City of Dallas Original Petition Seeking Reciever For Topletz Properties

FILED
DALLAS COUNTY
11/18/2015 9:08:17 AM
FELICIA PITRE
DISTRICT CLERK
Lantz Sandra
Cause No. DC-15-13993

_
V.
DENNIS TOPLETZ, INDIVIDUALLY,
AS HEIR OF HAROLD TOPLETZ AND

DBA TOPLETZ INVESTMENTS,
CASEY TOPLEZ, VICKIE TOPLETZ,
STEVEN TOPLETZ, MARVIN L. LEVIN,

BOTH INDIVIDUALLY AND IN HIS
CAPACITY AS THE EXECUTOR OF
THE ESTATE OF JACK TOPLETZ,
MONARCH DEVELOPMENT
CORPORATION, 2501
BETHURUM AVE., DALLAS, TEXAS,
in rem, 3737 GUARANTY ST.,
DALLAS, TEXAS, in rem, 1231 IOWA
AVE., DALLAS, TEXAS, in rem, 2603
MODREE AVE., DALLAS, TEXAS,
in rem, 3803 OCTAVIA ST., DALLAS,
TEXAS, in rem, 1304 PENNSYLVANIA

AVE., DALLAS, TEXAS, in rem, 2705
PENNSYLVANIA AVE., DALLAS,
TEXAS, in rem, 1203 STRICKLAND ST.,

DALLAS, TEXAS, in rem,
~~~~.
CITY OF DALLAS,
Plaintiff,
IN THE DISTRICT COURT
DALLAS COUNTY, TEXAS
193RD-L
JUDICIAL DISTRICT
CITY OF DALLAS' ORIGINAL PETITION, APPLICATION FOR

TEMPORARY AND PERMANENT INJUNCTION, AND
APPLICATION FOR APPOINTMENT OF RECEIVER
TO THE HONORABLE JUDGE OF SAID COURT:

The City of Dallas, Plaintiff, files this Original Petition, Application for Temporary
Injunction and Permanent Injunction, and Application for Appointment of Receiver, and in
support thereof would show unto the Court the following:
City of Dallas' Original Petition, Application for Temporary Injunction and

Permanent Injunction and Application for Appointment of Receiver
City of Dallas v. Dennis Topletz, et ai,
Page 1.
I. DISCOVERY CONTROL PLAN

1.
Discovery is intended to be conducted under Level 2 of Rule 190 of the Texas
Rules of Civil Procedure.

II. PARTIES
2.
Plaintiff, the City of Dallas ("City"), is a home rule municipal corporation situated
primarily in Dallas County, Texas, incorporated and operating under the laws of the State of
Texas.
3.
Defendant Dennis Topletz is an individual Texas resident owning real property
that is the subject of this lawsuit. Service of process may be made upon him at 7509 Inwood
Road, Ste 300, Dallas, Texas 75209 or wherever he may be found.
4.
Defendant Casey Topletz is an individual owning real property that is the subject
of this lawsuit. Service of process may be made upon him at 7509 Inwood Road, Ste 300,
Dallas, Texas 75209 or wherever he may be found.
5.
Defendant Vicki Topletz is an heir of Harold Topletz and therefore an individual
owning real property that is the subject of this lawsuit. Service of process may be made upon her
at 7519 Malabar Ln., Dallas, Texas 75230 or wherever she may be found.
6.
Defendant Steven Topletz is an heir of Harold Topletz and therefore an individual
owning real property that is the subject of this lawsuit. Service of process may be made upon
him at 6514 Tulip Ln., Dallas, Texas 75230 or wherever he may be found.
7.
Defendant Marvin L. Levin is an individual owning real property that is the
subject of this lawsuit in his individual capacity, as well as in his capacity as the executor of the
Estate of Joseph M. "Jack" Topletz. Service of process may be made upon him at 7509 Inwood

Page 2.
8.
Defendant Monarch Development Corporation is an inactive Texas Corporation
owning real property that is the subject of this lawsuit. Service of process may be made upon
Monarch Development Corporation, through its registered agent, Dennis Topletz at 7509 Inwood
9.
The real property located at Lots 33 and 34, Block 6/2548, also known as 2501
Bethurum Ave., Dallas, Texas (referred to hereafter as the "2501 Bethurum"), in rem, is real
property that is the subject of this lawsuit and may be served with citation through the owners,
Harold and Jack Topletz through the executor of the Estate of Jack Topletz, Marvin L. Levin at
7509 Inwood Road, Ste 300, Dallas, Texas 75209 or wherever he may be found, and Dennis,
Vicki, and Steven Topletz, in their capacity as heirs of Harold Topletz, at 7509 Inwood Road,
Dallas, Texas 75209 or wherever they may be found.
10.
The real property located at Southeast part of Lot 18, Block 1718, also known as
3737 Guaranty St., Dallas, Texas (referred to hereafter as the "3737 Guaranty"), in rem, is real
property that is the subject of this lawsuit and may be served with citation through the owner,
Marvin L. Levin at 7509 Inwood Road, Ste 300, Dallas, Texas 75209 or wherever he may be
found.
11.
The real property located at Lot 21, Block 40/3712, also known as 1231 Iowa
Ave., Dallas, Texas (referred to hereafter as the" 1231 Iowa"), in rem, is real property that is the
subject of this lawsuit and may be served with citation through the owner, Harold and Jack
Topletz through the executor of the Estate of Jack Topletz, Marvin L. Levin at 7509 Inwood
Road, Ste 300, Dallas, Texas 75209 or wherever he may be found, and Dennis, Vicki, and Steven
Topletz, in their capacity as heirs of Harold Topletz, at 7509 Inwood Road, Dallas, Texas 75209
or wherever they may be found.

City of Dallas v. Dennis Topietz, et ai,
Page 3.
12.
The real property located at Lot 18, Block 3/5155, also known as 2603 Modree
Ave., Dallas, Texas (referred to hereafter as the "2603 Modree"), in rem, is real property that is
the subject of this lawsuit and may be served with citation through the owner, Monarch
Development Corporation, through its registered agent, Dennis Topletz at 7509 Inwood Road,
Ste 300, Dallas, Texas 75209 or wherever he may be found.
13.
The real property located at Lot 20, Block F/1732, also known as 3803 Octavia
St., Dallas, Texas (referred to hereafter as the "3803 Octavia"), in rem, is real property that is the
subject of this lawsuit and may be served with citation through the owner, Casey Topletz, at 7509
Inwood Road, Ste 300, Dallas, Texas 75209 or wherever he may be found.
14.
The real property located at part of Lot 6, Block All162, also known as 1304
Pennsylvania Ave., Dallas, Texas (referred to hereafter as the "1304 Pennsylvania"), in rem is
real property that is the subject of this lawsuit and may be served with citation through the owner,
Harold and Jack Topletz through the executor of the Estate of Jack Topletz, Marvin L. Levin at
7509 Inwood Road, Ste 300, Dallas, Texas 75209 or wherever he may be found, and Dennis,
Vicki, and Steven Topletz, in their capacity as heirs of Harold Topletz, at 7509 Inwood Road,
Dallas, Texas 75209 or wherever they may be found.
15.
The real property located at Lots 21 and 22 less 250 square feet, Block 27/1310,
also known as 2705 Pennsylvania Ave., Dallas, Texas (referred to hereafter as the "2705
Pennsylvania"), in rem, is real property that is the subject of this lawsuit and may be served with
citation through the owner, Dennis Topletz at 7509 Inwood Road, Ste 301, Dallas, Texas 75209
or wherever he may be found.
16.
The real property located at Lot 4, Block D/3396, also known as 1203 Strickland
St., Dallas, Texas (referred to hereafter as the "1203 Strickland"), in rem, is real property that is
the subject of this lawsuit and may be served with citation through the owner, Monarch
City of Dallas v. Dennis Topietz. et ai,
Page 4.
Development Corporation, through its registered agent, Dennis Topletz at 7509 Inwood Road,
Ste 300, Dallas, Texas 75209 or wherever he may be found.
17.
The Defendants listed in paragraphs 3-8 above, Dennis Topletz, in his individual
capacity, as well as under the name of Topletz Investments, and, as an heir of Harold Topletz,
Steven Topletz, as an heir of Harold Topletz, Vicki Topletz, as an heir of Harold Topletz, Casey
Topletz, Marvin L. Levin, both individually and as independent executor of the Estate of Jack
Topletz, and Monarch Development Corporation, are hereinafter collectively referred to as
"Topletz."
18.
The real property defendants listed in paragraphs 9-16 are hereinafter collectively
referred to as the "Defendant Properties."

19.
The real properties listed in Exhibit 1 attached to this Petition are hereinafter
referred to collectively as the "Topletz Properties."

III. JURISDICTION AND VENUE
20.
The City brings this cause of action to obtain temporary and permanent injunctive
relief and recover civil penalties against Defendants pursuant to Subchapter B of Chapter 54 of
the Texas Local Government Code, as well as Chapter 125 of the Texas Civil Practice &
Remedies Code.
21.
This Court has jurisdiction pursuant to Section 65.021 of the Texas Civil Practice
and Remedies Code.

22.
Venue is proper pursuant to Section 54.013 of the Texas Local Government Code
and Section 125.002 of the Texas Civil Practice and Remedies Code.
23.
This cause of action is brought in personam and also in rem pursuant to Section
125.002(b) of the Texas Civil Practice and Remedies Code and Section 54.018(b)(2) of the
Texas Local Government Code.
Page 5.
IV. FACTS
Background of Topletz Ownership/Control of Residential Rental Properties.
24.
In the City of Dallas, the name "Topletz" is synonymous with dilapidated and
often crimeridden single-family rental property located primarily in South Dallas.

25.
Many of the one hundred ninety (190) residential rental properties that are the
subject of, or the management of which would be effected by, this suit (a complete list of which
is attached to this Petition as Exhibit 1 (the "Topletz Properties")) were once jointly owned and
controlled by the late brothers, Jack and Harold Topletz, in their names or in the names of other
close family members, fictitious DBAs, or now defunct corporate entities.
26.
Since at least the time of Jack and Harold Topletz's deaths in 2013 and 2014,
respectively, surviving family members including Dennis Topletz, Steven K Topletz, Vicki Lea
Topletz, Casey Topletz, Lane Topletz, Marvin Levin, and Judith Tycher (as a trustee of the Ivy
Rabinowitz Trust), similarly hold and/or control the Topletz Properties.
27.
Today virtually all of the Topletz Properties share certain characteristics: they are
single-family rental properties; they have extremely low appraisal value; and they are in poor to
structurally unsound condition.
The Topletz Business Model Violates Tenants' Rights Under State Law.
28.
In violation of a landlord's duties under Texas Property Code section 92.006(c),
the Topletz Defendants' standard lease purports to rent their dilapidated properties in an "as is"
condition, and charges tenants with the responsibility and cost for repairs to the property. See
Example of a Topletz lease, attached hereto as Exhibit 2. In addition, the Topletz Defendants
periodically send out letters reminding tenants not to complain about needed repairs, to tell City
of Dallas Code Inspectors that might knock on their door that, "There are no problems," and to

Page 6.
not allow City of Dallas Code inspectors into their homes without a warrant. See Topletz tenant
letter, attached as Exhibit 3.
Topletz Rental Properties Are Rife With Code Violations.
29.
The Topletz Defendants have allowed their properties to fall into such advanced
states of disrepair that the City of Dallas has had to obtain municipal court orders to demolish
and has demolished numerous structures owned by the Topletz Defendants.
30.
Notwithstanding a lack of complaints or cooperation from the Topletz
Defendants' tenants, over the course of the last thirteen months, the interiors of the Defendant
Properties were each inspected in the course of executing narcotics search warrants.
31.
The Defendant Properties were noted to contain numerous violations of the Dallas
City Code:
32.
Specifically, an itemized list of the code violations found at the Defendant
Properties, and copies of the cited ordinances, is attached hereto as Exhibit 4 and incorporated
by reference as if fully set forth herein.
33.
The ordinances contained in Exhibit 4 relate to:

a. The preservation of public safety, relating to the material or methods used to
construct a building or other structure or improvement, including the foundation,
structural elements, electrical wiring or apparatus, plumbing fixtures, entrances,
or exits;
b. the preservation of public health or to the fire safety of a building or other
structure or improvement;
c. dangerously damaged or deteriorated structures or improvements; and/or
d. conditions caused by accumulation of refuse, vegetation, or other matter that
creates breeding and living places for insects and rodents.

City of Dallas v. Dennis Topletz, et al,
Page 7.
34.
The conditions described in Exhibit 4 pose a substantial risk of injury or adverse
health impact to persons other than the Topletz Defendants and to property other than that of the
Topletz Defendants.
35.
On information and belief, the City alleges that the code violations set out in
Exhibit 4 currently exist at the Defendant Propelties, and that the same or similar code violations
exist on some or all of the Topletz Properties.

Topletz Properties are Magnets for Crime and a Nuisance to Neighborhoods.
36.
The Defendant Properties are only current examples of Topletz Properties that are
plagued by habitual drug sales, possession and use. Many Topletz Properties have been in and
out of the Dallas Police Department's SAFE program for criminal nuisance properties for years.
37.
From May 2014, to November 2015, the Dallas Police Department's Narcotics
Street Squads executed 229 narcotics search warrants at single family properties in the city of
Dallas based on undercover drug buys made at the properties. Nearly one out of every 10 of these
warrants was executed at a Topletz Property.
38.
The Topletz Defendants pay lip service to a "no drugs" policy in their lease, but in
reality, Topletz Defendants routinely allow drug dealers to thrive at Topletz Properties.
39.
The Topletz Defendants have ignored the criminal activity aJ the Defendant
Properties and the tell-tale signs of the activity such as the constant drug traffic and modifications
to the structures that serve to enable hand to hand transactions at the doorways while also being
resistant to police battering rams.
40.
A detailed list of criminal offenses that have occurred recently at the Defendant
Properties are detailed in the attached Exhibit 5, which is incorporated by reference as if fully set
forth herein.

Page 8.
41.
The Topletz Defendants maintain the Defendant Properties as places to which
persons habitually go for the delivery, possession, manufacture, or use of controlled substances in
violation of Chapter 481, Health and Safety Code. These criminal activities frequently occur at
the Defendant Properties and the Defendant Properties are frequently used in furtherance of the
criminal activities.
42.
The Topletz Defendants maintain a common nuisance at the Defendant Properties
as that term is defined in Section 125.0015 of the Texas Civil Practice and Remedies Code.
43.
The Topletz Defendants knowingly tolerate the habitual criminal activity referred
to in Exhibit 5, have failed to make reasonable attempts to abate the activity, and continue to
maintain the Defendant Properties as a common nuisance.
V. CAUSES OF ACTION, APPLICATION FOR APPOINTMENT OF A
RECEIVER, AND REQUEST FOR OTHER RELIEF
A. Temporary and Permanent Relief under Chapter 125 of the Texas Civil Practice
and Remedies Code
44.
The City re-alleges paragraphs 1- 43 as if fully set forth herein.
45.
The City requests a temporary injunction, and permanent injunction pursuant to
Section 125.002 of the Texas Civil Practice and Remedies Code immediately prohibiting the
Topletz Defendants from maintaining the Defendant Properties as a common nuisance,
specifically, as a places to which persons habitually go for delivery, possession, manufacture, or
use of a controlled substance in violation of Chapter 481, Health and Safety Code.
46.
If, after notice and hearing on a request by the City for a temporary injunction, the
Court determines that the City is likely to succeed on the merits in a suit brought under Section
125.002 of the Civil Practice and Remedies Code, the City requests that the Court order
reasonable requirements to prevent the use or maintenance of the Defendant Properties as a
common nuisance.

Page 9.
47.
The City further requests that if final judgment be in favor of the City, pursuant to
Sections 125.002(e) and (f) of the Texas Civil Practice and Remedies Code, the Court grant a
permanent injunction requiring the following: 1) ordering Defendants to abate the common
nuisance at the Defendant Properties; 2) enjoining Defendants from maintaining or participating
in the common nuisance at the Defendant Properties; and 3) imposing specific requirements on
Defendants to prevent the use or maintenance of the Defendant Properties as a common nuisance.
48.
Additionally, if final judgment be in favor of the City, such judgment would be a
judgment in rem against the Property as well as a judgment against the Topletz Defendants. As a
result, the City requests, and Section 125.002(e) of the Texas Civil Practices and Remedies Code
mandates, that the Judgment order that the Defendant Properties be closed for one year after the
date of the Judgment.
B. Temporary and Permanent Relief and Civil Penalties under Chapters 54 of the
Texas Local Government Code

49.
The City re-alleges paragraphs 1-48 as if fully set forth herein.
50.
These causes of action arise under Subchapter B of Chapter 54 and Subchapter A
of Chapter 211 of the Texas Local Government Code.

51.
Chapter 54 of the Texas Local Government Code provides: "A municipality may
bring a civil action for the enforcement of an ordinance: (1) for the preservation of public
safety... ; (2) related to preservation of public health... ; (3) for zoning that provides for the use
of land or classifies a parcel of land according to the municipality's district classification
scheme ... " Tex. Loc. Gov't Code 54.012.
52.
Section 54.016 of the Texas Local Government Code empowers the City to seek
injunctive relief against both the owners of the Property and the owner's representative with
control over the Property on a showing of substantial danger of injury or an adverse health

Page 10.
impact to any person or to the property of any person other than the defendant. This injunction
may prohibit specific conduct that violates the ordinance; and/or require specific conduct that is
necessary for compliance with the ordinance.
53.
Therefore, the City further requests temporary and permanent injunctive relief,
ordering Defendants to comply with Dallas City Code.

54.
As a matter of law, the City is not required to post a bond to obtain injunctive
relief requiring the Defendants to comply with the City Code. See Tex. Civ. Prac. & Rem. Code
6.002; Dallas City Charter, Ch. II, 1(4) & ch. XXIV, 2.
55.
Pursuant to Section 54.017 of the Texas Local Government Code, the City
requests an award of civil penalties not to exceed $1,000 per day for each violation of the City
Code that exists on the Property.
56.
The City seeks a judgment against Defendants.
57.
The City also requests post-judgment interest at the maximum amount allowed by
law and taxable costs of court.

C. Application for Appointment of Receiver
58.
Because of the Topletz Defendant's ongoing and repeated mismanagement of the
Topletz Properties through placement of tenants in substandard conditions, the intimidation of

the tenants in contravention of state law, intended to prevent them from seeking repair of these
conditions, the possibility of material injury to the properties and/or the tenants, and the failure to
pay the necessary expenses to maintain the Topletz Properties while collecting rents, the City
requests that the Court appoint a receiver to take charge and possession of the Topletz Properties.
Pursuant to Texas Civil Practice and Remedies Code Section 64.001 and Texas Rules of Civil
Procedure Rule 695, the City seeks the appointment of a receiver based upon the equitable
considerations enumerated above.
Page 11.
59.
In the alternative, the City seeks an appointment of a receiver pursuant to Texas
Local Government Code 214.003(b)(1), which states that a "court may appoint a receiver for the
property a nonprofit organization with a demonstrated record of rehabilitating properties if the
court finds that the structures are in violation of [ordinances governing the minimum standards
for the continued use and occupancy of all buildings]."
60.
Accordingly, the City requests that the Court order the following:
61.
A Receiver be appointed to take possession and charge of the Topletz Properties
and that the Receiver be allowed:

a)
to collect and receive rents/dues/assessments;
b)
to collect and compromise demands;
c)
to evict non-paying tenants;
d)
to make repairs to the Property as necessary to bring the Property into

compliance with minimum housing standards of the Dallas City Code;
e)
to board up the units as vacancies arise;
f)
to make payments necessary for the maintenance or restoration of utilities;
g)
to exercise all other authority that an owner of the Property would have
including the authority to sell the Property;
h)
upon completion of the receivership, file with the Court a full accounting
of all costs and expenses incurred in repairs, including reasonable costs for
labor and subdivision and all income received from the Property; and
i)
62.
to perform other acts in regard to the Property as authorized by the Court.
All representatives, agents, assigns, and employees of Defendants be prohibited
from being within 500 feet of the Topletz Properties.

Page 12.
63.
Defendants relinquish to the Receiver all accounts, books, rent rolls, funds, and
papers regarding the management of the Topletz Properties;

Defendants cease to hold themselves out as being
64.
III
control of the Topletz
Properties; and
65.
Defendants refrain from contacting any of the current tenants of the Topletz
Properties.
D. Request for Attorneys' Fees and Costs
66.
The City seeks Attorneys' Fees and costs under Texas Civil Practice and
Remedies Code Section 125.00(b) and (d).

VI. REQUEST FOR JURY TRIAL
67.
The City respectfully requests a trial by jury on all issues so triable.

VII. REQUEST FOR DISCLOSURES
68.
Defendants are requested to disclose, within fifty (50) days of service of this
request, the information or material described in Rule 194.2 of the Texas Rules of Civil
Procedure.
VIII. REQUEST FOR ENTRY AND INSPECTION
69.
Pursuant to Rule 196.7 of the Texas Rules of Civil Procedure, the City requests
entry upon the properties which are owned and or/controlled by the Defendants in this case,
including but not limited to those listed in Exhibit 1. The City requests entry to inspect the
properties, including the exteriors and interiors of structures, for compliance with the Dallas City
Code.
70.
The City requests this entry by City Code and/or building inspectors, accompanied
by Dallas Police when requested by such inspectors, within 50 days of service of this petition or
Page 13.
at an earlier, mutually-agreed upon time, for the purposes of conducting an inspection in

accordance with Rule 196.7(c)(l). This request is continuing in nature and the Defendants are
hereby notified of the City's request to enter the properties to determine compliance with any
order issued by this Court.
PRAYER
WHEREFORE PREMISES CONSIDERED, the City respectfully requests that the Court
grant the following relief in the City's favor:
1) that the City be granted temporary and permanent injunctive relief as requested
herein;
2) that the Court, upon notice and hearing, appoint a Receiver to take control of the
Topletz Properties;
3) that on final trial the City be awarded judgment in its favor for civil penalties of $1,000
per day, per violation for each day that Property remains in violation of the Dallas City Code;
4) that the City be awarded judgment in its favor for all costs of court and attorneys' fees;
5) that the City be awarded judgment in its favor for post-judgment interest at the highest
legal rate, and
6) such other and further relief, general or special, at law or in equity, to which the City
may show itself to be justly entitled.

Page 14.
Respectfully submitted,
WARREN M. S. ERNST
Dallas City Attorney
By: lsi Melissa A. Miles
MELISSA A. MILES
State Bar of Texas No. 90001277
melissa.miles@dallascityhall.com
ANNA WELCH
State Bar of Texas No. 24064988
anna. welch @dallascityhall.com
1500 Marilla, 7BN
Dallas, Texas 75201
Tel. (214) 670-3519
Fax (214) 670-0622
ATTORNEYS FOR PLAlNTIFF,
THE CITY OF DALLAS, TEXAS

Page 15.
VERIFICAnON
STATE OF TEXAS
COUNTY OF DALLAS
I, Kate Lawler, a certified code inspector with the City of Dallas, after being duly sworn, hereby
certify that I am qualified and authorized to make this affidavit, and that I have read each and
every factual allegation contained within paragraphs 29-35 and Exhibit 4 of this Petition, and that
said factual allegations are within my personal knowledge and are true and correct.
~
Kate Lawler
Subscribed and sworn to before me this 18th day of November 2015.
[)~M~
Notary Public
DANNA WALLS
Notary Public

City afDallas v. Dennis Tapletz, et aI,
Page 16.
Topletz Rental Properties - Information Populated by Dallas Central Appraisal District ("DCAD
Property Address
Ownerl
OwnAddrl
OwnAddr2
SUITE 301
7509 INWOOD RD STE 301
TotalVal
II
)
20l5CDU
24 3242 PINE ST
TOPLETZ INVESTMENTS
SUITE 301
25 2905 BIRMINGHAM AVE
TOPLETZ INVESTMENTS
SUITE 301
26 4824 FELLOWS LN
TO PLETZ IRIS
27 2229 JORDAN ST
TOPLETZ INVESTMENTS
28 4607 ROBERTS AVE
TOPLETZ DALE
29 2641 GHENT ST
TOPLETZ INVESTMENTS
30 2238 MACON ST
TOPLETZ HAROLD &
31 2331 HARDING ST
TO PLETZ INVESTMENTS
SUITE 301
32 2441 ELSIE FAYE HEGGINS ST
TOPLETZ HAROLD &
TOPLETZJACK
7509 INWOOD RD#301
33 2501 BETHURUM AVE
TOPLETZ INVESTMENTS
SUITE 301
34 2223 METROPOLITAN AVE
TOPLETZ INVESTMENTS
SUITE 301
35 3939 WILDER ST
TOPLETZ JACK &
HAROLD TOPLETZ
7509 INWOOD RD
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
36 2700 PENNSYLVANIA AVE
TOPLETZ HAROLD M &
TOPLETZ JACK
7509
INWOOD RD
9,210.00 UNSOUND
37 3519 PACKARD ST
TOPLETZ HAROLD & JACK
7509 INWOOD RD
9,500.00 FAIR
TOPLETZ INVESTMENTS
2 4435 JAMAICA ST
TOPLETZ INVESTMENTS
3 4003 PENELOPE ST
TOPLETZ HAROLD
STE 301
4 4305 EAST GRAND AVE
TOPLETZ JACK M ET AL
SUITE 301
5 2708 ANDERSON ST
TOPLETZ HAROLD ET AL
STE 301
6 2416 ANDERSON ST
TOPLETZ INVESTMENTS
SUITE 301
7 1639 FAYE ST
TOPLETZ INVESTMENTS
SUITE 301
8 1714 METROPOLITAN AVE
SUITE 301
9 5618 BEXAR ST
TOPLETZ INVESTMENTS
SUITE 301
10 4707 FRANK ST
LEVIN M L
% H J POPLER
11 2339 HARDING ST
TOPLETZ INVESTMENTS
7509 INWOOD RD
7509 INWOOD RD
12 2522 HOOPER ST
TOPLETZ DALE
SUITE 301
13 3625 S CENTRAL EXPY
TOPLETZ INVESTMENTS
SUITE 301
14 4322 SPRING AVE
TOPLETZ DENNIS
15 2821 CARTER ST
TOPLETZ DALE
7509 INWOOD RD
16 3527 PACKARD ST
TOPLETZ INVESTMENTS
SUITE 301
17 1146 FLETCHER ST
TOPLETZ JACK M ET AL
SUITE 301
18 4515 JAMAICA ST
TOPLETZ INVESTMENTS
SUITE 301
19 2229 DATHE ST
STE 301
20 3509 DUNBAR ST
TOPLETZ HAROLD &
JACK TOPLETZ
21 2618 VALENTINE ST
TOPLETZ INVESTMENTS
SUITE 301
7509 INWOOD RD
23 2911 WARREN AVE
TOPLETZ INVESTMENTS
7509 INWOOD RD

SUITE 301

SUITE 301

4,600.00 FAIR
4,750.00 AVERAGE
5,110.00 POOR
6,190.00 UNSOUND
6,250.00 VERY POOR
6,280.00 POOR
6,380.00 VERY POOR
6,720.00 UNSOUND
6,830.00 VERY POOR
6,900.00 POOR
7,100.00 VERY POOR
7,470.00 VERY POOR
7,510.00 POOR
7,530.00 FAIR
7,640.00 UNSOUND
7,710.00 FAIR
7,740.00 UNSOUND
7,760.00 VERY POOR
7,760.00 FAIR
7,800.00 FAIR
7,810.00 VERY POOR
7,820.00 VERY POOR
8,000.00 POOR
8,110.00 VERY POOR
8,130.00 UNSOUND
8,230.00 VERY POOR
8,500.00 FAIR
8,800.00 FAIR
8,890.00 VERY POOR
9,000.00 POOR
9,010.00 VERY POOR
9,050.00 UNSOUND
9,160.00 UNSOUND
9,170.00 UNSOUND
9,180.00 FAIR
EXHIBIT
38 3507 PACKARD ST
39 2638 SOUTHLAND ST
40 3816 ATLANTA ST
41 1624 MARBURG ST
42 4006 COLONIAL AVE
43 2239 STONEMAN ST
44 4632 BURMA RD
45 4619 SPRING GARDEN RD
46
47
48
49
50
51
52
53
54
55
56
57
3531 PACKARD ST
2634 MARBURG ST
2710 DATHE ST
2249 JORDAN ST
2224 COOPER ST
2532 LOWERY ST
3505 ROBERTS AVE
3602 HAVANA ST
4512 CONGO ST
2410 DATHE ST
3618 RUSKIN ST
4209 CARDINAL DR
2427 PENNSYLVANIA AVE
1304 PENNSYLVANIA AVE
2714 WARREN AVE
2707 CROSS ST
4318 YORKST
3526 PACKARD ST
3303 PINE ST
1114 DULUTH ST
2215 FOREMAN ST
58
59
60
61
62
63
64
65
66
67 3115 BERTRAND AVE
68
69
70
71
2416 LAWRENCE ST
3206 HARLANDALE AVE
2701 BIRMINGHAM AVE
2711 EANN ARBOR AVE
72 2658 FORDHAM RD
73 3703 TORONTO ST
75 3911 LE FORGE AVE

TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TO PLETZ JACK METAL
TOPLETZ INVESTMENTS
TOPLETZ DENNIS
TOPLETZ INVESTMENT CO
STE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
TOPLETZ DENNIS D
TOPLETZ INVESTMENTS
TOPLETZ HAROLD &
JACK TOPLETZ
SUITE 301
TO PLETZ JACK M ET AL
SUITE 301
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
SUITE 301
SUITE 301
TOPLETZ INVESTMENTS
SUITE 301
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
SUITE 301
TOPLETZ DENNIS D
TOPLETZ DENNIS
SUITE 301
TOPLETZ DENNIS
TOPLETZ INVESTMENTS
SUITE 301
TOPLETZ INVESTMENTS
SUITE 301
TOPLETZ HAROLD
STE 301
WORLD IS YOURS INVESTMENT GROUP THE
TOPLETZ HAROLD &
TOPLETZ DENNIS D
TOPLETZ HAROLD &
TOPLETZ INVESTMENTS
SUITE 301
TOPLETZ DENNIS D
TOPLETZ HAROLD M &
TO PLETZ JACK
TOPLETZ INVESTMENTS
MONARCH DEVELOPMENT CORP
SUITE 301
TOPLETZ INVESTMENTS
TOPLETZ DENNIS D
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
SUITE 301

7509
7509
7509
7509
7509
7509
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD
RD STE 301
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
RD STE 301
RD STE 301
RD
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
7509
7S09
7509
7509
7509
7509
7509
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
RD STE 301
RD #301
RD
RD STE 301
RD STE 301
RD STE 301
RD STE 301
7509
7509
7509
7509
7509
7509
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
RD STE 301
RD STE 301
RD
RD
RD
RD STE 301

7509 INWOOD RD
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
9,500.00 POOR
9,590.00 POOR
9,640.00
9,650.00
9,670.00
9,680.00
9,750.00
9,900.00
9,940.00
10,000.00
10,000.00
10,080.00
10,100.00
10,470.00
10,510.00
10,580.00
10,700.00
10,750.00
10,790.00
11,050.00
11,070.00
11,110.00
FAIR
VERY POOR
UNSOUND
POOR
POOR
AVERAGE
POOR
POOR
VERY POOR
FAIR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
POOR
AVERAGE
POOR
VERY POOR
POOR
UNSOUND
VERY POOR
AVERAGE
VERY POOR
VERY POOR
AVERAGE
11,230.00
11,430.00
11,680.00
12,000.00
12,000.00
12,110.00 POOR
12,130.00 FAIR
12,200.00 VERY POOR
12,240.00
12,280.00
12,340.00
12,360.00
12,470.00
12,500.00
12,650.00
12,740.00
VERY POOR
FAIR
UNSOUND
FAIR
POOR
UNSOUND
POOR
POOR
12,750.00 UNSOUND

78 3803 OCTAVIA ST
TOPLETZ INVESTMENTS
TOPLETZ CASEY
SUITE 301
79
80
81
82
83
84
2826 CASEY ST
2447 SKYLARK DR
2626 WILHURT AVE
2633 LEACREST DR
2603 MODREE AVE
2318 DATHE ST
TOPLETZ DENNIS D
TOPLETZ INVESTMENTS
TOP LETS DENNIS D
85 2730 SWANSON ST
86 2923 BARDWELL AVE
87 1203 STRICKLAND ST
88 1423 STELLA AVE
89 2630 ANN ARBOR AVE
90 1534 SOUTHERLAND AVE
91 1020 ANN AVE
92 1018 ANN AVE
93 2714 PINE ST
94 2134 ARDEN RD
95 3821 LATIMER ST
96 4526 HELEN ST
97 1117 BETTERTON CIR
98 3906 CARLST
99 2426 PINE ST
100 2659 VOLGA AVE
TOPLETZ CASEY
TOPLETZ HAROLD &
TOPLETZ DENNIS D
TOPLETZ HAROLD &
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ CASEY
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ HAROLD &
TOPLETZ HAROLD &
TOPLETZ DENNIS
TOPLETZ HAROLD M &
TOPLETZ CASEY
% TOPLETZ INVESTM 7509

7509
SUITE 301
7509
7509
7509
7509
7509
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
RD STE 301
RD STE 301
RD STE 301
RD
RD
RD STE 301
RD STE 301
TOPLETZ JACK
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
RD #301
RD
RD
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD
RD
RD #301
RD STE 301
RD
101
102
103
104
105
106
1150 FLETCHER ST
2822 CASEY ST
2111 HUDSPETH AVE
2403 S MARSALIS AVE
210 N CLIFF ST
2302 GREER 5T
107 1543 SOUTHERLAND AVE
108 4111 VINEYARD DR
109 4035 VINEYARD DR
TOPLETZ HAROLD &

TOPLETZ DENNIS D
TOPLETZ DENNIS D
TOPLETZ JACK
SUITE 301
SUITE 301
STE 301
JACK TOPLETZ
TO PLETZ JACK
STE 301
TOPLETZ JACK
STE 301
JACK TOPLETZ

7509 INWOOD RD #301
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7506
7509
7509
7509
7509
7509
7509
7509
7509
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
RD
RD #301
RD STE 301
RD STE 301
RD
RD
RD STE 301
RD
RD STE 301

7509 INWOOD RD
110 4518 COLONIAL AVE

111 1722 ATLAS DR
112 4524 HELEN ST
TOPLETZ DENNIS D
TOPLETZ INVESTMENTS

114 2823 CARPENTER AVE
115 3054 RAMSEY AVE
SAIGE PROPERTIES
TOPLETZ DENNIS
7509 INWOOD
7509 INWOOD RD
7509 INWOOD RD
STE 301
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
12,950.00 POOR
13,000.00 FAIR
13,250.00
13,500.00
13,550.00
13,800.00
VERY POOR
POOR
POOR
FAIR
13,850.00 POOR
13,860.00 AVERAGE
13,900.00
14,000.00
14,000.00
14,000.00
14,000.00
14,000.00
14,400.00
14,400.00
14,570.00
14,800.00
14,950.00
15,000.00
15,000.00
15,000.00
15,000.00
15,020.00
15,110.00
15,620.00
15,770.00
16,000.00
16,000.00
AVERAGE
FAIR
POOR
VERY POOR
AVERAGE
FAIR
UNSOUND
UNSOUND
POOR
POOR
POOR
VERY POOR
VERY POOR
FAIR
UNSOUND
FAIR
UNSOUND
POOR
POOR
VERY POOR
UNSOUND
16,000.00 FAIR
16,050.00 POOR
16,080.00 VERY POOR
16,080.00 VERY POOR
16,200.00 POOR
16,350.00 AVERAGE
16,440.00 POOR
16,460.00 FAIR
16,560.00 AVERAGE
16,750.00 UNSOUND
7509 INWOOD
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
116 4242 OPAL AVE
7509 INWOOD RD
117 4515 TACOMA ST
TOPLETZ DENNIS
118
119
120
121
122
123
2642 ALABAMA AVE

2351 JENNINGS AVE
3326 DETONTE ST
2215 MAR BURG ST
2907 KILBURN AVE
1217 NORTH ST
124
125
126
127
128
2822 EXETER DR
5015 BURNSIDE AVE
TOPLETZ INVESTMENTS
TOPLETZ DENNIS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ HAROLD &
TOPLETZ INVESTMENTS
129
130
131
132
133
134
135
136
137
138
139
140
2831 WILHURT AVE

3033 DAHLIA DR
2316 HARDING ST
3046 ALABAMA AVE
4429 CROZIER ST
5020 COLONIAL AVE
2938 RAMSEY AVE
1218 VERMONT AVE
4010 COLONIAL AVE
1218 STRICKLAND ST
2406 PEABODY AVE
3027 ALABAMA AVE
4017 S MARSALIS AVE
2958 KAVASAR DR
1231 IOWA AVE
4211 BIGLOW ST
5211 AUDREY ST
1327 NEPTUNE RD
2929 BIRMINGHAM AVE
141
142
143
144
145 2942 RAMSEY AVE
146
147
148
149
150
151
UTAH AVE
MARSHALL ST
ELSIE FAYE HEGGINS ST
FOREST LN

TOPLETZ DENNIS D
TOPLETZ HAROLD &
TOPLETZ HAROLD M &
GP ACQUISITIONS LLC
MEHALIA DR
TOPLETZ INVESTMENTS
E9TH ST
2205 ARDEN RD
2610 INGERSOLL ST
3314 JEROME ST
4606
4106
3525
152 8205
153 4015
154 1209
TOPLETZ HAROLD &

TOPLETZ DENNIS
TOPLETZ HAROLD
TOPLETZ HAROLD
STERLING MABLE LIFE EST
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ DENNIS
CAPSHAW INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ HAROLD &
TOPLETZ HAROLD &
TOPLETZ DENNIS D
TOPLETZ HAROLD M &
TOPLETZ DENNIS
MINSK FINANCE LLC
SUITE 301
APT 301
SUITE 301
SUITE 301
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
STE 301
7509
7509
REM:HAROLD & JACK 7509
SUITE 301
7509
7509
STE 301
7509
SUITE 301
7509
7509
7509
7509
7509
7509
#301
7509
7509
7509
7509
7509
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 300
RD STE 301
INWOOD RD STE 301

INWOOD RD STE 301
INWOOD RD STE 301
INWOOD RD
INWOOD RD STE 301
INWOOD RD
INWOOD RD STE 301
INWOOD RD STE 301
INWOOD RD
INWOOD RD STE 301
INWOOD RD STE 301
INWOOD RD STE 301
INWOOD RD
INWOOD RD
INWOOD RD
INWOOD RD STE 301
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
RD
RD
RD
RD
RD
STE 301
STE 301
STE 301
STE 301
7509 INWOOD RD
7509 INWOOD RD
7509 INWOOD
% TOPLETZ INVESTM 7509 INWOOD
TOPLETZ JACK
7509 INWOOD
7509 INWOOD
7509 INWOOD
%TOPLETZ DENNIS
7509 INWOOD
STE 301
RD STE 301
RD STE 301
RD
RD
RD STE 301
RD STE 301
16,970.00 FAIR
17,020.00 POOR
17,130.00 UNSOUND
17,260.00 POOR
17,320.00 POOR
17,460.00 AVERAGE
17,500.00 FAIR
17,500.00 FAIR
17,650.00 FAIR
17,880.00 VERY POOR
17,940.00 FAIR
18,000.00 AVERAGE
18,000.00 VERY POOR
18,000.00 FAIR
18,080.00 VERY POOR
18,210.00 UNSOUND
18,250.00 FAIR
18,600.00 VERY POOR
18,610.00 VERY POOR
18,680.00 VERY POOR
18,910.00 AVERAGE
19,000.00 FAIR
19,300.00 POOR
19,320.00 VERY POOR
19,440.00 VERY POOR
19,760.00 VERY POOR
20,450.00 POOR
20,560.00 AVERAGE
20,800.00 POOR
21,360.00 FAIR
21,670.00 POOR
21,810.00
22,450.00
23,100.00
23,450.00
23,460.00
VERY POOR
POOR
POOR
AVERAGE
AVERAGE
24,000.00 POOR
24,120.00 FAIR
24,360.00 UNSOUND
155 120 PALM OAK DR

156 1405 MINUET LN
TOPLETZ HAROLD &

157
158
159
160
161
133 W MAIN ST
2423 VOLGA AVE
1603 POPLAR ST
4419 COLONIAL AVE
1930 RAMSEY AVE
TO PLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ HAROLD &
TOPLETZ INVESTMENTS
162
163
164
165
166
167
168
169
170
171
411 WOODACRE DR
1603 ALGONQUIN DR
4213 WILLOW ST
4616/4618 HOPKINS AVE
TOPLETZ HAROLD &

TOPLETZ IRIS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS

172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187 4516/4518 HOPKINS AVE
190 115 N CISCO ST
JACK TOPLETZ
SUITE 301
SUITE 301

7509 INWOOD RD
TOPLETZ JACK
7509
7509
7509
7509
INWOOD RD #301
INWOOD
INWOOD RD STE 301
INWOOD RD STE 301
7509
7509
7509
7509
7509
7509
INWOOD RD STE 301

INWOOD RD STE 301
INWOOD RD STE 301
INWOOD RD STE 301
INWOOD RD STE 301
INWOOD RD STE 301
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
SUITE 301
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
7509
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
INWOOD
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
RD STE 301
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
TOPLETZ INVESTMENTS
SUITE 301
SUITE 301
SUITE 301
SUITE 301
7509
7509
7509
7509
INWOOD
INWOOD
INWOOD
INWOOD
RD STE 301
RD STE 301
RD STE 301
RD STE 301
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
24,580.00 POOR
24,950.00 VERY POOR
25,950.00 VERY POOR
26,590.00
28,600.00
28,980.00
36,600.00
37,720.00
38,220.00
FAIR
GOOD
POOR
AVERAGE
POOR
AVERAGE
38,950.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
S8,000.00
S8,000.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
58,000.00
S8,000.00
58,000.00
FAIR
VERY POOR
POOR
VERY POOR
VERY POOR
VERY POOR
POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
VERY POOR
58,000.00
58,000.00
58,000.00
109,810.00
VERY POOR
VERY POOR
VERY POOR
VERY POOR
~'.
TOPLETZ INVESTMENTS
7509 Inwood Road #301
Dallas, Texas 75209
(214) 350-7555
_ _ _,20
AcknOWledged (
ABSOLUTELY NO DRUG DEALING OR SUBJECT TO IMMEDIATE EVICTION !!!!

I (We) make application to rent the property known as_
We also agree
.
1. To pay $_ ,-_ ~
_ _ _' Dallas, Texas.
_---Per month on a monthly basis in advance at Topletz office on or before the date is
due and payable.

2. To pay $ (_as a secu~ty rental/damage deposit.
J. To pay $_ . \ . . _as a pet deposit. Tenant hereafter agrees if a pet is allowed at above
address
and a
.
.
deposit has not been paid for prior to occupancy, an amount double the deposit will be reqT:lired and must be
paid imm'ediately or tenant is subject to eviction.
4. Failure to pay rent when due shall entitle Topletz to terminate this agreement and take possession of the
premises and its' contents.
.
5. Tenant agrees to hold Topletz Investments harmless from any and all damages to person and propel1y during
tenancy occasioned by any defects, repairs, or improper construction of said premises.
6. No repairs or alterations will be done or paid for without consent of owners.
7. Tenant agrees to take care of house and yard. Premises will be kept free of rubbisbigarbage and high gra::>:>.
8. Tenant agrees to make all minor repairs at tenants expense.
9. Tenant or anyone else shall not damage the structure or its facilities
10. Tenant will immediately report any damage done by others relating to the property.
11. Tenant is responsible for all broken windows and all broken and stopped up pipes. A charge wi II be made
by Topletz if repaired, and must be paid for at time work is completed. L1111t:~~ prior aIT<lIl~L'lllL'lll:- 11;1\!~ hL'L'I:
made.
12. Tenant will not park or let others park in his yard.
13. Tenant agrees to pay a $30.00 service charge on all returned checks.
~'Tenant agrees to pay a $20.00 late charge whenever the rent is three (3) days late: pius, S20.()() pel' week
until the balance is paid in full.
5. Tenant understands that all r~nts are due and payable at our office on the due date. If a...collector must be
sent to your house, a $20.00 charge will be made for each and every trip. This charge is in addition to any
late charge.
.
1 Oo,Jenants deposit will be refunded ifTopletz is given 10 days notice of intent to move, leaves premises swept
clean and free of trash leaving the house in good condition. Deposits will be refuri'de9 within 5 Jays after
inspection has been verified.
17. A $25,00 Application/process fee will be charged if tenant does not want unit after tying up house in
additi ()n to per day rental due.
18. Tenant acknowledges he has inspected the premises and agrees to accept the property in "as is" condi tion.
19. Tenant acknowledges the smoke detector in this unit is in working condition and will maintain and/or
replac.e any and all parts as necessary during his tenancy.
20. Tenants agrees that there will be no loitering or drug dealing in or around their home. Anyone caught or
allowing others to break this rule will be subject to eviction and/or temlination of this agreement and
confis cation of the premises and its contents,
21. Tenant agrees to furnish their own appliances, air conditioning and heating, and maintain [hem ill propt:1'
workiLg condition.
22. Tenan..twill abide by all ordinances and laws of the City of Dallas and will hold Topletz hamlless ti'ol11 Llll~
violations caused by themselves or their invitees.
I
..
1D
I!'
11
..
E
3
EXHIBIT
'-~TOPLETZ
INVESTMENTf
7509 Inwood Road #301 .

Dallas, Texas 75209
(214) 350-7555
August 25,2013
Re: .
& all occ.
Dallas, Texas
Dear
TIlls letter is to advise you that effective on your next rental due date, it will be necessary for us to increase rental rates.
Substantial increases in taxes & insurance, are items beyond our control that have forced us t6 make this adjustment.
However, we are holding your rental increase to a minimum and your new rental rate will now be; $550 per month.
We are sure you will fInd these amounts still well below current rates for comparable housing.
Please recall your rental contract: "your home is rented on an 'as is' basis". You are responsible for your surroundings
and your guests. No "illegal activities are allowed": Any person dealmg drugs .on/around the premises will be dealt
with to the full extent of the law including arrest/eviction/confIscation of your property and whatever options he
Police/City of Dallas and our office may deem necessary to control illegal activities.
As long as we have your cooperation in taking care of your home, its' surroundings and not requiring additional
repairs, we shall resist raising our rents further. If you allow the City' of DallaslNeighborhood Services enter your
residence and they require repairs for which you are responsible, such items will be charged to you directly. If anyone
wants to enter your home for whatever the reason; tell them "this is your home, there are no problems and they
cannot enter without a warrant". No one has the right to enter your home without your permission,regardless
of what they say. Do your part and keep your house up to code and in the condition it was fIrst rented. Tenants or
anyone else shall not damage the structure or its facilities. Tenant is responsible for all broken windows, frozenlbroken
pipes, stopped up plumbing and code violations for which you are directly responsible. Tenant will also keep the
premises in and around their home free and clear of litter, hi grass, in-operable vehicles and garbage. Receptacles have
been provided for your trash to be removed on a regular basis (twice a week). Please use them!! A charge will be
made if we must clean up around your home or if repairs must be made to your home for things you should be doing as
a tenant per your rental agreement, and must be paid for at the time work is completed, unless prior arrangements have
been made.
With the recent passing of Mr. Jack Topletz, our senior partner who was in charge of collections & maintenance, it
becomes necessary for us to make adjustments to offset his duties with the company.
A) Concerning collections:
Y alL will need to timely make your payments directly to the office on or before their due date. If you cannot or
do not make your payments timely, a collectot will be sent to your home. and the $20.00 collection charge must
be paid for each & every trip the collector must make to collect your rent after the "3 day grace period" unless
you have called & made acceptable arrangements. The $20.00 collection cost is trip charge in addition to the
$20.00 late charges after the above mentioned "3 day grace period" that continue to accumulate until balance is
paid in full.
B) Concerning repairs & maintenance:
Since most of our tenants have held their requests to a minimum, we have cooperated by not passing our
subS1:antially increased costs on to you at this time.
Save these additional charges by taking care of your home, paying on time or calling the office if something
unavoidable happens. Paymellts to the office shoul~ be.by check or money order. Do not send cash in the mail.
EXHIBIT
~
E
3
Exhibit
Chapter 54 Code Violations
2501 BETHURUM AVE., DALLAS, TEXAS,
Failure to protect the exterior surfaces of the structure fi.om decay in violation of Section
27-11(b)(1);
Failure to provide and maintain in operating condition connections to discharge sewage
from a structure or land into a public sewer system in violation of Section 27-11 (c)(1);
Failure to provide and maintain in operating condition a toilet cOlli1ected to a water
source and to a public sewer in each structure intended for human habitation in violation
of Section 27-11(c)(2);
Failure to provide and maintain in operating condition connections and pipes to supply
potable water at adequate pressure to a structure intended for human occupancy in
violation of Section 27-11(c)(3);
Failure to provide and maintain in operating condition a device to supply hot water of a
minimum temperature of 120F. within each structure intended for human habitation in
Failure to provide and maintain heating equipment in operating condition so that it is
capable of maintaining a minimum inside temperature of 68F. From November 16
through March 15 in each room of a structure intended for human occupancy in violation
Failure to provide and maintain in operating condition, fi.om April 1 through November
1, refrigerated air equipment capable of maintaining a maximum inside temperature that
is 20 degrees lower than the outside temperature or 85F, whichever is warmer, in each
room of a structure intended for human occupancy in violation of Section 27-11(c)(8);
Failure to provide and maintain in operating condition electrical circuits sufficient to
safely carry a load imposed by normal use of appliances and fixtures in violation of
Section 27-11(c)(11);
Failure to provide a structure intended for human habitation with a screen for keeping out
insects at each opening of the structure if the structure is not cooled with refrigerated air
in violation of section 27-11 (d)(2);
2705 PENNSYLVANIA AVE., DALLAS, TEXAS
There are holes, excavations, sharp protrusions, and other object or condition that exists
on the land that are reasonably capable of causing injury to a person in violation of
Section 27-11(a)(1);
There are dead trees and tree limbs that are reasonably capable of causing injury to a
person in violation of Section 27-11(a)(5);
Failure to protect the exterior surfaces of the structure from decay in violation of Section
27-11(b)(1);
Failure to keep the structure in a water-tight and weather-tight condition in violation of
Section 27-11(b)(5);
The floors, walls, ceilings and all supporting structural members are not in a sound
condition capable of bearing imposed loads in violation of Section 27-11 (b)(6);
There are holes, cracks, and loose surface materials that are health or safety hazards in or
on floors, walls or ceilings in violation of Section 27-11 (b)(9);
from a structure or land into a public sewer system in violation of Section 27-11(c)(1);
Failure to provide and maintain in operating condition a toilet connected to a water
of Section 27-1 1(c)(2);
violation of Section 27-1 1(c)(4);
Failure to provide and COlmect a kitchen sink, bathtub or shower, and lavatory to a cold
and hot water source in each structure intended for human occupancy in violation of
Section 27-11(c)(5);
Failure to connect plumbing fixtures and heating equipment that the owner supplies in
accordance with the Dallas Plumbing Code and Dallas Mechanical Code in violation of
Section 27-11(c)(6);
Failure to provide and maintain in operating condition, from April 1 through November
room of a stlucture intended for human occupancy in violation of Section 27-11(c)(8);
Failure to provide and maintain in operating condition a supply line for electrical service
to each structure intended for human occupancy if electrical service is available within
300 feet in violation of Section 27-11(c)(9);
Section 27-11(c)(11);
in violation of section 27-11(d)(2);
Failure to install single and multiple-station smoke alarms in a single family residence or
duplex in the following locations: (1) in each sleeping room, (2) outside of each separate
sleeping area in the vicinity of the bedrooms, (3) on each additional story of the dwelling
including basements and cellars but not including crawl spaces and uninhabitable attics in
violation of Section R317.1 of the International Residential Code;
No person shall suffer or permit any cellar, vault, drain pool, privy, sewer, yard, grounds
or premises belonging to or controlled or occupied by him to become, from any cause,
nauseous, foul, offensive or injurious to public health, or unpleasant and disagreeable to

adjacent residents or persons in violation of Section 19-17;
1203 STRICKLAND ST., DALLAS, TEXAS,

There are dead trees and tree limbs that are reasonably capable of causing injury to a
person in violation of Section 27-11 (a)(5);
Failure to keep the doors and windows of a vacant structure securely closed to prevent
unauthorized entry in violation of Section 27-11 (a)(6);
27-11(b)(1);
Failure to provide and maintain railings for stairs, steps, balconies, porches and
elsewhere as specified in the Dallas Building Code in violation of Section 27-11(b)(3);
There are holes, cracks and other defects capable of causing injury to a person in stairs,
porches, steps, and balconies in violation of Section 27-11 (b)(4);
The floors, walls, ceilings and all suppoliing structural members are not in a sound
condition capable of bearing imposed loads in violation of Section 27-1 1(b)(6);
on floors, walls or ceilings in violation of Section 27-11(b)(9);
violation of Section 27-11 (c)(3);
of Section 27-11 (c)(7);
room of a structure intended for human occupancy in violation of Section 27-11 (c)(8);

safely carry a load imposed by nonnal use of appliances and fixtures in violation of
Section 27-11(c)(l1);
2603 MODREE AVE., DALLAS, TEXAS,

27-11(b)(1);
There are holes, cracks, and loose surface materials that. are health or safety hazards in or
is 20 degrees lower than the outside temperature or 85F, whichever is wanner, in each
room of a structure intended for human occupancy in violation of Section 27-1 1(c)(8);
safely canoy a load imposed by nonnal use of appliances and fixtures in violation of
3803 OCTAVIA ST., DALLAS, TEXAS
27-11(b)(l);
Section 27-l1(b)(5);
1231 IOWA AVE., DALLAS, TEXAS
Section 27-11(a)(l);
27-l1(b)(l);

on floors, walls or ceilings in violation of Section 27-11 (b)(9);
source and to a public sewer in each stlucture intended for human habitation in violation
Failure to provide and connect a kitchen sink, bathtub or shower, and lavatory to a cold
and hot water source in each structure intended for human occupancy in violation of
Section 27-1 1(c)(5);
Failure to connect plumbing fixtures and heating equipment that the owner supplies in
accordance with the Dallas Plumbing Code and Dallas Mechanical Code in violation of
Section 27-1 1(c)(6);
of Section 27-11 (c)(7);
Section 27-1 1(c)(l 1);
1304 PENNSYLVANIA AVE., DALLAS, TEXAS,


on floors, walls or ceilings in violation of Section 27-1 1(b)(9);
safely canoy a load imposed by nonnal use of appliances and fixtures in violation of
Failure to install single and multiple-station smoke alanns in a single family residence or
duplex in the following locations: (l) in each sleeping room, (2) outside of each separate
sleeping area in the vicinity of the bedrooms, (3) on each additional story of the dwelling
including basements and cellars but not including crawl spaces and uninhabitable attics in
violation of Section R317.1 of the International Residential Code;
3737 GUARANTY ST., DALLAS, TEXAS

violation of Section 27-11 (c)(3);
room ofa structure intended for human occupancy in violation of Section 27-11(c)(8);
Failure to obtain a pennit from the building official before erecting, constructing,
enlarging, adding to, altering, repairing, moving, improving, removing, installing,
converting, demolishing, equipping, using, occupying, or maintaining a structure or
building, service equipment, or causing same to be done in violation of Section 52301.1.1.
Code Violations at Non-Defendant Properties
1209 EAST 9TH STREET, DALLAS, TEXAS,

There are holes, excavations, sharp protmsions, and other object or condition that exists
Section 27-II(a)(l);
Failure to protect the extelior surfaces of the stmcture from decay in violation of Section
27-1 1(b)(l);
Failure to keep the stmcture in a water-tight and weather-tight condition in violation of
Section 27-II(b)(5);
on floors, walls or ceilings in violation of Section 27-1 1(b)(9);
Failure to maintain a fence so that it is not out of vertical alignment more than one foot
from vertical, measured at the top of the fence, for a fence over four feet high, or more
than six inches from the veliical, measured at the top of the fence, for a fence not more
than four feet high in violation of SeCtion 27-1 1(b)(IO)(A);
tlu'ough March 15 in each room of a stmcture intended for human occupancy in violation
room of a stmcture intended for human occupancy in violation of Section 27-II(c)(8);
Section 27-1 1(c) (1 1);
Failure to provide a stmcture intended for human habitation with a screen for keeping out
insects at each opening of the stmcture if the stmcture is not cooled with refrigerated air
in violation of section 27-1 1(d)(2);
No person shall suffer or pennit any cellar, vault, drain pool, privy, sewer, yard, grounds
There are accumulations of bricks and lumber that may be used as a harborage by rats,
which are not elevated at least 18 inches above ground in violation of Section 40-4;
There are accumulations of litter that are not in authorized private receptacles for
collection in violation of Section 7A-18;
2710 DATHE ST., DALLAS, TEXAS

There are holes, excavations, sharp protmsions, and other object or condition that exists
Section 27-1 1(a)(l);
Failure to protect the exterior surfaces of the stmcture fr'om decay in violation of Section
27-11(b)(l);

condition capable of bearing imposed loads in violation of Section 27-11(b)(6);
from a structure or land into a public sewer system in violation of Section 27-11(c)(l);
Failure to provide and maintain in operating condition, :from April 1 through November
is 20 degrees lower than the outside temperature or 85F, whichever is Walmer, in each
Failure to provide and maintain in operating condition electlical circuits sufficient to
Failure to maintain the interior of a structure or vacant portion of a structure :free :from
rubbish and garbage in violation of Section 27-11 (d)(3);
or premises belonging to or controlled or occupied by him to become, :from any cause,
3703 TORONTO ST., DALLAS, TEXAS,

27-11(b)(1);

condition capable of bearing imposed loads in violation of Section 27-11(b)(6);
from a structure or land into a public sewer system in violation of Section 27-1 l(c)(l);
Failure to provide and maintain in operating condition a toilet cOlUlected to a water
tIu'ough March 15 in each room of a structure intended for human occupancy in violation
Failure to provide and maintain in operating condition, i'om April 1 through November
1, reiigerated air equipment capable of maintaining a maximum inside temperature that
room of a structure intended for human occupancy in violation of Section 27-1 1(c)(8);
adjacent residents or persons in violation of Section 19-17
Minimum Urban Rehabilitation Standards
27-5.2
21-11
written notice or citation issued by the director or a

court order.
(B) allow the landlord 15 days to

corred the violation; or
(b) It is a defense to prosecution under

Subsection (a) that:
(9) the landlord proves that the rent

increase, service reduction, or attempted eviction was
for good cause and not for purposes of retaliation
against the tenant.
(1) rent was increased pursuant to an

escalation clause in a written lease which provided
for changes in costs of utilities, taxes, and insurance;
(2) rent was increased, services were
reduced, or notices to vacate were issued as part of a
pat tern of rent increases, service reductions, or
evictions for an entire multidwelling project;
the tenant was delinquent in rent

when the landlord gave notice to vacate or tiled an
evie tion action;
(3)
the tenant was responsible for or

caused a violation of this chapter that existed on
property occupied by the tenant;
(4)
the tenant's written lease fixing the

rent, services, or term of occupancy had expired,
unless, at the lime an action described in Subsection
(a)(l), (2), or (3)- occurred, a violation of this chapter
that 'Was reasonably dangerous to the physicaJ
health or safety of the tenant or another person
existed on property occupied by the tenant;
(5)
the tenant holds over after giving

notice of tennlnation or intent to vacate;
(6)
(7) the tenant holds over after the

landlord gives notice of termination at the end of the
rental term and, at the time the notice of termination
was given, the landlord or the landlord's agent had
not rece ived actual notice that a valid complaint had
been .filed with the city complaining of violations of
this chapter on property occupied by the tenant;
(8) before filing a complaint with the

city c:lrrtplaining of a violation of this chapter on
prope.rty occupied by the tenant, other than a
violation that is reasonably dangerous to the
physic-a! health or safety of the tenant or another
person, the tenant fails to comply with a written
lease p ro"Vision:' requinng the tenant to:
(A) notify the landlord or the
landlord's agent, in writing. of the violation; and
(c) An offense under this section may be

prosecuted upon the filing of a written complaint by
the tenant with the city attorney. (Ord. Nos. 20017;
26455)
SEC. 216.
RESERVED.
(Repealed by Ord. 26455)
SEC. 27-1.
RESERVED.
SEC. 218.
RESERVED.
SEC. 279.
RESERVED.
SEC. 2110.
RESERVED.
ARTICLBIIL
MIN1MUM STANDARDS.
SEC. 2111.
(a)
MINIMUM STANDARDS;
RESPONSIBIUTlES OF OWNER.
Property standards. An owner shaU:
(1) eliminate a hole, excavation, sharp

protrusion, and any other object or. condition that
exists on the land and Is reasonably capable of
causing injury to a person;
(2) securely cover or dose a well,
cesspool, or cistern;
Dallas City Code
7/08
2711
2711
(3) provide solid waste receptacles Or

containers when required by Chapter 18 of this code;
(10) maintain any fence on the property

in compliance with the following standards:
(4) provide drainage to

standing water and flooding on the land;
(A) maintain a fence so that it is

not out of vertical alignment more than one foot from
the vertical, measured at the top of the fence, for a
fence over four feet high, or more than six inches from
the vertical, measured at the top of the fence, for a
fence not more than four feet high, except that this .
provision does not apply to a masonry wall unless the
wall encloses:
prevent
(5) remove dead trees and tree limbs

that are' reasonably capable of causing injury toa
person; and
. (6) keep the doors and windows of a

vacant structure or vacant portion of a structure
seCl.uely dosed to prevent unauthorized entry.
.(1)
a multi-tenant property:
or
(b)
Structural standards. An owner shall:
protect the exterior surfaces of a

structure that are subject to decay by application of
paint or other coating;
(1)
fill hollow, masonry supporting

piers, if used, with concrete and anchor the piers to
concrete footings with a 5/8 inch steel dowel;
-'
(2)
(3) provide and maintain railings for

stairs, steps, balconies, porches, and elsewhere as
specified in the Dallas Building Code;
(4) repair holes, cracks, and other
defects reasonably capable 01 causing injury to a
person in stairs, porches, steps, and balconies;
(Ii) a single-family or duplex

property where the wall Is not shared with another
property:
(B) repair 01' replace rotted, fire

damaged, or broken wooden slab and support posts;
(C) repair or replace broken or bent
metal posts and tom, cut, bent, or ripped metal fencing
materials; and
(D) repair or replace loose bricks,
stones, rocks, mortar, and similar materials on any
masonry wall that encloses:
(i) . a multi-tenant property;

or
(5) maintain a structure intended for

human occupancy and a structure used as an accessory
to a structure intended for human occupancy In a
weather-tight and water-tight condition;
(6) maintain floors, walls, ceilings, and

all supporting structural members in a sound
conditicn, capable of bearing imposed loads safely;
(7) provide cross-ventilation of not less
than 1-112 square feet for each 25 lineal feet of wall
in each basement, cellar, and crawl space;
repair or replace chimney flue and

vent attachments that do not function properly:
(8)
(9) repair holes, cracks, breaks, and

loose surface materials that are health or safety
hazar~s in or on floors, walls, and ceilings; and
(il) a single-family or duplex

property where the wall is not shared with another
property.
(c)
Utility standards. An owner shall:
(1) prOVide and maintain in operating

condition connections t~ discharge sewage from a
structure or land into a public sewer system where
available:
(2) provide and maintain in operating
condition a toilet connected to a water SOUlce and to a
public sewer, where available, in each structure
intended for human habitation;

condition connections and pipes to supply potable
water at adequate pressure to a structure intended for
human occupancy;
Dallas City Code

8
7/08
27-11

. condition a device to supply hot water of a minimum
temperature of 120F. within each structure intended
for human habitation;
(S) provide and connect a kitchen sink,

bathtub or shower, and lavatory to a cold and hot
water source in each structure intended for human
habitation;
(6) connect plumbing fixtures and
heating equipment that the owner supplies in
accordance with the Dallas Plumbing Code and
Dallas Mechanical Code:
(7} provide and maintain heating
equipment in operating condition so that it is capable
of maintaining a minimwn inside temperature of 68"P.
frOIrl November 16 through March 15 in each room of a
structure intended for human occupancy;
(8) if screens are not provid~d as
required in Subsection (d)(2), provide and maintain in
operating condition, from April I through November
1, re.trigerated air equipment capable of maintaining
a maximum inside temperature that is 20 degrees
lower than the outside temperature or 8S"F.,
whichever is warmer, in each room of a structure
intended for human occupancy;

condition 'supply lines for electrical service to each
structure intended for human occupancy if electrical
service is available within 300 feet;
(IO) connect each heating and cooking

device that bums solid fuel to a chimney or flue; and
conditi(m electrical circuits and outlets sufficient to

safely carry a load imposed by normal use of
appliances and fixtures.
(d)
Health standards. An owner shall:

(1)
eliminate rodents and vermin in or on
the JU1d;
(2) prOVide a structure intended for

human .11abitation with a screen for keeping out
insects at: each opening of the structure if the structure
i5 not co<>!ed with refrigerated air;
27-11
(3) maintain the interior of a vacant

structure or vacant portion of a structure free from
rubbish and sullage; and
(4) keep the interior of a structure free

from insects, rodents, and vermin, except as specified
in Section 27-12(b).
(e) Security standards. An owner or operator
of a multifamily property, other than one exempt
from registration undet Section 27-30(b)(2) of this
chapter, shall:
(1) provide and maintain security
devices in each dwelling unit as required by Sections
92.153,92.154, and 92.155 of the Texas Property Code,
as amended; and
(2) if the multifamily property has 20

or more dwelling units, provide security lighting that
adequately illuminates all parking areas,
walkways, stairs and steps, doorways, and garbage
storage areas so tha~ persons moving in or around
those areas can be easily seen.
(f) It is a defense to prosecution under
Subsection (a) .of this section that the premises
concemed is the site of new construction and
reasonable and contlnl,lous progress Is being made to
complete the construction.
(g) It is a defense to prosecution under

Subsection (d)(4) of this section that the structure was
treated to eliminate insects, rodents, and vermin by a
person licensed under the Texas Structural Pest
Control Act once within the preceding six months.
(h) An owner shall provide a tenant with
alternative housing that meets the minimum
standaxds required by this section when:
(1) after being issued a notice or dtation
for violation of Subsection (c)(7) of this section, the
owner fails to repair heating equipment within n
hours after receiving such notice or citation and the
overnight low temperature, as measured by the
National Weather Service at Dallas Love Field, is
below 40F. for tht:ee conset:Utive days aiter receiving
such notice or citation; or
(2) alter being issued a notice or citation

for violation of Subsection (c)(8) of this section, the
Dallas City Code
7/08
19-11
assessment shall be paid which time shall not be

longer than 30 days from the date of the making of
the assessment. Such assessment shall bear interest
at the rate of 10 percent per annum from the date of
making the same. Any number of assessments against
different pieces of property may be levied in one and
the same ordinance. (Code 1941, Art. 86-53)
SEC. 19-12.
19-17
Health and Sanitation
SAME - SAME - PRIORITY

OF ASSESSMENT LIEN;
ENFORCEMENT,
SEC. 19-14.
TRASH, ETC., NOT TO BE

THROWN FROM HOUSES.
No person shall throw any article, trash, filth,

slop or anything else, whatever, from the roof or
upper story, or window of a house, upon the house or
premises of another or upon any street or sidewalk.
(Code 1941; Art. 87-4)
SEC. 19-15.
THROWING TRASH UPON

PUBLIC PLACES PROHIBITED.
The amount assessed under the terms of this

No person shall throw, or permit anyone in his
article against any property or owner thereof shall be
employ to throw upon any public place, any animal or
secured by a privilege lien upon the property to secure . vegetable substance whatever, or any tin, rock, brick
the expenditure so made. Such liens shall be second
or broken concrete, glass, glass bottle, nails, tacks,
only to tax liens and liens for street improvements,
wire, cans, pieces of iron or any other substance likely
and such assessment shall constitute a personal
to injure any person, animal or vehicle upon any
liability against the owner of the property in favor
public place. (Code 1941, Art. 86-61)
of the city. Such liens and liability may be enforced
by suit in any court having jurisdiction and the
DEPARTING TENANTS
assessment aforesaid or a certified copy thereof shall
SEC. 19-16.
be prima:;facie evidence of the amount expended in
REQUIRED TO LEAVE
any such 'work or improvement. (Code 1941, Art.
BUILDING AND PREMISES
86-54);';
SEC. 19-'13;
CLEAN AND SANITARY.
SAME - SAME - CONTEST OF

ASSESSMENT; BAR.
Any person having any interest in any property

against which any assessment shall have been made
or levied under the provisions of this article shall
have the right to contest the assessment or the
validity thereof, or the regularity of any proceeding
with reference to the assessment, or the special
benefits received by the owner of such property, by
filing suit in any court having competent jurisdiction
thereof, in which suit the city shall be defended;
provided, that such suit shall be brought within 10
days from the date of the passage of the ordinance
levying such assessment against such property and if
not so brought, then the owner or other person having
an interest in the property shall thereafter be barred
and estopped to question the validity of such
proceedings, assessment, liability and lien thereby
fixed. This bar and estoppel shall apply to the
heirs, assigns, successors and legal representatives of
such person. (Code 1941, Art. 86-55)
Whenever any person now occupying or using or

hereafter occupying or using any building or premises
in the city, improved or unimproved, whether such .
person be the owner, lessee or tenant, or any other
manner occupying the same, shall remove from and
vacate such building or premises, then it shall be the
duty of such person so vacating or removing from such
building or premises to immediately remove
therefrom all loose paper, garbage, filth, rubbish and
waste matter of every kind and character and to
place the building so vacated and the premises
adjacent thereto or used in connection therewith in a
clean and sanitary condition. (Code 1941, Art. 87-8)
SEC. 19-17.
UNWHOLESOME PREMISES GENERALLY.
No person shall suffer or permit any cellar,

vault, drain, pool, privy, sewer, yard, grounds or
premises belonging to or controlled or occupied by him
to become, from any cause, nauseous, foul, offensive or .
injurious to the public health, or unpleasant and
disagreeable to adjacent residents or persons. (Code
1941, Art 86-17)
Dallas City Code

4/10
SUBCHAPTER 3
PERMITS AND INSPECTIONS
SECTION 301
PERMITS
301.1 Permits required.
301.1.1 General. A person, fIrm, or corporation shall not, without first obtaining a permit
from the building official:
1. erect, construct, enlarge, add to, alter, repair, replace, move, improve, remove, install,
convert, demolish, equip, use, occupy, or maintain a structure or building service
equipment;
2. excavate or maintain an excavation;
3. pave or grade on a property; or
4. cause any work or activity described in Paragraphs 1 through 3 of this section to be
done. (Ord.26029)
301.1.2 Barricade permit require;l. No building construction or demolition activity,
including but not limited to equipment usage, deliveries, on and off loading of materials and
storage of materials, supplies, or debris, shall be done on public property or within a public
way, except as authorized by a barricade permit issued by the building official. A barricade
permit is also required for any temporary or part-day blocking of a street or sidewalk. The
issuance of a barricade permit requires the repair or replacement of any public street, curb,
sidewalk, drainage structure, or boulevard landscaping located within the barricaded area, or
otherwise damaged during construction or demolition, to equal or better condition than that
prior to the start of construction or demolition activities. (Ord. 26029)
301.1.3 Proper permits. The owner, agent, or lessee of a structure has the duty to ensure
that permits are obtained by properly qualified persons before work is started, and the owner,
owner's agent, or lessee shall be subject to the penalties provided in this chapter for failure to
obtain a proper permit. (Ord. 26029)
301.1.4 Permit issued to another person, firm, or corporation. A person, firm, or
corporation shall not do work by authority of a pennit issued to another person, firm, or
corporation, except under direct supervision of the person, finn, or corporation to whom the
permit was issued. (Ord. 26029)
301.1.5 Obtaining a permit for another person, firm, or corporation. A person, firm, or
corporation shall not obtain a pennit for use by another person, firm, or corporation. (Ord.
26029)
Chapter 52, Administrative Procedures for the Construction Codes (current through 1/12/11) - Page 18
Anti-Litter Regulations
(c) It is a defense to prosecution under

Subsection (a) of this section that the notice, poster,
paper, or device was posted or affixed in a manner
and location authorized or required by another city
ordinance or by state or federal law. (Ord. Nos. 10371;
23632)
SEC.7A-17.
THROWING OR DEPOSITING
LI1TER ON PRIVATE PREMISES.
A person commits an offense if he throws or

deposits litter on any occupied private premises
w~th.in the city, whether owned by the person or not,
or in or on any gutter, parkway, sidewalk, or alley
adjacent to the private premises; except, that the
owner, occupant, or person in control of private
premises may maintain authorized private
receptacles for collection in such a manner that litter
will be prevented from being carried or deposited by
the elements upon any street, gutter, parkway,
sidewalk, alley, or other public place or upon any
private premises. (Ord. Nos. 10371; 20599)
SEC- 7A-18.
DUTY TO MAINTAIN PREMISES

FREE FROM UTTER.
An owner, occupant, or person in control of

private premises commits an offense if he places,
deposits, or throws; permits to accumulate; or permits
or causes to be placed, deposited, or thrown, any litter
on the premises or in or on any gutter or parkway
adjacent to the premises or on one-half of that portion
of an alley adjacent to the premises, unless the litter
has been deposited in an authorized private
receptacle for collection. (Ord. Nos. 10371; 13804;
20599)
SEC. 7A-19.
DEPOSITING LITTER ON
VACANT LOTS PROHIBITED.
A person commits an offense if he throws or

deposits litter on any open or vacant private property
within the city, whether owned by the person or not,
or in or on any gutter, parkway, sidewalk, or alley
adjacent to the private property. (Ord. Nos. 10371;
2059~)
SEC.7A19.1.
7A-19.1
ClTYREMOVALOFUTTER
FROM PRIVATE PREl\.fiSES;
NOTICE REQUl;RED.
(a) Upon the failure of the owner, occupant, or

person in control of private premises to comply with
Section 7A-18 of this chapter, the director shall
have the litter removed from the premises;
(b) Before having the litter removed, the
director ~ust notify the owner of the premises to bring
the premises into compliance with Section 7A-IS
within seven days. The notice must be in writing and
may be served by handing it to the owner in pe~on or
by sending it United States regular mail, addressed to
the owner at the owner's address as.recorded in the
appraisal district records of the appraisal district in
which the premises are located.
(c) If personal service to the owner cannot be

obtained, then the owner may be notified by:
(1) publication at least once in the
official newspaper adopted by the city council;
(2) posting the notice on or near the front
door of each building on the premises to which the
violation relates; or
(3) posting the notice on a placard
attached to a stake driven into the ground on the
premises to which th~ violation relates.
(d) If the director mails a notice to a property
owner in accordance with Subsection (b) and the
United States Postal Service returns the notice as
"refused" or "unclaimed," the validity of the notice
is not affected, and the notice is considered as
delivered.
(e) In a notice provided under this section. the
director may, by regular mail and by a posting on the
property, inform the owner of the property on which
the violation exists that, if the owner commits
another violation of the same kind or nature that
poses a danger to the public health and safety on or
before the first anniversary of the date of the notice,
the city may, without further notice, correct the
violation at the owner's expense and then assess the
expense against the property. If a violation covered
by a notice under this subsection occurs within the
Dallas City Code
31M
. .,.
40-2
Rat Control
offered for sale, on racks, stands, platforms and in

vehicles outside of business buildings, shall have
floors paved with concrete or asphalt for the entire
surface area of the market. Display racks, stands or
platforms on which fruit or vegetables or any other
food products are displayed or offered for sale shall
be of sufficient height that all such fruit, vegetables
or other food products shall be kept at a distance of
not less than 18 inches above the floor pavement and
be so constructed that rats cannot harbor therein or
thereunder. (Ord. 7847)
.
SEC. 40-3.
DUMPING, ETC., GARBAGE, ETC.,

ON LAND OR WATER.
by this chapter and that such materials were not

available, is guilty of an offense.
(b) An offense under this chapter is
punishable by a fine of not more than $2,000 and, upon
a first conviction of a violation of Section 40-4 of this
chapter, not less than $200.
(c) The minimum fine established in
Subsection (b) shall be doubled for the second
conviction of the same offense within any 24-month
period and trebled for the third and subsequent
convictions of the same offense within any 24-month
period. At no time shall the minimum fine exceed the
maximum fine established in Subsection (b).
(Ord. Nos. 7847; 19963; 20599)
It shall be unlawful for any person to dump or

place on any land or on any water or waterway
within the city any dead animal, butchers' offal,
seafood or any waste vegetables, animal matter or
any food products whatsoever.
No garbage, rubbish, waste or manure shall be

placed, left, dumped or permitted to accumulate or
remain in any building or premises in the city so that
same shall or may afford food for or a harboring or
breeding place for rats. Rat burrows and other
exterior harborage shall be treated under methods
directed by the director of public health. (Ord.7847)
SEC. 40-4.
ACCUMULATION OF LUMBER,
BOXES, ETC
It shall be unlawful for any person to permit

any premises, improved or unimproved, and all open
lots and alleys in the city, to accumulate lumber,
boxes, barrels, bricks or stones and similar materials
that may be permitted to remain thereon and that
may be used as a harborage by rats, unless same shall
be placed on open racks and elevated not less than 18
inches above the ground, with a clear intervening
space underneath, to prevent the harborage of rats.
(Ord.7847)
SEC. 40-5.
PENALTY.
(a) Any person who violates any provision of

this chapter, except where it is shown that the
person has endeavored to obtain the necessary
materials required to ratproof the buildings covered
ARTICLE II.
BUSINESS BUILDINGS.
SEC. 40-6.
CONSTRUCTION OF BUILDINGS
TO CONFORM TO CHAPTER.
It shall be unlawful for any person to construct

within the corporate limits of the city any business
building, curb or farmers' m<:lrket, unless such
construction shall render the business building
ratproof in accordance with the regulations
prescribed by this chapter. (Ord. 7847)
SEC. 40-7.
INSPECTIONS TO DETERMINE
RAT INFESTATION; ORDER TO
PROTECf AGAINST
INFESTATION.
The director of public health of the city, or his

representative, is authorized to make frequent and
unannounced inspections of existing business buildings
within the corporate limits of the city for the
purpose of determining any rat infestation, and order
by written notice either the owner, occupant, agent or
any other person in custody of any rat-infested
business building to protect such business building by
rat-stoppage as herein prOVided, regardless of the
need for the remodeling of or repairs to such business
buildings, and further order that such other rat
control methods be employed as may be deemed
necessary by the director of public health or his
Dallas City Code

2
40-7
BUILDING PLANNING
3.3. 3/s-inch (9.5 mm) particleboard;

304. 1/4-inch (6.4 mm) hardboard;
3.5. 3/s-inch (9.5 mm) gypsum board; or
3.6. Corrosion-resistant steel having a base metal
thickness of 0.016 inch (00406 mm).
The above ignition barrier is not required where the
foam plastic insulation has been tested in accordance with
Section R316.6.
R316.5.5 Foam-filled exterior doors. Foam-filled exterior doors are exempt from the requirements of Sections
R316.3 and R316.4.
R316.5.6 Foam-filled garage doors. Foam-filled garage
doors in attached or detached garages are exempt from the
requirements of Sections R316.3 and R31604.
R316.5.7 Foam backer board. The thermal barrier specified in Section R316.4 is not required where siding backer
board foam plastic insulation has a maximum thickness of
0.5 inch (12.7 mm) and a potential heat of not more than
2000 Btu per square foot (22 720 kJ/m2) when tested in
accordance with NFPA 259 provided that:
1. The foam plastic insulation is separated from the

interior of the building by not less than 2 inches (51
mm) of mineral fiber insulation;
2. The foam plastic insulation is installed over existing
exterior wall finish in conjunction with re-siding; or
3. The foam plastic insulation has been tested in accordance with Section R316.6.
R316.5.8 Re-siding. The thermal barrier specified in Section R316.4 is not required where the foam plastic insulation is installed over existing exterior wall finish in
conjunction with re-siding provided the foam plastic has a
maximum thickness of 0.5 inch (12.7 mm) and a potential
heat of not more than 2000 Btu per square foot (22 720 kJ/
m 2 ) when tested in accordance with NFPA 259.
R316.5.9 Interior trim. The thermal barrier specified in
Section R31604 is not required for exposed foam plastic
interior trim, provided all of the following are met:
1. The minimum density is 20 pounds per cubic foot

(320 kg/m3).
2. The maximum thickness of the trim is 0.5 inch (12.7
mm) and the maximum width is 8 inches (204 mm).
3. The interior trim shall not constitute more than 10
percent of the aggregate wall and ceiling area of any
room or space.
4. The flame spread index does not exceed 75 when

tested per ASTM E 84 or VL 723. The smoke-developed index is not limited.
R316.5.10 Interior finish. Foam plastics shall be permitted as interior finish where approved in accordance with
Section R316.6 Foam plastics that are used as interior finish shall also meet the flame spread index and smokedeveloped index requirements of Sections R302.9.1 and
R302.9.2.
2012 INTERNATIONAL RESIDENTIAL CODE(\)
R316.5.1l Sill plates and headers. Foam plastic shall be

permitted to be spray applied to a sill plate and header
without the thermal barrier specified in Section R316.4
subject to all of the following:
1. The maximum thickness of the foam plastic shall be

31/ 4 inches (83 mm).
2. The density of the foam plastic shall be in the range
of 0.5 to 2.0 pounds per cubic foot (8 to 32 kg/m 3).
3. The foam plastic shall have a flame spread index of
25 or less and an accompanying smoke-developed
index of 450 or less when tested in accordance with
ASTM E 84 or VL 723.
R316.5.12 Sheathing. Foam plastic insulation used as
sheathing shall comply with Section R316.3 and Section
R31604. Where the foam plastic sheathing is exposed to
the attic space at a gable or kneewall, the provisions of
Section R316.5.3 shall apply.
R316.5.13 Floors. The thermal barrier specified in Section R31604 is not required to be installed on the walking
surface of a structural floor system that contains foam
plastic insulation when the foam plastic is covered by a
minimum nominal 1/2-inch-thick (12.7 mm) wood structural panel or equivalent. The thermal barrier specified in
Section R31604 is required on the underside of the structural floor system that contains foam plastic insulation
when the underside of the structural floor system is
exposed to the interior of the building.
R316.6 Specific approval. Foam plastic not meeting the
requirements of Sections R316.3 through R316.5 shall be
specifically approved on the basis of one of the following
approved tests: NFPA 286 with the acceptance criteria of
Section R302.9.4, FM4880, VL 1040, or VL 1715, or fire
tests related to actual end-use configurations. Approval shall
be based on the actual end use configuration and shall be performed on the finished foam plastic assembly in the maximum thickness intended for use. Assemblies tested shall
include seams, joints and other typical details used in the
installation of the assembly and shall be tested in the manner
intended for use.
R316.7 Termite damage. The use of foam plastics in areas
of "very heavy" termite infestation probability shall be in
accordance with Section R318.4.
SECTION R317
PROTECTION OF WOOD AND WOOD BASED
PRODUCTS AGAINST DECAY
R317.1 Location required. Protection of wood and wood
based products from decay shall be provided in the following
locations by the use of naturally durable wood or wood that is
preservative-treated in accordance with AWPA VI for the
species, product, preservative and end use. Preservatives shall
be listed in Section 4 of AWPA VI.
1. Wood joists or the bottom of a wood structural floor
when closer than 18 inches (457 mm) or wood girders
when closer than 12 inches (305 mm) to the exposed
65
BUILDING PLANNING
ground in crawl spaces or unexcavated area located

within the periphery of the building foundation.
2. All wood framing members that rest on concrete or
masonry exterior foundation walls and are less than 8
inches (203 mm) from the exposed ground.
3. Sills and sleepers on a concrete or masonry slab that is
in direct contact with the ground unless separated from
such slab by an impervious moisture barrier.
4. The ends of wood girders entering exterior masonry or
concrete walls having clearances of less than 1/2 inch
(12.7 mm) on tops, sides and ends.
5. Wood siding, sheathing and wall framing on the exterior of a building having a clearance of less than 6
inches (152 mm) from the ground or less than 2 inches
(51 mm) measured vertically from concrete steps,
porch slabs, patio slabs, and similar horizontal surfaces
exposed to the weather.
6. Wood structural members supporting moisture-permeable floors or roofs that are exposed to the weather,
such as concrete or masonry slabs, unless separated
from such floors or roofs by an impervious moisture
barrier.
7. Wood furring strips or other wood framing members
attached directly to the interior of exterior masonry
walls or concrete walls below grade except where an
approved vapor retarder is applied between the wall
and the furring strips or framing members.
R317.1.1 Field treatment. Field-cut ends, notches and

drilled holes of preservative-treated wood shall be treated
in the field in accordance with AWPA M4.
R317.1.2 Ground contact. All wood in contact with the
ground, embedded in concrete in direct contact with the
ground or embedded in concrete exposed to the weather
that supports permanent structures intended for human
occupancy shall be approved pressure-preservative-treated
wood suitable for ground contact use, except untreated
wood may be used where entirely below groundwater
level or continuously submerged in fresh water.
R317.1.3 Geographical areas. In geographical areas
where experience has demonstrated a specific need,
approved naturally durable or pressure-preservativetreated wood shall be used for those portions of wood
members that form the structural supports of buildings,
balconies, porches or similar permanent building appurtenances when those members are exposed to the weather
without adequate protection from a roof, eave, overhang or
other covering that would prevent moisture or water accumulation on the surface or at joints between members.
Depending on local experience, such members may
include:
1. Horizontal members such as girders, joists and decking.
2. Vertical members such as posts, poles and columns.
3. Both horizontal and vertical members.
66
R317.1.4 Wood columns. Wood columns shall be

approved wood of natural decay resistance or approved
pressure-preservative-treated wood.
Exceptions:
1. Columns exposed to the weather or in basements
when supported by concrete piers or metal pedestals projecting 1 inch (25.4 mm) above a concrete
floor or 6 inches (152 mm) above exposed earth
and the earth is covered by an approved impervious moisture barrier.
2. Columns in enclosed crawl spaces or unexcavated areas located within the periphery of the
building when supported by a concrete pier or
metal pedestal at a height more than 8 inches
(203 mm) from exposed earth and the earth is
covered by an impervious moisture barrier.
R317.1.5 Exposed glued-laminated timbers. The portions of glued-laminated timbers that form the structural
supports of a building or other structure and are exposed to
weather and not properly protected by a roof, eave or similar covering shall be pressure treated with preservative, or
be manufactured from naturally durable or preservativetreated wood.
R317.2 Quality mark. Lumber and plywood required to be

pressure-preservative-treated in accordance with Section
R318.1 shall bear the quality mark of an approved inspection
agency that maintains continuing supervision, testing and
inspection over the quality of the product and that has been
approved by an accreditation body that complies with the
requirements of the American Lumber Standard Committee
treated wood program.
R317.2.1 Required information. The required quality
mark on each piece of pressure-preservative-treated lumber or plywood shall contain the following information:
1. Identification of the treating plant.
2. Type of preservative.
3. The minimum preservative retention.
4. End use for which the product was treated.
5. Standard to which the product was treated.
6. Identity of the approved inspection agency.
7. The designation "Dry," if applicable.
Exception: Quality marks on lumber less than 1 inch

(25.4 mm) nominal thickness, or lumber less than nominal 1 inch by 5 inches (25.4 mm by 127 mm) or 2
inches by 4 inches (51 mm by 102 mm) or lumber 36
inches (914 mm) or less in length shall be applied by
stamping the faces of exterior pieces or by end labeling
not less than 25 percent of the pieces of a bundled unit.
R317.3 Fasteners and connectors in contact with preservative-treated and fire-retardant-treated wood. Fasteners,
including nuts and washers, and connectors in contact with
preservative-treated wood and fire-retardant-treated wood
shall be in accordance with this section. The coating weights
for zinc-coated fasteners shall be in accordance with ASTM
A 153.
2012 INTERNATIONAL RESIDENTIAL CODE
Exhibit
Abatable Crime at Topletz Nuisance Properties
~tember
1, 2013 through October 29, 2015
2501 Bethurum Ave.
11 undercover Narcotics Drug Buys

2 Narcotics Search Warrants executed on the Property
2 arrests for the delivery, possession, manufacture, or use of controlled substances;
One incidence of murder.
Top1etz has owned this property for many years. It has been the subject of three previous SAFE cases in
2003,2006, and 2007. While owned by Topletz, at least 4.1 grams of cocaine, 5.4 grams of heroin, and
695.1 grams ofmarijuana have been seized at the property.
In addition, four (4) other individuals have been arrested for outstanding warrant at this location.
2705 Pennsylvania Ave.

4 Narcotics Search Warrants executed on the Property
3 arrests for the delivery, possession, manufacture, or use of controlled substances;
1 incidence of found drug report.
Tllis is currently a SAFE property. A letter was sent to Topletz Investments on January 6, 2015, notifying
it of Code violations on the Property. Upon execution of an October 2014 search warrant, DPD found the
home heavily barricaded in a configuration typical of a "trap" house, and seized 1.9 grams of cocaine
packaged individually for resale.
In addition, four (4) other individuals have been arrested for outstanding warrant at this location.
1203 Strickland St.

1 Narcotics Search Warrant executed on the Property
1arrest for the delivery, possession, manufacture, or use of controlled substances;
1incident of aggravated assault as described by Section 22.02 of the Texas Penal Code
Upon execution of the search warrant in August 2015, DPD found the residence heavily
barricaded with metal cage doors, metal bars on the windows, and barnyard and Jamaica style
barricades on the doors. Two surveillance cameras also monitored the front and rear of the
residence. As a result of the warrant, 69.5 grams of marijuana and 4.1 grams of cocaine were
recovered. This is currently a SAFE property. It was also a SAFE case in 2005, when 270
grams of marijuana were seized from the property.
EXHIBIT
2603 Modree Ave.

1 Narcotics Search WatTant executed on the Property
1 arrest for the delivery, possession, manufacture, or use of controlled substances
1 incidence of found drug repoli
Topletz has owned this property for many years. It has been a SAFE case in 2001,2004,2006, and 2015.
Under Topletz ownership, the following drugs have been seized from the property: 8.2 grams of
Alprazalam, 38.8 grams of cocaine, 1,266.09 grams of codeine, 2.8 grams of hydrocodone, 1,204.2 grams
of marijuana, and 2,544.55 grams of PCP.
3803 Octavia St.

1 Narcotics Search WatTant executed on the Property
1 atTest for the delivery, possession, manufacture, or use of controlled substances.
As a result of the July 2015 search watTant, 108 grams of marijuana were recovered, appearing to be
packaged for redistribution.
1231 Iowa Ave.

1 Narcotics Search WalTant executed on the Property
1 incident of found drug report.
As a result of the September 2015 search walTant, 16 grams of cocaine were recovered.
In addition, one (1) other individual atTested for outstanding walTants at the location
1304 Pennsvlvania Ave.
1 Narcotics Search Wammt executed on the Property

1 alTest for the delivery, possession, manufacture, or use of controlled substances
3 incidences of found drug reports
In April, 2015, during the execution of a search walTant, 92.6 grams of cocaine and 258.4 grams of
marijuana were seized from the house. The house was equipped 4 surveillance cameras with a live feed
in the living room. One person alTested in the course of the execution of the search walTant described the
house as a "stash house."
3737 Guaranty St.

2 Narcotics Search WalTant executed on the Property
4 an-ests for the delivery, possession, manufacture, or use of controlled substances

tan'est for unlawfully can-ying a weapon
As a result of the 2 search wan-ants executed in 2014, 4 guns, 3.9 grams of cocaine, and 6.5 grams of
marijuana were seized from the property. In addition, one (l) other individual an-ested for outstanding
wan-ants at the location
Other Recent Narcotics Warrants Executed at Topletz Rental Properties (Non-Defendants)
1209-1211 East 9th St.

3 arrests for the delivery, possession, manufacture, or use of controlled substances
In the course of the execution of the search warrant in October 2014, DPD found the residence heavily
barricaded with cages and equipped with surveillance cameras. .7 grams of cocaine were seized, with
suspicion that suspects were able to destroy a large amount of cocaine before DPD made entry. In
addition, three (3) other individual arrested for outstanding warrants at the location
2710 Dathe St.

In October 2014,33.1 grams of cocaine and a handgun were seized as a result of the narcotics
search warrant.
3703 Toronto St.

In a January, 2015 search warrant, 87.9 grams of codeine were seized. Because of the presence
of scales, packaging, and other paraphernalia that indicated a drug sales enterprise, DPD believes
that a drug sale enterprise was run out of the house, but that drugs may have been destroyed in a
crock pot filled with hot boiling oil while police were attempting to gain entry to the house.
2730 Swanson St.

During the execution of an August 2014 search warrant, DPD found the home equipped with 8
surveillance cameras throughout the exterior of the property. DPD seized 1.1 grams of cocaine and 8.5
grams of marijuana. The drugs were individually packaged for resale.
2942 Ramsev Ave.

Upon execution of the search warrant in October 2014, DPD found the home equipped with 4
surveillance cameras. A "buy room" was configured in the front of the house, which had a small sliding
opening accessing the adjacent living room. DPD seized 32.1 grams of cocaine, 84.7 grams of marijuana,
and 3.1 grams of alprazolam.
This property was a SAFE case in 1998 and 2004.
2447 Skylark Dr.

1 arrest for the delivery, possession, manufacture, or use of controlled substances.
As a result of the search warrant, 48.5 grams of marijuana, 1.2 grams of cocaine, and Hydrocodone
pills were recovered.
As a result of the June 2015 search warrant, 1.2 grams of cocaine, 6.7 grams of hydrocodone, and 48.5
grams of marijuana were seized.
In addition, one (1) other individual arrested for outstanding warrants at the location
620 Woodbine Ave.*

This property was a SAFE case in 2003 and 2013. While under Topletz's ownership and/or control,
101.7 grams of cocaine, 2.9 grams of ecstasy, 12.6 grams of heroin, 2,109.9 grams of marijuana, and 4
handguns have been seized from the property.
*Topletz has owned 620 Woodbine for many years, but recently "sold" it to a tenant, though Topletz
financed the sale and retained a lien on the Property. The property was in such poor condition that it was
referred to the Urban Rehabilitation Docket for possible demolition, and the City brought suit against the
property. In that lawsuit, the City's Inspector documented the demolition-worthy problems with the
structure on the property, but Topletz (specifically Lane Topletz) appeared to represent the property, and
made repairs to the Property (though some of the repairs required building permits, which Topletz failed
to procure).

City of Dallas Original Petition Seeking Reciever For Topletz Properties

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City of Dallas Original Petition Seeking Reciever For Topletz Properties

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FILED

Cause No. DC-15-13993

DENNIS TOPLETZ, INDIVIDUALLY,

AS HEIR OF HAROLD TOPLETZ AND

CASEY TOPLEZ, VICKIE TOPLETZ,

STEVEN TOPLETZ, MARVIN L. LEVIN,

CAPACITY AS THE EXECUTOR OF

THE ESTATE OF JACK TOPLETZ,

BETHURUM AVE., DALLAS, TEXAS,

in rem, 3737 GUARANTY ST.,

DALLAS, TEXAS, in rem, 1231 IOWA

AVE., DALLAS, TEXAS, in rem, 2603

MODREE AVE., DALLAS, TEXAS,

in rem, 3803 OCTAVIA ST., DALLAS,

TEXAS, in rem, 1304 PENNSYLVANIA

PENNSYLVANIA AVE., DALLAS,

TEXAS, in rem, 1203 STRICKLAND ST.,

IN THE DISTRICT COURT

DALLAS COUNTY, TEXAS

CITY OF DALLAS' ORIGINAL PETITION, APPLICATION FOR

TO THE HONORABLE JUDGE OF SAID COURT:

City of Dallas' Original Petition, Application for Temporary Injunction and

I. DISCOVERY CONTROL PLAN

Discovery is intended to be conducted under Level 2 of Rule 190 of the Texas

Rules of Civil Procedure.

Defendant Dennis Topletz is an individual Texas resident owning real property

Defendant Vicki Topletz is an heir of Harold Topletz and therefore an individual

Defendant Steven Topletz is an heir of Harold Topletz and therefore an individual

Defendant Marvin L. Levin is an individual owning real property that is the

City of Dallas' Original Petition, Application for Temporary Injunction and

Permanent Injunction and Application for Appointment of Receiver

Defendant Monarch Development Corporation is an inactive Texas Corporation

City of Dallas' Original Petition, Application for Temporary Injunction and

referred to as the "Defendant Properties."

referred to collectively as the "Topletz Properties."

and Remedies Code.

often crimeridden single-family rental property located primarily in South Dallas.

In violation of a landlord's duties under Texas Property Code section 92.006(c),

City of Dallas' Original Petition, Application for Temporary Injunction and

Notwithstanding a lack of complaints or cooperation from the Topletz

Specifically, an itemized list of the code violations found at the Defendant

The ordinances contained in Exhibit 4 relate to:

City of Dallas' Original Petition, Application for Temporary Injunction and

The conditions described in Exhibit 4 pose a substantial risk of injury or adverse

exist on some or all of the Topletz Properties.

City of Dallas' Original Petition, Application for Temporary Injunction and

The Topletz Defendants maintain the Defendant Properties as places to which

The Topletz Defendants maintain a common nuisance at the Defendant Properties

The City re-alleges paragraphs 1- 43 as if fully set forth herein.

The City requests a temporary injunction, and permanent injunction pursuant to

Permanent Injunction and Application for Appointment of Receiver

Additionally, if final judgment be in favor of the City, such judgment would be a

Texas Local Government Code

The City re-alleges paragraphs 1-48 as if fully set forth herein.

These causes of action arise under Subchapter B of Chapter 54 and Subchapter A

of Chapter 211 of the Texas Local Government Code.

Permanent Injunction and Application for Appointment of Receiver

ordering Defendants to comply with Dallas City Code.

The City seeks a judgment against Defendants.

law and taxable costs of court.

Because of the Topletz Defendant's ongoing and repeated mismanagement of the

Topletz Properties through placement of tenants in substandard conditions, the intimidation of

City of Dallas v. Dennis Topietz, et ai,