VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF LYNCHBURG Austin, Shy-Lyn Plaintiff, y AHF-JAMES CROSSING ACQUISITION, Case No, CL2000899 P, Defendant, AGREED ORDER “The Plaintiff and the Defendant in the above captioned case have reached an agreement to resolve matter set for a Preliminary Injunction heating before this Court on September 25, 2020 at 2:30 p.tn. This Agreed Order applies to the property 1c ‘ed 1 TE Ly2chiurg, VA 24501. Upon the agreement of each named Plaintiff and Defendant, pursuant to Virginia Code 55.1-1259, and i appeating appropriate to do so, itis hereby ORDERED AND DECREED that: 1) Defendant shall provide Plaintiff with a compatable hotel room with the following minimam amenities: two beds, reftigerator, microwave, and kitchenette. Defendant shall pay for the cost of the hotel soonss and shall ensure the hotel rooms ate available until all repairs in this order have been completed, Defendant shall secure the hotel room for Plaintiff as soon 2s possible, but with a chech- in no later than September 29, 2020. 2) Defendant shall hire « licensed professional to develop a mold remediation plan, which is to beshared with the patties. 3) Defendant shall hire a licensed professional to remediate in all visual mold in accordance with ‘Virginia law, “Visual Surface Mold” includes the items identified in Attachment A, as well as any other visual mold the Defendant's professional identifies on inspection. Defendant shall provide a report to Plaintif?’s counsel of the remediation steps taken in cach apastment. 4) Defendant shall xeplace the bathroom vanities PlaintifP's apartment. 5) Defendant shail have a licensed professional clean and remediate the mold, dist, debris, and other damage to each HVAC unit, 6) Defendant shall have a licensed professional perform post-semediation testing and provide the results to the Plaintiff through counsel 7) Defendant shall provide Plaintiff, through counsel, a copy of all maintenance records and reports for Plaintiff's apartment. Records and reports from April 2019 forwatd shall be provided no later than 4:00 p.m. on September 29, 2020. 8) Defendant shall provide PlaintifPs counsel access to Plaintif?’s tenant record on a date a time agreeable by the parties, but not later than October 2, 2020 at 3:00 p.m. 9) Defendant shall provide Plaintiff, through counsel, a current account ledger no later than 4:00 p.m. on September 29, 2020. 10) This case remains on the docket of this Court for resolution of the remaining items in dispute between the patties. ‘The clerk is hereby ORDERED to provide certified copies of this order to the parties. Entered this__ day of, » 2020. JUDGEATTACHMENT A VISIBLE SURFACE MOLD Room Location as ‘Amount Kitchen Base of sink cabinet Scattered Kickplate Scattered Bottom edge of sink cabinet Al HVAC Coils All Bathroom 4 Side 0 % round All ‘Woll Cextending out fom B/C comer 2x2 | 17-224 throm 2 Base of vanity, ‘Seatigred Hot water heateHVAC | Condensate pice. Scattered Lower 4” wall B All 6x4" upper wall B in BIC comer Baseboard & Lower 4” wall A ScaiteredVsB No. 93071 Virginia Legal Aid Society, Inc. PO Box 6200 513 Church Street Lynchburg, VA 24505 434.846.1326 Tel. 434.846.3826 Fax lydiat@vlas.org Counsel for Plaintiff Seen and agreed: SITION, LP. By: Bryan Grimes Creasy, Esquire Johnson, Ayers & Matthews P.O. Box 2200 Roanoke, VA 24009 540-767-2039 Counsel for DefendantVIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF LYNCHBURG Hubbard, Dominique Plaine, AHF-JAMES CROSSING ACQUISITION, Case No. CL2000900 LP, Defendant AGREED ORDER ‘The Plaintiff and the Defendant in the above captioned case have reached an agreement to resolve matter set for a Preliminary Injunction hearing before this Court on September 25, 2020 at 2:30 pan. This “Agreed Order applies to the property located (| TIE Jy:chburg, VA 24501. Upon the agreement of each named Plaintiff and Defendant, pursuant to Virginia Code 55.1-1259, and it appeating appropriate to do so, itis heteby ORDERED AND DECREED that: 1) Defendant shall provide Plaintiff with a comparable hotel room with the following minimum amenities: two beds, refrigerator, microwave, and kitchenette, Defendant shell pay for the cost of the hotel s0oms and shall ensuze the hotel coms ate available until all repaiss in this oxder have been ‘completed. Defendant shall secure the hotel room for Plaintiff as soon as possible, but with a check- in no later than September 29, 2020. 2) Defendant shall hire 2 licensed professional to develop a mold remediation plan, which is to beshared with the parties. 3) Defendant shall bite « licensed professional to remediate in all visual mold in accordance with ‘Visginia law. “Visual Surface Mold” includes the items identified in Attachment A, as well as any other visual mold the Defendant's professional identifies on inspection. Defendant shall provide a report to Plaintiff's counsel of the remediation steps taken in each apartment. 4) Defendant shall replace the bathzoom vanities Plaintif?’s apartment, 5) Defendant shall have a licensed professional clean and remediate the mold, dirt, debris, and other damage to each HVAC unit. 6) Defendant shall have a licensed professional perform post-remediation testing and provide the results to the Plaintiff through counsel. 7) Defendant shall provide Plaintiff, through counsel, a copy of all maintenance records and reports for Plaintiffs apartment. Records and reports ftom Apsil 2019 forward shall be provided no later than 4:00 p.m. on September 29, 2020. 8) Defendant shall provide Plaintiff's counsel access to Plaintifs tenant record on a date a time agreeable by the parties, but not later than October 2, 2020 at 3:00 pan. 9) Defendant shall provide Plaintiff, through counsel, a cutrent account ledge: no later than 4:00 pan, on September 29, 2020, 10) This case remains on the docket of this Court for resolution of the remaining items in dispute between the patties. ‘The cletk is hereby ORDERE! to provide certified copies of this order to the parties. Entered this day of. 2020, JUDGEATTACHMENT A ___VISIBLE SURFACE MOLD 2 Location ‘Amount (| On metal HVAC ui Scattered Wall D at edge of d 1x6 ‘Condensation pipe Scattered | Hall closet te anel covering plumbing _[ Scattered fall B ‘Wail 0 Baseboard side D Baseboard side C ‘Wail stud inside access f vanity cabinet | Seattered | Bathroom 7 “Paper at ba oo | Drywail in back side of vanity cabinet | Lower 6" Bathroom 2 i ze Lower 6” fk Soaltered (C return In hall ScatteredWe ask for this: Lydld E. Tuenier, Esquire VSB No. 93071 Virginia Legal Aid Society, Inc. PO Box 6200 513 Church Street Lynchburg, VA 24505 434.846.1326 Tel. 434.846.3826 Fax lydiat@vlas.org Counsel for Plaintiff Seen and agreed: “ACQUISITION, LP. By: Bryan Grimes @éasy, Esquire Johnson, Ayers & Matthews P.O. Box 2200 Roanoke, VA 24009 540-767-2039 Counsel for Defendant