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                        SETTLEMENT AGREEMENT BETWEEN
                        THE UNITED STATES OF AMERICA
                        AND FIRST BOSTON REAL ESTATE
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    I. Introduction

     This Settlement Agreement is between the United States and First
     Boston Real Estate (First Boston) to settle alleged violations of
     Section 42 U.S.C. §§ 3601 et seq. of the Fair Housing Act, on the
     basis of race in the sale, rental, and listing for sale or rental
     dwellings in violation of the Act.

     The Department of Justice is authorized under the Fair Housing Act,
     42 U.S.C. § 3614, to investigate fully matters where information
     indicates that there may be a pattern and practice of violating the
     Fair Housing Act. Furthermore, the Attorney General is authorized
     under 42 U.S.C. § 3614 "(w)henever...(she) has a reasonable cause
     to believe that any person or group of persons is engaged in a
     pattern or practice of resistance to the full enjoyment of any of
     the rights granted by...(the Fair Housing Act), or that any group
     of persons has been denied any of the rights granted by... (the
     Fair Housing Act) and such denial raises an issue of general public
     importance, ... (to) commence a civil action in any appropriate
     United States district court." In consideration of the terms of
     this Settlement Agreement as set forth below, the Attorney General
     agrees to refrain from undertaking further investigation and from
     filing civil suit in this matter with regard to the alleged facts
     set forth in Section II below.

   II. Background

     First Boston is a real estate company located at 3200 NW 23^rd
     Street in Oklahoma City, Oklahoma. First Boston engages in the sale
     of residential real estate and does business in the Western
     District of Oklahoma.

     The Metropolitan Fair Housing Council of Greater Oklahoma (MFHC) is
     a private fair housing organization located in Oklahoma City,
     Oklahoma. As part of its program activities, MFHC receives and
     investigates complaints of unlawful housing discrimination and
     conducts periodic tests of rental and sales policies in Oklahoma
     City to measure compliance with federal, state, and local law. MFHC
     uses "testers" to compare the treatment afforded to different types
     of prospective renters or purchasers of housing. Testers are
     persons who, without the intent to rent or purchase, seek