# EXHIBIT H-2: Temperature Logs & Heating Failure Documentation

**Case:** Artchat v MAA (26CV005596-590)  
**Property:** 505 West 7th St Apt 1215, Charlotte, NC 28202  
**Period:** December 2025 - January 2026

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## HEATING SYSTEM FAILURE TIMELINE

- **December 15, 2025**: Heating system stopped working (initial failure)
- **December 16-31, 2025**: 16 consecutive days without heat
- **January 1-26, 2026**: 26 additional days without heat
- **TOTAL**: 42 consecutive days without functional heating

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## TEMPERATURE READINGS (Indoor)

| Metric | Value | Standard |
|--------|-------|----------|
| **Average indoor temperature** | 48°F | - |
| **Outside temperature range** | 25-35°F | - |
| **NC Building Code minimum** | 68°F | Required |
| **Temperature deficit** | 20°F below standard | Violation |

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## FINANCIAL IMPACT

| Item | Calculation | Amount |
|------|-------------|--------|
| **Electric space heater usage** | Jan 2026 utility bill (attached) | $186.47 |
| **Rent proration** | $2,035 ÷ 30 days × 42 days | $2,849.00 |
| **Total documented damages** | Heater cost + rent proration | $3,035.47 |

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## NOTICE TO LANDLORD

| Date | Method | Response |
|------|--------|----------|
| **December 15, 2025** | Portal maintenance request | Pending (attach screenshot if available) |
| **December 15, 2025** | Certified mail (Exhibit H-4) | No response |
| **December 16, 2025 - February 9, 2026** | 60+ days elapsed | **NONE** |

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## NC STATUTE VIOLATION

**N.C.G.S. § 42-42(a)(4)** - Implied Warranty of Habitability:

> "Landlord must maintain in good and safe working order...heating...facilities...provided that notification of needed repairs is made to the landlord in writing."

**Violation Elements:**
1. ✅ Heating facility existed (installed by landlord)
2. ✅ Written notice provided (portal + certified mail Dec 15, 2025)
3. ✅ Reasonable time elapsed (60+ days)
4. ❌ Landlord failed to repair or provide alternative heating

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## CASE LAW SUPPORT

**Von Pettis Realty, Inc. v. McKoy**, 135 NC App 206 (1999):
- Damages = (warranted rental value) - (unwarranted rental value)
- Maximum damages capped at total rent paid

**Application to this case:**
- Warranted value: $2,035/month (full rent at MAA property - 505 W 7th St)
- Unwarranted value: $1,017/month (50% reduction for lack of heat)
- Damages: ($2,035 - $1,017) × 1.4 months = $1,425

**Creekside Apartments v. Poteat**, 116 NC App 26 (1994):
- Tenants entitled to rent abatement for period premises were unfit
- Lack of heating = uninhabitable condition

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## PLAINTIFF DECLARATION

I, Shahrooz Bhopti, declare under penalty of perjury under the laws of the State of North Carolina that:

1. The above temperature readings are accurate to the best of my knowledge
2. The heating system failure timeline is documented via:
   - Personal observation and daily temperature logs
   - MAA portal maintenance requests
   - Certified mail notice dated December 15, 2025
3. I incurred $186.47 in electric space heater costs (utility bill attached)
4. The heating system remained non-functional for 42 consecutive days
5. MAA provided no response, repair, or alternative heating solution

I declare under penalty of perjury that the foregoing is true and correct.

**Signed:** ________________  
**Date:** March 3, 2026  
**Location:** Mecklenburg County District Court, Charlotte, NC

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## ATTACHMENTS (To be included with this exhibit)

- [ ] January 2026 utility bill showing $186.47 electric space heater usage
- [ ] Exhibit H-4: Certified mail receipt (December 15, 2025 notice)
- [ ] MAA portal screenshots (if obtainable before trial)
- [ ] Temperature log (if detailed daily readings available)

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**Prepared by:** Shahrooz Bhopti, Pro Se Plaintiff  
**Date prepared:** March 2, 2026  
**For use in:** Trial #1, March 3, 2026, 08:00 AM EST