Consent Decree United States v. Brinson (D. Nev.)

Date: 
Tuesday, June 14, 2016
Document Type: 
Settlement/Consent Decree

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VANITA GUPTA, Principal Deputy Assistant Attorney General for Civil Rights
SAMEENA-SHINAMAJEED,Chief
R. TAMAR HAGLER, Deputy Chief
AURORA BRYANT, Trial Attorney
CHRISTOPHER BELEN, Trial Attorney
United States Department of Justice
950 Pennsylvania Avenue NW
Washington, DC 20530
Tel: (202) 616-2602
Fax: (202) 514-1116
Aurora.Bryant@usdoj.gov

X   FILED

_ENTERED

_RECEIVEO

_SERVED ON             JUN 1 4 2016

COUNSEL/PARTIES OF RECORD

CLERK US DISTRICT COURT
DISTRICT OF NEVADA

DANIEL G. BOGDEN, United States Attorney
HOLLY A. VANCE, Assistant United States Attorney
100 West Liberty Street, Suite 600
Reno, Nevada
Tel: (775) 784-5438
Fax: (775) 784-5181

Attorneys for Plaintiff United States of America

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

UNITED STATES OF AMERICA,

Plaintiff,

v.

BETTY BRINSON and HUGHSTON
BRINSON,

Defendants.

Case No. 3:15-CV-359-HDM-VPC

CONSENT ORDER

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I. BACKGROUND

1. The United States Initiated this action on July 10,201 S, on behalf of Barbie Tese

and Stephen Tese and their three minor children (the "Teses"), as well as other aggrieved

persons, pursuant to Title VIII of the Civil Rights Act of 1968, as amended by the Fair

Housing Amendments Act of 1988 ("Fair Housing Act"), 42 U.S.C.§§ 3612(0) and 3614(a).

2. Defendants Betty Brinson and Hughston Brinson are residents of Nevada.

Defendants own and/or manage residential rental units in and/or around Carson City, Nevada.

3. The United States, in Its Complaint. alleges that Defendants refused to rent a "3 or

5" bedroom house located on Caroline Street in Carson City, Nevada, to Barbie Tese and

Stephen Tese because they had children, in violation of 42 U.S.C. § 3604(a) and (0); and that

Defendant Betty Brinson placed a series of printed and electronic advertisements indicating a

preference against renting dwellings to families with children, constituting a pattern or

practice of resistance to the full enjoyment of rights granted by the Fair Housing Act, and/or a

denial to a group of persons of rights granted by the Fair Housing Act that raises an issue of

general public importance.

4. The parties stipulate that this Court has subject matter jurisdiction over this action

pursuant to 28 U.S.C. §§ 1331 and 1345, and 42 U.S.C. §§ 3612(0) and 3614(a).

5. In an effort to avoid costly litigation, the parties have voluntarily agreed, as

indicated by the signatures below, to resolve the United States' claims against Defendants

without the necessity of a bearing on the merits and without admission of liability or

wrongdoing on the part of Defendants.

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Wherefore, It is ORDERED, ADJUDGED, and DECREED:

II. GENERAL INJUNCTION

6. Defendants, along with their agents, employees, successors, and all persons in

active concert with Defendants in their ownership, operation, or management of rental

housing, are enjoined from:

a. refusing to rent after the making of a bons fide offer, or refusing to

negotiate for the rental of, or otherwise making unavailable or denying, a:

dwelling to any person because of familial status in violation of 42 U.S.C. §

3604(a); and

c. making, printing, or publishing, or causing to be made, printed, or

published any notice, statement, or advertisement with respect to the rental of a

dwelling that indicates any preference, limitation, or discrimination based on

familial status in violation of 42 U.S.C. § 3604(c).

7.· Upon entry of this Consent Order, Defendants shall implement the Non-Discrimination

Policy appearing at Appendix A at all properties owned and/or managed, in

full or in part, by any Defendant.

III. NOTICE OF NON-DISCRIMINATION POLICY

8. Within thirty (30) days of the date of entry of this Consent Order; Defendants

shall take the following steps to notify the public of their non-discrlmination pollcy:

a.  Post and prominently display in all offices or areas Defendants may

currently or subsequently use for the rental of dwellings, a sign no smaller than

ten (10) inches by fourteen (14) inches indicating that all dwellings are available

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for rental on a nondiscriminatory basis. A poster that comports with 24 C.F .R.

Part 110 will satisfy this requirement.

b. Include the following written statement in all advertisements for rentals,

including advertisements in newspapers, Internet web pages, flyers, handouts,

telephone directories and other written materials, and on all rental applications

and all leases: "We are an equal opportunity housing provider. We do not

discriminate on the basis of race, color, religion, sex, disability, familial status

(having children under age 18), or national origin."

lV. MANDATORY TRAINING

9. Within ninety' (90) days after the entry of this Consent Order, Defendants Betty

Brinson and Hughston Brinson, and any individual who works with or for either Defendant

performing advertisement, rental, management, andlor adminlstrstive duties with respect to

the rental of housing owned andlor managed by either Defendant shall attend an educational

program offering instruction regarding their obligations under this Order and the federal Fair

Housing Act. Defendants shall pay the cost of this educational program. The United States

shall review and approve the content and form of the program. The trainer or training entity

shall be qualified to perform such training, Independent of Defendants and their counsel, and

approved in advance by the United States.

10. Any individuals hired or contracted to work with or for either Defendant who will

perform advertisement, rental, management, and/or administrative duties with respect to the

rental of housing owned and/or managed by either Defendant shall attend the fair housing

training program described in the above paragraph within thirty (30) days of the start of their

employment or contract Defendants shall bear any costs associated with this training.

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11.  Within ten (10) days of completing the educational program described In the

above paragraphs in this section, each individual shall certify that he or she has participated In

the educational training program, and understands and acknowledges his or her duties and

responsibilities under this Order and the federal Fair Housing Act, by completing an

acknowledgement in the form of Appendix B to this Order.

V. REPORTING AND RECORD·KEEPING REQUIREMENTS

12. Within one hundred twenty (120) days of the date of entry of this Consent Order,

and thereafter on the anniversary of the date of the entry of this Order, Defendants shall

submit to counsel for the United States a compliance report, except that the final report shall

be submitted sixty (60) days prior to the expiration of this Order.1 The compliance report

shall include: (a) copies of any training certifications completed as required by § IV, supra;

(b) copies of any advertising for rental housing owned andlor managed by Defendants in

newspapers, in telephone directories, on radio or television, on the Internet, or in other media

published since entry of this Order, or the submission of the prior compliance report; and (c)

photographs showing the Non-Discrimination Policy posted as required by § JU, supra.

13. Defendants shall notify counsel for the United States in writing within fifteen (15)

days of receipt of any written or oral complaint against any Defendant regarding housing

discrimination. If the complaint is written, Defendants shall provide a copy of it with the

notification. The notification shall include the full details of the complaint, including the

1 All correspolldence required to be sent to tho United St8tes under the provisions of this Order
shall be sent to: Chief, Housing and Civil Enforcement Section, Civil Rights Division, U.S. Department
of Justice, Attn: DJ 175-46-137, at the following address:
Regular U.S. Mail: 950 PCllnsylvania Avenue, NW - NWB
Washington, D.C. 20530
1800 G Street, NW
Suite 7002
Overnight Mail:
Washington, D.C. 20006

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complalaint's name, address, and telephone number. Defendants shall promptly provide the

United States all information responsive to any request pertaining to any such complaint, and

shall inform the United States in writing within fifteen (15) days of the terms of any resolution

of such complaint.

14. Defendants shall preserve all records related to this Order and to the rental

housing they own and/or manage. Such documents include, but are not limited to,

advertisements, applications, leases, and tenant files.  Upon reasonable notice to Defendants,

Defendants shall permit representatives for the United States to inspect and copy any records

related to this Order so as to determine compliance with the Order; provided, however, that

the United States shall endeavor to minimize any inconvenience to Defendants.

15. The United States may take steps to monitor Defendants' compliance with the

Consent Order including, but not limited to, conducting fair housing tests at the rental housing

owned and/or managed by Defendants to determine if Defendants are violating any part of

this Order.

VI.  ACQUISITION OR TRANSFER OF INTEREST IN DWELLINGS

16. Any Defendant who acquires a direct or indirect ownersblp interest in, or

management control over, a residential rental property shall notify counsel for the United

States within ten (10) days of that acquisition, by facsimile2 or emaiI3, and by mail. Any such

rental and any associated individuals involved in the rental or management of such rental shall

be covered by the terms of this Order.

2 Notice via facsimile is to be sent to (202) 514·' 116. Any submission must reference the case
name ("United Stllles v. Brinson") and/or OJ 17546·137.

3 Notice via email is to be sent to undersigned counsel for the United States, unless otherwise
directed.

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17. If at any time while this Consent Order remains in effect, any Defendant decides

to sell or otherwise transfer the entirety of their interest in any rental property owned and/or

managed, in full or in part, by either Defendant, to a bona-fide third-party purchaser in an

arm's length transaction, Defendant shall take the following steps:

a. At least thirty (30) days prior to completion of the sale or transfer, provide

the United States written notice of the Defendant's Intent to sell or otherwise

transfer interest in the property or mansgement services thereof, including the

prospective transferee's name, address and telephone number;

b. Within thirty (30) days following completion of the sale or other transfer,

the Defendant shall provide the United States a copy of the documents

memorializing the transfer in interest of the property;

c. If Defendants comply with Paragraph 17 a-b, and transfer all ownership,

management, or other financial interest to one or more properties covered by this

Order to an arms-length purchaser or other transferee, then Defendants shall

thereafter be relieved of obligations under this Consent Order with respect to the

those dwelling units or property In which all Interest was so transferred.

Defendants remain bound by Sections II (General lnjunction), VII (Monetary

Payment), VUI (Civil Penalty), and IX (Settlement Fund).

d. For purposes of this Older, "arms-length transaction" is defined as a

transaction that has been arrived at in the marketplace between independent, non-affiliated

persons, unrelated by blood or marriage, with opposing economic

Interests regarding that transaction. If the proposed transfer of Interest is not an

arms-Iength transaction, the Defendants shall remain jointly and severally liable,

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along with the purchaser or other transferee, for the obligations or violations of

this Order for its duration.

VII. MONETARY RELIEF

18. Defendants shall pay a total sum of $14,000 (fourteen thousand dollars) in

settlement of the case to Barbie Tese, Stephen Tese, and the three Tese minor children.

Within sixty (60) days of the date of the entry of this Order, Defendants shall deliver checks

payable pursuant to the written instructions to be provided by counsel for the United States to

Holly A. Vance, Assistant United States Attorney, 100 West Liberty Street, Suile 600, Reno,

Nevada 89501.

19. Upon receipt of the checks, the United States shall send to Defendants executed

releases (attached as Appendix C) of all claims, legal or equitable, that Barbie Tese, Stephen

Tese, and their three minor children may have against Defendants relating to the claims

asserted in this lawsuit, and shall thereafter deliver the checks to the Teses.

VIII. SETTLEMENT FUND

20. Within sixty (60) days of the date of entry of this Consent Order, Defendants shall

deposit in an interest-bearing escrow account the total sum of$10,OOO (ten thousand dollars)

for the purpose of compensating the aggrieved persons whom the Court determines were

harmed by the Defendant or Defendants' discriminatory practices (hereinafter "aggrieved

persons"). This money shall be referred to as the "Settlement Fund."

21. Any interest accruing to the fund shall become a part of the Settlement Fund and

be utilized as set forth herein.

22. All expenses related to the establishment of the account referenced in paragraph

20, supra, shall be borne by the Defendants.

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23. Within thlrty (30) days after the entry of this Order, Defendants shall publish the

notice set forth in Appendix: D in the Nevada Appeal. ThIs notice shall be no smaller than 3

columns by 6 inches and shall be published on three occasions in the classifieds section. The

publication dates shall be separated from one another by at least 21 days, and at least 2 of the

publication dates shall be Sunday. All of the costs associated with this notice, its publication,

and distribution shall be borne by Defendants.

24. Within thirty (30) days after the entry of this Order, Defendants shall provide a

copy of the notice set forth in Appendix D to all current residents of all residential rental

properties owned and/or managed in full or in part by any defendant, since January I, 2006.

and former residents to the extent Defendants have their contact information. To the extent a

former resident is deceased, or a current resident is incapacitated, Defendants shall send a

copy of the notice set forth in Appendh D to the last known next of kin or other responsible

party identified in Defendants' records.

25. Within thirty (30) days after the entry of this Order, Defendants shall make

available to the United States for inspection and copying all resident records for of all

residential rental properties owned and/or managed in full or in part by any defendant, since

January 1,2006, for the United States' use in identifying potential aggrieved persons. Such

records shall include, but not be limited to, records relating to resident complaints and records

relating to lease violations involving children.

26. Nothing in this Order shall preclude the United States from making its own efforts

to locate and provide notice to potential aggrieved persons (such as conducting door-to-door

interviews of current residents).

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27. Within 180 days of the entry of this Consent Order, the United States shall make a

determination as to which additional persons are aggrieved and an appropriate amount of

damages that should be paid to each aggrieved person. Defendants shall permit the United

States, upon reasonable notice, to review and copy any records that may facilitate its

determinations regarding the claims of allegedly aggrieved persons. The United States will

inform Defendants in writing of its determinations, and provide a copy of a sworn declaration

from each aggrieved person setting forth the factual basis of the claim. With respect to any

Identified aggrieved persons, Defendants shall have 14 days to review the declarations and

provide to the United States any documents or information that they believe may refute the

claims. After considering such documents and/or information, the United States will make the

final decision regarding the identity of, and amount payable to each aggrieved person, and

give notice of the distribution to the Court. Within ten (10) days after the filing of the notice

of distribution, the Defendants shall deliver to the United States checks payable to the

aggrieved persons in the amount listed in the notice of distribution, provided the aggrieved

person has executed a release in the form of Appendix C.

28. In no event shall the aggregate of all such checks exceed the amount of the

Settlement Fund, including any accrued interest.

29. In the event that less than the total amount in the Settlement Funds including

accrued interest is distributed to persons deemed aggrieved by the United States, the Court

shall order the remainder of the Settlement Fund to be distributed to a qualified

organization(s) for the purpose of conducting fair housing enforcement or educational

activities in the Reno and Carson City, Nevada areas. Before selecting the qualified

organization(s), the Defendants will obtain a proposal from the organization(s) on how the

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funds will be used consistent with the above-stated purpose, submit such proposal to the

United States, and consult with and obtain the non-objection of the United States. The United

States and the Defendants may request modification of the proposal before approving the

organization(s). The parties shall thereafter seek approval from the Court to distribute the

remaining funds to the qualified organlzalion(s). The qualified organizatlon(s) receiving the

funds shall submit to the United States and Defendants a detailed report on how the funds are

utilized within one year of receipt of funds, and every year thereafter until the funds are

exhausted.

IX. CIVIL PENALTY

30. Within sixty (60) days of the date of entry of this Consent Order, Defendants

shall pay a total of $12,000 (twelve thousand dollars) to the United States as a civil penalty,

pursuant to 42 U.S.C. § 3614(dXl)(C). The payment shall be in the forn of an electronic

funds transfer pursuant to written instructions to be provided by the United States.

31. In the event that any Defendant or any of their officers, agents, or employees is

found liable for any future violation of the Fair Housing Act, such violation shall Constitute a

"subsequent violation" pursuant to 42 U.S.C, § 3614(dXIXCXii).

X. SCOPE AND DURATION OF CONSENT ORDER

32. The provisions of this Consent Order shall apply to Defendants, their employees,

agents, successors, and all persons acting in active concert or participation with them.

33. This Order is effective immediately upon its entry by the Court and shall remain

in effect for five (5) years froin the date of entry.

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34. The Court shall retain jurisdiction over this action for all purposes related to the

enforcement of this Order throughout its term, after which time the case shall be dismissed

with prejudice.

35. The United States may move the Court to extend the period in which this Order is

In effect If it believes that any Defendant has likely violated one or more tenns, of this Order

or if the interests of justice otherwise require an extension.

36. The parties to this Order shall endeavor in good faith to resolve infornally any

differences regarding interpretation of and compliance with this Order prior to bringing such

matters to the Court for resolution. However, in the event that any Defendant either fails to

perforn in a timely manner any act required by this Order or acts in violation of any provision

of this Order, the United States may move the Court to impose any remedy authorized by law

or equity, including, but not limited to, an order requiring performance or non-performance of

certain acts and an award of any damages and costs that may have been occasioned by

Defendant's action or inaction.

37. Any time period set forth within this Order'for the performance of any act may be

changed by written agreement of the parties without Court approval.

Xl. COSTS OF LITIGATION

38. All parties shall be responsible for their own attorney's fees and costs associated

with this action.

Xl. TERMINATION OF LITIGATION HOLD

39. The parties agree that, as of the date of the entry of this Order,litigation Is not

"reasonably foreseeable" concerning the matters described in Paragraphs 1·4. To the extent

that either party previously implemented a litigation hold to preserve documents,

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electtonically stored information, things related to the matters described in Paragraphs 1-4,

the party is no longer required to maintain such a litigation hold. Nothing in this paragraph

relieves either party of any other obligations imposed by this Consent Order.

IT IS SO ORDERED, this 14th day of June, 2016

 

s/ Howard D. McKibben
THE HONORABLE HOWARD D. MCKIBBEN
UNITED STATES DISTRICT JUDGE
DISTRICT OF NEVADA

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Case 3:15-cv-00359-HDM
By their signatures below, the parties consent to the entry of this Consent Order

FOR THE UNITED STATES

Dated: May 20, 2016

DANIEL G BODGEN                             VANITA GUPTA
United States Attorney                       Principal Deputy Assistant Attorney General


HOLLY A VANCE                                 SAMEENA SHINA MAJEED
Assistant United States Attorney         Chief
United States Attorney's Office            R. TAMAR HAGLER
100 West Liberty Street, Suite 600       Deputy Chief
Reno, Nevada 89501                           AURORA BRYANT
Tel. (775) 784-5438                           CHRISTOPHER BELEN
Fax (775) 784-5181                           Taial Attorneys
                                                           Housing and Civil Enforcement Section
                                                           Civil Rights Division
                                                           U.S. Department of Justice
                                                           950 Pennsylvania Avenue, NW
                                                           Washington, DC 20530
                                                           Tel: (202) 305-4013
                                                           Fax: (202) 514-1116
                                                           Aurora.Bryant@usdoj.gov
FOR THE DEFENDANTS:

Dated: May 20, 2016

/S Betty Brinson

Dated: May 25th 2016

/s Hughston Brinson
 

By their signatures below, the parties consent to the enry of this Consent Order.

 

FOR THE UNITED STATES:
Dated: May 26, 2016

DANIEL G. BOGDEN                                      VANITA GUPTA
United States Attorney                                  Principal Deputy Assistant Attorney General

s/ HOLLY A VANCE                                       /S AURORA BRYANT
Assistant United States Attorney                   SAMEENA SHINA MAJEED
United States Attorney's Office                      R. TAMAR HAGLER
100 West Liberty Street, Suite 600                Deputy Chief
Reno, Nevada 89501                                    AURORA BRYANT
Tel: (775) 784-5438                                    CHRISTOPHER BELEN
Fax: (775) 784-5181                                   Trial Attorneys
                                                                    Housing and Civil Enforcement Section
                                                                    Civil Rights Division
                                                                    U.S. Department of Justice
                                                                    950 Pennsylvania Avenue, NW
                                                                    Northwestern Building, 7th Floor
                                                                    Washington, DC 20530
                                                                    Tel: (202) 305-4013
                                                                    Fax: (202) 514-1116
                                                                    Aurora.Bryant@usdoj.gov

 

FOR THE DEFENDANTS:

 

Dated:   _________________________
Betty Brinson __________________________
Dated:  ___________________________________
Hughston Brinson __________________________

APPENDIX A

Nondiscrimination Policy

It is the policy of this Landlord to comply with Title VllI of the Civil Rights Act of 1968,
as amended, commonly known as the Fair Housing Act, by ensuring that rental units are
available to all persens without regard to race, color, religion, national origin, disability, familial
status (having children under age 18), or sex. This policy means that, among other things, the
owners of this property and all their agents and employees with the responsibility for renting,
managing, or administering any apartments must not discriminate in any aspect of the rental of
dwellings against qualified applicants or tenants. Specificllily, they may not:

A. Refuse to rent, refuse to negotiate for the rental of, or otherwise make unavailable
or deny, a dwelling to any person'because of race, color, religion, national origin,
disability, famililll status, or sex;

B. Discriminate against any person in the terms, conditions or privileges of rental of
a dwelling, or in the provision of services or facilities in connection therewith,
because of race, color, religion, national origin, disability, familial status, or sex;

C. Make, print, or publish, or cause to be made, printed, or published any notice,
statement, or advertisement, with respect to the rental of a dwelling that indicates
any preference, limitation, or discrimination based on race, color, religion,
national origin, disability, familial status, or sex;

D. Represent to persens because of race, color, religion, national origin, disability,
familial status, or sex that any dwelling is not available for inspection or rental
when such dweiling is in fact so available; or

E.  Coerce intimidate, threaten, or interfere with any person in the exercise or
enjoyment of, or on account of his/her having exercised or enjoyed, or on account
of his/her having aided or encoouraged any other person In the exercise or
enjoyment of, any right granted or protected by the Fair Housing Act.

Any agent or employee who fails to comply with this Nondiscrimination Policy will be
subject to appropriate disciplinary action. Any action taken by an agent or employee that results
in unequal service to, treatment of, or behavior toward tenants or actua1 or potential applicants on
the basis of race, color, religion, national origin, disability, familial status, or sex may constitute
a violation of state and federal fair housing laws.

Any tenant or applicant who believes that any of the above policies have been violated by
any owner, agent, or employee may contact the U.S. Department of Housing and Urban
Development at 1.888·799-2085, or the U.S. Department of Justice at 1·800-896·7743 or 202·
514-4713.

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APPENDIX B

Certification of Completion of Training

On _______ , I successfully completed an in-person training on the

requirements of the federal Fair Housing Act, 42 U.S.C. §§ 3601-3631, including the prohibition

against discrimination based on familial status, in compliance with the Consent Order entered by

the United States District Court for the District of Nevada in Unltea States v. Brinson. I certify

that I fuliy understand my obligations under that Consent Order.

Signature  __________________________

Print name  ________________________

Job Title/Position  __________________

Date  _____________

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APPENDIX C

Full and Final Release of Claims

In consideration for the parties' agreement to the terms of the Consent Order entered in
United States v. Brinson. as approved by the United States District Court for the District of
Nevada, and in consideration for the payment of $  ___________, I _____________________
[print name]. do hereby agree. to remise. release. and forever discharge any and all claims of
any kind. nature or description whatsoever, related to the facts at issue In the litigation referenced
above, or in any way related to that litigation, up to and including the date of the entry of the
Consent Order. that I may have against Defendants Betty Brinson. Hughston Brinson, and their
agents. employees. officers. members. executors. spouses, administrators, successors, insurers,
and assigns.

I acknowledge and understand that, by signing this Release. I am waiving any right to
pursue my own legal action against Defendants Betty Brinson and Hughsion Brinson based on
the discrimination alleged by the United States in this case.

I also acknowledge thatl have been informed that I may review the terms of this Release
with an attorney of my choosing. and to the extent that 1 have not obtained legal advice.
I voluntarily and knowingly waive my right to do so.

I waive any claims I may have against the United States, the Department of Justice, or its
agents or employees. arising out of this action. This Release constitutes the entire agreement
between Defendants Betty Brinson. Hughston Briason, and me, without exception or exclusion.

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

Executed this _ day of ____, 20 .

Signature  ______________________

Print Name  ____________________

Address  ______________________

 

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APPENDIX D

NOTICE TO PUBLIC

On ______ , 2016, the United States District Court for, the District of

Nevada entered a consent order resolving litigation brought by the United States Department of

Justice in Carson City, Nevada. The litigation alleged that the Defendants, Betty Brinson and

Hughston Brinson, discriminated against residents on the basis on familial status by refusing to

rent to families with children and by placing discrimlnstory advertisements. The parties have

agreed to this Consent Order to avoid litigation.
 

Under this Consent Order, you may be entitled to receive monetary relief If you have or

had children In your household and were discriminated against on that basis while residing or

seeking to reside at any of the following properties:

- 704 W. Caroline St.

- 818 N. Minnesota St.

- 916 N. Minnesota St.

- 920 N. Minnesota St.

- 950 N. Minnesota St.

- 360 Bath St.

- 140 E. Park St.

- 144 E. Park St.

- 801 N. Carson St.

- 1421 N. Carson St.

Discrimination may include being turned away from renting because of the presence of

children In your household, or being evicted or threatened with eviction because of the presence

of children in your household.
 

If you believe that you have been discriminated against, please contact the United States

Department of Justice at 1·800·896-7743, mailbox number 991, or write or send an email to:

United States Department of Justice

Attn: DJ # 175-46-137

Case 3:15-cv-00359-HDM-VPC Document 38 Filed 06/14/16 Page 20 of 20

Civil Rights Division
Housing and Civil Enforcement Section
950 Pennsylvania Ave., NW - G Street
Washington DC 20530
Email address: fairhousing@usdoj.gov

Updated July 14, 2016