36. When (son) visited and on occasion stayed with his mother and siblings, (son) experienced
difficulty with his breathing. While living with his grandmother, (son) had fewer problems
with his asthma.

37. On September 3, 2017, Respondent Kalisha Winston, the Senior Property Manager for
Respondent Columbia Residential, issued a written denial of Complainant's July 2017
request to transfer. In the notice, Respondent Winston stated, "I apologize for the
inconvenience, but per my supervisor Mrs. Hunter your request to transfer to another unit
has been declined." The written denial also told Complainant that Respondent Winston
could "rewalk" the unit to schedule "repadding" for and the cleaning of the carpet.

38. Even after Respondents' maintenance staff removed part of the padding in Complainant's
unit, (son) continued to experience an increased occurrence of breathing problems
associated with his asthma when visiting Complainant's apartment. Respondents did not
replace the removed padding or the unit's carpet.

39. On or about October 19, 2017, Complainant [redacted] attorney made another written
request for a transfer "to a unit within the complex where there is no water damage or
elevated levels of moisture within the unit." This request was sent to Noel Khalil, the
registered agent for Respondent Columbia at Mechanicsville and Respondent Columbia
Residential at their principal office address, via certified mail, return receipt requested. The
United States Postal Service's delivery receipt confirms that the request was received on
October 23, 2017.

40 .Complainant [redacted] second request for a transfer included medical documentation
from her son's medical team including his pediatrician, Dr. il and from his
specialist, Dr. [redacted] The pediatrician indicated that he had been unable to control
(son's) and had sent him to a specialist.

41. The medical documentation provided to Respondents by Dr. [redacted] on or about October
12, 2017 indicated that: (a) Complainant [redacted] son had severe persistent asthma;
(b) exposure to mold, mildew, dust and humidity are triggers for asthma exacerbation; (c)
asthma symptoms can be life threatening; and (d) Complainant's son cannot live in a unit
that has mold, mildew, dust or humidity.

42. The medical documentation provided to Respondents by Dr. [redacted] on or about October
13,2017 indicated that: (a) (son) was being treated for asthma, (b) his symptoms could be
exacerbated by mold in the home, and (c) if his asthma had been exacerbated by the
conditions in the home, repair or relocation was required.

43. The second request to transfer identified five instances of flooding of Unit (): (a) the
first instance was in September 2014 resulting from a water heater and the second instance
was when additional water damage occurred in October 2014 from an upstairs unit's tub
that overflowed into Complainant's unit, (b) the third and fourth instances were in August
2015 and January 2016, when her sink overflowed due to a sewage backup, and (c) the

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