UNITED STATES DISTRICT COURT FOR THE
                         MIDDLE DISTRICT OF ALABAMA
                             NORTHERN DIVISION

   UNITED STATES OF AMERICA, Plaintiff,

   v.

   DAVID DAMRON, Defendant.

   _____________________________

                               CONSENT ORDER

   The United States initiated this action pursuant to Section 814 of the
   Fair Housing Act, 42 U.S.C. 3614, alleging that the Defendant has
   engaged in a pattern or practice of discrimination on the basis of
   race in the rental of dwellings at Bruner Trailer Park, in violation
   of the Fair Housing Act, as amended, 42 U.S.C. 3601, et seq. Bruner
   Trailer Park is located in Montgomery, Alabama, and is owned by
   Defendant David Damron.

   The Defendant admits that his actions in running the Bruner Trailer
   Park violate the Fair Housing Act. More specifically, were this case
   to proceed to trial, the Defendant admits that United States would
   present evidence as follows, which supports a finding by the Court
   that the Defendant has engaged in a pattern or practice of
   discrimination on the basis of race, in violation of Section 804 of
   the Fair Housing Act, 42 U.S.C. 3604:

    1. Defendant Damron inquired into whether potential white tenants had
       any African-American friends who might visit them at Bruner
       Trailer Park;
    2. Defendant Damron conditioned tenancy to prospective white tenants
       upon representations that the prospective tenants would not have
       any African-American visitors;
    3. Defendant Damron evicted and otherwise harassed white tenants who
       had African-American visitors;
    4. Defendant Damron instructed at least one agent responsible for
       screening applicants not to rent to African-Americans and to tell
       any African-Americans who inquired about available trailers that
       the landlord had just rented the last trailer;
    5. Defendant Damron made statements indicating a preference not to
       rent to African-Americans; and
    6. In a fair housing test conducted by the Federal Bureau of
       Investigation, Defendant Damron:
         a. told the African-American FBI agent that he had just rented
            the last available trailer while informing the white FBI

                    UNITED STATES DISTRICT COURT FOR THE
                         MIDDLE DISTRICT OF ALABAMA

   UNITED STATES OF AMERICA, Plaintiff,

   v.

   DAVID DAMRON, Defendant.

   ___________________________

                                 COMPLAINT

   The United States of America alleges:

    1. 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.
    2. This Court has jurisdiction over this action under 28 U.S.C.
       1345 and 42 U.S.C. § 3614.
    3. Defendant David Damron resides at 44 Bruner Drive, Montgomery,
       Alabama, in the Middle District of Alabama. He is the owner and
       manager of real property known as Bruner Trailer Park, also known
       as Court Street Trailer Park, located at the intersection of the
       Southern Bypass and Court Street in Montgomery, Alabama in the
       Middle District of Alabama. Bruner Trailer Park consists of
       approximately 60 lots and trailer homes offered for rent.
    4. The lots and trailer homes offered for rent at Bruner Trailer Park
       constitute dwellings within the meaning of 42 U.S.C. § 3602(b).
    5. During the time period that defendant Damron has owned and
       operated Bruner Trailer Park, he has engaged in a number of
       intentionally discriminatory actions against African-American
       persons because of their race and color, which were designed to
       exclude such persons from the Park, including the following:
         a. he inquired into whether potential white tenants had any
            African- American friends who might visit them at Bruner
            Trailer Park;
         b. he conditioned tenancy to prospective white tenants upon
            representations that the prospective tenants would not have
            any African-American visitors;
         c. he evicted and otherwise harassed white tenants who had
            African-American visitors;
         d. he instructed at least one agent responsible for screening
            applicants not to rent to African-Americans and to tell any
            African-Americans who inquired about available trailers that
            the landlord had just rented the last trailer; and
         e. he made statements indicating a preference not to rent to