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SETTLEMENT AGREEMENT BETWEEN
THE UNITED STATES OF AMERICA;
JUBILEE APARTMENTS, INC.; FALCON DEVELOPMENT COMPANY; and
J. LAMONT LANGWORTHY
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I. Introduction
This Settlement Agreement is between the United States; Jubilee
Apartments, Inc.; Falcon Development Company; and J. Lamont
Langworthy (respondents) to settle alleged violations of Section
804(f)(3)(C) of the Fair Housing Act, 42 U.S.C. § 3604(f)(3)(C)
with respect to the design and construction of the apartments at
Palermo Apartments, formerly known as Jubilee Apartments.
II. Background
Falcon Development Company is the developer of Palermo Apartments
(Palermo), which are located at 5870 W. Harmon Avenue, Las Vegas,
Nevada. Falcon Construction Services built Palermo. J. Lamont
Langworthy is the architect who designed Palermo. Palermo is an
apartment complex comprised of eleven (11) buildings with 168
units, 84 of which are ground-floor units. The 84 ground-floor
units at Palermo are "covered multi-family dwellings" within the
meaning of the Fair Housing Act, 42 U.S.C. § 3604(f)(7)(A) (the
Act).
By letter dated January 27, 2000, the Department of Housing and
Urban Development (HUD) referred to the United States Department of
Justice, for possible pattern and practice litigation, a housing
discrimination complaint against then-named Jubilee Apartments,
(HUD File Number 09-98-1087), alleging violations of the design and
construction provisions of the Fair Housing Act (the Act). After
investigating the complaints, HUD concluded that a basis may exist
for the commencement of proceedings against the owner, developer,
architect, and civil engineer of this property for failure to
design and construct the units there to include the accessibility
features mandated by the Act.
In general, the accessibility features of the Act require that, for
buildings with four or more units, all ground floor units in
non-elevator buildings, such as the apartments at Palermo, include
certain basic accessibility and adaptability design features
intended to make housing usable or adaptable by a person who is, or
who becomes, disabled. The design requirements under the Act
include: (a) public use and common use areas that are readily
SNIPPETS:
JUBILEE APARTMENTS,
This Settlement Agreement is between the United States;
Apartments, Inc.; Falcon Development Company; and J. Lamont Langworthy to settle alleged
Falcon Development Company is the developer of Palermo Apartments, which are located at 5870
Falcon Construction Services built Palermo.
The 84 ground-floor units at Palermo are "covered multi-family dwellings" within the meaning
By letter dated January 27, 2000, the Department of Housing and Urban Development referred to
After investigating the complaints, HUD concluded that a basis may exist for the commencement
the United States alleges that the ground floor units at Palermo did not fully comply with
For instance, the United States alleges that as originally designed and constructed, the
Respondents deny any violations of the Fair Housing Act, and their signatures on this
All parties agree that the controversy outlined above should be resolved without judicial
Public Use and Common Areas Respondents have taken the following retrofit actions:
The respondents shall also post such a sign in the sales or rental office of any other
For three years from the date of this Agreement, respondents shall place in all future media
For the term of this Agreement, respondents shall advise counsel for the United States in
In the event the parties are not able to resolve this issue to the reasonable satisfaction of
Housing and Civil Enforcement Section Civil Rights Division Department of Justice
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