fifth instance was in July 2017 because of a fire on an upstairs floor which resulted in the
sprinkler system flooding the unit.

44. During HUD's investigation, Respondents did not address the first four instances of
flooding but admitted that there was water damage in 2017 although they found it to be of
little to no consequence. Flooding issues were not specifically noted in Complainant
[redacted] tenant file. Despite the repairs made by Respondents' maintenance in
response to the damage, the affected carpet was left in place.

45. On or about October 31, 2017, Respondent Winston issued another written notice to
Complainant [redacted] advising her that Respondent Columbia Residential's Corporate
office decided that it would be feasible for Complainant's carpet to be replaced at
Complainant's expense. The notice included three quotes for repairs, replacement and costs
equivalent to replacement of all the carpet. The notice also included an option for
Complainant to reschedule carpet replacement. Complainant [redacted] did not respond.

46. On or about June 12, 2018 Complainant [redacted] filed a fair housing complaint ("HUD
Complaint") because her requests to transfer had been denied, forcing her to have her minor
son live with her mother.

47. Prior to June 12, 2018, Respondents denied Complainant's July 2017 request for a transfer
based on their review of her unit and determination that there was minimal impact from
the water leak in July 2017, the unit was in good repair and Complainant [redacted]
housekeeping was deficient.

48. After the filing of the HUD Complaint, Respondents denied Complainant's July 2017
request for a transfer because she failed to provide medical documentation to establish that
the transfer was necessary.

49. Respondents took no action on Complainant [redacted] October 2017 request for a
transfer because Respondents considered it to be a duplication of her first request which
Respondents had already handled.

50. There have been two additional instances of water damage to Unit |Jjiilf in October and
November of 2019 which Complainant [redacted] reported to Respondents. In October of
2019 Complainant [redacted] found standing water in her bathroom. In November of 2019
there was a bathtub leak in the unit that was also reported to Respondents.

51. As of June 2020, (son) has lived apart from his mother and siblings for over 33 months.
As aresult of Respondents' discriminatory conduct, Complainant [redacted], Complainant's two
other minor children, her adult son and her mother suffered actual damages, including but
not limited to out of pocket costs, emotional distress, inconvenience and loss of a housing
opportunity.

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