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    22K views79 pages

    Complaint by Carla and Jason Pierce

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    News Channel 9
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    © All Rights Reserved
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    CARLA PIERCE and JASON PIERCE, Plaintiffs, vy. CS1031 17 BROAD APARTMENTS ST, LLC, a Delaware limited liability company, as signatory trustee, not in its individual capacity, but in its sole capacity as trustee holding record title on behalf of CS1031 17 BROAD STREET APARTMENTS, DST, a Delaware statutory trust d/b/a 17 BROAD and BH MANAGEMENT SERVICES, LLC, Defendants. DOC. NO. AC 510 DIV. COMPLAINT Plaintiffs, Carla Pierce and Jason Pierce, by and through counsel, hereby bring this action against the above-referenced Defendant, and for their Complaint would state as follows: PARTIES, JURISDICTION, AND VENUE 1. Plaintiff Carla Pierce is an adult and resident of Cobb County, Georgia. 2. Plaintiff Jason Pierce is the adult child of Carla Pierce and a former resident of Hamilton County, Tennessee, now living in Cobb County, Georgia. 3. Defendant, CS1031 17 BROAD APARTMENTS ST, LLC, a Delaware limited liability company, as signatory trustee, not in its individual capacity, but in its sole capacity as trustee holding record title on behalf of CS1031 17 BROAD STREET APARTMENTS, DST, a Delaware statutory trust d/b/a 17 BROAD (“17 BROAD” or “Defendant”), is registered with and doing business in the state of Tennessee and may be served through its registered agent, Incorp Services, Inc., 1585 Mallory Ln, Ste. 104, Brentwood, Tennessee 37027. 4, Defendant, BH Management Services, LLC, an Towa limited liability company, (“BH Management” or “Defendant”), is registered with and doing business in the state of Tennessee and may be served through its registered agent, Corporation Service Company, 2908 Poston Ave, Nashville, Tennessee 37208. 5. 17 BROAD is the owner and lessor of an apartment complex located 1701 Broad ‘Street, Chattanooga, Tennessee 37408. 6. BH Management manages the apartment complex located 1701 Broad Street, Chattanooga, Tennessee 37408. 7. Plaintiffs leased Apartment #417 located at the apartment complex owned by 17 BROAD, and due to significant mold problems that developed within the leased space during the lease term, incurred damages as a result of said significant mold problems. 8. As the causes of action arise out of the lease agreement between Plaintiffs and 17 BROAD formed at 1701 Broad Street, Chattanooga, Tennessee 37408, in Hamilton County, this Court has jurisdiction and venue is proper in Hamilton County, Tennessee pursuant to T.C.A. § 20- 4101. 9, Pursuant to an Apartment Lease Contract (“Lease”), attached hereto as Exhibit A, and incorporated by reference, Plaintiffs leased Apartment 418 located at 1701 Broad Street, ‘Chattanooga, Tennessee 37408 (the “Apartment”) from 17 BROAD. 10. The Lease term was from July 1, 2021, to September 30, 2022; and upon agreement by both parties was being extended to December 31, 2022. Finalization of the Lease extension was pending signatures when the mold was discovered. 11. At the time, Plai iff, Jason Pierce, was a student at the University of Tennessee- Chattanooga, where he was entering his final semester set to graduate in December 2022. He also was a student-athlete member of the football team. 12. During the Lease term, specifically on August 16, 2022, Jason Pierce discovered extensive significant mold growth throughout the Apartment. 13. Upon discovery of the significant mold, Jason Pierce notified his parents immediately. 14, Carla Pierce and her husband, Jeffery Pierce, had Jason Pierce place a “Damp Rid” ‘moisture bag in the middle of the Apartment to check moisture build up. Jeffery Pierce is a senior environmental engineer, who is a registered Professional Engineer in 21 states including Tennessee, with over 38 years of experience in the environmental field. Carla Pierce is a former regional program manager in the Region 4 Air and Radiation Division for the United States Environmental Protection Agency (USEPA). 15. The “Damp Rid” moisture bag was monitored (with video) each day during remediation/cleaning. 16. On August 17, 2022, Carla Pierce arrived from Powder Springs, GA to the Apartment to assess the situation and verified extensive significant mold throughout the ‘Apartment. 17, A letter dated August 17, 2022, addressed to 17 Broad Management, a copy of which is attached hereto as Exhibit B and incorporated by reference, was hand delivered to BH Management regarding the situation and Plaintiffs’ intent to vacate due to illness and damages. 18, For several weeks prior and leading up to August 17, 2022, Jason Pierce experienced progressively worse negative impacts on his health within 15-30 minutes of entering the Apartment. At no point prior to August 16, 2022, did Jason Pierce know or have reason to know that the Apartment was experiencing a mold outbreak. It was only after discovering the mold outbreak on August 16, 2022, and discussing it with his parents, that Jason Pierce considered that his health issues he had been experiencing were caused by a condition within the Apartment. 19. Jason Pierce experienced sickness, which physical and emotional discomfort is compensatory in itself, and also required the purchase of medical supplies to treat his illness. 20. From August 18, 2022, to August 22, 2022, Carla Pierce conducted mold remediation efforts at the Apartment that not only benefited the Apartment by avoiding further damage to the Apartment itself, the remediation efforts of Carla Pierce also salvaged personal property of Jason Pierce and Carla Pierce, which mitigated their damages. 21. On August 23, 2022, BH Management attached a letter, a copy of which is attached hereto as Exhibit C and incorporated by reference, on the Apartment to inform Plaintiffs that BH Management would enter the Apartment that date to inspect the Apartment for mold. 22. Plaintiffs vacated the Apartment and tumed in their keys to BH Management on August 23, 2022. 23. BH Management informed Carla Pierce she would receive a copy of the report rendered as a result of its inspection that took place on August 23, 2022. 24, To date, neither 17 BROAD nor BH Management has produced a copy of said report to Plaintiffs. 25. Plaintiffs have requested a copy of the report from BH Management on multiple occasions in writing, as well as through attempted telephone calls. 26. Plaintiff's need a copy of the report to provide to their renter’s carrier. 27. On September 15, 2022, Carla Pierce FedEx mailed and emailed a letter with supporting documents, a copy of which is attached hereto as Exhibit D and incorporated by reference, to BH Management. 28. The September 2022 rental payment for the Apartment was never paid by Plaintiffs, nor were any payments for the months of October, November, or December 2022, pursuant to the oral agreement to extend the Lease to December 31, 2022. 29. On September 30, 2022, BH Management’s billing department emailed to Carla Pierce a receipt, a copy of which is attached hereto as Exhibit E and incorporated by reference, indicating that no further balance was due. 30. Plaintiffs were allowed to vacate the Apartment in August and not be charged rent for the month of September, despite the original Lease term running through September 30, 2022, and the pending extended term through December 31, 2022. 31. 17 BROAD and/or BH Management allowed Plaintiffs to prematurely terminate the Lease because Defendants knew they had breached the Lease by failing to provide a safe living condition, 32, Item #32 of the Lease, on page 5, states as follows: RESPONSIBILITIES OF OWNER. We will act with customary diligence to comply with requirements of applicable building and housing codes materially affecting health and safety. Notice of any non-compliance by us must be properly given to us in writing. 33. The significant mold event at the Apartment caused the Apartment to be unfit for habitation. 34. The apartment complex where the Apartment is located is a multi-unit complex with hundreds of apartment units. 35. The significant mold conditions Plaintiffs experienced in the Apartment appear to be stemming from the HVAC system servicing multiple apartment units, which is, upon information and belief, the cause of the significant mold issues in the Apartment. 36. The HVAC system, including air conditioning ducts, are considered common areas under the control and authority of Defendants to maintain. 37. Upon information and belief, Defendants’ other apartment units experienced significant mold conditions, also stemming from the common HVAC system. 38, Upon information and belief, Defendants knew or should have known of the unsanitary significant mold outbreak that plagued multiple apartment units, including the Apartment at issue in this ease. 39. The Lease, specifically the third paragraph of item #8 titled “Insurance,” urged Plaintiffs to obtain renters insurance for losses to Plaintiffs’ personal property. 40. Plaintiffs did obtain personal property insurance through Liberty Mutual. 41. As arresult of the damages incurred by Plaintiffs from the significant mold issue, Plaintiffs filed a claim with their personal property insurance carrier, Liberty Mutual. 42, Liberty Mutual required additional information to process Plaintiffs’ claim, such as the cause of the significant mold event. 43. Starting in September 2022, Plaintiffs requested from BH Management the cause of the mold event. 44, Plaintiffs have requested from BH Management the cause of the mold event on multiple occasions via attempted telephone calls and in writing. 45. _ BH Management has not, to date, provided Plaintiffs the result of their inspection, which detail the cause of the mold event. 46. Plaintifis’ claim filed with Liberty Mutual has not been paid due to Defendants’ failure to provide the requested information, COUNT I: BREACH OF CONTRACT 47. Plaintiffs incorporate Paragraphs 1 — 46 herein by reference. 48, Defendant 17 BROAD’s responsibilities under the Lease required it to act with customary diligence to comply with requirements of applicable building and housing codes materially affecting health and safety. 49. The amount of significant mold in Plaintiffs’ Apartment rendered the Apartment materially affected the health and safety of Plaintiffs and their patrons, causing the Apartment to be unsafe and unsanitary. 50. Defendants failed to exercise customary diligence in inspecting and maintaining the apartment complex’s common areas to avoid the significant mold outbreak. 51, Defendants failed to exercise customary diligence in responding to information that significant mold was present in the common areas to avoid the significant mold outbreak. 52. Asa direct and proximate result of Defendants’ breach of contract, Plaintiffs have suffered special damages in the amount of $9,615.91, in addition to personal injuries in the form of emotional distress and inconvenience, as well as mileage, plus interest that has accrued since September 15, 2022, and continues to accrue. COUNT I: PREMISES LIABILITY, NEGLIGENCE 53. Plaintiffs incorporate Paragraphs 1 — 46 herein by reference. 54, Defendant was aware of the significant mold in the common areas that infiltrated the Apartment. 58. Defendant owed a duty of care to Plaintiffs to remove or warm against the significant mold in the common areas that infiltrated the Apartment. 56. Defendant failed to remove or wam against the significant mold in the common areas that infiltrated the Apartment. 57. Asa direct and proximate result of Defendants’ failure to wam or remove the significant mold in the common areas that infiltrated the Apartment, Plaintiff has suffered damages in the amount of $9,615.91, in addition to personal injuries in the form of emotional distress and inconvenience, as well as mileage, plus interest that has accrued since September 15, 2022, and continues to accrue. COUNT Ii: VIOLATION OF UNIFORM RESIDENTIAL LANDLORD AND TENANT ACT, § 66-28-50, et sea, 58. Plaintiffs incorporate Paragraphs 1 — 46 herein by reference. 59. Defendant held a duty to provide essential services to Plaintiffs. T.C.A. § 66-28- 502(a)(1). 60. Essential services includes any obligation imposed upon the landlord which materially affect the health and safety of the tenant. T.C.A. § 66-28-502(a)(3).. 61. Defendant held an obligation to ensure the common areas under its control did not contain significant mold that would infiltrate the Apartment leased by Plaintifi. 62. Defendant breached its obligation to Plaintiffs to avoid having the air conditioning ducts be a conduit for significant mold into Plaintiffs’ Apartment. 63. Defendant is liable to Plaintiffs for the amounts Plaintiffs incurred to sect substitute housing and their reasonably incurred attomey’s fees. T.C.A. § 66-28-502(a)(2). COUNT IV: PUNITIVE DAMAG! 64. Plaintiffs incorporate Paragraphs 1 — 46 herein by reference. 65. Defendant allowed for Plaintifié to be subjected to dangerous and unsanitary living conditions due to its concealment or negligent failure to discover the significant mold issue in the common areas of its apartment complex. 66. Defendant's actions were intentional, fraudulent, malicious, and/or reckless, 67. Furthermore, Defendant insisted that Plaintiff's acquire insurance to compensate Plaintiffs for any losses to personal property at the Apartment. 68. Plaintiffs acquired such required insurance. 69. However, when Plaintiffs needed information that was unavailable to them and required to be provided by Defendant, Defendant intentionally, fraudulently, maliciously, and/or recklessly withheld the information, which kept Plaintiffs from being paid by their insurance company on the claim. 70. Asa result, Defendant is liable for punitive damages in this action. WHEREFORE, Plaintiffs pray: A. That process issue and be served upon Defendant, requiring it to Answer within the time required by law; B. That Plaintiffs be awarded judgment in the amount of $9,615.91, in addition to compensation for personal injuries in the form of emotional distress and inconvenience, as well as mileage, for Defendant’s breach of contract, negligence, and violation of the Uniform Residential Landlord and Tenant Act; C. That Plaintiff be awarded attorneys’ fees pursuant to T.C.A. § 66-28-502(a)(2); D. That Plaintiff be awarded punitive damages for Defendant’s actions that were intentional, fraudulent, malicious, and/or reckless; E. That Plaintififbe awarded pre and post-judgment interest; F, That ajury be empaneled to try all issues so triable in this cause; and G, That the Court award Plaintififs such other and further relief as it deems just and proper. RESPECTFULLY SUBMITTED: McKOON, WILLIAMS, ATCHLEY & STULCE, PLLC JAMES R. McKOON, BPR #009554 ANDREA D. HAYDUK, BPR #026777 KYLE S. MeGUIRE, BPR #040023 Attorneys for Plaintiffs 633 Chestnut Street, Suite 1500 Chattanooga, TN 37450 (423) 756-6400/Fax: (423) 756-8600 Email: jmekoon@mwalawfirm.com Email: ahayduk(@mwalawfirm.com Email: kmeguire@mwalawfirm.com 10 ‘Doan Emo BRANDS. 74E-""4BBAT-BRATEFEEAIO® APARTMENT LEASE CONTRACT sone 18, 2021 [when the Lest Contract led ot) Dat of eat Contact: Thiste binding document. Read carefully before stoning. as 1 PARTIES. Ths Lease Contract Gometines referred to as the "ener between yo, the resident) (lt al pope ining te Lose Contac) carla Pier Jason Pieres ‘Moving In— General Information 5. KEYS. You willbe provided _3__key(9}__1_ mailbox ey, FOR) andlor others dee or fcnsetothebuldingandamenclesatnoadsitonl creat rave: Inctfceey FOB or ther aces device become damaged oles Suringyortnenyorisotreirnesorisetrned damaged heh suumevecut youll resposielorthecostsfortbereaceest {najor real ofthe same {6 RENTAND CHARGES. Unless aodiid by and you wll psy $1248, 00 permonhforrentpayabeinadvanceandwitoit toms atic onste managers oc or W stourontinepaymentsieor Oe. snd the owner: 17 Broad (ame of conan o elder) Youve agreed torent Dwelling #57 AE Broad Steet Paver adaread a CiatEao: (apy Tenner, ip code forure a3 private Feslence only. Terma ye ad Your fe to al residents latedabove The terms"we"ua"sndoorreferttheownerbited sbi ran oowner soars inner Ween “nyone cls har guranteed performanee otis Lease Contac» epaate eat Contract sranty foreach guarantors attaches ‘OCCUPANTS. The dwelinguniewilbe occupied only by yu and (liseeloter ceoprte na signing the Leave Contac) ‘owe mast ot sty the dling fr more tan 7 thanewlee that many day inary one oth the previons pace Bee devel daly 2021 andendeseit 9 ibm. the 0th dayot_—_Septesbex —""" “daz foumonth nes ithe party gives st lest-—60 ~ daye written ‘tis oftrmnaion oneal owes Touied by paragraph 45 (Move Out Noi). Iehe numberof days aed Teast 4, SHCURITYDEPOSIT. Unless modedbyaddendahettaeceurty ‘epost that of earn oft Lae Contractor alse inthe dwelingunitie$ 0:00. due anor bear he date thisLeaseConvactissigied Resentosecary Jepostis deposed tesients secur deposi (© 202 naona Apartment Aocaton ne /2028, Tennesse ‘You specifically waive the right to receive notice of termination of tenancy for non~ paymentof rent. Therefore, a detainer warrant may be filed immediately upon breach of the agreement for failure to pay rent. Prertedentof$_1249.00 _isdueforthe remainder o (eck tne Ch Sstmontvor Candin on Daly 2 ‘Otherwise, you mustpay you rent on before he 1st ay ofeach ‘month ve dt) cash le nacceprable without our pie writen Permission You must at withld or let eat unless athe barat Wemay, tour option require ty te You sy sllrentandetber sums in cab cried ocasher check, moe ‘Isereion, we may conver anya all checks athe Avtamated ‘eringoase(ACH sytem for cheparposerofale=t eseonderedaceged Ute AH ‘Mtr th itt) ay othe ent which sad istalment de ‘allindude ante charge gual tothe ten (103) percent ofthe ren “hia charge shal ecome a portion ofthe rent dv under te term an conten of thir lar Resident ogres to py ast Fenty money oder ocetiied nds We wl nocinposs hate ‘harge te it) yall Sunday ology and eovispaid on the ex busines day. Inadion ou wl lo pay a ‘hargeof$ 30.00 pat toonned $3.00} foreach returned heck or rejected electronic payment youd pay rest on tne, ‘yout dingent ndallremeces under the LeneeContract wl Teattheraed Wella havea other remedies for such aatn Aipasmen obiations under hie Lease Coeract shal const Fettunder is Lente Contre 7. UTILITIES. Well pay forthe flowing ems iehecked Cveter " Chigae Ch secssety C) matterantena CG vastewater trash Gl ealerv etree ‘You'lpy forall oter iis ose rated epost andy coher cargesor maintenance fer lated thors otherseeror {ervicesYoumartnatlow sities tobediscntertedIncing isconnaction or ot paying your bill-—uet the lease erm oF renewal period ends. Coble chanel that are provided maybe ‘hong ringthe lease emt change apes lednt ‘Usiiesmay be ued only oracrmal household purposes and mst, rot be waste four electri Is evr eterrpted, you mis ae nly battery-operated lighting. tf any ules or services ae ‘etre the dvelinguaierprovd yan alcate formal few tach an adenG Co hs Lease Contacn comple wi state agency rls or ty ordinance, ‘8. INSURANCE. We donotmlnainlnsurancetocover your persona Droperty or peronalinury, Weare norerponibleoany sie {ester ecapat or damage rosso persna propery er prsoal fajry om (incdng bat a ied) re sok, en ed, ‘ter an pp en a, nor liptring wind explosion, ‘erthguakeierropion often het hurricane tegen ‘threes dents orcpant or nited/uineted ust arvandlams Snes otherwise required bylaw. Inadaion weurgeal residents, partly those residing it ‘eastlarnsaenrnearines sbdatexpronetoloodig, 2 bee Food insurance Rentesinsurance my hot cover damage Your broparty de totlooingAleodineurnceerource which maybe ‘rae indudes the Netto Pood lasrance Program maniged Upehe Fedral Emergency Managemen Agency (FEMA property orinjies duct et fle water damage ipeleahs and ‘Aina youare check one requied to purchase person Tinney insurance C) wot equfed to purchase person labity Insurance ifm bors check, personal isle insurance sot egulred equi, alureto attain personal ay nsorance ‘hrouhout your tenancy, ineliing ay renewal periods apd/or lease extensions, ran incurable breach of his Lease Contra and ‘tay reat inthe termination of tenancy ani eviction andor any ther remedies a provided by this Lease Corea or stat Youackaowledge that no portion ofthe ret pidby you unde his hat you aren away a counsured under any sich pole and that inorderta reduce hecorofinrarnes, che Owner ar ocek toparehselireandestended coverage iesurance orthepoperty Forwhichthe above rental preement apie with deduct e theamounters yeu or any member of our household, gest or nit. as damages tothe premize in am Soon tht i or than the aunt of his isurance deduce, Sou agree to indemty and reimburse the Owner far he scant {feach damage, and that ou maybe ae for costs xcs af ‘hededuce wader any subrogation clause ofthe said pli. is ‘Semen yn cnc arn ote er eet 19, LOCKS AND LATCHES. Keyed ack() wil be rekeed ate he Dor resident mover ot, The rekeying wil be dane eter before Jouve nor within? daysater You move ‘Youmay tan tine esta change or ekey acres ring ‘eee Term, We must comply hore requests, bayou must a or them uses otberwise provided av Paymentfor Rekeying, Repatrs,Bt, Youmspayforallepirs rreplacemersaiaing from misuse o damage to Jevies DF YOU Sr your eceupant, or guste ding your expan. You may be ‘equiedts payin advance enotty yeu wibinarensonbletine ter yourrguer tha you are more than 30 day delinquent imborsingferepating on eplasngadevie whch wars ‘rented you your grstoranocxpaterfyouhave requested ‘hatwereairorcange orale thesame devi aringthe 304075 recoding your requetand we have complied with your requ. Dtherwise you mur pay immediately fer the work seompeted, ‘Special Provisions and "What If Clauses 0SPECIALPROVISIONS. Thefolowingepeiaprovsionrandany ddencn orveritn le urnahedto oust before sighing wll become apart ofthis Leuse Contract and wil supersede any Sev any oddiinal paca provisions LEARLYMOVE-OUT, Youllbelabetousforareletingshareeat * (pottocnceed 100% the highest monthly ent ing ease arm) you: o {ato io writen move-out notice as reglred in paraeraph 45 (ove Out Noi) or anyother apliale e oF rrenewel pried ar (3) move oat our deinand Because of your defelto {4} srefudialy evicted ‘The relating charge set cancion fo and does nat release @ Nota Release. The reetting charges not lease cancelation ee rbayeuticeteanapreedtsligeemedamauntcoering nl a ‘our damages that cute flr andexpente in finding od processing replacement These damageareuncetin and ie {Dascertate—prtcaan hoe eating te incanenince paperwork ‘iverting. showing dwelling anit lt or showing, her ing amoges apd at the charge due whether of nat oU eletng ‘temptesveced fnaamcantestipuatesyourmar'py ours felting carte sofaasthey can bedetermied The leting charge oes not tlease yourton continaed abit fr: ature or pashdae ent charges for deanng cepa eae, uretaraed ys brother sums de AZREINBURSEMENT. You must promytly reimburse ws for loss damage, government Ines ar cot of repute of service tthe mminiy dota vaaton ofthe Lease Contractor les mproper te, onegligenceby Yu or your ers or aecopants Unless the damage or wastewater stoppages dueto our negligence wee fc for~and you mast py for—repalts replacement fost and darmage tothe fllowing that result from youror your Invites guosts or ocrupanty’ negligence or itentonal sts (G} damage to doors windows, or sereens (2) damage (rom ‘windows or door elt open an (3) damage rom wastewater ‘Soppagescansadby inproper elect tines exctacray serving Yyourdwllingunt Wemnyreqirpeymentatany ine incding {ivancpaymentofroparforwhichyne eile. Deayin demanding ‘Contractallien. When perfecedby the ing aorm VCE, 905 ‘erey ie we alen upon all your propery stunted upon the sad (02078 nates Apres Assan ne -6/2028, Teese ent predtobe pid hereundes forany damage cased by you, and {Greourcorteandtorey fer incarredunderthetermaberet Property Left in Dwelling Unit. After sbandonenent det Paragraph SO (Deposit Retr Surender, and Abandonmond) we ‘alone ourposrestonsand personal elect the premises nd stare uth personal possessions and persona effect fr not Iegethan tity days Yourayretaimsuchposesions personal ‘Secs romuswithn sich bir-duy period fyou donate ‘chposuersoneand personal ects withnauey nr dy pein, (wemaysalorathree dispose of your possesansand persona ‘ects and apply the proceed ofthe sale tothe unpad Pents, ‘nage storage ees sl csteandattornaysees Any balancer retobe held byuetora period fast monte ster the sake {SAPALINGTOPAYFIRST MONTHSRENT, yoadortpay thelist ‘months rem whenerbeforethe ese Conta beige ny od Surg oteceancy and recover damages tare ret eleting harge, storeey fey, courecost and therlawfuearges Out fights andvemedies uncer paragraphs 1 (Eri ove-Out) ands (Gets by Resident apply to aceeration under ts paragraph, Increases of Lease Contract changes are allowed befor he inti sae Coiratterm ends excepto changes allowed by ay speci provslns in paragraph 10 (Spec Provisions) bya written Esdendumoratondinent signed by you ano by reasonable ‘hangs of dwelling ne ole allowed under paragraph 19 (Commanty Poses Rules atleast ay beorethe sovance Sr dealine freed ei paragraph 3 (Laas Term) we give [ouweitten nticesfrntincreasee ries changes fective when the lester or ronewal prio end, his Lasse Content wil tomaticliycantinue moatrtosmonh wth helnereased eof ica change The new modified Leste Contract wil begin onthe Ssesatedinehe notice witht necessity o you seta) ales Jeuswurwteminoe stan snerprgas area AGDELAY OF OCCUPANCY. 1f occupancy iso wll be deed for onstruction reais cleaning, oa previous resident heding ter were nt response forthe dey. The Leave Contac Wi emainin force subject: (2) abatement of rent ona dally Sass Goring dle; ad (2) your right terminate a set rth blow. ‘ermination oie mat be In wring After erminatio, you sre tnetiedontoefundot depot) day rencpal. entbatement trleae termination docent api isforieaningorrepaes thar don prevent you rom etupyag te dling un Irehereies delay and we haven given tice of ely a forth Inmadiatly blow, you may terminate up tote date whes the ‘aling unis eady for occupancy but ota (3) Mowe gie writ poicetoany ofyou when orater heii termarcetforthin Paragraphs (Lease Term) —andtbe matic ‘Sus thacoccupany as been deed beau construction traprevoce residents oldiog oer and tht he dengue wilbe en ona specie date—you may terminate the nase Goma tin’ dg your nig nib nt Docs Erle 0: 2489570 TOKE, icmAnnTaronANae 2 te gue ween sate af yout te ntl tem | ‘seth infargaph3 Lave Term andthe oe tates thetconsrction dey resected and tate linge ‘ibe edy fr yout ccmpy a specie dat You may Terminate rhe ese Cora win aye ater Sy a 904 {eles writen noe bot ter herent ae ‘Seudre he nw nial em ae foro Paragraph 3 {Use Term for lpurpeee sno nestor ed {SSntarer date were we oa young {7.AD VALOREM TAXES/FEES AND CHARGES- ADDITIONALRENT, Unless otherwise probbte hy lav ering tae fran ote _Agretan any ait iy tate o federal Government inposes pon Ur any fe charb, or tam which flted oor charged by ‘henumber of occupants orby be Premizes tae such hate are ‘hargeda fe, charge or tax based pon our use or eceupeny of the Premises. we may a scharg as Addionl Ret daring ‘hcermaftheLeae Contract wih hry (30) dayaaivanceveriten tice oyou Aterthiswrittn notice he amount or approxima Snountotbectargewlbetncluded), ousgrestopayarsaitoes ent the amount of he charge, tx or fee impose apo ws © sult of your seca. As examples these hares ea ne, Batre netimtedtoranychargeswerecieforanyaoningvilaten, fhroniemusanco type statue, 911 or eer le suey pe person, ISthen assessed tous for payment AB.DISCLOSURE RIGHTS. fsomeone requests formation 08 ou siness purposes, we may provide ‘While You're Living in the Dwelling Unit ‘ecupants mast comply with any writen welling nt rule ‘urrulesare considered part ofthis Lease Contract Wermay ake Feasonable ote thoyaredistbutedadappicaletoallunte Inthe cmmunity and donot charg dlar mounts on page 1 af Teerved for our privat use must be kept dean ane of ath, nrbage andoter debris Tash ste disposed ofatleatwecly "dss ay bd ony or ety oo Yu area hep {rath storage ems, anda forms of persoal property. Ne person hal ride oll bikes skateboarder ather sma object in ‘he pasagerays. Any swimming pools saunas spas.tanning beds trercgerooms orerooms any roms andor reas st ‘wosed tthcarein accordance with dwelingunitruler and posted {signe Css containers are prohibited inal common are. Yo, your ocupans or gustamay nocanftbere the comity se {Candles or ure kersen amps or kerosene heaters without Prlor writen approval cook on balcenies or outside; sali ‘banessorontriutions Canductngany nd bint ncaa ‘hl ate services) your dwelling to nthe oman prchibites~excepthat ny nw user condor at home” bycompoter mal or lephonets permisslesfcutomers ents patent or ther burner usoctesdonotcemeto our dueling “nitor business purpose, le may regulate (1) the do a pais Saloni ana porches (2) the conde offerte movers ed

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