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Building SafetyHousing Conditions

941 HOE AVENUE

Bronx · ZIP 10459 · BIN 2113354 · Longwood · Last violation Jul 29, 2026 · Last complaint Jul 31, 2026

NeighborhoodLongwood
More violations than 84% of nearby buildings
More violations than 84% of buildings and more complaints than 78% of buildings in Longwood. Size-normalized against residential buildings in the neighborhood for issues in the last 10 years.
ViolationsComplaints
Activity TrendsLast 5 years
More activity recently than in past years
Last 2 yrs: 987 violations · 459 complaints
'21'26ViolationsComplaints
▼ View all activity over time
Severityⓘopen violations
150 immediately hazardous (Class C) violations still open
Class C violations include lead paint, mold, pest infestations, heat/hot water failure, and structural hazards — the most serious category.
Class Cimmediately hazardous150Class Bhazardous386
Housing Preservation & Development Violations
Total violations since 2008
1,820
96 per year avg.↑ Up 194% in the last 2 years (987 vs 336 prior 2 yrs)
Open violations
602
Class C (immed. haz.)ⓘ150
Class B (hazardous)ⓘ386
Rent-impairingⓘ36
Housing Preservation & Development Complaints
Total complaints since 2007
1,716
86 per year avg.↑ Up 92% in the last 2 years (459 vs 239 prior 2 yrs)
Complaint Resolution
No access19%Violation issued22%No violation42%Phone resolved16%Other1%(1,716)
Urgency breakdown
Last 12 mo.

Top violation categories

5 yrsAll time
Maintenanceⓘ551 violations
Egressⓘ227 violations
Extermination & Rodent Eradicationⓘ173 violations
Water Supplyⓘ133 violations
Cleaningⓘ85 violations
Carbon Monoxide Detecting Devicesⓘ81 violations
Smoke Detecting Devicesⓘ71 violations
Paintingⓘ40 violations
Top complaint groupsⓘ
5 yrsAll time
Water & plumbingⓘ221 complaints
Mold & pestsⓘ176 complaints
Bldg maintenanceⓘ118 complaints
Heat / hot waterⓘ88 complaints
Electricalⓘ61 complaints
Appliancesⓘ29 complaints
Safety & fireⓘ20 complaints
See violations →Hide complaints ↑

Complaint log

1,716 complaints

All categoriesUNSANITARY CONDITIONPAINT/PLASTERPLUMBINGWATER LEAKHEAT/HOT WATERAllOpenClosed
Type
See something wrong? File a complaint with 311
Open violation ages
▪ < 30 days5% (32)
▪ 30–90 days18% (110)
▪ 3–12 months34% (207)
▪ 1–3 years40% (243)
▪ 3+ years2% (10)
Prior 4 yr.
Immed. Emergency3%4%
Emergency51%51%
Non-Emergency46%45%
(314)
(491)
Status
Apt
Received
Category
Non-emergencyClosed1BAug 13, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed1BAug 13, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed1BAug 13, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosed5GAug 10, 2021DOOR/WINDOW · DOORThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed5GAug 10, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed1BAug 2, 2021ELECTRIC · OUTLET/SWITCHThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed3SJul 21, 2021GENERAL · VENTILATION SYSTEMThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed1BJul 13, 2021GENERAL · CABINETThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed1BJul 13, 2021PAINT/PLASTER · WALLThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed1BJul 13, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed1BJul 13, 2021ELECTRIC · OUTLET/SWITCHThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed1BJul 13, 2021PAINT/PLASTER · WALLThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed3HJul 12, 2021PLUMBING · BATHTUB/SHOWERThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed3HJul 12, 2021ELECTRIC · OUTLET/SWITCHThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed3HJul 12, 2021WATER LEAK · SLOW LEAKThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed3HJul 12, 2021DOOR/WINDOW · DOORThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed3HJul 12, 2021DOOR/WINDOW · WINDOW FRAMEThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed3HJul 12, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed3HJul 12, 2021PAINT/PLASTER · WINDOW/FRAMEThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed3HJul 12, 2021PAINT/PLASTER · CEILINGThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed7IJun 30, 2021PAINT/PLASTER · WALLThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed7IJun 30, 2021APPLIANCE · REFRIGERATORThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed3EJun 24, 2021GENERAL · CABINETThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosed1BJun 3, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed1BJun 3, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed1BJun 3, 2021PAINT/PLASTER · CEILINGThe Department of Housing Preservation and Development inspected the following conditions. Violations were previously issued for these conditions. Information about specific violations is available at www.nyc.gov/hpd.
Non-emergencyClosed1BJun 3, 2021PAINT/PLASTER · WALLThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed1BJun 3, 2021ELECTRIC · OUTLET/SWITCHThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosed1BJun 3, 2021DOOR/WINDOW · DOORThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed1BJun 3, 2021PAINT/PLASTER · CABINETThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosed1BJun 3, 2021UNSANITARY CONDITION · MOLDThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed2QJun 2, 2021WATER LEAK · HEAVY FLOWThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed2QJun 2, 2021DOOR/WINDOW · DOORThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed2QJun 2, 2021ELECTRIC · LIGHTINGThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosedQMay 18, 2021PAINT/PLASTER · WALLThe Department of Housing Preservation and Development contacted an occupant of the apartment and verified that the following conditions were corrected. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosedQMay 18, 2021DOOR/WINDOW · DOORThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosedQMay 18, 2021PLUMBING · BASIN/SINKThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosedQMay 18, 2021PLUMBING · BASIN/SINKThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed2QApr 6, 2021DOOR/WINDOW · DOORThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed2QApr 6, 2021PLUMBING · BASIN/SINKThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed2QApr 6, 2021PLUMBING · BASIN/SINKThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed5NMar 23, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed5NMar 23, 2021UNSANITARY CONDITION · MOLDThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed5NMar 23, 2021UNSANITARY CONDITION · PESTSThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed5NMar 23, 2021PAINT/PLASTER · CEILINGThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed5NMar 23, 2021GENERAL · VENTILATION SYSTEMThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed5NMar 23, 2021PLUMBING · TOILETThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed5NMar 23, 2021FLOORING/STAIRS · FLOORThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed5NMar 23, 2021PAINT/PLASTER · WALLThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed5NMar 23, 2021DOOR/WINDOW · DOOR FRAMEThe Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Aug 13, 2021Apt 1B
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed
Aug 13, 2021Apt 1B
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Aug 13, 2021Apt 1B
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosed
Aug 10, 2021Apt 5G
DOOR/WINDOW · DOOR
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed
Aug 10, 2021Apt 5G
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed
Aug 2, 2021Apt 1B
ELECTRIC · OUTLET/SWITCH
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jul 21, 2021Apt 3S
GENERAL · VENTILATION SYSTEM
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jul 13, 2021Apt 1B
GENERAL · CABINET
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jul 13, 2021Apt 1B
PAINT/PLASTER · WALL
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jul 13, 2021Apt 1B
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jul 13, 2021Apt 1B
ELECTRIC · OUTLET/SWITCH
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jul 13, 2021Apt 1B
PAINT/PLASTER · WALL
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jul 12, 2021Apt 3H
PLUMBING · BATHTUB/SHOWER
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Jul 12, 2021Apt 3H
ELECTRIC · OUTLET/SWITCH
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Jul 12, 2021Apt 3H
WATER LEAK · SLOW LEAK
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
Jul 12, 2021Apt 3H
DOOR/WINDOW · DOOR
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
Jul 12, 2021Apt 3H
DOOR/WINDOW · WINDOW FRAME
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Jul 12, 2021Apt 3H
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Jul 12, 2021Apt 3H
PAINT/PLASTER · WINDOW/FRAME
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
Jul 12, 2021Apt 3H
PAINT/PLASTER · CEILING
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Jun 30, 2021Apt 7I
PAINT/PLASTER · WALL
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed
Jun 30, 2021Apt 7I
APPLIANCE · REFRIGERATOR
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jun 24, 2021Apt 3E
GENERAL · CABINET
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosed
Jun 3, 2021Apt 1B
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Jun 3, 2021Apt 1B
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed
Jun 3, 2021Apt 1B
PAINT/PLASTER · CEILING
The Department of Housing Preservation and Development inspected the following conditions. Violations were previously issued for these conditions. Information about specific violations is available at www.nyc.gov/hpd.
Non-emergencyClosed
Jun 3, 2021Apt 1B
PAINT/PLASTER · WALL
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed
Jun 3, 2021Apt 1B
ELECTRIC · OUTLET/SWITCH
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosed
Jun 3, 2021Apt 1B
DOOR/WINDOW · DOOR
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jun 3, 2021Apt 1B
PAINT/PLASTER · CABINET
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosed
Jun 3, 2021Apt 1B
UNSANITARY CONDITION · MOLD
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Jun 2, 2021Apt 2Q
WATER LEAK · HEAVY FLOW
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Jun 2, 2021Apt 2Q
DOOR/WINDOW · DOOR
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jun 2, 2021Apt 2Q
ELECTRIC · LIGHTING
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
May 18, 2021Apt Q
PAINT/PLASTER · WALL
The Department of Housing Preservation and Development contacted an occupant of the apartment and verified that the following conditions were corrected. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
May 18, 2021Apt Q
DOOR/WINDOW · DOOR
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
May 18, 2021Apt Q
PLUMBING · BASIN/SINK
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
May 18, 2021Apt Q
PLUMBING · BASIN/SINK
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
Apr 6, 2021Apt 2Q
DOOR/WINDOW · DOOR
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Apr 6, 2021Apt 2Q
PLUMBING · BASIN/SINK
The Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
Non-emergencyClosed
Apr 6, 2021Apt 2Q
PLUMBING · BASIN/SINK
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Mar 23, 2021Apt 5N
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
Mar 23, 2021Apt 5N
UNSANITARY CONDITION · MOLD
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Mar 23, 2021Apt 5N
UNSANITARY CONDITION · PESTS
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Mar 23, 2021Apt 5N
PAINT/PLASTER · CEILING
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Mar 23, 2021Apt 5N
GENERAL · VENTILATION SYSTEM
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
Mar 23, 2021Apt 5N
PLUMBING · TOILET
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Mar 23, 2021Apt 5N
FLOORING/STAIRS · FLOOR
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Mar 23, 2021Apt 5N
PAINT/PLASTER · WALL
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
Non-emergencyClosed
Mar 23, 2021Apt 5N
DOOR/WINDOW · DOOR FRAME
The Department of Housing Preservation and Development was not able to gain access to inspect the following conditions. The complaint has been closed. If the condition still exists, please file a new complaint.
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