CHRISTOPHER M. CORRIGAN, ESQ.

,
26220 HILLIARD BOULEVARD
WESTLAKE, OHIO 44145
Phone (440) 385-7616
Facsimile (440) 210-6515
cmcorrigan73@sbcglobal.net
November 29, 2016

Derick Waller
NewsChannel 5 Cleveland
3001 Euclid Avenue
Cleveland, Ohio 44115
Re:

Lake Shore Tower Apartments

Policies Concerning Bed Bug Prevention and Eradication

Dear Mr. Waller:

I am in receipt of your email of 12:15 pm and do not have time to meet with you before
your 4 p.m. deadline today. However, please accept the following information as to the
litigation.
Since it became apparent that Ohio was experiencing outbreaks of bed bugs, Lakeshore
Associates has invested time and resources into studying the best ways to prevent
infestations and, in cases of infestations, how to eradicate such problems. Unfortunately,
this pest is very difficult to eliminate once it has established a foothold in a premises and
often requires a series of procedures to wipe out the problem. To this end, Lakeshore
Associates, with the help of extermination professionals, has developed an integrated pest
management plan which includes policies that require inspection of certain property
being brought in by tenants and regular inspections of each individual unit.
In establishing its policies, Lakeshore Associates has complied with the Department of
Housing and Urban Development and its notices, especially HUD Notice H 2012-5. As
well, its management has on-going communications with HUD concerning its policy and
methods of prevention and eradication. The bed bug policy used at Lake Shore Tower
Apartments has been reviewed and approved by the United States Department of Housing
and Urban Development. In developing its policy, Lakeshore Associates has also made
sure that its policy and procedures comply with the Ohio Landlord Tenant law and local
ordinances.
Our staff works in the building and there is no pervasive infestation of the building.
Whenever Lakeshore Associates learns of any potential pest encroachment, an
investigation is immediately performed into the type of pest and potential infestation. A
professional exterminator is consulted for the purposes of eradication as well as the

source of the encroachment. Steps for eradication are immediately taken when
circumstances require such measures and preventive measures taken to prevent similar
encroachments. There are regularly scheduled inspections of the building by trained
exterminators each month and Lakeshore Associates policies make sure that every
portion of the building is inspected at least four times a year.
Since each instance is different, any occasion of a problem is handled on a case by case
basis. Lakeshore Associates obtains as much information from as many different sources
as possible to learn about the source and the extent of each intrusion. Pursuant to HUD
regulations and Chapter 5321 of the Ohio Revised Code, if it is determined that an
individual tenant is responsible for having caused an infestation, Lakeshore Associates
holds that tenant responsible for the damage incurred. Making sure that a responsible
party is held accountable only insures that the policies set up Lakeshore Associates for
the prevention of infestations are stringently followed.
The litigation that has been filed seeks to stop the property owners and managers from
enforcing their bed bug policy and attempts to force the management to weaken the
policy. A few tenants are upset that they have been held accountable for violating the
policy.
As to your request about the counterclaim, those tenants who have joined the suit
individually agreed to resolutions for responsibility for causing bed bugs to access their
unit. As such, there was a resolution that was supposed to prevent litigation and the
agreements attached to the counterclaim show there was a resolution of the issue of bed
bugs in their unit yet these tenants have decided to breach their agreement and file suit.
Further, the counterclaim asks the court to declare that the policy of Lakeshore
Associates fully complies with the law as the United States Department of Housing and
Urban Development has already determined.
Lakeshore Associates understands the issues faced by its tenants and has always sought
reasonable resolutions for individual problems. Yet for the safety and peaceful
enjoyment of all the residents at Lake Shore Tower Apartments, the procedures were
developed to prevent bed bugs and all pests from encroachment into the building have to
be enforced. The evidence establishes that the vast majority of residents at Lake Shore
Tower Apartments support the measures that Lakeshore Associates has taken to keep the
premises clean and pest free.
If you would like to discuss this matter further, please do not hesitate to contact the
undersigned.
Sincerely yours,
/s/ Christopher M. Corrigan
Christopher M. Corrigan