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75 LENOX ROAD

Brooklyn · ZIP 11226 · BIN 3116211 · Flatbush · Last violation Jul 28, 2026 · Last complaint Jul 26, 2026

NeighborhoodFlatbush
More violations than 99% of nearby buildings
More violations than 99% of buildings and more complaints than 96% of buildings in Flatbush. Size-normalized against residential buildings in the neighborhood for issues in the last 10 years.
ViolationsComplaints
Activity TrendsLast 5 years
A steady level of activity over time
Last 2 yrs: 960 violations · 374 complaints
'21'26ViolationsComplaints
▼ View all activity over time
Severityⓘopen violations
109 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 hazardous109Class Bhazardous197
Housing Preservation & Development Violations
Total violations since 1990
3,359
91 per year avg.↑ Up 125% in the last 2 years (960 vs 427 prior 2 yrs)
Open violations
355
Class C (immed. haz.)ⓘ109
Class B (hazardous)ⓘ197
Rent-impairingⓘ12
Housing Preservation & Development Complaints
Total complaints since 2003
2,055
86 per year avg.↑ Up 78% in the last 2 years (374 vs 210 prior 2 yrs)
Complaint Resolution
No access23%Violation issued35%No violation35%Phone resolved7%Other0%(2,055)
Urgency breakdown
Last 12 mo.

Top violation categories

5 yrsAll time
Maintenanceⓘ667 violations
Extermination & Rodent Eradicationⓘ156 violations
Paintingⓘ154 violations
Water Supplyⓘ146 violations
Egressⓘ126 violations
Cleaningⓘ81 violations
Carbon Monoxide Detecting Devicesⓘ64 violations
Smoke Detecting Devicesⓘ63 violations
Top complaint groupsⓘ
5 yrsAll time
Water & plumbingⓘ166 complaints
Bldg maintenanceⓘ166 complaints
Mold & pestsⓘ144 complaints
Heat / hot waterⓘ54 complaints
Appliancesⓘ47 complaints
Electricalⓘ40 complaints
Safety & fireⓘ16 complaints
Adminⓘ1 complaints
See violations →Hide complaints ↑

Complaint log

2,055 complaints

All categoriesPAINT/PLASTERPLUMBINGUNSANITARY CONDITIONGENERALDOOR/WINDOWAllOpenClosed
Type
See something wrong? File a complaint with 311
Open violation ages
▪ < 30 days7% (25)
▪ 30–90 days32% (114)
▪ 3–12 months41% (144)
▪ 1–3 years10% (34)
▪ 3+ years11% (38)
Prior 4 yr.
Immed. Emergency5%3%
Emergency44%38%
Non-Emergency52%59%
(225)
(530)
Status
Apt
Received
Category
Non-emergencyClosedG5Apr 4, 2005PAINT/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-emergencyClosedG5Apr 4, 2005APPLIANCE · REFRIGERATORThe 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.
EmergencyClosedG5Apr 4, 2005PLUMBING · 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.
Non-emergencyClosedG5Apr 4, 2005PAINT/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-emergencyClosedG5Apr 4, 2005PAINT/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.
EmergencyClosedG5Apr 4, 2005GENERAL · DOORSThe 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.
EmergencyClosedK5Mar 15, 2005PLUMBING · WATER SUPPLYThe 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.
EmergencyClosedK5Mar 15, 2005PAINT/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.
EmergencyClosedM1Feb 28, 2005PAINT/PLASTER · CEILINGThe 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-emergencyClosedM1Feb 28, 2005PAINT/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
EmergencyClosedM1Feb 28, 2005PAINT/PLASTER · CEILINGThe 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-emergencyClosedM1Feb 28, 2005PAINT/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
EmergencyClosedD1Jan 24, 2005PLUMBING · WATER-LEAKSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosedJ2Jan 18, 2005APPLIANCE · ELECTRIC/GAS RANGEThe 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.
EmergencyClosedD1Jan 14, 2005PLUMBING · WATER-LEAKSThe 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.
EmergencyClosedM2Jan 8, 2005HEATING · HEAT RELATEDThe 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.
EmergencyClosedM2Jan 8, 2005PAINT/PLASTER · CEILINGThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedM2Jan 8, 2005GENERAL · DOORSThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosedM2Jan 8, 2005APPLIANCE · REFRIGERATORThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedM2Jan 8, 2005APPLIANCE · ELECTRIC/GAS RANGEThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosedM2Jan 8, 2005PLUMBING · WATER SUPPLYThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosedM2Jan 8, 2005PLUMBING · WATER SUPPLYThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedF4Dec 16, 2004APPLIANCE · ELECTRIC/GAS RANGEThe 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.
Non-emergencyClosedF4Dec 16, 2004APPLIANCE · REFRIGERATORThe 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.
Non-emergencyClosedF4Dec 14, 2004APPLIANCE · ELECTRIC/GAS RANGEThe 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.
Non-emergencyClosedF4Dec 14, 2004APPLIANCE · REFRIGERATORThe 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.
EmergencyClosedD1Dec 12, 2004PLUMBING · WATER-LEAKSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedD7Nov 17, 2004GENERAL · CERAMIC-TILEThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedD7Nov 17, 2004GENERAL · MOLDThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosedD7Nov 17, 2004PLUMBING · BATHTUB/SHOWERThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosedD7Nov 17, 2004PLUMBING · BATHTUB/SHOWERThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosedL1Nov 5, 2004GENERAL · CABINETThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosedL1Nov 5, 2004APPLIANCE · REFRIGERATORThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedL1Nov 5, 2004PLUMBING · WATER-LEAKSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedL1Nov 5, 2004GENERAL · DOORSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosedL1Nov 5, 2004APPLIANCE · ELECTRIC/GAS RANGEThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedL1Nov 5, 2004GENERAL · WINDOWSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosedL1Nov 5, 2004PAINT/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
EmergencyClosedL1Nov 5, 2004GENERAL · DOORSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedL1Nov 5, 2004PLUMBING · TOILETThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosedD1Sep 30, 2004PLUMBING · WATER-LEAKSThe 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.
EmergencyClosedD1Sep 17, 2004PLUMBING · WATER-LEAKSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedD1Sep 3, 2004PLUMBING · WATER-LEAKSThe 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.
EmergencyClosedD 1Aug 14, 2004PLUMBING · WATER-LEAKSThe 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.
EmergencyClosedG2Aug 4, 2004PLUMBING · WATER-LEAKSThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosedG2Aug 4, 2004PAINT/PLASTER · CEILINGThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosedG2Aug 2, 2004PLUMBING · WATER-LEAKSThe 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.
EmergencyClosedG2Aug 2, 2004GENERAL · MOLDThe 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.
EmergencyClosedG2Aug 2, 2004PLUMBING · WATER-LEAKSThe 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.
EmergencyClosedG2Aug 2, 2004GENERAL · MOLDThe 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.
Non-emergencyClosed
Apr 4, 2005Apt G5
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
Apr 4, 2005Apt G5
APPLIANCE · REFRIGERATOR
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
Apr 4, 2005Apt G5
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.
Non-emergencyClosed
Apr 4, 2005Apt G5
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
Apr 4, 2005Apt G5
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.
EmergencyClosed
Apr 4, 2005Apt G5
GENERAL · DOORS
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 15, 2005Apt K5
PLUMBING · WATER SUPPLY
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 15, 2005Apt K5
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.
EmergencyClosed
Feb 28, 2005Apt M1
PAINT/PLASTER · CEILING
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
Feb 28, 2005Apt M1
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
EmergencyClosed
Feb 28, 2005Apt M1
PAINT/PLASTER · CEILING
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
Feb 28, 2005Apt M1
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
EmergencyClosed
Jan 24, 2005Apt D1
PLUMBING · WATER-LEAKS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jan 18, 2005Apt J2
APPLIANCE · ELECTRIC/GAS RANGE
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
Jan 14, 2005Apt D1
PLUMBING · WATER-LEAKS
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
Jan 8, 2005Apt M2
HEATING · HEAT RELATED
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
Jan 8, 2005Apt M2
PAINT/PLASTER · CEILING
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Jan 8, 2005Apt M2
GENERAL · DOORS
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
Jan 8, 2005Apt M2
APPLIANCE · REFRIGERATOR
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Jan 8, 2005Apt M2
APPLIANCE · ELECTRIC/GAS RANGE
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jan 8, 2005Apt M2
PLUMBING · WATER SUPPLY
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Jan 8, 2005Apt M2
PLUMBING · WATER SUPPLY
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Dec 16, 2004Apt F4
APPLIANCE · ELECTRIC/GAS RANGE
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.
Non-emergencyClosed
Dec 16, 2004Apt F4
APPLIANCE · REFRIGERATOR
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.
Non-emergencyClosed
Dec 14, 2004Apt F4
APPLIANCE · ELECTRIC/GAS RANGE
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.
Non-emergencyClosed
Dec 14, 2004Apt F4
APPLIANCE · REFRIGERATOR
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
Dec 12, 2004Apt D1
PLUMBING · WATER-LEAKS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Nov 17, 2004Apt D7
GENERAL · CERAMIC-TILE
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Nov 17, 2004Apt D7
GENERAL · MOLD
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
Nov 17, 2004Apt D7
PLUMBING · BATHTUB/SHOWER
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
Nov 17, 2004Apt D7
PLUMBING · BATHTUB/SHOWER
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Nov 5, 2004Apt L1
GENERAL · CABINET
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Nov 5, 2004Apt L1
APPLIANCE · REFRIGERATOR
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Nov 5, 2004Apt L1
PLUMBING · WATER-LEAKS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Nov 5, 2004Apt L1
GENERAL · DOORS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Nov 5, 2004Apt L1
APPLIANCE · ELECTRIC/GAS RANGE
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Nov 5, 2004Apt L1
GENERAL · WINDOWS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Nov 5, 2004Apt L1
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
EmergencyClosed
Nov 5, 2004Apt L1
GENERAL · DOORS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Nov 5, 2004Apt L1
PLUMBING · TOILET
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
Sep 30, 2004Apt D1
PLUMBING · WATER-LEAKS
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
Sep 17, 2004Apt D1
PLUMBING · WATER-LEAKS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Sep 3, 2004Apt D1
PLUMBING · WATER-LEAKS
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
Aug 14, 2004Apt D 1
PLUMBING · WATER-LEAKS
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
Aug 4, 2004Apt G2
PLUMBING · WATER-LEAKS
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 4, 2004Apt G2
PAINT/PLASTER · CEILING
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 2, 2004Apt G2
PLUMBING · WATER-LEAKS
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
Aug 2, 2004Apt G2
GENERAL · MOLD
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
Aug 2, 2004Apt G2
PLUMBING · WATER-LEAKS
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
Aug 2, 2004Apt G2
GENERAL · MOLD
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.
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