This petition serves as a plea to the Attorney General of Tennessee Herbert Slatery III and Governor Bill Haslam to help roughly 650 University of Knoxville students who despite having lease agreements with The Standard are presently suffering by being homeless or housing insecure for months, or are suffering in substandard and unsafe housing at The Standard after being homeless or housing insecure for months.

This problem affects roughly 650 University of Tennessee students, and the financial scale through November 1, 2016 is over $2 million.

Roughly 650 University of Knoxville students signed a lease with The Standard at Knoxville, a pedestrian housing apartment complex which targets students, located at 705 17th Street South, Knoxville, Tennessee, with the promises of “unparalleled amenities & safety features”, “high quality construction”, “Peace of Mind – On Site Management and Maintenance – Controlled Access Garage Parking”, “video-recorded surveillance”, and apartments that are “well-appointed with luxury finishes”, with individual floor plans and overall schematics and the virtual tour prominently featuring balconies as well as “Exclusive Penthouse Units – with Rooftop Patios Available”. Students and parents were told “Rest Assured, at The Standard you’ll experience the very best in student living”.

We are desperate for help. We have tried to get help from The Standard at Knoxville and their parent company Landmark Properties, only to be ignored or deceived/misled.

The details and timelines follow.

In summary:

• Students have not been informed the truthful and realistic status of Move In(s)
• The Standard did not provide consistent, stable, secure, temporary housing
• Students have had to move multiple times, with little to no notice
• The Standard has ignored emails and phone calls
• The leasing office was closed without notice
• Key amenities were removed (balconies) without sufficient and complete notice or reasonable compensation
• Gift cards were not given consistently
• Students do not have the guaranteed, secured parking promised
• The apartments have many issues (walls, floors, dust), and The Standard has ignored requests for repair
• There are issues with garbage, vomit, and feces in common areas
• There are serious problems with construction dust
• The alley is hazardous
• Charges to accounts are improper
• We have concerns about adherence to Fair Housing laws
• Students on Floors 7 & 8 are still not moved in

1. We feel that there has been systemic and pervasive deliberate misrepresentation regarding occupancy dates. The lease stipulates that the apartments will be ready for occupancy on 8/13/16, and if not, that The Standard will provide temporary accommodations.
   1. The reality is that The Standard has been misleading students and parents regarding Move In, since at least May. Communications from The Standard include:
      • i. Email of May 25 reassuring students and parents (guarantors) that The Standard would open on time, and gave assurances such as “our experienced construction team has built thousands of apartments around the country and this isn’t the first time they’ve had to do some creative scheduling to get done on time” and “Our team of experienced professionals have a detailed plan of what needs to get done in order to open our doors on time” and “Trust us – we are doing it!”
      • ii. Email of July 13 – “Unfortunately, The Standard at Knoxville will be experiencing delayed move-ins…..Until recently, we had every indication that we would be able to meet our target move-in date.”
      • iii. Email of August 3 – “We will be permitted to allow phased move-ins, beginning with the 1st and 2nd floors. Once we have more information about the dates in which each floor will be ready for move-in, we will let you know. We are still tracking for September 20th for the completion of all units.”
      • iv. Email of August 11 – “We are still on track to have everyone moved in by the 20th of September. Right now, we are tracking that the first floors should be ready for move-in around the second week of September.”
      • v. Email of August 26 – “Next, we would like to apologize for the lack of a construction update last week. We did not have any new information to share with you, but should have still communicated that with you... Per our latest meeting, we are tracking the following dates. Please note that these are subject to change and could slide forward or backward somewhat. We are scheduled to start having furniture installed on the bottoms floors on 9/6 and it moves up from there. Below are our most up-to-date projections.Floors 1-2 – 9/10, Floors 3-4 – 9/15, Floors 5-8 - 9/20. For amenities, we are tracking to have interior amenities completed by 9/20.
      • vi. Email of Sept 8 – “As of right now, we are moving forward with Floors 1 – 4 moving in on 9/15. We are waiting on certificates of occupancy, but feel strongly that these will be granted.”
      • vii. Email of Sept 14, sent in the afternoon – “Unfortunately we will be unable to move people into the building tomorrow, the 15th. We have a few more items to complete to be granted certificates of occupancy. These items will be completed in phases by floor. There has been a lot of progress made this week. Right now, we are anticipating the following: Floors 1and 2 will be able to get in on the 17th , Floor 3 on the 19th, Floor 4 on the 21st
      • viii. Email of Sept 16, sent at 4 pm – “We are deeply sorry to let you know that no residents will be able to move in at The Standard beginning tomorrow, September 17, as previously anticipated based on construction projections… We are confident that all apartments will be ready for move-in by Oct. 12…..”
      • ix. Email of Sept 28, We have received approval from the City inspector for all apartments on the first floor and most on the second, third and fourth floors. We're awaiting completion of final punch list items, inspection of common areas and written approval from the fire marshal before proceeding with phased occupancy.
        We know that you are looking forward to a definite move-in date, but we do not have those at this time. We will send another update tomorrow and again on Friday as we continue to get news day-by-day.
      • x. Email of Sept 29, 9:42 pm. Although we'd like to be able to provide you with a specific date today, we're unable to do that. But, we still wanted to give you an update on today's activities. Inspections continued throughout the day and are going well. We expect to begin phased occupancy within the next few days but are still awaiting final approvals from the City inspector and fire marshal. We will provide an update tomorrow following another walkthrough.
      • xi. September 30th (Friday) No update as promised on 9/28 and 9/29.
      • xii. Email of October 3, Inspections and construction work continued throughout the weekend and today. Both the fire marshal and building inspector were onsite this afternoon and plan to be onsite tomorrow. We have scheduled a meeting for our team to meet with the inspector and fire marshal together on Wednesday afternoon. Based on the current assessments, we expect to come out of that meeting with approval to begin phased occupancy for floors 1-4 as early as Thursday.
        Between now and then, we will be working to complete final punch list items and cleanings and ensure operation for all elevators in the building.
        At this time, we recommend residents on floors 1-4 begin arranging plans for move-in on Friday, Saturday or Sunday (there is some potential for Thursday, but residents will have the option to wait until Friday, if so). Immediately following Wednesday's meeting, we will issue another update with move-in information and projections for upper floors.
      • xiii. Email of October 5, 3:10 pm. phased move-in will not begin tomorrow, October 6… We are currently anticipating phased occupancy to begin on Friday, October 7, starting with floors 1-4. Once move-in begins, we will provide updated projections for floors 5-8.
      • xiv. Email of October 7, Earlier today, we received sign-off from the fire marshal for the building's monitoring system. We also narrowed our final punch list to just a few minor items for floors 1-4. We are highly confident we will complete the punch list items by tomorrow afternoon prior to a scheduled walkthrough with our construction team and the City inspector.
        If those punch list items are completed upon tomorrow's inspection, we understand we'll be allowed to proceed with phased occupancy for approved levels. We will spend the remainder of the day putting finishing touches on those apartments and common areas.
        If we do receive approval tomorrow, we will begin move-in for floors 1-4 on Sunday, October 9.
      • xv. Email of October 8, 8:12 pm. This afternoon, we received final approval from the City inspector for floors 1-4. As a result, we will proceed with move-in for floors 1-4 beginning tomorrow, Sunday, October 9.
        1. Take note that UT Fall Break was October 5-9. Many students were out of town beginning October 4 or 5, many students had personal, family, professional engagements long planned and left Knoxville not knowing what to do about their possessions, what would happen with their possessions, due to the chaos of ever shifting Move In dates.
      • xvi. Email of October 12, Wednesday, 7;15 pm. We did not receive final sign-off today on floor five. The City inspector will return tomorrow for another walk through. As soon as that takes place, we will provide another update. At this time, we encourage residents on floor five to plan for a Friday move-in. Hotel rooms are booked through Thursday night. If we do receive approval tomorrow, but you are unable to move-in due to limited notice, this is completely fine. You will be permitted to stay in your current hotel until Friday at 11am…For floor six, we are now anticipating a Sunday move-in.
      • xvii. Email of October 13, Thursday, 5:58 pm. Fifth floor residents can begin moving in immediately. We will have staff onsite this evening until 9pm for residents to pickup their keys… For residents who do not want to move in tonight, all hotel rooms are booked until tomorrow morning at 11. We will begin issuing keys again tomorrow at 9am. You must check-out of your hotel room by tomorrow at 11am… Note – with no notice, students were given 3 hours to get their keys! We are still anticipating a Sunday move-in for residents on floor six.
      • xviii. Email of October 14, Sixth floor residents may begin moving in Sunday at 9am unless you are notified about a delay with your specific room.
      • xix. Email of October 21. Floor 7: We are working on a few punch list items and final sign-off from the City inspector. We're currently expecting move-in to begin next Thursday… If move-in does begin on Thursday but you're unable to move during the week, you will have until Saturday at 11am to check out of your hotel and pick up your key. Floor 8: Still working on mechanical inspections, punch list items and final sign-off from the City inspector. We anticipate move-in to begin next Saturday, pending final approval from the City inspector. If move-in does begin on Saturday, you will have until Sunday at 11am to checkout of your hotel.
      • xx. Email of October 25. Floor 7: Our anticipated move-in schedule has been pushed back to Saturday through Monday. Floor 8: Projected move-in for the eighth floor has been pushed back to Tuesday through Thursday. We are working on punch list items and final sign-off from the City inspector. Floor 8: Projected move-in for the eighth floor has been pushed back to Tuesday through Thursday. We are working on punch list items and final sign-off from the City inspector.
      • xxi Email of October 27. Floor 7: We continue to work with the City on their final checklist and expectations. At this time, we anticipate move-ins on the seventh floor to begin next Thursday, Nov. 3. Please begin making tentative arrangements for moving in on that day. Seventh floor residents' hotel rooms have been extended through Thursday morning. Floor 8: Unfortunately, we do not have an exact projected move-in date for the eighth floor at this time, but we do anticipate beginning move in 2-3 days following Floor 7.
      • xxii Email October 31. Floor 7: We are working on a few punch list items over the course of the next few days to receive final sign-off from the City inspector. We are still anticipating at Thursday move-in but will not know until late Thursday afternoon whether or not occupancy will begin on that day. As a result, we are working on extending hotel rooms and will provide an update with the latest check-out date tomorrow evening. Floor 8: We do not have an exact projected move-in date for the eighth floor. We are working with the City to receive approval and have a number of meetings with our construction team and inspectors this week. We anticipate beginning move in 2-3 days following Floor 7, pending sign-off from the City inspector.
      • xxiii. Email November 2. We understand many of you are hoping for a firm move-in projection for Floors 7 and 8; at this time, however, we are unable to provide a concrete projection. We are still working with the City for final sign-off.
        Specifically, in order to receive sign-off for Floor 7, we must also have final approval for Level 0 of the parking garage. We currently anticipate receiving that approval this Friday, but that is dependent upon the City's inspection.
        If we are allowed to occupy Floor 7 separately from Floor 8, it could also be ready this Friday. We continue to work closely with the inspections department on these matters and will provide updated information as soon as we have it. For now, it is safest to plan on moving in early to mid-week next week… Floor 8 will likely be another 10-15 days as we work to complete final items required for the building to have a complete Certificate of Occupancy. We have recently been informed that the complete CO may be required before 8th-floor residents can occupy the building. We hope this too can happen sooner, but the exact timing is challenging to predict.
   2. It is evident from the permitting approval of BU15-0723 that the information given by The Standard is in these communications is inconsistent with the reality of the construction progress.
      • i. The updates use language such as “final punch list items” and “a few more items to complete”, implying minor things preventing occupancy, when in fact, there were and are major issues.
   3. Note that, along with promises that Move In would happen, there were demands that students move out of their hotels on the same day. Many times, with just hours notice. By 11:00 am. Many students didn’t even have cars. How does that work without a car? Or while trying to study? The Standard unnecessarily created housing emergencies. Their inability to properly plan and project management, does not give them the right to upend everyone else. Students and parents are not simply waiting around day-by-day with no other plans or commitments, and 100% available to Move In whenever The Standard demands. This is not professional, and is not consistent in any way with the spirit of our lease agreement which requires The Standard to provide temporary accommodations.
2. 2.The negative impacts to students due to the above misleading deadlines, were compounded because The Standard did not provide consistent and reliable temporary housing.
   • a.While it is true that the lease agreement merely says that The Standard will provide temporary housing, including hotels, it is a reasonable expectation that the housing will be stable AND within walking distance of campus (since The Standard is advertised as such, promoted as Pedestrian Housing, and targets college students). This has NOT happened.
   • Many residents were forced to move from their hotels multiple times (moving as many as 10 times back and forth) with very little notice, and days apart. Sometimes the notice was merely hours. Some students were displaced in hotels 10 miles from campus, and this has been a terrible hardship since many students don’t have cars – and in signing a lease with The Standard didn’t need a car for school since The Standard is pedestrian housing.
   • Some students could not manage to be housed 10 miles away and instead opted to couch surf.
   • All students had to find a way to move and store their possessions. While going to class. The Standard did not offer help to all students. For example, at least one student asked for moving help and was promised moving help, but despite the student emailing and calling many, many times the week of the move to get the promised help, the student was ignored and never received the promised help.
   • News media has reported on this particular fiasco, with video of students struggling with their possessions, and walking to their friend’s home/couch.
   • The Standard made no attempt to work with The University of Knoxville to secure dorm rooms for students. Only through the efforts of parents contacting the Dean of Students, was this housing option secured.
3. Per the lease agreement, if students could not Move In by 10/13, they would be allowed to break their lease. Since these are students, on a semester system, and given the housing shortage in Knoxville, it is impractical, if not impossible, for a student to secure housing in mid October. If The Standard had been forthright, and provided reasonable Move In dates, it would have been obvious in Spring of 2016 that the 10/13 date was not possible. Students could have secured alternate housing during the spring or even the summer before classes started – and would now be living in secure housing. Instead, The Standard provided misleading information to students about Move In, and essentially guaranteed no alternative housing would even be a possible option for students, thereby locking students into their one year lease agreements. Numerous requests from parents and students since July, to allow their students to terminate their lease agreements with The Standard without penalty so they could secure stable housing were ignored, denied, referred to legal action. The resources of students, and even their parents, do not match those of a corporate entity. The Standard used their power to take advantage of desperate students. These students had (and 7th and 8th floor students still have) no choice but to accept the housing being supplied by The Standard.
4. The Standard removed balconies, a significant and valuable feature from the apartments, without reducing the rent. Some residents were notified via email in July that the balconies were removed and offered a nominal item for their apartment, such as a coffee maker. But not all tenants were even notified. Some tenants just showed up at Move In and the apartment had no balcony. When parents and students protested, The Standard would either a) not respond, or b) referred parents and students to Landmark Properties General Counsel.
5. 5.Various financial commitments from The Standard were not fulfilled:
   1. One month’s credit and IN ADDITION not having to pay rent until Move In.
   2. In November, students that are not even moved in (and not subject to rent until move in) were assessed late fees for not paying rent.
   3. Weekly gift cards were promised, to help defray restaurant costs, since the hotels were not efficiencies with kitchens. Many times, the gift cards were delayed, with no notice. Struggling, hungry students, navigated to the leasing office, through major construction only to be told there are no gift cards. On one occasion, the weekend of September 16-18, The Standard closed their office with no notice, and students couldn’t pick up their gift cards all weekend – even though staff was actually present in the office. They literally locked their doors on the students, who then could not get their gift cards needed for FOOD for the weekend. Last week, The Standard, with no notice, quit issuing gift cards entirely and issued rental credits. In the words of one parent “ What exactly would you do if your employer decided that rather than give you a paycheck they were just going to pay your bills? That is exactly how my son feels. He has been in a hotel for 80 DAYS!!! He has no kitchen, no means of food storage.....” Since this affects hundreds of students, it’s roughly $80,000 per week. So, this amounts to hundreds of thousands of dollars that The Standard has promised, but not delivered in a timely manner.
   4. A promise from The Standard to discount rent by 25% until amenities are fully in place, has not been honored. Instead, residents at The Standard were charged full rent on November 1, with a promise to give a weekly credit. That’s not the same as discounting rent by 25%. Since they charged the full rent on November 1, if 400 students paid full rent, at an average rent of $800 per month that equals $320,000. 25% is $80,000. So this results in The Standard gaining $80,000 in cash flow.
6. 6.When students went to pick up the promised gift cards on 9/30, without notice they were required to sign an open ended lease agreement addendum, in order to get the promised gift cards – which students need to buy FOOD.
7. 7.We have concerns regarding adherence with Fair Housing laws.
   1. How were some students selected to stay at hotels adjacent to campus and others selected to live in hotels 10 miles away?
   2. 141 students were placed at the Holiday Inn. All were displaced the weekend of the Florida Game. And only 45 were allowed to return to the Holiday Inn on Sunday. How were some students selected to return the the hotel, while other students were relocated to a hotel 10 miles away?
   3. In the last week, The Standard has claimed it provided moving help to students. This was never part of the overall email communications. How did The Standard decide who got offers of moving help, and who didn’t get help?
   4. How did The Standard decide to offer incentives such as Keurigs and paying tickets to some students, but not offer these incentives and financial benefits to other students?
8. 8.The phased Move In is a disaster, fraught with health, safety, security issues in addition to non-performance of promised features and amenities.
   1. The promised “controlled community access” and “electronic key system for access control” is not implemented.
   2. The parking garages are not complete. Only 50% of the spaces are available, yet roughly 70% of the occupants have moved in. Some students who contracted for parking, checked into their apartments and were not given parking passes because The Standard ran out of parking. Where are they supposed to park? Students that contracted for secured parking and were actually given passes and are paying for parking, have not been able to securely park in the garage. Some students have returned to the garage to find no parking available, and have to scrounge for parking elsewhere. Some students have had cars towed. Some students have been forced to street park blocks away and had to walk back to The Standard very late at night alone. Some students have been late to class and late to work because of unavailable parking – which was promised to be available. None of the garage entries are ADA compliant.
9. The living conditions are intolerable and unhealthy. The Standard did NOT put maintenance or cleaning contracts in place prior to moving students into the building. Anita Arnold a parent on 10/10, a day after Move In for floors 1-4, that The Standard hadn’t even begun the process to find anyone, specifically – they hadn’t even sent bids out.
   1. The most serious problem, is the construction dust. It’s horrible. Per OSHA “visible material in the air – If you see visible clouds of vapor or particles, there may be a serious exposure problem. Remember, however, that most gases and vapors are invisible, and that often the most dangerous particles are too small to see. Ø Settled dust – If there is chemical dust on the ground or other surfaces, it probably got there by settling out of the air. If disturbed, settled dust can become airborne again. The construction dust that continues to swirl in the garages, and be tracked into the common areas, and apartments is hazardous. The dust has coated the living environment and students’ possessions. Students are touching, breathing, sleeping in, this dust constantly. Living for weeks, months, with pervasive construction dust is unhealthy, and well-documented.
   2. Garbage, vomit, feces in hallways.
   3. Repeated requests to management to address the problems are ignored. In speaking with management on November 3, (Lance Tribble) he said The Standard does not have the resources to resolve the maintenance and parking issues, because all available resources are being prioritized and dedicated to finishing floors 7 and 8. But what about the people already there?
10. Apartments that students moved into, do not meet the promises of “luxury finishes” and “high quality construction”. Examples include: damage to walls, missing and damaged trim, damaged flooring, stained and filthy carpets, problems with the stoves, filthy windows.
11. In addition to the security problems noted above, and the sanitation issues noted above, and the dust issues noted above, students have been endangered by high level floors’ (floors 4 & 6) floor to ceiling windows opened without barricades in common areas.
12. The alley is the only way to enter the garage. The alley is not finished and hazardous. It is still not paved. It is incredibly dusty and uneven. There is a utility pole directly across level 1 exit, that is very difficult to avoid hitting. Leaving the garage is dangerous due to chaotic traffic patterns, the dust, and the pole. Sidewalks are not paved.
13. 13.Due to The Standards mismanagement and misinformation, student have experienced health issues ranging from: respiratory issues, headaches, stress, and anxiety. Students are also reporting significant negative impact to their grades due to the stress, disruption, and health impacts.
14. 14.During all of this, hundreds (and perhaps thousands) of emails were sent from frustrated, worried, and concerned parents (and guarantors) and students, and hundreds (and perhaps thousands) of phone calls were made. Repeatedly, The Standard did not reply to emails or return phone calls.
15. 15.The financial impact is large.
    • a.Since throughout all of this, we are all paying rent, at roughly an average of $800 per person per month, The Standard has charged rent of roughly $1.5 million dollars.
    • b.And, if each student put one month’s rent as a security deposit upon signing, The Standard has been holding roughly another half a million dollars. All while students are suffering, and being ignored.