IN THE UNITED STATES DISTRICT COURT
   FOR THE NORTHERN DISTRICT OF CALIFORNIA

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

                                                            C 01-00324 SI

   HILLTOWNE APARTMENTS;
   LARRY POLICK;
   BSR REALTY, INC.;
   TIM A. SHARROCK; and
   JOSEPH PERRY,
        Defendants.

   ______________________________

                               CONSENT ORDER

   On January 19, 2001, the United States commenced this action on behalf
   of Brian M. Crump and Jeanette D. Crump, and their minor children
   Brian M. Crump Jr. and Brandie R. Crump; and Gean Toms, and her minor
   children Rayvon A. Toms (now an adult) and Bruce Hayes Jr.
   (collectively &"the Complainants&"), pursuant to Section 812(o) of the
   Fair Housing Act (Title VIII of the Civil Rights Act of 1968), as
   amended, 42 U.S.C. § 3612(o). At all times relevant to the events at
   issue in the Complaint:

    1. Defendant Hilltowne Apartments was the owner of the subject
       property, a 52-unit apartment complex located at 1220, 1238, and
       1252 Walpert Street in Hayward, California;
    2. Defendant Larry Polick was the general partner of Defendant
       Hilltowne Apartments;
    3. Defendant BSR Realty, Inc., was the property management company
       for the subject property;
    4. Defendant Tim A. Sharrock was the property manager for the subject
       property; and
    5. Defendant Joseph Perry was an on-site manager of the subject
       property.

   The United States' Complaint alleges that the Defendants discriminated
   against the Complainants by discriminating in the terms, conditions,
   or privileges of rental of a dwelling, or in the provision of services
   or facilities in connection with the rental of a dwelling, because of
   race, color, and familial status, in violation of 42 U.S.C. § 3604(b);
   and by making, printing, or publishing notices or statements with

                    IN THE UNITED STATES DISTRICT COURT
                  FOR THE NORTHERN DISTRICT OF CALIFORNIA

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

                                                            C 01-00324 SI

   HILLTOWNE APARTMENTS;
   LARRY POLICK;
   BSR REALTY, INC.;
   TIM A. SHARROCK; and
   JOSEPH PERRY,
        Defendants.

   ______________________________

                                 COMPLAINT

                           DEMAND FOR JURY TRIAL

   The United States alleges:

    1. This action is brought by the United States on behalf of Brian
       Crump and Jeanette Crump, and their minor children Brian Crump Jr.
       and Brandie Crump; and Gean Toms, and her minor children Rayvon
       Toms and Bruce Hayes, pursuant to Section 812(o) of the Fair
       Housing Act (Title VIII of the Civil Rights Act of 1968), as
       amended, 42 U.S.C. § 3612(o).
    2. Jurisdiction: This Court has jurisdiction over this action under
       28 U.S.C. § 1345 and 42 U.S.C. § 3612(o).
    3. Brian Crump and Jeanette Crump and their minor children Brian
       Crump Jr. and Brandie Crump are residents of the Northern District
       of California.
    4. Gean Toms and her minor children Rayvon Toms and Bruce Hayes are
       residents of the Northern District of California.
    5. Intradistrict Assignment: The subject property is a 52-unit
       apartment complex located at 1220, 1238, and 1252 Walpert Street
       in Hayward, California. Hayward is located in Alameda County, in
       the Northern District of California.
    6. The subject property is a dwelling within the meaning of 42 U.S.C.
       § 3602(b).
    7. At all times relevant to this complaint, Defendant Hilltowne
       Apartments, a California limited partnership, was the legal owner
       of the subject property.
    8. At all times relevant to this complaint, Defendant Larry Polick