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1 .- /, November, Files rrom: l(b)()(c) _fubject: United States v. Trump Mgt. 4 0 On September.4,, we received the initial ompliance report from Trump Mgt. in accordance with -he Consent Order filed on June 0,. his My analysis of report has revealed that the defendant has not fully omplied with several of the provisions outlined in the ecreej Specifically, Section, d. of the Consent. Order equires the defendant to forward to this Department a report howing the name, race and position of each employee. dditionally, this report was to include the building to hich the employees are assigned and copies of their signed tatements. The_-nja'te:t;ia l_-_ubmitted corresponding to this ( rovision included a list containing the name, race and '(\S' rasition of their employees. The list revealed thae go.hite persons are employed by the defendant. The majority 0. pf these employees are list showing the. pumber of employees in the various postions is attached as xhibi$\ A. ;tit. r.pet tq 'the,..employees we also received lrigned statements from 0 employees. Of these statements 4 0 indicated the building to which the persons were agned. e defendant therefore failed to forward signed statements at least half of his staff and failed to inform us of the uildings at which half his staff was employed.

2 ! The second violation concerns Section d rec.uiring fhe defendant to forward to us the current tistics-wixkx kacial statistics of the tenants in each of the buildings 4.ed or managed by the efendant. n response to this 0 4 revision the defendant forwarded a list entitled acial ensus Reportu tl:'-..at included the names of all h i s buildings nd two columns showing the dates // and //. Under categories opposite each building the defendant indi a numerical figure. From the manner in which this eport was prepared can assume that the figures represent he current number of black tenants as of July and September, f my assumption is accurate the defendant failed to 'nclude the current statistics.for white tenants residing n his apartment complexes. The third violation cncerns the advertising provision. nder this provision the defendant was required to include '!Equal Housing Opportunityrt in all its advertisementr. i dditionally, the defendant was reauired to place a monthly line display ad in the Amsteram Ne"tqs, a black oriented 0, ewspaper and El Diaria, a Spanish oriented newspaper. The defendants newspaper advertisements placed in the inorit y papers contained a cross-section of Trump's buildings s required by the Decree. However, an advertisement placed 4 each of these papers failed to meet the length requirement s pointed out in the decree. Specifically, an ad place in! he Amsterdam News on August, was lines and an ad n the El Diaro on August?, was 0 lines.? - l&-t- OPO

3 ... :-: -- _l_ i! \ "'\ 4, y. -\., d:, ';,( \'J \. 'f\g \,? ', 0 \. J. tqf. \J. \ ' " '., 4 \) \ Hi 0 4 The advertising provision.also requires the defendant o place an advertisement at least inches in length in the ew York Times one Sunday every month. This provision urther indicated that the Equal Housing Opportunity slogan hall be in prominent capital letters. We received a copy f a newspaper advertisement that appeared in the N.Y. T imes n Sunday July,. The following analysis of this dvertisement is based solely on my assumption that the d corresponds with the above-mentioned reuirement. First, the ad was less than inches tn length. Secondly, ad contained information for Patio Gardens, a predominantly lack building and Shore Haven: a relatively all-white building he EHO slogan Lmmediately following Patio Gardens was in large black capital letters while the ERO slogan following hore Haven was in very samll capital letters. n view of he lettering discrepancy this particular advertisement ould possibly indicate a signa.t to prospctive black applican s. f the purpose of the ad was not to indicate a signal the ad still not correct. since the slogan was not placed at the ottom in all capital letters. An advertisement placed in the New York Times on aturday August, approximately / inches and showi cross section of the defendant's buildings included a EHO J logan. However, in my opinion tbe slogan was not prominent. - -

4 a 4 The fourth violation concerns the submissio of nformation in categories pertaining to inquirers. form was prepared and attached to the Consent Decree ncluding the following categories to be reported on ach inquirer by race: () made inquirf; (?. ) were affered 0 t 4 owever, n application () filled out an application (4) submitted eposit with application (). were accepted for occupancy ()were rejected ()withdrew application and () had pplication pending at the end of the reporting peiod. For each of the buildings listed in the decree he defendant submitted his report pertaining to nquirers. the report failed to include the information for! umbers through above. ; The fifth violation concerns vacancies. We received the defendants list of vacancies as required by the Consent ecree. However, the decree states that the defendant shall 0 4 G on the list where appropriate the dates the Open ousing - ter..as contacted concerning these vaca;ncies. ; ]'e Jjt.. t#:.,e(h - _ efendant 's list did not include this information. h,u ::.,.. F ;: With respect to the provision of the decree concerning otifying various organizations the defendant is in semi ompliance. Specifically, the decree requires the defendan otify apartment locators credit checking _cpani'es, eferral agencies, Fair Housing grops and labor unions. e received a copy of the letter sent to lpor uniq.ns. e also received copies of the letters sent to the Open ousing Cene; Shanton Realty Corp and Kraham Reaty Cprp..!...! dvising of their non-discriminatory pol icy. With respect

5 a \ o the letters forwarded to the realty corporations do if these corporations are the apartment locators, agencies, credit checking companies or management bompanies. n view of this am unable to determine " the defendant has fully complied with this provision. The decree requires the defendant to forward a report eflecting applications for tenancy at each building. n accordance with this provision we received all the equired information. A report showing the number of persons ho were accepted or rejected at each of the buildings and nformation pertaining to inquirers is attached as Exhibits & D. The report reveals that the majority of persons ubmitting a deposit with their applications secured apartents pecifically, black persons submitted deposits and?4 were! ccepted; white persons submitted deposits and? secured partments; other minorities submitted applications and ecured apartments_ 0 The report further reveals that approximately the sa ercentage of black and white persons making inuiries actually eceive apartments. Specifically, 0 white persons made and. of these persons or.% were accepted; 04 black persons made inuiries and?.4 of these. persons were accepted. With respect to the other u inorities made inquiries and or 40% were accepted. - -

6 n view of the information pertaining to applications [it appears that the defendant is in eompliance with the pirit of the decree. ( find this bard to believe.) therefore plan to write the defendant a letter the technical deficiencies of the decfee. have read your memos advising of the recent compliance rom prospective black applicants. However, the vacancies hese persons refer to do not appear on the defendants ist of vacancies. n view of this, will investigate the 0. tter further to determine if the defendant is providing us the reauired information. will also try to determin 4!! black persons believed there were vacancies when in act no vacancies existed. Regardless of my findings think we should conduct a ecords inspection in the near future but not during the winter 0 4

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