encountered building materials and debris. Ms. Kinnard spoke with the defendant
the following day and instructed him to remove the debris from the property. After numerous
attempts to reinspect the property, Ms. Kinnard was able to gain access on November 24.
At that time, she discovered that the building materials and debris had been pushed to the rear
edge of the property, abutting the ravine. Ms. Kinnard was unable to access the property
again until April 7, 2010, at which time she encountered “a pile of junk, concrete, and
rubbish” on the lot, as well as dumpsters and equipment.

               On cross-examination, Ms. Kinnard testified that the ravine at the rear of the
Beacon Road properties runs behind 1925, 1915, and 1909Beacon Road, as well as other lots
on that road. Ms. Kinnard admitted that, since at least 2007, she had witnessed debris in the
ravine that had never been cleaned out. Ms. Kinnard admitted that Mr. Grifton Jones, whose
property was just east of 1909 Beacon Road and which also backed up to the ravine, was
cited for having debris and rubbish on his property at one time.

              On redirect examination, Ms. Kinnard testified that, in all of her dealings with
the defendant, he never complained that others were dumping debris on his property.

             Debra Hardaway with the City of Memphis office of Condemnation of Property
and Code Enforcement