Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 09 8:04 AM-18CV005717
paying program fees. (B. Craig aff., ¶ 20); (J. Hall aff., ¶¶ 59-60). In another instance, a couple was charged $100 a week each to live in the common area of a basement; they hung up a curtain for privacy and the carpet was often wet because the bathroom upstairs leaked. (B. Snider aff., ¶ 7); (D. Holder aff., ¶ 6). In three of the Summer Rays program houses, residents live and sleep in quasi-renovated garages. Chuck Kirk calls these garages “couples suites.” Program residents have lived in these spaces both prior to and after the renovations. None of the renovations have been done pursuant to code. The renovation work on these properties was completed by Summer Rays residents who worked for Chuck Kirk. In one instance, the Summer Rays resident worked in the very early morning until only 9:00 am because Chuck Kirk instructed him to work in secret. Even after the renovations, the condition of the garages was of questionable habitability. For example, the floors are all painted concrete and the spaces are not properly insulated or ventilated. (A. DeLong aff., ¶ 12); (B. Craig aff., ¶ 19); (J. Hall aff., ¶¶ 55-58); (A. Holder aff., ¶ 4). One of the most egregious examples of housing conditions is the duplex located at 1273/1275 Lancaster Avenue. Numerous Summer Rays residents lived at 1273/1275 Lancaster Ave. for extended periods of time. While certain Summer Rays residents were living there, the duplex never had heat, air conditioning, or running water. Both the electric meter and water meter had been removed from the house. In the winter, residents often used gas powered generators and extension cords to power space heaters. To shower, residents had to go to the public gym down the street.
At various points in time, the duplex lacked electricity, a
refrigerator, and/or a stove. The interior of the duplex was essentially unfinished. One of the bathrooms had a hole in the exterior wall where a window should have been. For several months, a Summer Rays resident slept in the unfinished basement of the duplex, on a box spring 15