UNITED STATES OF AMERICA Plaintiff, United States v. Donald Sterling, et al. (C.D. Cal.)

Similar documents
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

Case: 5:10-cv Doc #: 1 Filed: 10/12/10 1 of 8. PageID #: 1

FIRST AMENDED COMPLAINT

Fwd: CF Public Comment

Plaintiff Privacy Pop, LLC ( Plaintiff ) complains and alleges as follows against Defendant Gimme Gimme, LLC ( Defendant ).

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES. Plaintiff, Defendants. General of the State of California, hereby alleges as follows:

FILED 16 AUG 29 PM 2:30

FILED 16 AUG 09 PM 2:59

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF NEW YORK

Case 1:13-cv JG-JMA Document 1 Filed 04/29/13 Page 1 of 18 PageID #: 1

FEDERAL TRADE COMMISSION, Plaintiff,

FILED 16 NOV 03 PM 2:13

IN THE SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION

7 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE 8 STATE OF WASHINGTON, 9 Plaintiff,

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) Plaintiff,

Complaint, Joly v. Town of Lake Hunting and Fishing Club Inc, Docket Nos. 2:05-cv-02223, 2:06-cv (Central District of Illinois 2006)

FEDERAL TRADE COMMISSION UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS LUFKIN DIVISION

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Case 5:14-cv Document 1 Filed 11/06/14 Page 1 of 12 Page ID #:1

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA CASE NO.: 1. BREACH OF IMPLIED CONTRACT 2. TRESPASS TO CHATTEL

THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 1:18-cv UNA Document 1 Filed 11/28/18 Page 1 of 11 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION ) ) ) ) COMPLAINT

Case 2:17-cv Document 1 Filed 12/29/17 Page 1 of 22 Page ID #:1

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION ORIGINAL COMPLAINT

Case3:15-cv DMR Document1 Filed09/16/15 Page1 of 11

UNITED STATES OF AMERICA DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT OFFICE OF HEARINGS AND APPEALS

IN THE IOWA DISTRICT COURT FOR STORY COUNTY ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 05/30/18 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA

Case 3:17-cv AJB-KSC Document 1 Filed 05/23/17 PageID.1 Page 1 of 8

Case 1:17-cv Document 1 Filed 02/03/17 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 9:18-cv RLR Document 1 Entered on FLSD Docket 05/22/2018 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.

Superior Court of California

United States Bankruptcy Court. Northern District of California ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 7:17-cv Document 1 Filed 05/14/17 Page 1 of 11

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION

Case 1:17-cv JCH-JHR Document 17 Filed 03/31/17 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

Case 0:12-cv RSR Document 7 Entered on FLSD Docket 12/18/2012 Page 1 of 15

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA JOHN JOSEPH BENGIS, an individual,

CIV97-476PHXR0S. United States Attorney II I III II District of Arizona MR STATE OF ARIZONA; J. FIFE

Amended Complaint, Gassman v. Frischholtz et al, Docket No. 1:05-cv (Northern District of Illinois 2005)

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA Orlando Division

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Case 1:19-cv PKC Document 1 Filed 01/14/19 Page 1 of 5

Case 2:17-cv Document 1 Filed 07/31/17 Page 1 of 10 Page ID #:1

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION Case No: 5:11-cv ) ) ) ) ) ) ) ) ) )

Case4:13-cv JSW Document112 Filed05/05/14 Page1 of 3

Courthouse News Service

Case3:05-cv WHA Document1 Filed02/14/05 Page1 of 5

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE COMPLAINT FOR PATENT INFRINGEMENT

IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT, IN AND FOR SARASOTA, MANATEE, DESOTO COUNTY, FLORIDA

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN MILWAUKEE DIVISION COMPLAINT FOR PATENT INFRINGEMENT

Case 1:10-cv LTB Document 1 Filed 08/31/10 USDC Colorado Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO COMPLAINT

IN UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION COMPLAINT FOR PATENT INFRINGEMENT

-CIVIL RIGHTS EMPLOYMENT

Case 1:16-cv Document 1 Filed 09/22/16 Page 1 of 6

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION

Filing # E-Filed 06/13/ :25:39 PM

ATTORNEYS FOR PLAINTIFF FEDERAL TRADE COMMISSION FEDERAL TRADE COMMISSION, Plaintiff,

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS. Civil Action No. COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL

) ) ) ) ) ) ) ) ) ) ) ) Plaintiff, Defendant.

Case 2:16-cv JTM-TJJ Document 1 Filed 05/25/16 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

Case 3:15-cv JLS-JMA Document 1 Filed 06/26/15 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA JURISDICTION AND VENUE

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Case 1:14-cv Document 1 Filed 02/18/14 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION ORIGINAL COMPLAINT

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION

Case: 1:17-cv Document #: 1 Filed: 03/08/17 Page 1 of 14 PageID #:1

COMPLAINT FOR VIOLATIONS OF THE LANHAM ACT AND TRADEMARK INFRINGMENT

Case 2:15-cv JMA-SIL Document 34 Filed 02/22/16 Page 1 of 19 PageID #: 221 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK

Case 8:18-cv Document 1 Filed 08/07/18 Page 1 of 26 Page ID #:1

Case 2:16-cv JRG-RSP Document 1 Filed 10/19/16 Page 1 of 8 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS

thejasminebrand.com thejasminebrand.com

Case 6:15-cv Document 1 Filed 04/06/15 Page 1 of 5 PageID #: 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff, Defendants. COMPLAINT FOR PATENT INFRINGEMENT

Case 1:15-cv EJF Document 2 Filed 09/25/15 Page 1 of 12

Case 3:14-cv RS-EMT Document 1 Filed 03/28/14 Page 1 of 11

Case 2:15-cv SVW-AS Document 1 Filed 02/12/15 Page 1 of 15 Page ID #:1

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK COMPLAINT

cij;'l~jl NO~ AC..

Case3:15-cv Document1 Filed07/10/15 Page1 of 12

Case 1:12-cv UNA Document 1 Filed 05/29/12 Page 1 of 13 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

Courthouse News Service

Transcription:

ALBERTO GONZALES Attorney General WAN J. KIM Assistant Attorney General STEVEN H. ROSENBAUM Chief KEISHA DAWN BELL Deputy Chief JULIE J. ALLEN E-mail: julie.allen@usdoj.gov MING-YUEN MEYER-FONG E-mail: ming-yuen.meyer-fong@usdoj.gov Attorneys Housing & Civil Enforcement Section U.S. Department of Justice 950 Pennsylvania Avenue, N.W. - G Street Washington, DC 20530 Tel: (202) 307-6275 Fax: (202) 514-1116 DEBRA WONG YANG United States Attorney LEON W. WEIDMAN Chief, Civil Division KEVIN B. FINN Assistant United States Attorney Calif. Bar No. 128072 E-mail: kevin.finn@usdoj.gov Federal Building, Suite 7516 300 North Los Angeles Street Los Angeles, CA 90012 Tel: (213) 894-6739 Fax: (213) 894-7327 Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA Plaintiff, v. Page 1 of 7

DONALD STERLING, individually, in his capacity as trustee for the Sterling Family Trust, and doing business as Beverly Hills Properties; ROCHELLE STERLING, individually and in her capacity as trustee for the Sterling Family Trust; STERLING FAMILY TRUST; and THE KOREAN LAND COMPANY, L.L.C. Defendants. ) COMPLAINT (And Demand for Jury Trial) Plaintiff United States of America, alleges: 1. 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 et seq. ( Fair Housing Act ). 2. This Court has jurisdiction over this action pursuant to 28 U.S.C. 1345 and 42 U.S.C. 3614(a). 3. Venue in this district is proper pursuant to 28 U.S.C. 1391(b). The events or omissions giving rise to this claim occurred in the Central District of California; the property that is the subject of the action is situated in the Central District of California; and the Defendants conduct business in this District. 4. Defendant Donald Sterling and Defendant Rochelle Sterling are residents of Los Angeles, California, and are the owners and/or managers of numerous multi-family residential rental properties located in Los Angeles County, California. 5. Beverly Hills Properties is Donald Sterling s doing business as name. Beverly Hills Properties manages multi-family residential rental properties located in Los Angeles County, California. 6. Defendant Sterling Family Trust holds title to and owns multi-family residential rental property in Los Angeles County. 7. At all times relevant to this Complaint, Defendants Donald Sterling and Rochelle Sterling have been trustees of the Defendant Sterling Family Trust, and are sued Page 2 of 7

herein both individually and as trustees of the Sterling Family Trust. 8. Defendant Korean Land Company is a California limited liability company that holds title to and owns multi-family residential rental property in Los Angeles County. 9. Defendants multi-family residential rental properties in Los Angeles County are dwellings within the meaning of the Fair Housing Act, 42 U.S.C. 3602(b). 10. Defendants Donald Sterling, Rochelle Sterling, and their agents and/or employees have engaged in a pattern or practice of discrimination on the basis of race, national origin, and familial status in connection with the rental of dwellings owned by the Korean Land Company, the Sterling Family Trust, and Donald and Rochelle Sterling, in violation of the Fair Housing Act. 11. Donald Sterling, Rochelle Sterling, the Korean Land Company, and the Sterling Family Trust have, at all times relevant to this Complaint, had the authority to control and direct the agents who committed the discriminatory actions stated herein. 12. The Defendants and their agents have engaged in a pattern or practice of discrimination by, among other ways: (a) Refusing to rent to non-koreans at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Koreatown section of Los Angeles County; (b) Refusing to rent to African-Americans at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Beverly Hills section of Los Angeles County; (c) Refusing to rent to families with children at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in Los Angeles County; (d) Creating, maintaining, and perpetuating an environment that is hostile to non-korean tenants at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Koreatown Page 3 of 7

section of Los Angeles County; (e) Providing inferior treatment to non-korean tenants in the terms, conditions, and/or privileges of a rental at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Koreatown section of Los Angeles County; (f) Misrepresenting the availability of units to non-koreans at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Koreatown section of Los Angeles County; (g) Misrepresenting the availability of units to African-Americans at the multifamily residential rental properties that Defendants own or manage, or have owned or managed, in the Beverly Hills section of Los Angeles County; (h) Misrepresenting the availability of units to families with children at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in Los Angeles County; (i) Making statements and publishing notices or advertisements in connection with the rental of units that express a preference for Korean tenants and discrimination against non-korean tenants; and (j) Making statements or publishing notices or advertisements in connection with the rental of units that express discrimination against African-Americans and families with children as tenants. 13. At all relevant times Defendants Donald Sterling, Rochelle Sterling, their agents and/or their employees committed the discriminatory acts contained in Paragraph 12 as agents for the Korean Land Company, the Sterling Family Trust, or Donald and Rochelle Sterling. 14. The conduct of the Defendants as described in Paragraph 12, constitutes: (a) A refusal to rent, a refusal to negotiate for the rental of, and conduct otherwise making unavailable or denying dwellings to persons because of race, Page 4 of 7

national origin, and familial status, in violation of 42 U.S.C. 3604(a); (b) Discrimination in the terms, conditions, or privileges, of rental of dwellings on the basis of race or national origin, in violation of 42 U.S.C. 3604(b); (c) Statements of preference or limitation on the basis of race, national origin and familial status in connection with the rental of dwellings, in violation of 42 U.S.C. 3604(c); (d) Publications or notices of preference or limitation on the basis of race or national origin in connection with the rental of dwellings, in violation of 42 U.S.C. 3604(c); and (e) Misrepresentations regarding the availability of units on the basis of race, national origin and familial status, in violation of 42 U.S.C. 3604(d). 15. The conduct of Defendants, as described herein, was intentional, willful, and taken in disregard for the rights of others. 16. The conduct of the Defendants described in Paragraph 12 constitutes: (a)a pattern or practice of resistance to the full enjoyment of rights secured by the Fair Housing Act, 42 U.S.C. 3601 et seq.; and (b)a denial to a group of persons of rights granted by the Fair Housing Act, 42 U.S.C. 3601 et seq., which denial raises an issue of general public importance. 17. Individuals who were subjected to Defendants discriminatory housing practices are aggrieved persons as defined by the Fair Housing Act, 42 U.S.C. 3602(i), and have suffered actual injury and damages as a result of Defendants conduct as described herein. WHEREFORE, the United States prays that the Court enter an order that: A. Declares that Defendants policies and practices, as alleged herein, violate the Fair Housing Act, as amended, 42 U.S.C. 3601 et seq.; Page 5 of 7

B. Enjoins the Defendants, their agents, employees, and successors, and all other persons in active concert or participation with them from: (1) Discriminating on account of race, national origin, and familial status against any person in any aspect of the rental of a dwelling; and (2) Interfering with any person in the exercise or enjoyment of rights granted or protected by the Fair Housing Act. C. Awards monetary damages to each person aggrieved by Defendants discriminatory housing practices, pursuant to 42 U.S.C. 3614(d)(1)(B); and E. Assesses a civil penalty against each Defendant in order to vindicate the public interest, pursuant to Section 814(d)(1)(C) of the Fair Housing Act, 42 U.S.C. 3614(d)(1) (C). The United States further prays for such additional relief as the interests of justice may require. Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the United States of America hereby demands a trial by jury of this action of all issues triable of right to a jury. ALBERTO GONZALES Attorney General DEBRA WONG YANG United States Attorney WAN J. KIM Assistant Attorney General LEON W. WEIDMAN Chief, Civil Division KEVIN B. FINN Assistant United States Attorney STEVEN H. ROSENBAUM Chief, Housing and Civil Enforcement Section KEISHA DAWN BELL Deputy Chief Page 6 of 7

Calif. Bar No. 128072 JULIE J. ALLEN E-mail: kevin.finn@usdoj.gov E-mail: julie.allen@usdoj.gov Federal Building, Suite 7516 MING-YUEN MEYER-FONG 300 North Los Angeles Street E-mail: ming-yuen.meyer-fong@usdoj.gov Los Angeles, CA 90012 Attorneys Tel: (213) 894-6739 Housing and Civil Enforcement Section Fax: (213) 894-7327 U.S. Department of Justice 950 Pennsylvania Ave., N.W. - G St. Washington, D.C. 20530 Phone: (202) 307-6275 Fax: (202) 514-1116 Document Filed: August 7, 2006 Page 7 of 7