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Building SafetyHousing Conditions

1 JACOBUS PLACE

Manhattan · ZIP 10463 · BIN 1064588 · Kingsbridge-Marble Hill · Last violation Jun 1, 2026 · Last complaint May 21, 2026

NeighborhoodKingsbridge-Marble Hill
More violations than 98.5% of nearby buildings
More violations than 99% of buildings and more complaints than 99% of buildings in Kingsbridge-Marble Hill. 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: 328 violations · 525 complaints
'21'26ViolationsComplaints
▼ View all activity over time
Severityⓘopen violations
20 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 hazardous20Class Bhazardous30
Housing Preservation & Development Violations
Total violations since 1996
2,842
92 per year avg.↓ Down 27% in the last 2 years (328 vs 448 prior 2 yrs)
Open violations
62
Class C (immed. haz.)ⓘ20
Class B (hazardous)ⓘ30
Rent-impairingⓘ2
Housing Preservation & Development Complaints
Total complaints since 2003
3,896
162 per year avg.↓ Down 32% in the last 2 years (525 vs 771 prior 2 yrs)
Complaint Resolution
No access16%Violation issued26%No violation36%Phone resolved22%Other1%(3,896)
Urgency breakdown
Last 12 mo.

Top violation categories

5 yrsAll time
Maintenanceⓘ385 violations
Paintingⓘ105 violations
Egressⓘ93 violations
Water Supplyⓘ82 violations
Extermination & Rodent Eradicationⓘ67 violations
Lead-Based Paintⓘ64 violations
Carbon Monoxide Detecting Devicesⓘ43 violations
Smoke Detecting Devicesⓘ41 violations
Top complaint groupsⓘ
5 yrsAll time
Heat / hot waterⓘ473 complaints
Water & plumbingⓘ245 complaints
Mold & pestsⓘ219 complaints
Bldg maintenanceⓘ192 complaints
Electricalⓘ72 complaints
Safety & fireⓘ22 complaints
Appliancesⓘ18 complaints
Elevatorⓘ16 complaints
Outdoor / structuralⓘ10 complaints
Adminⓘ1 complaints
See violations →Hide complaints ↑

Complaint log

3,896 complaints

All categoriesPAINT/PLASTERHEAT/HOT WATERPLUMBINGUNSANITARY CONDITIONHEATINGAllOpenClosed
Type

Building safety complaints, construction, permits, and structural issues filed with the NYC Dept. of Buildings, are scored separately.

Building Safety →
See something wrong? File a complaint with 311
Open violation ages
▪ < 30 days39% (24)
▪ 30–90 days34% (21)
▪ 3–12 months15% (9)
▪ 1–3 years10% (6)
▪ 3+ years3% (2)
Prior 4 yr.
Immed. Emergency5%6%
Emergency48%55%
Non-Emergency47%39%
(197)
(1,271)
Status
Apt
Received
Category
EmergencyClosedC57Jul 22, 2009PAINT/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.
EmergencyClosedC57Jul 22, 2009GENERAL · LOCKSThe 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.
EmergencyClosedC57Jul 22, 2009GENERAL · WINDOWSThe 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-emergencyClosedC57Jul 22, 2009ELECTRIC · WIRINGThe 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-emergencyClosedC57Jul 22, 2009GENERAL · 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.
EmergencyClosedC57Jul 22, 2009PLUMBING · 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-emergencyClosedC57Jul 22, 2009PAINT/PLASTER · 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-emergencyClosedC57Jul 22, 2009PAINT/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-emergencyClosedC57Jul 22, 2009PAINT/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-emergencyClosedA4Jun 1, 2009ELECTRIC · WIRINGThe 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-emergencyClosedA4Jun 1, 2009ELECTRIC · WIRINGThe 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.
EmergencyClosedA4Jun 1, 2009ELECTRIC · 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.
EmergencyClosedA4Jun 1, 2009ELECTRIC · 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.
EmergencyClosedA4Jun 1, 2009PLUMBING · 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.
EmergencyClosedA4Jun 1, 2009PAINT/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.
EmergencyClosedA4Jun 1, 2009ELECTRIC · WIRINGThe 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-emergencyClosedA4Jun 1, 2009PAINT/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-emergencyClosedA4Jun 1, 2009GENERAL · 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.
EmergencyClosedA4Jun 1, 2009GENERAL · 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.
Non-emergencyClosedA4Jun 1, 2009PLUMBING · 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.
EmergencyClosedA4Jun 1, 2009PLUMBING · 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.
EmergencyClosedA4Jun 1, 2009PLUMBING · 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.
EmergencyClosedA4Jun 1, 2009PLUMBING · 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.
EmergencyClosedA4Jun 1, 2009PLUMBING · 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.
EmergencyClosed44AMay 22, 2009HEATING · HEAT RELATEDThe Department of Housing Preservation and Development was not able to gain access to your apartment or others in the building to inspect for a lack of heat or hot water. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosedB32May 18, 2009PLUMBING · BASIN/SINKThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedB32May 18, 2009GENERAL · WINDOWSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedB32May 18, 2009GENERAL · WINDOWSThe 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.
EmergencyClosedB32May 18, 2009PLUMBING · BASIN/SINKThe 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.
EmergencyClosedB32May 17, 2009PLUMBING · WATER-LEAKSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedB32May 17, 2009PLUMBING · 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-emergencyClosedB32May 17, 2009PLUMBING · WATER SUPPLYThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedB32May 17, 2009GENERAL · WINDOWSThe 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-emergencyClosedB32May 17, 2009GENERAL · WINDOWSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedB32May 17, 2009GENERAL · WINDOWSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed22AMay 7, 2009PAINT/PLASTER · WALLThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed22AMay 7, 2009GENERAL · FLOORThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed22AMay 7, 2009GENERAL · CERAMIC-TILEThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosed22AMay 7, 2009GENERAL · 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
Non-emergencyClosed22AMay 7, 2009PAINT/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-emergencyClosed22AMay 7, 2009PAINT/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-emergencyClosed22AMay 7, 2009NONCONST · VERMINThe Department of Housing Preservation and Development inspected the following conditions. Violations were issued. Information about specific violations is available at www.nyc.gov/hpd
EmergencyClosedA2Apr 30, 2009GENERAL · MOLDThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosedA2Apr 30, 2009PAINT/PLASTER · WALLThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedA2Apr 30, 2009PAINT/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-emergencyClosedA2Apr 30, 2009PAINT/PLASTER · WALLThe 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-emergencyClosedA2Apr 30, 2009PAINT/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
EmergencyClosedA2Apr 30, 2009GENERAL · MOLDThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosedA2Apr 30, 2009PLUMBING · WATER-LEAKSThe Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed44AMar 24, 2009HEATING · HEAT RELATEDThe Department of Housing Preservation and Development was not able to gain access to your apartment or others in the building to inspect for a lack of heat or hot water. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
Jul 22, 2009Apt C57
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
Jul 22, 2009Apt C57
GENERAL · LOCKS
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 22, 2009Apt C57
GENERAL · WINDOWS
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 22, 2009Apt C57
ELECTRIC · WIRING
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 22, 2009Apt C57
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
Jul 22, 2009Apt C57
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 22, 2009Apt C57
PAINT/PLASTER · 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.
Non-emergencyClosed
Jul 22, 2009Apt C57
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
Jul 22, 2009Apt C57
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 1, 2009Apt A4
ELECTRIC · WIRING
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 1, 2009Apt A4
ELECTRIC · WIRING
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
Jun 1, 2009Apt A4
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.
EmergencyClosed
Jun 1, 2009Apt A4
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.
EmergencyClosed
Jun 1, 2009Apt A4
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.
EmergencyClosed
Jun 1, 2009Apt A4
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
Jun 1, 2009Apt A4
ELECTRIC · WIRING
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 1, 2009Apt A4
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 1, 2009Apt A4
GENERAL · 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.
EmergencyClosed
Jun 1, 2009Apt A4
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.
Non-emergencyClosed
Jun 1, 2009Apt A4
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
Jun 1, 2009Apt A4
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
Jun 1, 2009Apt A4
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
Jun 1, 2009Apt A4
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
Jun 1, 2009Apt A4
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 22, 2009Apt 44A
HEATING · HEAT RELATED
The Department of Housing Preservation and Development was not able to gain access to your apartment or others in the building to inspect for a lack of heat or hot water. The complaint has been closed. If the condition still exists, please file a new complaint.
EmergencyClosed
May 18, 2009Apt B32
PLUMBING · BASIN/SINK
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
May 18, 2009Apt B32
GENERAL · WINDOWS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
May 18, 2009Apt B32
GENERAL · WINDOWS
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.
EmergencyClosed
May 18, 2009Apt B32
PLUMBING · BASIN/SINK
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.
EmergencyClosed
May 17, 2009Apt B32
PLUMBING · WATER-LEAKS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
May 17, 2009Apt B32
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
May 17, 2009Apt B32
PLUMBING · WATER SUPPLY
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
May 17, 2009Apt B32
GENERAL · WINDOWS
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
May 17, 2009Apt B32
GENERAL · WINDOWS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
May 17, 2009Apt B32
GENERAL · WINDOWS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
May 7, 2009Apt 22A
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
May 7, 2009Apt 22A
GENERAL · FLOOR
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
May 7, 2009Apt 22A
GENERAL · CERAMIC-TILE
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
May 7, 2009Apt 22A
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
Non-emergencyClosed
May 7, 2009Apt 22A
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
May 7, 2009Apt 22A
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
May 7, 2009Apt 22A
NONCONST · VERMIN
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
Apr 30, 2009Apt A2
GENERAL · MOLD
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
Non-emergencyClosed
Apr 30, 2009Apt A2
PAINT/PLASTER · WALL
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Apr 30, 2009Apt A2
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
Apr 30, 2009Apt A2
PAINT/PLASTER · WALL
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
Apr 30, 2009Apt A2
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
Apr 30, 2009Apt A2
GENERAL · MOLD
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Apr 30, 2009Apt A2
PLUMBING · WATER-LEAKS
The Department of Housing Preservation and Development inspected the following conditions. No violations were issued. The complaint has been closed.
EmergencyClosed
Mar 24, 2009Apt 44A
HEATING · HEAT RELATED
The Department of Housing Preservation and Development was not able to gain access to your apartment or others in the building to inspect for a lack of heat or hot water. The complaint has been closed. If the condition still exists, please file a new complaint.
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