Amicus Curiae Brief — Chong Yim, et al., Petitioners v. City of Seattle, Washington

Supreme Court briefNov 10, 2023

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No. 23-329

In the Supreme Court of the United States

____________________

CHONG and MARILYN YIM, KELLY LYLES,

EILEEN, LLC, and RENTAL HOUSING

ASSOCIATION OF WASHINGTON,

Petitioners,

v.

THE CITY OF SEATTLE,

Respondent.

____________________

On Petition for Writ of Certiorari to the

U.S. Court of Appeals for the Ninth Circuit

____________________

BRIEF OF AMICUS CURIAE GRE

DOWNTOWNER LLC IN SUPPORT OF

PETITIONERS

____________________

W. CHRISTOPHER POOSER

Counsel of Record

STOEL RIVES LLP

101 S. Capitol Blvd, Suite 1900

Boise, ID 83702

(208) 389-9000

christopher.pooser@stoel.com

Counsel for Amicus Curiae GRE Downtowner LLC

i

QUESTION PRESENTED

Does Seattle’s restriction on private owners’

right to exclude potentially dangerous tenants from

their property violate the Fourteenth Amendment’s

Due Process Clause?

ii

TABLE OF CONTENTS

QUESTION PRESENTED ........................................ i

TABLE OF CONTENTS ..........................................ii

TABLE OF AUTHORITIES ................................... iii

INTEREST OF AMICUS CURIAE.......................... 1

SUMMARY OF ARGUMENT .................................. 2

ARGUMENT ............................................................. 3

I.

Development and Management of The

Addison on Fourth .......................................... 3

II.

Sources of GRE’s Data .................................... 5

III.

The Undue Burden of the FCHO on GRE ..... 6

CONCLUSION ....................................................... 12

APPENDIX

Fold-Out Exhibits

2016 Data from The Addison on Fourth ......... App. 1

2017 Data from The Addison on Fourth ......... App. 2

2018 Data from The Addison on Fourth ......... App. 3

2019 Data from The Addison on Fourth ......... App. 4

2020 Data from The Addison on Fourth ......... App. 5

iii

TABLE OF AUTHORITIES

Cases

Brady v. Whitewater Creek, Inc.,

521 P.3d 236 (Wash. Ct. App. 2022) ............. 6, 11

Statutes

Seattle’s Fair Chance Housing Ordinance

(“FCHO”).................................................. 1-3, 5-12

Seattle Mun. Code § 14.09 ....................................... 1

Seattle Mun. Code § 14.09.010................................. 7

Seattle Mun. Code § 14.09.025(A)(2) ....................... 7

Seattle Mun. Code § 14.09.115(B)............................ 7

Wash. Rev. Code § 59.18.060 ............................. 6, 11

Rules

Supreme Court Rule 37(2)(a) ................................... 1

Supreme Court Rule 37(6) ....................................... 1

Other Authorities

https://data.seattle.gov/ ............................................ 5

https://data.seattle.gov/Public-Safety/SPDCrime-Data-2008-Present/tazs-3rd5 ............ 6, 11

1

INTEREST OF AMICUS CURIAE

GRE Downtowner LLC (“GRE”) submits this

amicus curiae brief in support of the petition for

certiorari filed by Petitioners Chong and MariLyn

Yim, Kelly Lyles, Eileen, LLC, and Rental Housing

Association of Washington (“Petitioners”). 1 GRE is the

owner and operator of an apartment building located

in Seattle, Washington. The apartment building is

known as The Addison on Fourth (the “Addison”).

GRE’s interest in this case stems from its

experience managing the Addison when the City of

Seattle’s Fair Chance Housing Ordinance (the

“FCHO”) went into effect in February 2018. See

Seattle Mun. Code (“SMC”) ch. 14.09, et seq. The

FCHO prohibits a private landlord’s use of a

prospective tenant’s criminal history in determining

their suitability for tenancy. GRE offers this amicus

curiae brief to describe its experience before and after

the FCHO.

GRE’s experience provides additional insight

into the burden on a landlord when it is unable to

screen a prospective tenant’s criminal background to

determine the applicant’s ability or inability to meet

1 Pursuant to Supreme Court Rule 37(2)(a), all parties

received notice of the intent to file this amicus curiae brief 10

days prior to the due date for such brief. Pursuant to Supreme

Court Rule 37(6), undersigned counsel certifies that (A) no party’s

counsel authored this brief, in whole or in part; (B) no party or

party’s counsel contributed money that was intended to fund

preparing or submitting this brief; and (C) no person, other than

the amicus curiae, contributed money that was intended to fund

preparing or submitting this brief.

2

the obligations of tenancy. GRE’s experience supports

Petitioners’ position that the FCHO places an undue

burden on private landlords, impairing their

fundamental property right to exclude potentially

dangerous tenants.

SUMMARY OF ARGUMENT

As a landlord with legal and moral obligations

to its tenants, GRE normally reviews an assortment of

background information about a potential tenant

before reaching a tenancy decision. That information

includes the applicant’s financial stability, rental

history, references, and criminal history. The FCHO

prohibits private landlords from inquiring into any

aspect of an applicant’s criminal history and from

using that information if it is obtained. Little if any

study has been conducted on the practical impacts of

such a blanket prohibition on landlords’ ability to

choose their tenants and provide a safe living

environment.

Given the lack of study, GRE wishes to share its

experience for the two years immediately before and

after the FCHO went into effect. GRE’s experience

post-FCHO was drastically different than its

experience pre-FCHO. Unable to screen a prospective

tenant’s criminal history, evictions at the Addison

quadrupled from 2016 to 2019 and its occupancy

declined. The Addison’s eviction and vacancy costs

increased accordingly. Security costs also increased

greatly. Among other things, GRE was compelled to

hire armed security guards. The increase in crime in

3

and around the Addison is confirmed by data on

reported crimes from the Seattle Police Department.

The FCHO took away an important risk

management tool from GRE: screening for criminal

activity that is a threat to the health, safety, or

property of its existing tenants. The ordinance

improperly burdened GRE. It forced GRE to accept

tenants who were not suitable for tenancy, while GRE

sought, at the same time, to fulfill its legal and moral

obligations to protect existing tenants from the

criminal acts of people it invited onto its property. It

also jeopardized GRE’s ability to maintain the

Addison as viable low-income housing.

ARGUMENT

I.

Development and Management of The

Addison on Fourth

The Addison is located in Seattle’s ChinatownInternational District. It was built in 1911 as a hotel

and was converted to low-income housing in 1969. In

2012, GRE purchased the building for $12 million.

GRE invested $27 million more in major renovations

to convert the building to 254 apartment homes, artist

lofts, and musician studios. The Addison reopened in

November 2013.

GRE’s acquisition and renovation of the

Addison were financed primarily with tax-exempt

bonds issued by the Washington State Housing

Finance Commission. The project is also federally

subsidized. So long as the project continues to comply

with requirements of the Internal Revenue Code,

4

interest on the bonds is expected to remain exempt

from federal income tax. The requirements include

limits on the income of apartment residents and limits

on the amount of rent that can be charged for an

apartment.

Nearly identical restrictions on income levels

and maximum rent amounts allow the project to also

qualify for federal low-income housing tax credits. The

Addison provides housing for Seattle residents

earning up to 60 percent of the area’s median income.

For example, in 2020, that was $45,600 for one person.

The monthly rent for a studio apartment was capped

at $1,162, while the maximum monthly rent for a onebedroom unit was $1,245. Rental payments for many

of the Addison’s tenants are subsidized with rental

assistance from nonprofits or governmental agencies.

GRE is affiliated with Goodman Real Estate,

Inc. (Goodman Real Estate). 2 Goodman Real Estate is

a privately held real estate investment company that

specializes in multifamily, retail, and commercial real

estate and has been headquartered in Seattle for more

than 30 years. Goodman Real Estate has a primary

focus in the Pacific Northwest while also having a

considerable presence in a variety of cities throughout

the United States. Goodman Real Estate and its

2 GRE is a Washington limited liability company. Its

members include GRE Downtowner Manager LLC, also a

Washington limited liability company. GRE Downtowner

Manager LLC’s members are individuals affiliated with

Goodman Real Estate.

5

affiliates currently own and manage 9,232 units, with

an additional 1,592 units under construction.

II.

Sources of GRE’s Data

GRE is not aware of studies into the impact on

private landlords from a blanket prohibition on the

use of criminal history in tenancy decisions. In the

absence of such studies, GRE has gathered data preFCHO and post-FCHO regarding the Addison’s

occupancy rates, evictions, and security costs, among

other information. GRE keeps its records in the

normal course of business, including audited financial

statements. GRE compiled the data from its records

for the purposes of this amicus curiae brief. The data

is submitted in an appendix.

As noted, the FCHO went into effect in

February 2018. For comparison purposes, GRE relies

on two years of pre-FCHO data, using data from

calendar years 2016 and 2017. For post-FCHO data, it

relies on data from calendar years 2018 to 2019, as

well as data from January to March 2020. In March

2020, a moratorium on residential evictions went into

effect in Seattle due to the COVID-19 pandemic. So

that any effects of the moratorium do not affect

comparisons, GRE limits its discussion of its postFCHO experience to data through March 2020.

GRE has also reviewed and gathered public

data from the City of Seattle. 3 In particular, the

Seattle Police Department maintains crime data from

3 See generally https://data.seattle.gov/ (all websites last

visited Nov. 10, 2023).

6

2008 to present, which can be downloaded. 4 The crime

data can then be filtered based on precinct, beat, and

a property’s 100 block address. As explained below,

there are limitations in this data, but it helps

corroborate the changes the Addison experienced after

the FCHO went into effect.

III.

The Undue Burden of the FCHO on GRE

GRE is legally obligated to keep the Addison’s

premises fit for habitation. See Wash. Rev. Code

§ 59.18.060. Washington law also imposes a duty on

landlords to protect tenants from foreseeable harm

caused by the criminal acts of third persons. Brady v.

Whitewater Creek, Inc., 521 P.3d 236, 246-47 (Wash.

Ct. App. 2022). As shown below, the FCHO interfered

with GRE’s goals to provide safe, clean, comfortable,

stable, and affordable housing for the Addison’s lowincome tenants and to maintain the project as a

sustainable enterprise.

During the first years after the Addison

reopened, those goals were met. The Addison’s

occupancy rate was high. For example, in 2016 and

2017, the two years before passage of the FCHO, the

monthly average occupancy rate was 95.69 percent. 5

See App. 1-2. Overall, new and long-term residents

See https://data.seattle.gov/Public-Safety/SPD-CrimeData-2008-Present/tazs-3rd5.

4

5 GRE’s audited financial statements include rental

revenue data such as “max rents,” “loss/gain to lease,” and

“vacancy loss.” In the appendix, monthly occupancy rates are

determined by comparing “vacancy loss” to “max rents” +/“loss/gain to lease.”

7

were happy with the renovations and respectful of the

rules for occupancy. The project was economically

viable.

In February 2018, GRE began to abide by the

FCHO’s new prohibitions against obtaining and using

criminal history information for prospective tenants. 6

See SMC § 14.09.025(A)(2). Before that change in

procedure, to determine an applicant’s eligibility to

become a tenant, GRE used an application process

that included a criminal background check by a

reporting agency. If the applicant had a history of

criminal convictions, the agency would look at the type

of crime and length of time since the crime was

committed and determine whether the applicant

satisfied pre-established criteria. That criteria

assessed whether the criminal conduct indicated a

demonstrable risk to resident safety and/or property.

Then, without including any underlying

information about the criminal history, the reporting

agency would notify GRE whether an applicant was

“approved” (i.e., passed the screening process), should

be “declined” (did not pass the screening process), or

might be “approved with conditions” (such as an

increased deposit). The procedure was intended to

eliminate bias and also allowed GRE protection to

make decisions on the applicant’s suitability for

tenancy.

6 The FCHO exempts “landlords of federally assisted

housing subject to federal regulations that require denial of

tenancy,” but does not define “federally assisted housing.” SMC

§§ 14.09.115(B), 14.09.010. Uncertain whether the FCHO applied

to the Addison, GRE elected to abide by the new prohibitions.

8

With the discontinuation of that procedure in

February 2018, there was a noticeable change, as

living conditions at the Addison declined over time.

Recall that the Addison was nearly fully occupied in

the two years prior to the FCHO. For 2018, the

average monthly occupancy rate remained high at

94.38 percent. App. 3. But as natural turnover

occurred, the impacts of the FCHO became more

pronounced. In 2019, the monthly occupancy rate

dropped to an average of 90.60 percent. App. 4. From

January to March 2020, the monthly occupancy rate

eroded further, averaging 88.37 percent. App. 5.

Evictions also increased. 7 Certainly evictions

are part of the rental business, necessary to deal with

problem tenants who endanger others, damage

property, or violate the lease agreement. But evictions

at the Addison quadrupled after 2018. In 2016 and

2017, GRE was forced to initiate 14 and 17 judicial

evictions, respectively. App. 1-2. In 2018, eviction

proceedings began to increase, eventually totaling 34.

App. 3. In 2019, GRE began 63 eviction proceedings.

App. 4. Of those 63 evictions, 33 of the tenants moved

in after the FCHO went into effect in February 2018

and after GRE stopped screening for criminal history.

Id. Another 12 eviction proceedings began between

January and March 2020, nine of which involved

tenants who moved in after the FCHO went into effect.

App. 5.

7 GRE measures evictions by the filing of eviction

proceedings in Washington state courts.

9

As would be expected, the increase in turnover

and evictions had a direct impact on GRE’s ability to

provide safe and affordable housing for low-income

tenants and remain a viable enterprise. In 2016 and

2017, GRE spent an average of $1,461 per month on

evictions and a total of $35,059. 8 App. 1-2. In 2018,

that expense rose to an average of $2,228 a month, and

in 2019, it climbed to an average of $3,785 a month,

totaling $72,157 over those two years. App. 3-4. From

January to March 2020, the average eviction cost was

$3,169 a month. App. 5.

Vacancies also hit GRE’s bottom line. There is

a cost to vacant apartments. In 2016 and 2017, the

average loss due to vacancies each month was $8,913

and $12,117, respectively. App. 1-2. In 2018, the

average monthly loss increased slightly to $14,724.

App. 3. In 2019, it nearly doubled to $26,381 a month.

App. 4. From January to March 2020, the average loss

was $32,543 a month. App. 5.

What accounts for those considerable changes?

The only explanation GRE has found is the FCHO’s

prohibition against obtaining and using criminal

history information for prospective tenants.

Anecdotally, GRE can recount the fights that broke

out in the lobby of the building; the six-month resident

who stabbed his guest in November 2019; the used

needles, trash, and feces left in stairways and

hallways; the fire alarms set off repeatedly in the

middle of the night; employees who were afraid to

8

expenses.

GRE’s audited financial statements include eviction

10

work alone; and the increase in the Addison’s annual

assault and battery insurance deductible. GRE can

also speak to its employee turnover, which increased

from losing two employees in 2016 and 2017 to nine

employees in 2018 and 2019. App. 1-4.

But more directly, the Addison’s security costs

greatly increased. Between 2016 and 2018, security

costs averaged $2,335 a month and totaled $84,059. 9

App. 1-3. Compare those costs to what occurred

between January 2019 and March 2020. Over that 15month period, security costs averaged $14,786 a

month and totaled $221,786. App. 4-5. GRE hired

armed security guards, installed cameras in the

hallways on every floor and in other public areas,

upgraded door hardware, installed a controlled access

system for the elevator, and gave residents fobs that

allowed them access only to their respective floors.

Data from the Seattle Police Department

confirms the increasing crime in and around the

Addison after the FCHO went into effect. GRE

recognizes that this data has limitations. For example,

it documents crimes reported and is not specific to the

Addison alone. Using the Seattle Police Department

public dataset, GRE isolated violent crimes (e.g.,

homicide, rape, robbery, and aggravated assault),

property crimes (e.g., arson, burglary, larceny-theft,

and motor vehicle theft) and societal crimes (e.g.,

drug/narcotic offenses and weapon law violations) to

the Addison’s block within the Chinatown9 The Addison’s security costs were compiled as a

summation of various expense categories (and in some cases

partial amounts) from GRE’s audited financial statements.

11

International District. 10 This data shows there were

31 crimes reported in and around the Addison in 2016,

57 crimes reported in 2017, 105 crimes reported in

2018, and 145 crimes reported in 2019.

As documented above, the impact and burden to

GRE and the Addison was measurable. The FCHO

inhibited GRE’s ability to provide habitable, safe, and

affordable housing for low-income tenants, which is its

legal obligation. See generally Wash. Rev. Code

§ 59.18.060; Brady, 521 P.3d at 246-47. Unable to

ensure that new tenants would not threaten the

health, safety, or right to peaceful enjoyment of other

tenants, evictions and vacancies increased. And GRE’s

costs increased, jeopardizing the Addison as an

economically viable project. In the end, the City of

Seattle’s refusal to let private landlords screen

applicants for criminal history imposed an unduly

oppressive and irrational burden on GRE.

10 The Seattle Police Department’s public dataset can be

downloaded and isolated by year, type of crime, precinct (the

Addison’s is West), beat (the Addison’s is K3), and address

location blurred to the 100 block (the Addison’s is 3XX block of

4th Avenue South). See https://data.seattle.gov/PublicSafety/SPD-Crime-Data-2008-Present/tazs-3rd5 (identifying the

fields under the heading “Columns in this Dataset”). The Addison

sits on the block bounded by 4th Avenue South, South Jackson

Street, 5th Avenue South, and South Main Street. The Addison

has two neighbors on the block: a modern apartment building

completed in 2016 and an office building.

12

CONCLUSION

The right to exclude is a fundamental right, and

the FCHO unduly burdened GRE to accept tenants

with criminal histories who were not suitable for

tenancy. GRE respectfully urges the Court to grant

the petition for writ of certiorari.

Respectfully submitted,

W. CHRISTOPHER POOSER

Counsel of Record

STOEL RIVES LLP

101 S. Capitol Blvd, Suite 1900

Boise, ID 83702

(208) 389-9000

christopher.pooser@stoel.com

Counsel for Amicus Curiae

GRE Downtowner LLC

APPENDIX

i

APPENDIX

TABLE OF CONTENTS

Fold-Out Exhibits

2016 Data from The Addison on Fourth ......... App. 1

2017 Data from The Addison on Fourth ......... App. 2

2018 Data from The Addison on Fourth ......... App. 3

2019 Data from The Addison on Fourth ......... App. 4

2020 Data from The Addison on Fourth ......... App. 5

2016 Data from The Addison on Fourth

Jan 2016

4000-000 REVENUE:

4005-000 RENTAL REVENUE

4005-100

Max Rents

4005-200

Loss/Gain to Lease

4050-020

Vacancy Loss

Occupancy Based on Vacancy Los

5001-169 ADMINISTRATION EXPENSES

5001-290

Evictions

Evictions of tenant(s) screened

for criminal history (before

FCHO)

Evictions of tenant(s) not

screened for criminal history

(after FCHO)

Total Evictions

Feb 2016 Mar 2016 Apr 2016 May 2016 Jun 2016

Aug 2016 Sep 2016

Oct 2016 Nov 2016 Dec 2016

243,558.00 243,558.00 243,558.00 243,558.00 243,558.00 243,558.00 243,558.00 243,558.00 243,558.00 243,558.00 243,558.00 243,558.00

-8,313.00 -7,455.00 -6,624.00 -6,193.00 -4,704.00 -5,224.00 -4,343.00 -3,355.00 -2,416.00 -2,272.00 -1,265.00

-459.00

-3,435.17 -2,956.13 -6,856.01 -12,025.28 -11,885.97 -4,178.58 -4,332.36 -7,130.80 -17,689.87 -12,151.43 -12,668.30 -11,643.81

98.54%

1,479.98

98.75%

125.00

97.11%

94.93%

95.02%

2,118.96

2,302.94

2,128.47

98.25%

98.19%

97.03%

125.00

125.00

954.98

92.66%

94.96%

1,358.98

0.00

94.77%

95.21%

1,099.98

3,128.45

1

0

2

3

1

0

1

2

1

0

2

1

1

0

2

3

1

0

1

2

1

0

2

1

1,655.00

2,710.00

1,240.00

2,000.00

2,855.00

4,180.00

1

Empl. Turnover

Security Cost

Jul 2016

2,000.00

2,000.00

2,000.00

2,000.00

2,375.00

App. 1

2,165.00

2017 Data from The Addison on Fourth

Jan 2017

4000-000 REVENUE:

4005-000 RENTAL REVENUE

4005-100

Max Rents

4005-200

Loss/Gain to Lease

4050-020

Vacancy Loss

Occupancy Based on Vacancy Los

5001-169 ADMINISTRATION EXPENSES

5001-290

Evictions

Evictions of tenant(s) screened

for criminal history (before

FCHO)

Evictions of tenant(s) not

screened for criminal history

(after FCHO)

Total Evictions

Feb 2017 Mar 2017 Apr 2017 May 2017 Jun 2017

Aug 2017 Sep 2017

Oct 2017 Nov 2017 Dec 2017

243,558.00 243,558.00 243,558.00 243,558.00 245,466.00 245,466.00 241,244.67 245,466.00 245,466.00 245,466.00 245,466.00 245,466.00

-263.00

225.52

746.26

903.01

-824.00

-216.00

295.00

1,444.00

4,058.00

5,094.00

6,522.00

7,683.00

-11,547.04 -10,593.58 -15,099.62 -11,557.84 -11,524.21 -7,783.87 -11,966.86 -17,561.95 -9,537.62 -12,340.52 -9,935.12 -15,952.09

95.25%

3,579.90

95.65%

420.00

93.82%

95.27%

95.29%

96.83%

95.05%

1,048.49

2,690.94

1,200.00

2,165.92

2,709.96

92.89%

96.18%

350.00

437.49

95.07%

96.06%

93.70%

3,114.43

1,371.49

1,023.00

3

3

1

0

0

3

3

1

0

3

0

0

3

3

1

0

0

3

3

1

0

3

0

0

1,975.00

4,000.00

2,000.00

2,000.00

2,000.00

2,000.00

1

Empl. Turnover

Security Cost

Jul 2017

1,805.75

1,622.00

2,000.00

5,344.00

2,000.00

App. 2

2,025.00

2018 Data from The Addison on Fourth

Jan 2018

4000-000 REVENUE:

4005-000 RENTAL REVENUE

4005-100

Max Rents

4005-200

Loss/Gain to Lease

4050-020

Vacancy Loss

Occupancy Based on Vacancy Los

5001-169 ADMINISTRATION EXPENSES

5001-290

Evictions

Evictions of tenant(s) screened

for criminal history (before

FCHO)

Evictions of tenant(s) not

screened for criminal history

(after FCHO)

Total Evictions

Feb 2018 Mar 2018 Apr 2018 May 2018 Jun 2018

Aug 2018 Sep 2018

Oct 2018 Nov 2018 Dec 2018

260,712.00 260,712.00 260,712.01 260,712.02 260,712.00 260,712.00 260,712.00 260,712.00 260,712.00 260,712.00 260,712.00 260,712.00

-6,288.00 -4,828.00 -4,401.00 -3,809.00 -2,966.00 -1,385.00

583.00

4,352.00

7,265.00 10,490.00 12,659.00 13,959.00

-23,514.52 -26,521.03 -20,105.45 -13,632.89 -4,749.80 -6,225.36 -9,241.28 -18,199.34 -9,151.96 -12,181.56 -15,620.87 -17,540.09

90.76%

89.64%

92.16%

94.69%

1,018.00

3,763.06

1,231.00

4,788.00

4

5

1

2

4

5

1

2

98.16%

-415.00

2

2

97.60%

96.46%

1,965.00

4,911.41

1

6

1

93.13%

467.00

0

96.58%

95.51%

94.29%

93.61%

1,638.00

3,016.00

1,838.00

2,520.00

3

2

1

3

1

1

0

2

6

0

4

3

1

5

3,265.00

2,100.00

2,000.00

2,000.00

2,100.00

2,100.00

4

Empl. Turnover

Security Cost

Jul 2018

2,100.00

2,100.00

4,441.31

1,240.30

2,914.20

App. 3

1,746.28

2019 Data from The Addison on Fourth

Jan 2019

4000-000 REVENUE:

4005-000 RENTAL REVENUE

4005-100

Max Rents

4005-200

Loss/Gain to Lease

4050-020

Vacancy Loss

Occupancy Based on Vacancy Los

5001-169 ADMINISTRATION EXPENSES

5001-290

Evictions

Evictions of tenant(s) screened

for criminal history (before

FCHO)

Evictions of tenant(s) not

screened for criminal history

(after FCHO)

Total Evictions

Feb 2019 Mar 2019 Apr 2019 May 2019 Jun 2019

Aug 2019 Sep 2019

Oct 2019 Nov 2019 Dec 2019

284,740.00 284,740.00 284,740.00 284,740.00 283,697.22 284,740.00 284,740.00 284,740.00 284,740.00 284,740.00 284,740.00 284,740.00

-8,128.00 -6,472.99 -5,971.00 -4,247.00 -2,906.99 -3,687.00 -2,257.00 -2,258.00 -1,751.00 -3,201.00 -2,556.00 -4,344.00

-21,346.94 -30,877.80 -23,993.93 -24,334.25 -17,657.13 -14,968.78 -24,186.29 -31,153.61 -31,411.94 -33,025.05 -29,723.19 -33,897.34

92.28%

88.90%

91.39%

91.32%

3,010.00

4,780.00

8,015.00

3,089.00

5

4

9

2

2

2

5

7

6

14

93.71%

94.67%

91.44%

88.97%

88.90%

88.27%

89.47%

87.91%

1,723.00

4,199.00

6,383.60

1,052.40

1,949.00

3,773.00

8,245.00

3

1

0

2

0

1

2

1

0

2

2

5

0

4

4

2

5

2

5

3

5

2

4

5

4

6

4,664.76

4,891.71

4,891.71

23,484.15

-802.36

5

Empl. Turnover

Security Cost

Jul 2019

3,300.00

3,300.00

32,050.00

34,398.00

33,720.00

App. 4

30,348.00

20,920.00

0.00

2020 Data from The Addison on Fourth

Jan 2020

4000-000 REVENUE:

4005-000 RENTAL REVENUE

4005-100

Max Rents

4005-200

Loss/Gain to Lease

4050-020

Vacancy Loss

Occupancy Based on Vacancy Loss

5001-169 ADMINISTRATION EXPENSES

5001-290

Evictions

Evictions of tenant(s) screened for

criminal history (before FCHO)

Evictions of tenant(s) not

screened for criminal history

(after FCHO)

Total Evictions

290,209.00 290,209.00 290,209.00

-10,012.00 -10,187.00 -11,171.00

-28,362.76 -33,749.23 -35,516.11

89.88%

87.95%

87.27%

2,082.00

2,140.00

5,286.00

0

0

3

5

2

2

5

2

5

2

Empl. Turnover

Security Cost

Feb 2020 Mar 2020

0.00

10,062.29

15,755.77

App. 5

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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