IN THE UNITED STATES DISTRICT COURT FOR THE
                            DISTRICT OF COLORADO

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

                                                            NO.:00-N-2543

   HOUSING AUTHORITY of the City of
   AURORA, COLORADO,
        Defendant.

   ___________________________________

                                 COMPLAINT

   The United States of America alleges:

    1. This action is brought by the United States on behalf of Tanya
       Harris and her minor son Anthony Harris to enforce the provisions
       of Title VIII of the Civil Rights Act of 1968 (the Fair Housing
       Act), as amended by the Fair Housing Amendments Act of 1988, 42
       U.S.C. §§3601 et seq.
    2. This Court has jurisdiction over this action under 28 U.S.C.
       §§1345 and 1331 and 42 U.S.C. §3612(o). Venue is proper in this
       judicial district pursuant to 42 U.S.C. §1391(b) and 42 U.S.C.
       §3612(o) as Defendant is located in this judicial district and the
       events or omissions giving rise to the claim occurred in this
       judicial district.
    3. The Defendant Housing Authority of the City of Aurora (hereinafter
       "AHA") is a body corporate and politic organized in accordance
       with the provisions of the Colorado Housing Authorities Law,
       C.R.S. §29-4-201, et seq. AHA was established pursuant to the city
       Code of the City of Aurora, Colorado Section 42-27 (Code 1979,
       §8-221) and City of Aurora Ordinance 75-19 for the purposes, with
       the powers, and subject to the restrictions set forth in the
       Colorado Housing Authorities Law. AHA is a quasi-municipal
       corporation which is empowered to operate, manage, lease and do
       all things necessary to provide low-income housing, including
       administration of Section 8 and other housing subsidy programs.
    4. Tanya Harris and Anthony Harris (the "Harrises") are individuals
       who in the fall of 1995 resided in site-based Section 8 Moderate
       Rehabilitation rental housing subsidized by AHA at 1768 Billings,
       Number 202, Aurora, Colorado 80011.
    5. Tanya Harris and Anthony Harris both suffer from illnesses,
       including Post Traumatic Stress Disorder (hereinafter "PTSD"). The

                IN THE UNITED STATES DISTRICT COURT FOR THE
                            DISTRICT OF COLORADO

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

                                                            NO.:00-N-2543

   HOUSING AUTHORITY of the City of
   AURORA, COLORADO,
        Defendant.

   ___________________________________

                               CONSENT DECREE

   The United States filed this action on behalf of Tanya Harris and her
   minor son Anthony Harris to enforce the provisions of Title VIII of
   the Civil Rights Act of 1968 (the Fair Housing Act), as amended by the
   Fair Housing Amendments Act of 1988, 42 U.S.C. §§3601 et seq. The
   complaint alleged that the Defendant, Housing Authority of the City of
   Aurora, Colorado (AHA), discriminated against Tanya Harris and Anthony
   Harris by refusing to make reasonable accommodations in its rules,
   policies, practices, and services when it denied Tanya Harris a
   portable Section 8 voucher.

   On or about December 13, 1995, Tanya Harris, individually and on
   behalf of her minor son, Anthony Harris, timely filed complaints with
   the United States Department of Housing and Urban Development (HUD)
   pursuant to Section 810(a) of the Fair Housing Act, 42 U.S.C. §3610(a)
   against her prior landlord, Aurora East Apartments, and AHA. The
   complaint against Aurora East Apartments was settled pursuant to a
   Conciliation Agreement dated July 16, 1997. The complaint against AHA
   alleged that the Defendant improperly refused to grant Tanya Harris
   and Anthony Harris a reasonable accommodation necessary to allow them
   an equal opportunity to use and enjoy a dwelling when the Defendant
   did not provide Tanya Harris a Section 8 certificate or voucher.

   As required by Section 810(a) and (b) of the Fair Housing Act, 42
   U.S.C. §§3610(a) and (b), the Secretary of HUD (hereinafter the
   "Secretary") conducted an investigation of the AHA complaint, and
   attempted conciliation without success. Based on the information
   gathered in this investigation, the Secretary, pursuant to 42 U.S.C.
   §3610(g)(1), determined that reasonable cause exists to believe that a
   discriminatory housing practice has occurred. Therefore, on September
   29, 2000, the Secretary issued a Charge of Discrimination pursuant to