UNITED STATES DISTRICT COURT
                         DISTRICT OF MASSACHUSETTS

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

   BOSTON HOUSING AUTHORITY,
        Defendant.

   __________________________________

                                 COMPLAINT

   The United States of America alleges as follows for its Complaint in
   this matter:

    I. INTRODUCTION
         1. The United States alleges that the defendant, Boston Housing
            Authority, has violated the rights under the Fair Housing
            Act, as amended, 42 U.S.C. § 3601 et seq., of numerous
            tenants, and has engaged in a pattern or practice of
            discrimination by tolerating and failing to protect tenants
            from pervasive and violent racial harassment at housing
            developments that the defendant owns and operates. This
            harassment includes, but is not limited to, racially
            motivated acts of physical violence and the threat of
            physical violence, destruction of property, racist graffiti,
            and racist name-calling. The United States alleges that the
            defendant - despite its knowledge of pervasive racial
            harassment in its developments and, in some cases, of the
            identity of the harassers - failed to adequately document,
            investigate, or otherwise respond to or address the problem.
            Through its systemic failure to protect tenants from such
            harassment, the BHA has, because of race, color, or national
            origin, (a) made housing unavailable to those tenants; (b)
            discriminated against those tenants in the terms, conditions
            or privileges of rental; and (c) coerced, intimidated,
            threatened, or interfered with those tenants in the exercise
            or enjoyment of rights granted or protected by the Fair
            Housing Act. The United States seeks declaratory, injunctive,
            and monetary relief.
   II. JURISDICTION AND VENUE
         2. This action is brought by the United States to enforce the
            Fair Housing Act, Title VIII of the Civil Rights Act of 1968,
            as amended by the Fair Housing Amendments Act of 1988, 42
            U.S.C. §§ 3601 - 3619.

                        UNITED STATES DISTRICT COURT
                     FOR THE DISTRICT OF MASSACHUSETTS

   JANE DOE No. 1, et al.,
       Plaintiffs,

   v.

   THE CITY OF BOSTON and
   THE BOSTON HOUSING AUTHORITY,
       Defendants.

   ______________________________       CONSOLIDATED WITH

   UNITED STATES OF AMERICA,
       Plaintiff,

   v.

   THE BOSTON HOUSING AUTHORITY,
       Defendant.

   ______________________________

                       SETTLEMENT AGREEMENT AND ORDER

    I. INTRODUCTION
       Between February and June 1996, Named Plaintiffs (defined below)
       filed thirteen administrative complaints against the Boston
       Housing Authority ("BHA") with the United States Department of
       Housing and Urban Development ("HUD") alleging violations of the
       Fair Housing Act, 42 U.S.C. 3601, et seq. (the "HUD Administrative
       Action"). Named Plaintiffs, who are Haitian, Hispanic,
       Trinidadian, Nigerian, St. Thomian, Black, black African American,
       and Hispanic, alleged that they, their families, and their
       visitors were repeatedly subject to racial violence, harassment
       and intimidation because of their race, color and national origin
       by white tenants and others during Named Plaintiffs' tenancies at
       two predominantly white BHA developments -- Old Colony in South
       Boston and Bunker Hill in Charlestown. This alleged harassment
       includes racially motivated acts of physical violence and threats
       of physical violence, destruction of property, racist graffiti,
       and racist name-calling. Named Plaintiffs alleged that they
       repeatedly complained about this racial harassment to the BHA, and
       that the BHA failed to adequately investigate or respond to their
       complaints.
       On December 17, 1996, Named Plaintiffs filed a class action in
       this Court against the BHA and the City of Boston (the "City"),