IN THE UNITED STATES DISTRICT COURT
                      FOR THE DISTRICT OF NORTH DAKOTA

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

                                                         CA No. A1-00-143

   KELVIN A. MOLDENHAUER; and
   LAUNA L. MOLDENHAUER,
        Defendants

   ______________________________

                               CONSENT ORDER

   On December 18, 2000, the United States commenced this action on
   behalf of Bobbi and Jeff Zueger, their minor daughter Katie Zueger,
   Deanne and Stewart Schatz, their minor children Kaeley and Daxton
   Schatz, and the North Dakota Fair Housing Council. At all times
   relevant to this case, Defendants Kelvin and Launa Moldenhauer were
   owners of K & L Apartments, located in Bismarck, North Dakota, which
   contains approximately sixty (60) dwelling units.

   The United States' complaint was brought pursuant to section 812(o) of
   the Fair Housing Act, 42 U.S.C. § 3612(o). The Complaint alleges that
   Defendants violated the Fair Housing Act by discriminating against the
   complainants by refusing to rent or negotiate for, or otherwise making
   unavailable or denying, a dwelling on the basis of familial status, in
   violation of 42 U.S.C. § 3604(a). The Complaint also alleges that
   Defendants made or caused to be made statements with respect to the
   rental of a dwelling that indicate a preference, limitation or
   discrimination because of familial status, in violation of 42 U.S.C.
   3604(c). The Complaint further alleges that Defendants represented to
   the complainants, because of their familial status, that dwellings
   were not available for inspection or rental when such dwellings were
   in fact so available, in violation of 42 U.S.C. § 3604(d).

   Defendants Kelvin and Launa Moldenhauer have denied and continue to
   deny each and every allegation of the Complaint, and have denied and
   continue to deny that they refused to rent or otherwise discriminated
   against families with children. It is expressly understood and agreed
   that this Consent Order is not an admission of liability; but rather
   is a compromise of disputed claims and that said actions contemplated
   herein are not in any manner to be construed as an admission of
   liability on the part of Defendants, their agents, servants,

                    IN THE UNITED STATES DISTRICT COURT
                      FOR THE DISTRICT OF NORTH DAKOTA

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

                                                         CA No. A1-00-143

   KELVIN A. MOLDENHAUER; and
   LAUNA L. MOLDENHAUER,
        Defendants

   ______________________________

                                 COMPLAINT

   The United States of America alleges:

    1. This action is brought by the United States on behalf of Jeff and
       Bobbi Zueger, their minor child, Katie Zueger; Deanne and Stewart
       Schatz, their minor children, Kaeley and Daxton Schatz; and the
       North Dakota Fair Housing Council, pursuant to Section 812(o) of
       the Fair Housing Act, as amended, 42 U.S.C. § 3612(o).
    2. This Court has jurisdiction over this action under 28 U.S.C.
       1345 and 42 U.S.C. § 3612(o).
    3. Defendants Kelvin A. and Launa L. Moldenhauer are residents of the
       District of North Dakota. At all relevant times, Defendants Kelvin
       and Launa Moldenhauer owned K & L Apartments, located in Bismarck,
       North Dakota.
    4. At all relevant times, in addition to owning K & L Apartments,
       Kelvin Moldenhauer reviewed applications for rental and made
       decisions to accept or reject prospective tenants.
    5. Jeff Zueger, Bobbi Zueger and their minor child Katie Zueger are
       residents of the State of North Dakota.
    6. Deanne and Stewart Schatz and their minor children, Kaeley and
       Daxton Schatz, are residents of the State of North Dakota.
    7. The North Dakota Fair Housing Council, Inc. (NDFHC), is a
       non-profit corporation organized under the laws of the State of
       North Dakota with its principal place of business located in
       Bismarck, North Dakota. NDFHC's mission is to achieve equal
       housing for its constituents in North Dakota, including families
       with children, through education, counseling, referral services
       and enforcement activities.
    8. The units in K & L Apartments are dwellings within the meaning of
       42 U.S.C. § 3602(b).
    9. On or about April 1, 1996, Jeff Zueger called K & L Apartments to