UNITED STATES DISTRICT COURT
                       NORTHERN DISTRICT OF ILLINOIS

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

   FOXCROFT PARTNERSHIP;
   WILFRED BARRY;
   FOXCROFT MANAGEMENT AND
   CONSTRUCTION, INC.; and
   D'ABAR BUILDERS, INC.,
        Defendants.

   ______________________________

                                 COMPLAINT

   The United States of America alleges:

    1. This action is brought 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 (the "Fair Housing Act"), 42 U.S.C.
       3601-3619.

                           Jurisdiction and Venue

    2. This Court has jurisdiction over this action under 28 U.S.C.
       1345 and 28 U.S.C. § 3614(a).
    3. Venue is proper in that the claims alleged herein arose in the
       Northern District of Illinois.

                              Subject Property

    4. Foxcroft Apartments (the "Complex") is an apartment complex
       located on Foxcroft Road, Naperville, in the Northern District of
       Illinois. The Complex consists of nine (9) buildings containing a
       total of 180 dwelling units, as well as a rental office and
       clubhouse. Forty-four of the apartments are located on the ground
       floor.
    5. The apartments at the Complex and the adjoining clubhouse were
       designed and constructed for first occupancy after March 13, 1991.
       Each of the apartments is a dwelling within the meaning of 42
       U.S.C. § 3602(b).
    6. Each of the 44 ground-floor apartments at the Complex is a
       "covered multifamily dwelling" within the meaning of 42 U.S.C.
       3604(f)(7)(A) and is subject to the design and construction