IN THE UNITED STATES DISTRICT COURT
                   FOR THE EASTERN DISTRICT OF WISCONSIN

   UNITED STATES OF AMERICA, Plaintiff,

   v.

   LYLE KRUEGER, Defendant.

   __________________________

                         CIVIL ACTION NO. 98-C-0886
                           Judge Myron L. Gordon

                               CONSENT DECREE

   This action was filed by the United States on September 8, 1998, and
   amended ______, 1999, to enforce the provisions of Title VIII of the
   Civil Rights Act of 1968, as amended by the Fair Housing Act
   Amendments of 1988, 42 U.S.C. 3601 et seq. (the Fair Housing Act).

   Defendant owns six (6) residential rental properties, containing ten
   (10) rental units, and is in the business of renting and, at times,
   managing these properties. These properties are located in the Eastern
   District of Wisconsin, all of which are at the following addresses:
     * 1626 59th Street, Kenosha, WI (4 two-room efficiencies)
     * 1922-24 61st Street, Kenosha, WI (2 three-bedroom apartments)
     * 1870 Sheridan Road, Kenosha, WI (3 mobile home trailers)
     * 20030 82d Street, Bristol, WI (1 single family home)

   In this action, the United States alleges that Defendant has engaged
   in a pattern or practice of sexual harassment in the rental of his
   apartments, in violation of the Fair Housing Act. The United States
   alleges specifically that Defendant Lyle Krueger implemented this
   pattern or practice by subjecting female tenants to extensive,
   continuous, and unwelcome sexual harassment by conditioning their
   tenancy on the grant of sexual favors, by creating a hostile
   environment for female tenants, and by retaliating against women who
   filed complaints of sexual harassment against him or refused to grant
   him sexual favors, in violation of 42 U.S.C. 3604(b) and 3617.

   The parties have agreed that in order to avoid protracted and costly
   litigation, the controversy should be resolved without further
   litigation. Therefore, without a trial or adjudication of all of the
   facts alleged by the United States, the parties consent to the entry
   of this Decree.

    I.

                    IN THE UNITED STATES DISTRICT COURT
                   FOR THE EASTERN DISTRICT OF WISCONSIN

   UNITED STATES OF AMERICA,
   Plaintiff,

   v.

   LYLE KRUEGER,
   Defendant.

   __________________________

                             AMENDED COMPLAINT

   The United States of America alleges:

    1. This action is brought by the United States to enforce 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. 1331,
       28 U.S.C. 1345, and 42 U.S.C. 3614(a) and (b)(2).
    3. Defendant Lyle Krueger is a resident of the Eastern District of
       Wisconsin, residing at 20030 82nd Street, Bristol, Wisconsin,
       53140. At all relevant times, defendant has been the owner and
       manager of numerous residential rental properties in Bristol and
       Kenosha, Wisconsin, also in the Eastern District of Wisconsin.
    4. The rental properties at issue in this case are dwellings within
       the meaning of 42 U.S.C. 3602(b).
                             FIRST CAUSE OF ACTION
    5. Defendant owns and, at all relevant times, managed a rental
       property located in the Eastern District of Wisconsin at 1870
       Sheridan Road, Lot #29, in Kenosha, Wisconsin.
    6. Complainant Teresa Szopinski lived in the rental property
       described in ¶5 between April 1994 and around February 1996.
    7. In November 1996, Ms. Szopinski filed a complaint with the United
       States Department of Housing and Urban Development (HUD) alleging
       that defendant violated the Fair Housing Act, 42 U.S.C. 3601, et
       seq., by harassing her and attempting to evict her on the basis of
       sex and race and threatening to retaliate against her for
       exercising her rights under the Fair Housing Act (Attachment A).
    8. On August 20, 1997, after the administrative complaint was filed
       but before a charge was issued, defendant and Ms. Szopinski signed
       a Conciliation Agreement. HUD approved the Conciliation Agreement
       on August 27, 1997, pursuant to 42 U.S.C. 3610(b) (Attachment B).
    9. The Conciliation Agreement provides that defendant will refrain
       from violating the Fair Housing Act, and will pay Ms. Szopinski