IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
United States of America,
Plaintiff,
v.
CIVIL ACTION NO. 3:99-CV-0495-R
Prestonwood Properties, Inc.;
Stillmeadow Property
Management, Inc.;
Kevin Lane Hinds, also
known as Kevin Layne:
Hinds, individually and in his
capacity as officer of
Stillmeadow;
Ronald D. Hinds, individually
and in his capacity as officer
of Prestonwood;
Leslie Hinds, individually and
in his capacity as officer of
Prestonwood,
Defendants.
______________________________
COMPLAINT
The United States of America alleges:
I. JURISDICTION AND VENUE
This action is brought by the United States to enforce the Fair
Housing Act, Title VIII of the Civil Rights Act of 1968, as amended by
the Fair Housing Amendments Act of 1988, 42 U.S.C. §§ 3601 - 3619.
1. This Court has jurisdiction over this action under 28 U.S.C.
1345, 42 U.S.C. § 3612, and 42 U.S.C. § 3614.
2. Venue is proper under 28 U.S.C. § 1391(b) because all Defendants
reside in Texas, and Defendants Kevin Layne Hinds and Ronald D.
Hinds reside in the Northern District of Texas.
II. PROPERTY AND PARTIES
3. "Manor House" is residential rental property at 703 Bumpas Street,
SNIPPETS:
FOR THE NORTHERN DISTRICT OF TEXAS
United States of America, Plaintiff,
Stillmeadow Property
Kevin Lane Hinds, also known as Kevin Layne: Hinds, individually and in his capacity as
Ronald D. Hinds, individually and in his capacity as officer of Prestonwood; Leslie Hinds,
This action is brought by the United States to enforce the Fair Housing Act, Title VIII of
Venue is proper under 28 U.S.C. § 1391because all Defendants reside in Texas, and Defendants
The property and approximately 100 apartments at Manor House are dwellings within the meaning
At all relevant times, the Manor House apartments were subsidized by the Department of
Defendant Stillmeadow Property Management, Inc., is a Texas corporation that, for the period
Ronald Hinds resides as 965 Gibbs Crossing, Coppell, Texas, 75019.
Ronald Hinds is the brother of Defendant Kevin Hinds and the son of Defendant Leslie Hinds.
From approximately mid-1989 until at least July 31, 1994, Stillmeadow and Kevin Hinds managed
Wayne Asset Management, Inc., formerly known as Sunrise Asset Management, Inc., is a Texas
On or about March 8, 1995, complainants Mary Jackson, Vicky Lucero, Virginia Carrasco, and
These complaints, filed pursuant to 42 U.S.C. § 3610, allege that Kevin Hinds had sexually
On or about June 1, 1995, complainant Jimmie Sue Davis, who had worked in the Manor House
Based on the information gathered in that investigation, the Secretary, pursuant to 42 U.S.C.
Defendants Prestonwood, Stillmeadow, Ronald Hinds, Leslie Hinds, and Kevin Hinds have
Specifically, Kevin Hinds subjected the complainants to extensive, continuous, unwelcome, and
with respect to Jimmie Sue Davis, terminating or causing her to be terminated from her
Defendants Prestonwood, Stillmeadow, Ronald Hinds, Leslie Hinds, and Kevin Hinds have
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