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1
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS DISCRIMINATORY UNITED STATES DWELLINGS FAIR HOUSING PURSUANT COMPLAINANT CALIFORNIA FAIR HOUSING ACT DESIGN CONSTRUCTION MCFH EQUAL OPPORTUNITY INVESTIGATING DISCRIMINATORY HOUSING PRACTICES ACCESSIBILITY LYTTON PALO ALTO APARTMENTS BUSINESS DISABILITIES VIOLATION UNITED STATES ATTORNEY DAMAGES COURT SAN FRANCISCO SCHAFFRAN CARRASCO TOPFLIGHT SPECS |
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
LYTTON IV HOUSING CORPORATION,
E.M. SCHAFFRAN AND COMPANY,
CARRASCO & ASSOCIATES, and
TOPFLIGHT SPECS,
Defendants.
____________________________________
COMPLAINT
DEMAND FOR JURY TRIAL
The United States of America alleges:
1. This action is brought by the United States on behalf of
Mid-Peninsula Citizens for Fair Housing (MCFH), pursuant to
subjection 812(o) of the Fair Housing Act, Title VIII of Civil
Rights Act of 1968, as amended by the Fair Housing Amendments Act
of 1988 (Fair Housing Act), 42 U.S.C. §§ 3601-3619.
2. The Court has jurisdiction over this action under 28 U.S.C. § 1345
and 42 U.S.C. § 3612(o).
3. Lytton Courtyard ("subject property") is a U.S. Department of
Housing and Urban Development Section 202 project for very low
income seniors located at 330 Everett Avenue in Palo Alto,
California. Subject property is an apartment building containing
51 apartments on three floors. The building contains an elevator.
Subject property was designed and constructed for occupancy after
March 13, 1991.
4. Complainant MCFH is a non-profit corporation organized under the
laws of the State of California, with its principal place of
business in the City of Palo Alto, County of Santa Clara, State of
California. MCFH's specific purposes and goals include: (a) the
promotion of equal opportunity in the renting, purchasing,
financing and advertising of housing; and (b) the elimination of
all forms of illegal housing discrimination. To that end, the
activities in which MCFH engages include, but are not limited to:
a. providing outreach and education to the San Francisco Bay
Area Mid-Peninsula community including housing providers and
local governments regarding fair housing;
b. acting as a local and regional advocate of equal housing
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