language found in their policy of nondiscrimination
(mentioned in the first bullet) in all material used for recruitment or general information.
–  Grantees must ensure that all members of the population with visual or hearing
impairments are provided with the information necessary to understand and participate in
the programs offered.
–  Methods for ensuring participation may include qualified sign language and oral 

interpreters, readers, or the use of taped and Braille materials. 


19.3.5

Other Accessibility Rules

Americans with Disabilities Act of 1990 (ADA)
The Americans with Disabilities Act of 1990 (ADA) guarantees equal opportunities for persons
with disabilities in employment, public accommodations, transportation, State and local
government services, and telecommunications. Unlike Section 504 which applies only to
programs and activities receiving Federal financial assistance, the ADA applies even if no
Federal financial assistance is given. Title II of ADA prohibits discrimination based on disability
by State and local governments.

9 Facilities
–  Title II also requires that facilities that are newly constructed or altered, by, on behalf of, or
for use of a public entity, be designed and constructed in a manner that makes the facility
readily accessible to and usable by persons with disabilities. Facilities constructed or
altered in conformance with either the Uniform Federal Accessibility Standards (UFAS) or
the ADA Accessibility Guidelines for Buildings and Facilities (ADAAG) shall be deemed to
comply with the Title II Accessibility requirements, except that the elevator exemption
contained in Section 4.1.3(5) and Section 4.1.6(1)(j) of ADAAG shall not apply.

9 Roads and Pedestrian Walkways
–  Title II specifically requires that all newly constructed or altered streets, roads, highways,
and pedestrian walkways must contain curb ramps or other sloped areas at any
intersection having curbs or other barriers to entry from a street level or pedestrian
walkway and that all newly constructed or altered street level pedestrian walkways must
have curb ramps at intersections . Newly constructed or altered street level pedestrian
walkways must contain curb ramps or other sloped areas at intersections to streets,
roads, or highways.

Architectural Barriers Act of 1968
The Architectural Barriers Act of 1968 (ABA) requires that certain buildings financed with
Federal funds must be designed, constructed, or altered in accordance with standards that
ensure accessibility for persons with physical disabilities. The ABA covers any building or
facility financed in whole or in part with Federal funds, except privately-owned residential
structures. Covered buildings and facilities designed, constructed, or altered with CDBG funds
are subject to the ABA and must comply with the Uniform Federal Accessibility Standards

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-11

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 12 ofExhibit
19
I
Chapter 19: Fair Housing

(UFAS). In practice, buildings built to meet the requirements of Section 504 and the ADA, will
conform to the requirements of the ABA.

19.3.6 Self Evaluation Plan and Transition Plan
Self Evaluation Plan
Self evaluation is required by both Section 504 and the Americans with Disabilities Act. Self
evaluation promotes inclusion of the programmatic and project-specific alternations that are
necessary to ensure long term compliance with the requirements.
If a grantee has not already performed a Section 504 self-evaluation of programs, services, and
activities to determine if they are programmatically and physically accessible to person with
disabilities, they must conduct such evaluation and document all needs. Note: If a grantee has
already performed a self-evaluation, a new one is not required.
Grantees should also involve persons with disabilities in these evaluations. While performing
the self-evaluation, a careful inspection of the following should be performed to determine if they
are free from discriminatory effects and practices:

9 Evaluate current policies and practices and analyze them to determine if they adversely
affect the full participation of individuals with disabilities in its programs, activities, and
services. Be mindful of the fact that a policy or practice may appear neutral on its face, but
may have a discriminatory effect on individuals with disabilities.

9 Modify any policies and practices that are not or may not be in compliance with Section 504
or Title II and Title III of the ADA regulations. (See 24 CFR Part 8 and 28 CFR Parts 35, 36.)

9 Take appropriate corrective steps to remedy those policies and practices that either are
discriminatory or have a discriminatory effect. Develop policies and procedures by which
persons with disabilities may request a modification of a physical barrier or a rule or practice
that has the effect of limiting or excluding a person with a disability from the benefits of the
program.

9 Document the self-evaluation process and activities. HUD recommends that all recipients
keep the self-evaluation on file for at least three years, including records of the individuals
and organizations consulted, areas examined and problems identified, and document
modifications and remedial steps.
An approach many grantees have used to examine service and program accessibility is to do a
walk-through of the process required for participation. Analyze not only the physical path
traveled, but also the administrative requirements, service delivery, eligibility criteria, and
application procedures.
Any policies and practices that are found to be discriminatory or contrary to Section 504
requirements must be modified and steps taken to remedy the discrimination.

Transition Plan
If structural barriers have been identified during the self-evaluation process and cannot be
removed with nonstructural solution, a Transition Plan must be completed and made available
for public review and comment.

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-12

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 13 ofExhibit
19
I
Chapter 19: Fair Housing

The plan must address the following items:

9 Identification of physical obstacles in the facilities that limit program accessibility;
9 Description of the method that will be used to make facilities accessible;
9 Specify a schedule to achieve full program compliance and, if the plan is longer than one
year, identify steps to be taken during each year;

9 Indicate the person responsible for implementing the plan; and
9 Identify the person or groups with whose assistance the plan was prepared.
The grantee is not necessarily required to make each existing facility or every part of an existing
facility accessible. The Transition Plan must involve persons with disabilities and/or
representative organizations.

19.4 Employment and Contracting
Employment and contracting activities also trigger employment and contracting rules related to
equal employment practices.
The following is a summary of the topics in this section, applicable statutory and regulatory
cites, and other reference materials available from HUD.
Key Topics in This Section

9 Employment
9 Procurement (MBE/WBE)
9 Section 3

Regulatory/Statutory Citations

Section 109
§570.607

Other Reference Materials on This
Topic

9 Fair Housing and Equal Opportunity Website:
http://www.hud.gov/offices/fheo/index.cfm
9 The Uniform Guidelines on Employee Selection Procedures adopted
by the Equal Employment Opportunity Commission in 1978

19.4.1 Employment
Nondiscrimination is a requirement of employment and employment practices. Employment
opportunities may not be denied on the basis of race, color, national origin, sex, age, religion,
familial status, or disability. Affirmative action and equal employment opportunity policies are
fundamental aspects of CDBG funded activities.
The Americans with Disabilities Act modifies and expands the Section 504 Rehabilitation Act of
1973 to prohibit discrimination against “a qualified individual with a disability” in employment and
public accommodations. The ADA requires that an individual with a physical or mental
impairment who is otherwise qualified to perform the essential functions of a job, with or without
reasonable accommodation, be afforded equal employment opportunity in all phases of
employment.
The Equal Employment Opportunity Act empowers the Equal Employment Opportunity
Commission (EEOC) to bring civil action in Federal court against private sector employers after

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-13

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 14 ofExhibit
19
I
Chapter 19: Fair Housing

the EEOC has investigated the charge, found “probable cause” of discrimination, and failed to
obtain a conciliation agreement acceptable to the EEOC. It also brings Federal, State, and local
governments under the Civil Rights Act of 1964.
Steps that can be taken to prevent discrimination in employment include the following:

9 Review of jurisdictional employment policies and procedures for discriminatory intent or
practice and document review;

9 Advertise employment opportunities and/or to recruit employees for project-related positions;
9 Develop and maintain employment data that indicates staff composition by race, sex,
handicap status and national origin; and

9 An Equal Employment Opportunity Poster must be displayed in a prominent place at the
office of the grantee.
Specifically, Section 504 has a number of general prohibitions against employment
discrimination. Grantees must ensure that the following items are adhered to:

9 No qualified individual with a disability shall, solely on the basis of their disability be subject
to discrimination in employment under any program or activity that receives Federal
assistance.

9 Any grantee cannot legally limit, segregate or classify applicants or employees in any way
that negatively affects their status or opportunities because of disability.

9 In pre-employment and employment activities, discrimination based on a disability must not
occur and reasonable accommodations must be made to the physical or mental limitations of
otherwise qualified individuals unless it creates undue hardship for the grantee. HUD
regulations specify that an employer is prohibited from discrimination in the following
instances:

9 Recruiting, advertising, and processing of applications;
–  Hiring, upgrading, promoting, tenure, demotion, transfer, layoffs, termination right or return
from layoffs, illness, and rehiring;
–  Rates of pay and any other forms of compensation;
–  Job assignments, classifications and descriptions, organizational structures, lines, 

progression, and seniority lists;

–  Leaves of absence, sick leave, or any other leave;
–  Fringe benefits available by virtue of employment;
–  Selection and financial support for training, including apprenticeship, professional
meetings, conferences, and other related activities and selection for leaves of absence for
training;
–  Employer sponsored activities (including social or recreation programs); and
–  Any other term, condition, or privilege of employment.

9 Grantees may not participate in a contractual or other relationship that subjects qualified
disabled applicants or employees to discrimination.

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-14

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 15 ofExhibit
19
I
Chapter 19: Fair Housing

Reasonable accommodation, under Section 504, in employment is determined on a case-bycase basis. It means reasonable modifications on the job or in the workplace to enable a
disabled person to perform the job for which she/he is qualified. Section 504 does not require
the hiring or promotion of someone simply because she/he has a disability.

19.4.2

Procurement

All procurements made in whole or in part with CDBG funds must comply with the applicable
Federal requirements found in 24 CFR Part 85.36 (referred to as the “Common Rule”). The
goal in using these procurement procedures is to achieve maximum open and free competition.
Each grantee is required to adopt written procurement procedures for CDBG projects, as
required in 24 CFR Part 85.36(b). If local procurement procedures are more stringent than
those described in this chapter, the more stringent of the two should be followed.
Important elements that are required to comply with Federal requirements, but that are often
missing in local procurement codes, include:

9 A code of conduct to govern the performance of the grantee’s officers, employees, or agents
in contracting with CDBG funds; and

9 A requirement that positive efforts be made to use small, minority, female, low-income and/or
locally-owned businesses.
Part 85 provides that the grantee shall take affirmative steps to encourage contracting with
small minority and female owned business enterprises when possible as sources of supplies,
equipment, construction, and services.
At the very least, the grantee must also include minority business enterprises (MBEs) and
women business enterprises (WBEs) on solicitation lists and send them an Invitation to Bid.
Other outreach efforts that grantees should consider are:

9 Assuring that small businesses and MBE/WBEs are solicited whenever they are potential
sources;

9 When economically feasible, dividing total requirements into smaller tasks or quantities so as
to permit maximum participation by small businesses and MBE/WBEs;

9 Where the requirements permit, establishing delivery schedules which will encourage
participation by small businesses and MBE/WBEs;

9 Using the services and assistance of the Small Business Administration;
9 If any subcontracts are to be executed, requiring the prime contractor to take the above
affirmative steps; and

9 When economically feasible, including MBE/WBE criteria with additional points in selection
criteria for professional services procurements.
The Vietnam Era Veterans Readjustment Act, as amended, includes the obligation to refrain
from discrimination in employment against protected veterans. The regulations also require all
covered contractors and subcontractors to include a specific equal opportunity clause in each of
their nonexempt contracts and subcontracts.

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-15

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 16 ofExhibit
19
I
Chapter 19: Fair Housing

19.4.3

Section 3

Section 3 of the Housing and Urban Development Act of 1968, as amended, requires the
provision of training, employment and other economic opportunities that arise through HUDfinanced housing and community development assistance to lower-income residents of the
project area, particularly residents of government-subsidized housing, to the greatest extent
feasible and consistent with Federal, State, and local laws and regulations. Also required is that
contracts be awarded to businesses that provide economic opportunities for low- and very lowincome persons residing in the project area. Amendments to Section 3 in 1992 included
requirements for providing these opportunities in contracts for housing rehabilitation, including
lead-based paint abatement, and other construction contracts.
Section 3 applies when a housing construction, housing rehabilitation or other public
construction project or activity exceeds certain thresholds. Contractors and subcontractors
providing services on projects for which the total amount of the housing and community
development assistance exceeds $200,000 and the amount of the contract or subcontract
exceeds $100,000 are required to comply with Section 3. If a grantee receives housing or
community development assistance for a covered project that is funded in part with CDBG
funds, Section 3 requirements apply to the entire project or activity.
It is important to document efforts made to comply with Section 3 through recordkeeping. Files
should contain memoranda, correspondence, advertisements, etc., illustrating contractor and
subcontractor attempts to hire low income residents and business concerns.

19.5 Recordkeeping and Monitoring
Effective recordkeeping procedures and monitoring are tools that grantees use to ensure short
term and long term compliance.
The following is a summary of the topics in this section, applicable statutory and regulatory
cites, and other reference materials available from HUD.
Key Topics in This Section

9
9
9
9
9
9

Regulatory/Statutory Citations

Section 109
§570.506

Other Reference Materials on This
Topic

9 CDBG Guide to Eligible Activities and National Objectives, Chapters 2 & 3
9 Managing CDBG: A Guidebook for CDBG Grantees on Subrecipient
Oversight

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

Fair Housing Records
Direct Benefit Records
504 Records
Employment and Contracting
Monitoring
FHEO Compliance and Monitoring

19-16

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 17 ofExhibit
19
I
Chapter 19: Fair Housing

19.5.1

Fair Housing Records

The following records must be maintained by the grantee in a separate equal opportunity and
fair housing file:

9 Documentation of the action(s) the grantee has taken to affirmatively further fair housing,
including records on funds provided, if any, for such actions; and

9 Demographic data (actual survey or latest census data) depending on the project undertaken
may include:
–  The population of the jurisdiction of the unit of general local government receiving CDBG
funds;
–  The minority population of the locality (number and percentage);
–  The target area population;
–  The minority population of the target area (number and percentage);
–  The number of disabled, elderly households, and female-headed households in the target
area; and
–  A map of the locality showing the locations of assisted housing units, concentrations of
minority population, concentrations of LMI, and the target area.

19.5.2

Direct Benefit Records

It is important that grantees maintain statistical information on the persons benefiting from the
project be maintained and updated throughout the implementation of the project. Even if the
project activities meet the “presumptive benefit” test for proving LMI benefits and surveys have
not been conducted or statistical data on beneficiaries has not been collected, benefit data for
fair housing and equal opportunity purposes must be maintained.
Grantees should note that those benefiting from the project must be determined. A Project
Benefit Profile must be maintained for each activity except administration, planning, and
contingency.

9 For direct benefit activities, provide data on the extent to which persons have applied for
benefits and participated in or benefited from any program or activity funded in whole or in
part with CDBG funds. Records must be kept by race, ethnicity, and gender of heads of
households.

19.5.3

Section 504 Records

The following records must be maintained by the grantee in a separate 504 file:

9 A copy of the self-evaluation;
9 A copy of the transition plan;
9 A list of interested persons who were consulted;
9 A description of areas and buildings examined and any problems identified;
9 A description of modifications made and remedial steps taken to comply with the regulations;
and

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-17

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 18 ofExhibit
19
I
Chapter 19: Fair Housing

9 Evidence that new or substantial rehab multi-family projects were constructed/rehabilitated to
meet 504 standards.

19.5.4

Employment and Contracting

Data on employment of the local government that is carrying out an activity funded in whole or
in part with CDBG funds. The data to be maintained in the files includes:

9 A description of the local government work force in percentage by race, gender, job title,
salary, and hire date;

9 The percentage of minorities in the jurisdiction of the unit of general local government that is
receiving CDBG funds and the percentage of minorities working for that unit of general local
government;

9 The number of project area residents employed with CDBG funds;
–  Data should show the percentage by race and gender of the personnel in any department,
office, or agency of the unit of local government using CDBG funds to employ staff.
–  For example, if CDBG funds are being used to pay a portion of a bookkeeper's salary in
the accounting department of the city, then employment data should be available for the
department.

9 Government hiring practices and policies;
9 Affirmative Action Plan (if applicable);
9 Documentation of the affirmative actions the grantee has taken to overcome the effects of
prior discrimination as determined through a formal compliance review or court proceeding,
where the grantee has previously discriminated against persons on the grounds of race,
color, national origin, or sex in administering a program or activity funded in whole or in part
with CDBG funds.

9 Procurement procedures and implementation plan;
9 Minority and Women Business Enterprise (MBE/WBE) outreach and networking;
9 MBE and WBE reporting;
9 Section 3 Plan;
9 Section 3 Summary Report (CAPER); and
9 Section 3 reporting by contractors.

19.5.5

Monitoring

The designated fair housing and equal opportunity coordinator and/or officers should review
compliance requirements on an annual basis.
Grantees will be monitored by HUD on a periodic basis. Proper notification of a monitoring visit
will be provided. However, it is important for grantees to keep all records and files in
“monitoring readiness” condition at all times. Some of the areas HUD staff will review to
determine if grantees meet compliance with all fair housing and equal opportunity requirements
and laws are listed below:

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-18

 Case 1:19-cv-01442-CCB Document 1-9 Filed 05/16/19 Page 19 ofExhibit
19
I
Chapter 19: Fair Housing

9 A check of the availability and adequacy of employment records;
9 Identification of programs and activities assisted through CDBG funding and assessment of
program impact on protected groups;

9 An examination of procurement procedures and awards to assess the utilization of minority
and/or female owned enterprises and businesses located in the project area or owned in
substantial part by project area residents;

9 A review of voluntary efforts to promote fair housing; and
9 An examination of the extent to which various protected groups have been impacted by
relocation activities.

19.5.6

HUD FHEO Compliance and Monitoring

HUD’s Office of Fair Housing and Equal Opportunity (FHEO) is responsible for seeking
cooperation from and providing assistance to grantees regarding compliance. FHEO may
perform periodic reviews of grantees or require reports or other information to measure
compliance including records of program participation by individuals with handicaps.
It is important for grantees to keep organized records and document their Section 504 activities.
A complaint can be made by any individual or authorized representative of that individual who
believes they have been denied opportunities or treated differently, due to their race, ethnicity,
gender, disability, or age.
This complaint would be filed with FHEO under the Housing Discrimination Form 903.1. The
complainant’s identity will be held in confidence unless written authorization is given. The time
period for filing complaints is within one hundred eighty (180) days of the alleged act. Grantees
should have copies of this form available to the public.
Person who believes his/her rights have been violated may file in Federal court. The remedy
through court action may include the award of damages, back pay, seniority and as with any
equal opportunity action, attorney fees, or injunction against the noncomplying project.
It is HUD’s policy to encourage informal resolutions to matters, solicit voluntary compliance and
corrective action. Noncompliance may result ultimately in the termination of or refusal to grant
Federal assistance.

Basically CDBG (July 2012)
HUD, Office of Block Grant Assistance

19-19

 Caseof1:19-cv-01442-CCB
Cttp
Annapolis

Document 1-10 Filed 05/16/19 Page 1Exhibit
of 3
J

Department of Planning & Zoning
145 Gorman Street Third Floor
Annapolis, MD 21401-2517
Permitting®.annapolis.gov • 410-260-2200 • Fax 410-263-9158 • www.annapQlis.gov
Deaf, hard of hearing or speech disability - use MD Relay or 711

Notice of Inspection
CITY OF ANNAPOLIS HO,
c/o Venus Bradford
1217 Madison Street
ANNAPOLIS, MD 21401

Re.

August 04, 2016

1125MADISONSTB3

Dear Owner/Agent:
Enclosed is a City of Annapolis Property Maintenance Inspection Correction Notice for the above referenced property which
outlines property maintenance code violations found during a recent inspection. Our records indicate that you own/operate
this property.

Friday, September 2, 2016
Please note that if these violations are not corrected or abated by the re-inspection date above, a municipal infraction citation
of $200.00 will be issued in accordance with Annapolis Charter and Code Section 17.40.890. Additional municipal
infraction citations may be assessed for each successive day that the violation has not been corrected.
The enclosed violation corrections must be made regardless of any lease agreements between owner and tenant. If you feel
for any reason that the attached notice is unfair or creates undue hardship, you may appeal this action to the Board of
Appeals established by Chapter 17.40.880 of the Annapolis Charter and Code. In order to initiate an appeal, contact the
Director of the Department of Neighborhood and Environmental Programs in writing within ten (10) days of the date of this
notice indicating your reason for appealing, along with a $250.00 non-refundable fee made payable to the City of Annapolis.
You will be notified of the hearing date.
If you have any questions, please contact our office at 410-260-2200.
Sincerely.

Property Maintenance Inspector

 8/4/2016

Case 1:19-cv-01442-CCB Document 1-10 Filed 05/16/19 Page 2 Exhibit
of 3
J

Page 1 of 2

Case Violation History

Case Number
Case Name

RENT1608-004

Opened

RKNTAL
VIOLATIONS
U N I M - R REVIEW

Subtype
Status
Description:

Follow Up

Site Address

City

1 125 MADISON S'l B.3

ANNAPOLIS

Owner
Address

CITY OF A N N A P O L I S I1O,
c/o Venus Bradford
ANNAPOLIS, MD 21401

Observed
Type

8/3/2016
Building

Status

NOT ABATED

Location

8/4/2016

ML

9/2/2016

ML-

Closed
Last Action

State
MD

Zip
21403

Site APN

020600000142200

Responsible Party CITY OF ANNAPOLIS HO,
c/o Venus Bradford
ANNAPOLIS, MD 21401

(8/4/2016 12:41 I'M MEL)
CHECK F.NT1RH UNIT FOR MOLD AND CLLAK BY LICHNSFD MOLD CONTRACTOR
BEFORE f L N A N T IS P U T B A C K INTO I HE U N I T

Throughout

Date Corrected
Observed
Type

8/3/2016
Ceiling defective

Status

N O T ABATKD

Location

BATHROOM

Date Corrected

Observed 8/3/2016
Type
Walls Defective ( I n t e r i m
Status
Location

NO I ABATE!)
MASTER BKDKOOM - WALLS
& FLOORING

Date Corrected

305.3 Interior surfaces. All interior surfaces, including windows
and doors, shall he maintained in good, clean and sanitary
condition. Peeling, chipping, linking or abraded paint shall he
repaired, removed or covered. Cracked or loose plaster,
decayed wood and other defective surface conditions shall he
corrected.
(8/4/2016 12:40 I'M MLK)
BAfHROOM - CEILING - SFWAGF LEAKAGE IN THE BATHROOM CEILING AREA
R E M O V E DRYWAL1 IN THIS A R E A AND REPLACE
IPMC305.3 Interior surfaces. All interior surfaces, including windows
and doors, shall be maintained in good, clean and sanitary
condition. Peeling, chipping, linking or abraded paint shall he
repaired, removed or covered. Cracked or loose plaster,
decayed wood and other defective surface conditions shall he
corrected.
(8/4/2016 12:39 PM MKK)
MASTER BEDROOM - WALLS - OUTER WALL AREA MEFTiNG THE NEXT
B U I L D I N G - WATER DAMAGE FROM ROOF D R A I N A G E ISSUE;- R E M O V E
DRY WAI EON THIS AREA ANi> RKFM.ACK - BUILDING PERMITS WILL BE
R E Q U I R E D WHEN R E M O V I N G MORE THEN A SMHK I OF DRY WALL
ALL MOLD REMEDIATION MUST BE DONE BY ,[CENSED AND APPROVED MOLD
CONTRACTOR
E M P O R A R I L Y WHILE: U N I T IS BEING

Cnsc#RENTI608-004

Assigned Officer:

Mary F.mrick

 Case 1:19-cv-01442-CCB Document 1-10 Filed 05/16/19 Page 3 Exhibit
of 3
J

Observed M/.V2016

Type

1'loor or sub-floor dctcctuc

Status

NO I ABATHI)

Location

MASTER H I D R O O M - W A I , I S
& H.OOKlMi
(K.M'20Ui 12:17 I'M Ml !•)

IMte rorrcctcc!

MAS I L K DKDRODM - !•!.()( )R[>iCi - I A!>< >S]-;i) l ( ) MOLD SI'ORI .S - RKMOVT. AND
RClM.At'l

i H N A N i ' w n I.M;I-:D 10 HI-: RI::x)cA n.n \vnn.i A ! I A I I : M I ' \ I ' o r ' - r m - H.<HIRING

RK\T16()8-(I04

Assigned Officer:

Mary l-mrick