Housing And Civil Enforcement Cases Documents

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY


UNITED STATES OF AMERICA,
     Plaintiff,

v.

Civil Action No. 99cv2900 (JCL)

GARDEN HOMES MANAGEMENT, CORP.;
JOSEPH WILF; WESTBOUND
HOMES, INC.; REDSTONE GARDEN
APARTMENTS, INC.; and
CATHY ROSENSTEIN,
     Defendants.

___________________________________________


Consent Order

The United States initiated this action on June 21, 1999 pursuant to § 814 of the Fair Housing Act, 42 U.S.C. 3614, alleging that the Defendants have been engaged in a pattern or practice of discrimination on the basis of race in the rental of dwellings at Lakeview Garden Apartments, located at 200 Vail Road; Westgate Garden Apartments located at 350 Parsippany Road; and Redstone Garden Apartments, located at Redstone Drive ("Subject Properties"), in violation of the Fair Housing Act, as amended, 42 U.S.C. §§ 3601, et seq. On July 10, 2000, the Court granted the United States' Motion to Amend Complaint, authorizing the filing of the United States' Amended Complaint, which added a claim that Defendants' pattern or practice of discrimination included discrimination on the basis of familial status in the terms and conditions of rental, in violation of the Fair Housing Act, as amended, 42 U.S.C. 3604(b), et seq.

The Subject Properties are located in Parsippany, New Jersey, and are owned and/or managed by Defendants Garden Homes Management, Corp., Joseph Wilf, Westbound Homes, Inc. and Redstone Garden Apartments, Inc.("Defendants"). Defendant Rosenstein has been employed as the rental agent at the Subject Properties since 1988.

From April 1998 through May 1998, the United States and the Northern New Jersey Fair Housing Council conducted a series of fair housing tests which, as alleged by the United States, revealed that the Defendants engaged in racially discriminatory housing practices at the Subject Properties.

Other aggrieved persons have been identified who allege that they received similar discriminatory treatment on the basis of race and familial status when inquiring for housing at the Subject Properties in 1998 and 1999. A complete recitation of the facts can be found in the Court's Opinion denying the Defendants' Motion for Summary Judgment, US v. Garden Homes Management, Inc., 2001 WL 897586 (D.N.J. August 10, 2001).

The United States contends that the evidence that would be presented at trial demonstrates that the Defendants refused to rent, refused to negotiate for the rental and/or otherwise made housing unavailable because of race and familial status, and represented to a group of persons because of race and familial status that a dwelling was not available for rental when such dwelling was in fact so available, in violation of 42 U.S.C. § 3604.

The entry into an agreement to the terms and conditions of this Consent Order shall and do not constitute any admission by the Defendants.

The United States and Defendants desire to avoid costly and protracted litigation and have voluntarily agreed, as indicated by the signatures below, to resolve the United States' claims against the Defendants without the necessity of a trial. Therefore, the parties have waived a trial and have agreed to the entry of this Consent Order, as indicated by the signatures appearing below. The parties fully anticipate that the provisions of the Order shall ensure that the Defendants will fully comply with and otherwise avoid any violations of the Fair Housing Act. However, the parties agree that in the event that the Defendants do engage in any future violation(s) of the Fair Housing Act, such violation (s) shall constitute a "subsequent violation" pursuant to 42 U.S.C. § 3614(d)

Therefore, it is ORDERED, ADJUDGED and DECREED:

  1. Scope and Duration of Consent Order
    1. The provisions of this Consent Order shall apply to all the Defendants, their employees, agents, anyone acting under their direction, and all those acting in concert or participation with any of them.
    2. Joseph Wilf, as of the date of this Consent Order, is no longer involved in the daily activities of Garden Homes Management, Inc. properties and he is hereby, dismissed with prejudice from this action. If Joseph Wilf becomes involved again in the daily activities of the Garden Homes Management, Inc. he shall immediately comply with the education and training provision under Section V.
    3. The provisions of this Consent Order, except Sections VII and X, which provides for monetary relief, shall apply to all rental properties, which are owned, managed or whose managers are supervised by these Defendants.

      These complexes hereinafter are jointly referred to as "the Apartment Complexes."

    4. This Consent Order is effective immediately upon its entry by the Court and shall remain in effect for three (3) years from the date of entry or ninety (90) days after the last report under Section VII is received, whichever date is later.
    5. The Court shall retain jurisdiction over this action and over the Defendants during the three-year period specified above.

  2. Injunctive Relief

    The Defendants, their agents, employees, successors, and all persons in active concert or participation with any of them are enjoined, with respect to the rental of dwelling units at the subject Properties, from:

    1. Refusing to rent a dwelling unit, refusing or failing to provide or offer information about a dwelling unit, or otherwise making unavailable or denying a dwelling unit to any person because of race and familial status;
    2. Discriminating against any person in the terms, conditions or privileges of renting a dwelling unit, or in the provision of services or facilities in connection therewith, because of race and familial status;
    3. Making, printing, publishing, or causing to be made, printed, or published any notice, statement or advertisement with respect to the rental of a dwelling unit that states any preference, limitation or discrimination based on race and familial status;
    4. Misrepresenting to any person because of race, color or familial status that any dwelling unit is not available for inspection or rental when such dwelling unit is, in fact, so available;
    5. Taking any action to enforce, modify or enact any rules, regulations, policies, practices, or any other restrictions pertaining to occupancy at any of the Apartment Complexes, which prohibit families with minor children from residing in certain units of the complex, or which limit or purport to limit occupancy or use of facilities by families with children in any manner; and
    6. Engaging in any other discriminatory housing practice prohibited by 42 U.S.C. 3601, et seq.

  3. Notice to Public of Nondiscriminatory Policies

    Within twenty (20) days after the date of entry of this Consent Order, Defendants shall take the following steps to notify the public of their nondiscriminatory policies:

    1. Prominently post in the rental office at each of the Apartment Complexes, and in any office or apartment where there is rental activity and/or personal contact with prospective applicants for dwelling units at any of the Apartment Complexes, a Fair Housing sign no smaller than 10 inches by 13 inches that indicates that all apartments are available for rent on a nondiscriminatory basis. The sign shall conform with regulations promulgated by the U.S. Department of Housing and Urban Development, 24 C.F.R. Part 109;
    2. Whenever dwelling units are available at each of the Apartment Complexes, prominently post an easily readable "For Rent" or "Vacancy" sign or notice at the entrance to the complex and in front of the rental office. The sign or notice shall include the slogan "Equal Housing Opportunity" and the fair housing logo. Such slogan and logo shall be prominently displayed and easily readable;
    3. Include the words "Equal Housing Opportunity" and/or the fair housing logo in all advertising conducted for any of the Apartment Complexes (when next published or otherwise subscribed to) by Defendants or agents or employees in newspapers, telephone directories and other written materials; on radio, television or other media broadcasts; and on all billboards, signs, pamphlets, brochures and other promotional literature. The words and/or logo shall be prominently placed and easily readable. In addition, all newspaper and radio advertising regarding the Apartment Complexes subsequent to the date of entry of this Order shall conform to the provisions of the applicable advertising guidelines of the U.S. Department of Housing and Urban Development, 24 C.F.R. Part 109;
    4. Include the following phrase in the standard rental application and lease used for each of the Apartment Complexes, using letters of equal size to those of the text in the body of the document:

      We are an equal housing opportunity provider. We do not discriminate on the basis of race, color, sex, national origin, religion, handicap or familial status (having children under age 18); and

    5. Within twenty (20) days of the entry of this Consent Order, and on an annual basis thereafter so long as this Consent Order is in effect, provide written notification to the designated organizations listed in Attachment B that Defendants rent apartments at each of the Apartment Complexes, and that their policy is to rent apartments subject to uniform, nondiscriminatory standards to all qualified persons without regard to race, color, national origin, sex, handicap, or familial status.

  4. Standards for Accepting and Processing Applications

    Within ten (10) days of the entry of this Consent Order, Defendants shall, with respect to each dwelling rented at the Apartment Complexes:

    1. Maintain an accurate list of all dwelling units known or expected to be available for rental, including for each unit the address or apartment number, number of bedrooms, and monthly rent;
    2. Inform all persons who inquire about renting dwelling units of all available units at that complex of the type about which the person has inquired (e.g., one-bedroom or two-bedroom), if any, and if none are available, about the availability of the Waiting List;
    3. Permit all persons who inquire about renting dwelling units the opportunity to complete a written rental application and/or to be placed on the Waiting List;
    4. Permit all persons who inquire about renting dwelling units the opportunity to complete a written rental application and/or to be placed on a waiting list, which shall be maintained pursuant to subparagraph E, below; and
    5. Maintain a Waiting List of all persons who inquire about renting dwelling units and who wish to be placed on such a list in chronological order by date and time of inquiry. For each such person, the List shall state the person's name, current address and daytime and evening telephone numbers, a description of the dwelling desired (e.g., number of bedrooms), and, based on the good faith belief and observation of the Defendants or their agents or employees, the person's race (Black/Non-Hispanic, White/Non-Hispanic, Hispanic, Asian, Native American, or Other).

      When the defendants or their agents or employees become aware of any vacancy at the complex, they shall contact persons on the Waiting List in chronological order to offer them an opportunity to apply for the apartment, before making that dwelling unit available to any other person. Notations shall be made on the List of the date and time of each attempt to contact persons on the List.

  5. Mandatory Education and Training
    1. Within ninety (90) days after the date of entry of this Consent Order, the Defendants, as well as all agents or employees of the Defendants with responsibility for showing, renting or managing dwelling units at any of the Apartment Complexes, shall complete an educational program, to be conducted by ______________________ (entity to be approved by the United States) at the Defendants' expense, that shall include the following:
      1. Informing each individual of his or her duties and obligations under this Consent Order as well as under the federal Fair Housing Act and applicable state laws;
      2. Providing a copy of the federal Fair Housing Act to each agent or employee whose duties include showing, renting or managing dwelling units, and each agent or employee who supervises such activities;
      3. Instructing each individual on procedures to ensure that race or familial status does not enter into the process of providing rental information to persons who make inquiry or making decisions on rental applications;
      4. A question and answer session to review each of the foregoing areas;
      5. Securing the signed statement appearing at Attachment A from each such agent or employee indicating that he or she has received, read, and understands this Consent Order and the Defendants' policy of nondiscrimination and further understands that violation of this Order may result in sanctions against the Defendants by the Court; and
      6. Certification of attendance by the person conducting the educational program for each person attending the program.
    2. During the period in which this Consent Order is in effect, each new employee or agent of the Defendants shall complete the educational program described above and sign the statement appearing at Attachment A, within ten (10) days after the date on which he or she commences an employment or agency relationship with the Defendants.

  6. Attraction of African Americans and Other Minority Residents
    1. To remedy the consequences and effects of the Defendants' alleged past racially discriminatory housing practices, the Defendants agree to undertake reasonable efforts designed to attract African American and other minority group persons - who may have been, previous to the Consent Order, discouraged from applying to, or rejected for occupancy at, any of the Apartment Complexes - to apply for residence at the Apartment Complexes.
    2. Defendants further agree to undertake the following action throughout the duration of this Order:
      1. At least once a month Defendants shall publish a display advertisement of at least two columns by three inches in the news section of the Star-Ledger informing the public about the Apartment Complexes and describing the amenities available at the Apartment Complexes;
      2. Whenever Defendants publish an advertisement for actual or upcoming vacancies at any of the Apartment Complexes in any newspaper, Defendants shall publish the same advertisement in the Star Ledger; and
      3. Defendants shall notify the Agencies listed in Attachment B for all actual or upcoming vacancies at the Apartment Complexes so that those Agencies may refer potential applicants.

  7. Record Keeping and Monitoring
    1. With respect to the rental of dwelling units at the Subject Properties, Defendants shall ensure that each of the following are maintained for each complex:
      1. An Availability List on a daily basis that includes the address and apartment number of each unit known to be available or reasonably expected to be available for rental within thirty (30) days, the number of bedrooms in each such unit, the monthly rent for each such unit (including any rent special and/or other discounts), the date the Defendants or their agents or employees were first informed it would be available for rental, and the first date it would be available for rental or occupancy by a new tenant;
      2. An Inquiry Register on a daily basis of all persons who inquire about renting a dwelling unit. The Register shall contain space for each person to record the following information: the date of inquiry, the person's name, current address, telephone number, race and signature. The top portion of the Register shall contain the following disclaimer: "The following information is requested to assist [name of apartment complex] in complying with the federal Fair Housing Act and will be kept confidential. Providing your race is voluntary and this information is not required in order to rent an apartment"; and
      3. A Rental Application Log on a daily basis that sets forth the name and race of the applicant (based on the employee's or agent's good faith observation), whether the application for tenancy was approved or rejected, the building and unit number occupied for all approved applicants, and a detailed explanation for all rejected applications.
    2. Within one hundred twenty (120) days of the date of entry of this Consent Order, the Defendants shall deliver to counsel for the United States (1) the following documents:
      1. Copies of all mandatory education acknowledgments signed by Defendants' agents and employees and certifications of attendance at such educational program as required under Section V of this Order;
      2. A report detailing the occupancy of each dwelling unit in each of the Apartment Complexes, by race of occupant(s), as of the date of entry of this Order;
      3. A listing, by unit number and familial status of the occupants, of the move-ins and of the move-outs during the reporting period; and
      4. A photograph of each office or apartment in which rental or sales activity is conducted, showing the fair housing signs required by Section III of this Order.
    3. Within six (6) months of the date of entry of this Consent Order, and every six (6) months thereafter for the period in which the Order is in effect, the Defendants shall deliver to counsel for the United States a detailed report covering the preceding six months containing information about the Defendants' compliance efforts, including but not limited to:
      1. Copies of all mandatory education acknowledgments signed by Defendants' agents and employees and all certifications of attendance of the Defendants, their agents and employees in such educational program, pursuant to Section V of this Order;
      2. Copies of the Availability Lists, Inquiry Registers, Rental Application Logs and Waiting Lists maintained pursuant to Section VII of this Order;
      3. A list setting forth the occupancy of each dwelling unit in each of the Apartment Complexes, by race and familial status of occupant(s), as of the close of the reporting period;
      4. A list setting forth the move-ins and move-outs at each Apartment Complex, by unit number and race as of the close of the reporting period; and
      5. A listing, by unit number and familial status of the occupants, of the move-ins and of the move-outs as of the close of the reporting period.
    4. During the period in which this Consent Order is in effect, the Defendants shall preserve all records that are the source of, contain, or relate to any of the information pertinent to the obligations under this Order, including all rental applications, leases, and Occupancy Lists for dwelling units at the Apartment Complexes. Upon reasonable notice to counsel for the Defendants, representatives of the United States shall be permitted to inspect and copy all such records at any and all reasonable times.
    5. During the period in which this Consent Order is in effect, the Defendants shall notify counsel for the United States in writing within fifteen (15) days of receipt of any written or oral complaint against the Defendants, the Apartment Complexes, or the Defendants' agents or employees, regarding equal opportunity or discrimination in housing. If the complaint is written, the Defendants shall provide a copy of it with the notification. The notification shall include the full details of the complaint, including the complainant's name, address, and telephone number. The Defendants shall also promptly provide the United States all information it may request concerning any such complaint and its actual or attempted resolution.

  8. Compliance Testing

    Defendants shall conduct testing designed to detect and prevent any future acts of discrimination at any of the Apartment Complexes. Within 180 days of the date of entry of this Order, Defendants will enter into a contract with a company or organization with experience in discrimination testing (to be approved by the United States), to develop and implement a program to test for racial and familial status discrimination at each of the Apartment Complexes. The contract will provide for a minimum of three paired tests per year at each of the Apartment Complexes for the duration of the Consent Order. Defendants will review the testing results with the relevant individual employees and will use the results to determine how to address any concerns with individual employees and whether changes in training are necessary. Every six months, Defendants will provide copies of all test reports and other documents related to the tests to the United States.

  9. Provisions Relating to Cathy Rosenstein

    In the event the Cathy Rosenstein leaves the employment of Garden Homes Management and continues to be involved in the business of leasing or selling dwellings, Defendant Rosenstein shall promptly notify Counsel for the United States that she intends to become involved in the business of leasing or selling dwellings and shall inform Counsel of the name and location of such business.

  10. Compensation of Aggrieved Persons
    1. Within ten (10) business days after entry of this Order, Defendants shall deposit the sum of $200,000.00 in an interest- bearing account for the purpose of compensating any aggrieved persons who may have been the victims of the discriminatory housing practices at Subject Properties, and who may be identified through the procedures set forth in this Section. Also within ten (10) of the date of entry and filing of this Consent Order with the Clerk of the United States District Court for the District of New Jersey, the Defendants shall submit proof to the United States that the account has been established and the funds deposited.
    2. At least once each week during the ninety (90) days following the date of entry of this Consent Order, including on at least five Sundays, Defendants shall arrange and publish a Notice to Potential Victims of Housing Discrimination ("Notice") as follows:
      1. Each Notice shall appear in the news sections of newspapers and periodicals known to have significant minority readerships, and shall be at least an eighth of a page;
      2. Each Notice shall set forth a summary of the legal and evidentiary contentions of the United States and a general statement of the relief provided under this Consent Order. Each Notice shall also contain a statement that the United States seeks information from any persons who claim to have been subjected to racial or familial status discrimination at the Subject Properties in connection with inquiring about, applying for or obtaining housing, or with respect to the terms or conditions or privileges of housing. Each Notice shall invite such persons to contact counsel for the United States concerning their complaints within ninety (90) days of the publication of the Notice. The Text of this Notice shall be as set forth in Attachment D-F; and
      3. Defendants shall provide a copy of the newspaper containing each such Notice to counsel for the United States within three (3) days after publication of the Notice. Defendants shall notify counsel for the United States in writing of the date on which the last such notice was published within five (5) days of its publication.
    3. Defendants shall produce or permit representatives of the United States to review any rental/tenancy records of the Subject Properties in the possession or control of the Defendants, their agents or employees, upon notice to Defendants' counsel, which the United States believes to be useful in identifying persons who may be entitled to relief under this Order. Upon reasonable notice, the Defendants shall provide such rental/tenancy records or shall permit representatives of the United States to receive copies of such rental/tenancy records through Defendants' counsel or alternatively to make such an inspection of rental/tenancy records on any business day.
    4. Allegedly aggrieved persons shall have ninety (90) days from the date of the last published Notice within which to contact the United States to assert any claims in connection with this Order.
    5. Within one hundred eighty (180) days from the date of the last published Notice, the United States shall determine which persons, who have timely contacted the United States, are likely to have been victims of the discriminatory housing practices at the Subject Properties, and shall determine in its sole discretion an appropriate amount of damages to be awarded to each such person, provided that:
      1. No person shall be paid pursuant to this Section until after execution of a written release [Attachment C] of all claims, legal or equitable, that he or she might have against the Defendants relating to the claims asserted in this lawsuit; and
      2. The total amount to be paid by the Defendants pursuant to this Section shall not exceed $200,000.00 plus any interest accrued in the account established under subsection A.
    6. The United States shall notify the Defendants in writing of its determinations. Within thirty (30) days after receiving this written notification, the Defendants shall deliver to counsel for the United States checks to the aggrieved persons payable as directed in the written notification. Counsel for the United States shall not forward an aggrieved person's check to that person until the United States has received that person's executed release of claims.
    7. In the event that the United States distributes less than the total amount of compensation for aggrieved persons specified in Section A, above, seventy percent (70%) of the remainder shall be paid to the Urban League of Morris County and thirty percent (30%) of the remainder shall be paid to the Morris County Fair Housing Council. Both organizations are engaged in activities that promote fair housing in the Morris County, New Jersey area.

  11. Civil Penalty
    1. Within thirty (30) days after the entry of this Consent Order, the Defendants, jointly and severally, shall pay the sum of $50,000.00 to the United States as a civil penalty, pursuant to 42 U.S.C. 3614(d)(1)(C). This payment shall be delivered to counsel for the United States in the form of a cashier's check payable to the "United States Treasury."
    2. In the event that any of the Defendants or their agents or employees engage in any future violation(s) of the Fair Housing Act, such violation(s) shall constitute a "subsequent violation" pursuant to 42 U.S.C. 3614(d).

  12. Remedies for Non-Compliance
    1. The United States may move the Court to extend the period in which this Order is in effect if it determines that the Defendants have violated one or more terms of the Order or if the interests of justice otherwise require an extension of the terms of the Order.
    2. The parties to this Consent Order shall endeavor in good faith to resolve informally any differences regarding interpretation of and compliance with this Order prior to bringing such matters to the Court for resolution. However, in the event of a failure by any of the Defendants, whether willful or otherwise, to perform in a timely manner any act required by this Consent Order or otherwise to act in violation of any provision thereof, the United States may move this Court to impose any remedy authorized by law or equity, including, but not limited to, an order requiring performance of such act or deeming such act to have been performed, and an award of any damages, costs, and attorney' fees which may have been occasioned by the Defendants' violation or failure to perform.

  13. Time for Performance

    Any time limits for performance imposed by this Consent Order may be extended by mutual written agreement of the parties.

ORDERED this ____________________ day of ________________, 2001.

______/sig/______________
UNITED STATES DISTRICT JUDGE


The undersigned agree to and request the entry of this Consent Order:

For the United States:



ROBERT J. CLEARY
United States Attorney

RALPH BOYD
Assistant Attorney General

MICHAEL A. CHAGARES
Assistant U.S. Attorney
970 Broad Street
Suite 700
Newark, N.J. 07102
(201) 645-2700

JOAN A. MAGAGNA
Chief
JON M. SEWARD
Deputy Chief
ERIC I. HALPERIN
RHONDA L. CAMPBELL
Attorneys
U.S. Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section
P.O. Box 65998
Washington, D.C. 20035-5998
(202) 305-2951

For the Defendants:


PETER W. TILL, Esq.
105 Morris Avenue, Suite 201
Springfield, New Jersey 07081

ATTACHMENT A

On _______________________, 2001, I was instructed by ________________________ with respect to my responsibilities under the Consent Order entered by the federal district court in United States v. Garden Homes Management, Corp., et al., C.A. No. 99cv2900 (D.N.J.), the federal Fair Housing Act and applicable state laws. I also was instructed as to the [Name of Apartment Complex] rental policies and procedures. I have received copies of and have read the Consent Order and the federal Fair Housing Act. I understand my legal responsibilities and will comply with those responsibilities. I further understand that the Court may impose sanctions on me if I violate a provision of this Order and that my employer may also discipline me if I violate a provision of this Order. I have been informed by my employer that I will not be reprimanded by my employer for providing information to any law enforcement agency (including the U.S. Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, P.O. Box 65998, Washington, D.C. 20035-5998, telephone 202-514-4713) or official regarding my employer's compliance with the Fair Housing Act and/or the Consent Order.

_______________________
(Signature)
_______________________
(Print Name)
_______________________
(Date)


ATTACHMENT B
LIST OF NEW JERSEY HOUSING GROUPS

Fair Housing Council of Northern New Jersey
131 Main Street, Suite 140
Hackensack, NJ 07601

Housing Coalition of Central New Jersey
78 New Street, Suite #3
New Brunswick, NJ 08901

Morris County Fair Housing Council
65 Spring Street
P.O. Box 773
Morristown, NJ 07963

Urban League of Morris County
13 ½ James Street
Morristown, NJ 07927


ATTACHMENT C RELEASE

In consideration for the parties' agreement to the terms of the Consent Order entered in United States v. Garden Homes Management, et al., Civil Action No. 99cv2900 (D.N.J.), and the Defendants' payment to me [and my spouse jointly] of $_______________, I hereby release and forever discharge all claims related to the facts at issue in the litigation referenced above, or in any way related to that litigation, and any other claims arising from alleged housing discrimination up to and including the date of execution of this release, that I may have against any of the Defendants, their heirs, executors, administrators, successors or assigns.

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

          Executed this ____ day of _____________, 2001.

____________________________
[Name]


ATTACHMENT D NOTICE TO POTENTIAL VICTIMS OF DISCRIMINATION AT LAKEVIEW GARDEN APARTMENTS, PARSIPPANY, NEW JERSEY
[Insert Picture]

On _________________, 2001, the United States District Court for the District of New Jersey entered a Consent Order resolving a lawsuit brought by the United States Department of Justice against the owners, managers and rental agents of Lakeview Garden Apartments. The lawsuit alleged that the Defendants had discriminated against African Americans and families with children who sought rental housing at Lakeview Gardens. Under this Consent Order, you may be entitled to receive monetary relief if you asked about, applied, or rented an apartment at Lakeview Garden Apartments (partially pictured above), an apartment complex located at 200 Vail Road, Parsippany, New Jersey, at any time after January 1, 1996, and:

  1. You may have been denied an opportunity to live there because of your race or the race of someone who would be living with you; or
  2. You may have been denied falsely told that no apartments were available because of your race or the race of someone who would be living with you; or
  3. You may have been otherwise discriminated against on the basis of race in connection with your occupancy at Lakeview Garden Apartments or your attempt to rent a unit there; or
  4. You may have been denied an opportunity to live there because you had children under the age of 18 in your family; or
  5. You may have been required to live on in a first floor apartment unit because you had children under the age of 18 in your family.

If you believe you have been discriminated against because of race or because they had children under the age of 18 at Lakeview Garden Apartments, or if you have any information about persons who may have been discriminated against there on the basis of race or because they had children under the age of 18, please contact _______________ at ___________, or the United States Department of Justice, at 1-800-896-7743. You may also write to:

United States Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section
P.O. Box 65998
Washington, D.C. 20035-5998.

NOTE: You must call or write no later than ninety (90) days from [INSERT DATE OF PUBLICATION OF ADVERTISEMENT].


ATTACHMENT E NOTICE TO POTENTIAL VICTIMS OF DISCRIMINATION AT REDSTONE GARDEN APARTMENTS, PARSIPPANY, NEW JERSEY
[Insert Picture]

On ______________________________, 2001, the United States District Court for the District of New Jersey entered a Consent Order resolving a lawsuit brought by the United States Department of Justice against the owners, managers and rental agents of Redstone Garden Apartments. The lawsuit alleged that the Defendants had discriminated against African Americans and families with children who sought rental housing at Redstone Gardens. Under this Consent Order, you may be entitled to receive monetary relief if you asked about, applied, or rented an apartment at Redstone Garden Apartments (partially pictured above), an apartment complex located on Redstone Drive, Parsippany, New Jersey, at any time after January 1, 1996, and:

  1. You may have been denied an opportunity to live there because of your race or the race of someone who would be living with you; or
  2. You may have been falsely told that no apartments were available because of your race or the race of someone who would be living with you; or
  3. You may have been otherwise discriminated against on the basis of race in connection with your occupancy at Lakeview Garden Apartments or your attempt to rent a unit there; or
  4. You may have been denied an opportunity to live there because you had children under the age of 18 in your family; or
  5. You may have been required to live on in a first floor apartment unit because you had children under the age of 18 in your family.

If you believe you have been discriminated against because of race or because they had children under the age of 18 at Redstone Garden Apartments, or if you have any information about persons who may have been discriminated against there on the basis of race or because they had children under the age of 18, please contact _______________ at ___________, or the United States Department of Justice, at 1-800-896-7743. You may also write to:

United States Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section
P.O. Box 65998
Washington, D.C. 20035-5998.

NOTE: You must call or write no later than ninety (90) days from [INSERT DATE OF PUBLICATION OF ADVERTISEMENT].


ATTACHMENT F NOTICE TO POTENTIAL VICTIMS OF DISCRIMINATION AT WESTGATE GARDEN APARTMENTS, PARSIPPANY, NEW JERSEY
[Insert Picture]

On ________________________, 2001, the United States District Court for the District of New Jersey entered a Consent Order resolving a lawsuit brought by the United States Department of Justice against the owners, managers and rental agents of Westgate Garden Apartments. The lawsuit alleged that the Defendants had discriminated against African Americans and families with children who sought rental housing at Westlake Gardens. Under this Consent Order, you may be entitled to receive monetary relief if you asked about, applied, or rented an apartment at Westgate Garden Apartments (partially pictured above), an apartment complex located at 350 Parsippany Road, Parsippany, New Jersey, at any time after January 1, 1996, and:

  1. You may have been denied an opportunity to live there because of your race or the race of someone who would be living with you; or
  2. You may have been falsely told that no apartments were available because of your race or the race of someone who would be living with you; or
  3. You may have been otherwise discriminated against on the basis of race in connection with your occupancy at Lakeview Garden Apartments or your attempt to rent a unit there; or
  4. You may have been denied an opportunity to live there because you had children under the age of 18 in your family; or
  5. You may have been required to live on in a first floor apartment unit because you had children under the age of 18 in your family.

If you believe you have been discriminated against because of race or because they had children under the age of 18 at Westgate Garden Apartments, or if you have any information about persons who may have been discriminated against there on the basis of race or because they had children under the age of 18 , please contact _______________ at ___________, or the United States Department of Justice, at 1-800-896-7743. You may also write to:

United States Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section
P.O. Box 65998
Washington, D.C. 20035-5998.

NOTE: You must call or write no later than ninety (90) days from [INSERT DATE OF PUBLICATION OF ADVERTISEMENT].


1. All documents or other communications required by this Order to be sent to counsel for the United States shall be addressed as follows: Chief, Housing and Civil Enforcement Section, Civil Rights Division, DJ 175-48-225, United States Department of Justice, P.O. Box 65998, Washington, D.C. 20035-5998.


Document Signed: September 21, 2001.
Entered: September 25, 2001.
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Updated August 6, 2015

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