Declaration of Joshua Chambless — Chambless v. Redfield

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IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF LOUISIANA 
MONROE DIVISION 
CHAMBLESS ENTERPRISES LLC;  
and APARTMENT ASSOCIATION OF 
LOUISIANA, INC.,  
Plaintiffs, 
v. 
CENTERS FOR DISEASE CONTROL AND 
PREVENTION, et al., 
Defendants.
Case No.  3:20-cv-01455
Judge Terry A. Doughty 
Magistrate Judge Karen L Hayes
 DECLARATION OF  
JOSHUA CHAMBLESS IN SUPPORT 
OF PLAINTIFFS’ MOTION FOR 
PRELIMINARY INJUNCTION  
I, JOSHUA CHAMBLESS, make this declaration based upon my personal knowledge, 
information and belief and state: 
1. I am a resident of the Louisiana and am over the age of 18.
2. I am the sole owner of Chambless Enterprises LLC.
3. I have reviewed the Complaint in this matter and verify the factual allegations set out
in paragraphs 12 and 37-41 based on my personal knowledge. I am also familiar with
the September 4, 2020, order issued by the Center for Disease Control, prohibiting
eviction of non-paying tenants who submit Renter’s Declarations (“Temporary Halt in
Residential Evictions to Prevent the Further Spread of COVID-19”).
4. Chambless Enterprises owns and manages 725 rental units in Louisiana, including 14
apartment complexes and several single-family homes in the cities of Monroe, West
Monroe, Lakeshore and Calhoun.
5. Under our lease agreements, rent is due for our tenants on the first of the month;
however, we allow a five-day grace period before late fees will begin to accrue. If a

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tenant is behind on rent for a month I will typically begin the eviction process at that 
time, unless they have agreed to a repayment plan.  
6. On March 17, 2020, Chambless Enterprises entered a lease with a tenant who it would 
like to evict (“Tenant A”). Tenant A’s base-rent is $695.00.  
7. Tenant A last paid rent on July 22, 2020. Tenant A failed to work-out a repayment plan. 
Accordingly, on August 17, 2020, Chambless Enterprises filed for eviction against 
Tenant A. Exhibit A. 
8. At the eviction hearing, on September 17, 2020, before the City Court of West Monroe, 
the Tenant A submitted Renter’s Declaration. Exhibit B. For this reason, the City Court 
of West Monroe refused to issue a writ to compel eviction through pendency of the 
CDC eviction moratorium.  
9. Tenant A is still behind on rent, and currently carries a balance of $3,925.00. If Tenant 
A fails to pay anything between now and December 31, 2020, the outstanding balance 
on this account will be $4,620.00. 
10. Chambless Enterprises has another tenant it would like to evict for non-payment of rent 
(“Tenant B”). Tenant B signed a lease on August 1, 2017, which has been renewed 
annually since then. Under the current lease, Tenant B agreed to pay a base-rent of 
$710.00.  
11. Tenant B last paid rent on August 25, 2020. Tenant B attempted to set-up a payment 
plan in October; however, Tenant B failed to make any payments under that plan.  
12. Chambless Enterprises cannot evict Tenant B because the tenant has signed a Renter’s 
Declaration on September 9, 2020. Exhibit C. Tenant B’s outstanding balance is 
$3,090.00, and if the tenant fails to pay anything between now and December 31, 2020, 
the outstanding balance on this account will be $3,800.00. 
13. Chambless Enterprises also had another non-paying tenant who signed a Renter’s 
Declaration (“Tenant C”) on September 12, 2020. Exhibit D. Tenant C moved out on 


Chambless Decl. Exh. A

Chambless Decl. Exh. B

Chambless Decl. Exh. C

Chambless Decl. Exh. D





IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF LOUISIANA 
MONROE DIVISION 
CHAMBLESS ENTERPRISES LLC; and 
APARTMENT ASSOCIATION OF 
LOUISIANA, INC.,  
Plaintiffs, 
v. 
CENTERS FOR DISEASE CONTROL AND 
PREVENTION, et al., 
Defendants.
Case No. ___________ 
DECLARATION OF  
TAMMY ESPONGE IN SUPPORT OF 
PLAINTIFFS’ MOTION FOR 
PRELIMINARY INJUNCTION  
I, TAMMY ESPONGE, make this declaration based upon my personal knowledge, 
information and belief and state: 
1. I am a resident of the State of Louisiana and am over the age of 18.
2. I have reviewed the Complaint in this matter and verify the factual allegations set out
in paragraphs 13, and 42-45 based on my personal knowledge. I am also familiar with
the September 4, 2020, order issued by the Center for Disease Control, prohibiting
eviction of non-paying tenants who submit Renter’s Declarations (“Temporary Halt in
Residential Evictions to Prevent the Further Spread of COVID-19”).
3. I am the Association Executive for the Apartment Association of Louisiana (“AAL”).
In this role I advocate on behalf of Louisiana’s landlord community, including AAL’s
376 owner/manager companies. AAL’s membership owns and or manages
approximately 118,000 rental units across Louisiana.

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4. AAL coordinates with various local apartment associations across Louisiana. When a 
member joins their local apartment association they are automatically enrolled as a 
member of AAL at the state-level.  
5. In addition to my role with the AAL, I am the Association Executive for the Greater 
New Orleans Apartment Association, the Houma Apartment Association, and the 
Thibodaux Apartment Association. In my capacity as Association Executive for AAL, 
and on behalf of these local apartment associations, I have heard from many landlord 
and management companies that are facing challenges under CDC’s eviction 
moratorium (“CDC Order”).  
6. I have heard from many Louisiana landlords and management companies that have 
received Renters Declarations from non-paying tenants. They are unable to evict these 
non-paying tenants because of the CDC Order.  
7. Based on my experience in the field of property management, individuals who are three 
or more months behind on rent and have been unable to make even partial payments 
typically will not have funds to pay back that rent after an eviction proceeding and 
claim for back rent. Accordingly, AAL members will not likely recover rents owed by 
non-paying tenants covered by the CDC Order. And AAL members are precluded from 
replacing non-paying tenants, who have signed Renter’s Declarations, with tenants who 
are willing and able to pay. 
8. I know that AAL members typically rely on rental income from their properties to pay 
for their mortgages, taxes, and other overhead expenses, such as repairs, replacement 
of appliances, and other necessary improvements. AAL members also typically rely on 
rental income to cover other property management costs, including landscaping 
contracts, and maintenance of various amenities. 
9. I can attest that AAL members have changed their policies with regard to screening 
prospective tenants in response to the CDC Order. Because the CDC Order prohibits 


 
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CERTIFICATE OF SERVICE 
I certify that on this 12th day of November, 2020, I served copies of the foregoing on all 
Defendants in this action pursuant to Federal Rule of Civil Procedure 5(b)(2)(C) by delivering 
copies to the U.S. Postal service to be sent by certified mail to their last known address. 
By /s/ JAMES C. RATHER, JR 
.  
          JAMES C. RATHER, JR.

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