When Home Becomes Hazardous: Maintenance Neglect, Health Risks, and Accommodation Failures (Attorney-Only)
When Home Becomes Hazardous: Maintenance Neglect, Health Risks, and Accommodation Failures (Attorney-Only)
CONFIDENTIAL – ATTORNEY–CLIENT PRIVILEGED (DRAFT NARRATIVE / WORK PRODUCT)
Do not publish publicly. For counsel review and record support only.
Parties / Reference
Tenant: Janice Coffey (Unit/Property: )
Property/Agency: (KCDC / Montgomery Village – as applicable)
Counsel: Attorney G. Michael Davis (Legal Aid of East Tennessee)
Maintenance Director: Mr. Hatmaker
Management staff referenced: Ms. Webb; Ms. Tiara
Opposing counsel referenced: Attorney Gore
Court: Hon. Chuck Cerny (hearing date: 12/9/2025)
Summary of Habitability / Health & Safety Conditions
This narrative documents ongoing conditions affecting habitability, including: (a) suspected or visible fungal contamination affecting HVAC usability, (b) bathroom mold associated with improper ventilation and condensation around HVAC piping, (c) pest activity and infestation concerns (including reports of nesting in/around wiring and fixtures), and (d) structural/installation issues affecting air filtration and air pathways.
The draft includes photo references and descriptive notes originally compiled alongside the post content, including concerns about improper air vent installation and wrong-sized filters. (See embedded image sections.)
Reasonable Accommodation and Scheduling Failures
I have requested that maintenance be performed using defined appointment windows (morning or afternoon blocks), due to medical needs including thyroid medication scheduling and lymphedema management, and due to privacy needs during bathroom-related work. These accommodation requests have been met with repeated scheduling delays and inconsistent notice, resulting in disruption to medical activities and household functioning.
I postponed Dermatologist Physician Assistant Blake Childress' requested prescribed Physical Therapy due to prolonged uncertainty and delays in maintenance scheduling being set at management convenience rather than with accommodations honored.
Key Privacy Incident
One incident involved an attempted maintenance access/arrival during a time when I needed to use the shower in preparation for a medical appointment, creating an invasion of privacy and medical risk. (Jan 14, 2021 Dr. Carol Ackerman, Podiatrist; Maintenance man, Joshua Kitchen/communications: Unannounced Chrome Bathroom Rails Delivery )
HVAC Use, Air Filters, and Alternative Heating (Medical Context)
I refused air filter servicing at a time when the HVAC system was not being used because of mold/fungal concerns. I relied on a stack heater for medically necessary warmth to support lymphedema management. I later began limited HVAC use again; however, I believe the system is contaminated with fungi and requires proper assessment and remediation.
Court Context and Concern About Scope of Work
On 12/9/2025, Attorney Davis conveyed to Judge Chuck Cerny my agreement to allow Mr. Hatmaker’s assessment and work order addressing infested wiring and bathroom/HVAC mold caused by improper ventilation and condensation around HVAC pipes. I am concerned maintenance may be narrowed to air filter retrieval only, contrary to the broader scope represented/expected. I request counsel guidance on whether an appeal or protective action is needed within ten (10) days from 12/9/2025 to preserve rights.
Embedded Photos / Figures / Notes
Retained existing embedded images and captions below as-is
Infested Electrical Grid's Lamps
Requested Relief / Outcomes (For Counsel Use)
- Defined maintenance windows (AM/PM blocks) with adequate advance notice.
- Bathroom work scheduled only with confirmed time window; no surprise arrivals.
- Professional HVAC assessment for fungal contamination; remediation if indicated.
- Completion of wiring/fixture remediation consistent with work order scope.
- Non-retaliation and documentation of communications and scheduling.
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