IN THE UNITED STATES DISTRICT COURT
                     FOR THE DISTRICT OF MASSACHUSETTS

   UNITED STATES OF AMERICA
   Plaintiff;

   HOUSING DISCRIMINATION PROJECT, INC.
   Intervenor/Plaintiff

   v.

   CHOICE PROPERTY CONSULTANTS, INC.
   KAREN SOUCIE; and PAMELA MCGUIRK
   Defendants.

   _____________________________________

                  CONSENT ORDER WITH RESPECT TO DEFENDANTS
             CHOICE PROPERTY CONSULTANTS, INC. AND KAREN SOUCIE

    I. Background
       The United States of America and the Housing Discrimination
       Project, Inc. ("HDP") brought this action pursuant to § 814 of the
       Fair Housing Act ("the Act"), 42 U.S.C. § 3601 et seq., alleging
       that Choice Property Consultants, Inc. and Karen Soucie ("Choice
       and Soucie") violated the Act by discriminating against applicants
       for housing on the basis of race, national origin, and familial
       status. Prior to the filing of this action, HDP initiated
       proceedings before the U.S. Department of Housing and Urban
       Development ("HUD") against defendants Choice and Soucie. After
       HUD issued a reasonable cause determination that Choice and Soucie
       had engaged in illegal housing discrimination practices, HDP
       elected to have its claims adjudicated in this Court. The United
       States then commenced this action on behalf of HDP, pursuant to
       812(o) of the Act, and under its authority to sue persons engaged
       in a pattern or practice of resistance to the full enjoyment of
       the rights granted by the Fair Housing Act, and to sue where the
       discriminatory conduct raises an issue of general public
       importance, pursuant to § 814(a) of the Act. HDP subsequently
       intervened in the action.
       Specifically, the United States and HDP alleged that Choice and
       Soucie violated the Fair Housing Act by recording the
       discriminatory preferences of their landlord clients on documents
       used by Choice and Soucie to place tenants in available housing
       and by honoring those preferences by failing to inform minority
       apartment seekers and apartment seekers with children of available
       units owned by landlords who did not wish to rent to minorities or
       to families with children. Thus, Choice and Soucie:

                        UNITED STATES DISTRICT COURT
                         DISTRICT OF MASSACHUSETTS

   UNITED STATES OF AMERICA,
   Plaintiff,

   v.

   CHOICE PROPERTY CONSULTANTS,
   INC. and KAREN SOUCIE,
   Defendants.

                                 COMPLAINT

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

   I. INTRODUCTION

   1. The United States alleges that the defendants, Choice Property
   Consultants, Inc. and its president, Karen Soucie, have violated the
   Fair Housing Act, 42 U.S.C. § 3601 et seq., by inquiring as to the
   discriminatory preferences of its landlord clients, by reflecting
   those discriminatory preferences on Vacancy Reports provided to
   Choice's agents and employees, and by honoring those preferences by
   failing to inform minority apartment seekers or apartment seekers with
   children of available units owned by landlords who did not wish to
   rent to minorities or to families with children. The United States
   seeks declaratory, injunctive, and monetary relief.

   II. PARTIES

   2. This action is brought by the United States under 42 U.S.C.
   3614(a), and on behalf of the Housing Discrimination Project, Inc.,
   under 42 U.S.C. § 3612(o).

   3. The Housing Discrimination Project, Inc. (HDP), is a private
   non-profit corporation located in Holyoke, Massachusetts. HDP's
   mission is to promote fair housing practices, particularly in Hampden,
   Hampshire and Worcester Counties, Massachusetts.

   4. The defendant, Choice Property Consultants, Inc. ("Choice"), is a
   Massachusetts corporation located at 10 Richmond Avenue, Worcester,
   Massachusetts.

   5. The defendant, Karen Soucie, is the president and owner of Choice
   and is a licensed real estate broker. She resides at 11 Hadwen Road,
   Worcester, Massachusetts.