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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA MIAMI-DADE DIVISION

HOUSING OPPORTUNITIES PROJECT FOR EXCELLENCE, INC., INDIA BAZEMORE, DONNTAY COOPER, MICHAEL GOLDWIRE, and YOLANDA GODFREY, Plaintiffs vs. SPV REALTY LC Defendants _________________________________/

CASE NO:

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF COMES NOW, the Plaintiffs, HOUSING OPPORTUNITIES PROJECT FOR EXCELLENCE, INC., INDIA BAZEMORE, DONNTAY COOPER, MICHAEL GOLDWIRE, and YOLANDA GODFREY and sues Defendant, SPV REALTY LC and states as follows:

1.

This is an action initiated for the denial of federally secured rights of fair Plaintiffs seek declaratory and injunctive relief as well as damages and

housing.

attorney's fees for the denial of equal housing opportunities based on race and/or color.

JURISDICTION
2.

This Court has jurisdiction pursuant to 42 U.S.C. 3613 as well as 28

U.S.C. 1331 and 1343(a)(3) and (4). Claims are asserted pursuant to the Fair Housing

Law Offices of Matthew W. Dietz, P.L., 2990 Southwest 35 Avenue, Miami, Florida 33133

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 2 of 20 Act, 42 U.S.C. 3601, et seq., and to the extent that declaratory relief is sought, claims are asserted pursuant to 28 U.S.C. 1367 and 2201-2202.
3.

Venue is proper in this District under 28 U.S.C. 1391 as this is the

district in which the events giving rise to the Plaintiffs' claims occurred and as this is an action which is not founded solely on diversity of citizenship.

PARTIES
4.

The

Plaintiff,

HOUSING

OPPORTUNITIES

PROJECT

FOR

EXCELLENCE, INC. (hereinafter HOPE), is a private, Florida not-for-profit, 501 (c) 3 corporation established in 1988, one of three in Florida dedicated to eliminating housing discrimination and promoting fair housing. HOPE employs a three-tiered system of private enforcement, education outreach and counseling to achieve its mission to affirmatively further fair housing. Its programs are designed to ensure that people are offered the right to select housing of their choice without discrimination based on race, religion, color, national origin, sex, disability, marital or familial status, or such other protected classes as may be conferred by federal, state or local laws. HOPE is the only private not-for-profit fair housing organization in Miami-Dade and Broward Counties engaged in testing for fair housing law violations, and pursuing enforcement of meritorious claims.
5.

Throughout Miami-Dade and Broward Counties, HOPE engages in

activities to identify barriers to fair housing practices, including practices that discriminate against persons because of race or color. As part of its mission to uncover housing discrimination, HOPE expends its resources to train and deploy testers Law Offices of Matthew W. Dietz, P.L., 2990 Southwest 35 Avenue, Miami, Florida 33133
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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 3 of 20 individuals who, without an intent to rent or purchase a home or apartment, pose as a renter or purchaser for the purpose of collecting evidence of discriminatory housing practices.
6.

The Plaintiff, INDIA BAZEMORE, is an African-American woman who

is employed as a tester for HOPE, and is otherwise sui juris.


7.

The Plaintiff, DONNTAY COOPER, is an African-American man who is

employed as a tester for HOPE, and is otherwise sui juris.


8.

The Plaintiff, MICHAEL GOLDWIRE, is an African-American man who

is employed as a tester for HOPE, and is otherwise sui juris.


9.

The Plaintiff, YOLANDA GODFREY, is an African-American woman

who is employed as a tester for HOPE, and is otherwise sui juris.


10.

The Defendant, SPV REALTY LC owns and operates Design Place

Rental Apartments, which consists of over 500 spacious, fully renovated two and threebedroom Miami rental apartments on 26 beautifully landscaped acres in the midst of the Design District in the City of Miami. SPV REALTY LC is a Florida Limited Liability Company, located at 5175 NE 2nd court, Miami, Florida, and licensed and doing business in Miami-Dade County, Florida.

11.

As part of its investigation, Plaintiff HOPE conducted tests at Design

Place Rental Apartments which revealed the following: (1) African-American testers were told that units were unavailable when similarly-situated White testers were advised that units were immediately available; (2) African-American testers were quoted prices far in excess of prices that were quoted for similarly situated White testers; (3) SPV
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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 4 of 20 Realty obtained demographic information from White testers but did not obtain such information from similarly situated African American testers; (4) SPV Realty publishes advertisements which tend to indicate a preference for White tenants by only showing White models; and (5) SPV Realty indicated a preference for White tenants by indicating that it maintained higher than local rents to keep away the bad people who would usually reside in Little Haiti. THE TESTS Day # 1, October 19, 2012
12.

HOPE initially assigned a test on October 19, 2012, at Design Place

Rental Apartments for three testers to obtain rental information about a two bedroom apartment in order to investigate housing practices and to determine how the similarly situated testers were treated.
13.

On Friday, October 19, 2012, at 12:35p.m., Plaintiff INDIA BAZEMORE

arrived at Design Place Miami Rental Apartments and was greeted by leasing agent, Yillianis Lima. INDIA BAZEMORE is a 47 year old African-American female and a tester for HOPE. INDIA BAZEMORE inquired about the availability of a two (2) bedroom, one (1) bathroom apartment for November 1, 2012. The test lasted until 1:00p.m and revealed the following: a. INDIA BAZEMORE was told that no apartments were available for November 1, 2012. b. INDIA BAZEMORE was told by Yillianis Lima that she was too late as they already had individuals who wanted the units. BAZEMORE was told that the rent for a two (2) bedroom, one (1) bathroom with small den was $1,195

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 5 of 20 per month and that BAZEMORE would have to submit $1,195, plus a $25 application fee before the following day to have a chance of renting a unit. INDIA BAZEMORE was told that if someone brought their money to the leasing office before her that she would have to go on a waiting list. c. INDIA BAZEMORE was not asked any identifying or demographic information including family income, source of income, employment, credit history, rental history, reason for moving, marital status, family size, number of children, age of anyone in household, who would live here, or whether anyone in the household is disabled. d. After INDIA BAZEMORE asked, she was given a rental application and shown the gym.
14.

On Friday, October 19, 2012, Erin Lewis, a White woman who is 28 years

old, and a tester for HOPE, arrived at Design Place Miami Rental Apartments at 1:10p.m. and was greeted by leasing agent, Yuly. The test revealed the following: a. Erin Lewis was told that two (2) bedroom apartments were available for November 1, 2012. b. Erin Lewis was asked to fill out a form and provide information including her name, email address, number of bedrooms, move in date and how she heard about Design Place apartments. The rental agent, Yuly, asked Erin Lewis demographic information including her family size, age of anyone in household, and who would be living in the unit.

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 6 of 20 c. Yuly showed Erin Lewis the gym, pool area, community laundry area and volleyball courts on the property. d. Without prompting, the rental agent, Yuly, voluntarily provided Erin Lewis with a brochure, application and rates and requirement documentation. e. Erin Lewis was informed that the two (2) bedroom apartment was $1,095 per month and that the deposit was different for everyone because it was dependent on the individuals credit and background checks.
15.

On Friday, October 19, 2012, at 3:15p.m., Plaintiff DONNTAY COOPER,

a 23 year old African-American male, and a tester for HOPE, arrived at Design Place Miami Rental Apartments. Once inside the leasing office, COOPER was greeted by leasing agent, Yillianis Lima. COOPER inquired about the availability of a two (2) bedroom apartment, with any number of bathrooms. The test revealed the following:
a. DONNTAY COOPER was told that no apartments were available for

November 1, 2012. No information about a waiting list was provided to DONNTAY COOPER. He was only told to check back for December 1, 2012 availability.
b. DONNTAY COOPER was asked about his family size and who would be living

with him.
c. DONNTAY COOPER was informed that a two (2) bedroom, two (2) bathroom

unit would be $1,395.


16.

As a result of these three tests, HOPE decided to confirm the results of this

test and conduct further tests using persons who have extensive testing experience to

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 7 of 20 ensure the reliability of the results. As such, HOPE assigned paired testers to conduct tests at Design Place Apartments on October 22, 2012 and October 25, 2012. THE TESTS Day # 2, October 22, 2012
17.

On October 22, 2012 at 3:45p.m., Plaintiff MICHAEL GOLDWIRE, a 41

year old African American male, and a tester for HOPE, arrived at Design Place Miami Rental Apartments to perform a test on the rental property. Upon entering the leasing office, MICHAEL GOLDWIRE, was greeted by Yuly, a leasing agent of Design Place Apartments. GOLDWIRE asked Yuly if there was a two (2) bedroom apartment available for November 1, 2012. MICHAEL GOLDWIREs test of Design Place Apartments revealed the following:
a. MICHAEL GOLDWIRE was not provided any forms to fill out at the leasing

office. Further, Yuly did not request any identifying or demographic information from GOLDWIRE.
b. MICHAEL GOLDWIRE was advised that there were no units available for

November 1, 2012.
c. MICHAEL GOLDWIRE was told that a two (2) bedroom, one (1) bathroom

would be $1,195 and that a two (2) bedroom with no den would be $1,300.
d. MICHAEL GOLDWIRE was not shown any amenities at Design Place

Apartments. After asking, he received a rental application. He was advised that he would have to pass a background check, credit check and preliminary screening before the leasing agent could discuss a deposit amount and rental price.

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 8 of 20


18.

On October 22, 2012 at 4:25p.m., Mark Cassini, a White man who is 33

years old, and a tester for HOPE, arrived at Design Place Miami Rental Apartments and was approached by rental agent, Yuly. Mark Cassini informed Yuly that he was interested in a two (2) bedroom apartment for November 1, 2012 and that his price range was $1,150-$1,200 per month for rent. The test revealed the following:
a. Mark Cassini was told that there were apartments available for November 1,

2012.
b. Mark Cassini was told the first floor unit, a two (2) bedroom, two (2) bathroom

apartment with a washer and dryer cost $1,350 per month and the second floor unit, a two (2) bedroom, one (1) bathroom unit with a small den, cost $1,095 per month.
c. Mark Cassini was asked to fill out a form that requested identifying and

demographic information.
d. Mark Cassini was shown the gym, the pool and the location of the laundry

facilities and volleyball courts on the property.


e. Without prompting, the rental agent voluntarily provided Mark Cassini with a

brochure, rental application and rates and requirements documentation. THE TESTS Day #3, October 25, 2012
19. On October 25, 2012, at 1:36p.m., Plaintiff YOLANDA GODFREY, a 35 year old

African-American female and tester for HOPE arrived at Design Place Apartments and was greeted by rental agent, Yillianis Lima. YOLANDA GODFREY inquired whether there was a two (2) bedroom apartment available for November 1st, 2012.

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 9 of 20


a. YOLANDA GODFREY was advised by Yillianis Lima that Design Place

Apartments did not have any two (2) bedroom units available but that there was a three (3) bedroom apartment available for $1,395.
b. YOLANDA GODFREY was not provided any forms to fill out at the leasing

office, and no identifying information or demographic information was requested of her.


c. After asking, YOLANDA GODFREY was provided a brochure and floor plan. d. YOLANDA GODFREY was directed to instead check rental availability with a

different property called Portofino Apartments located on 140th Street and Biscayne Boulevard.
e. YOLANDA GODFREY was then told she could call Design Place Apartments

in December to check their availability. GODFREY was not shown any units on the property nor was she shown any of the amenities at Design Place Apartments.
20. On October 25, 2012, at 2:00p.m., Charlotte Jensen, a White woman who is 38 years

old, arrived at Design Place Miami Rental Apartments to conduct a test for HOPE and was promptly asked by the receptionist if she needed assistance. Charlotte Jensen informed the receptionist that she was looking for a two (2) bedroom apartment. The test revealed the following:
a. The receptionist asked Charlotte Jensen to fill out a form that requested

identifying and demographic information including name, phone number, email address, size of apartment desired, when she wanted to move in, reason for
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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 10 of 20 moving, how she heard about Design Place Apartments, and how many adults and children would be living in the apartment.
b. Charlotte Jensen then met with leasing agent, Yillianis Lima, and advised Ms.

Lima that she was looking for a two (2) bedroom apartment and was looking to move in November 1, 2012. Charlotte Jensen was told that units were available for November 1, 2012.
c. Without prompting, Yillianis Lima gave Charlotte Jensen a tour of a two (2)

bedroom model.
d. Charlotte Jensen was told that Design Place Apartments had called around to

compare prices and found that their rental prices were close to those in Little Haiti so they decided to raise their prices to keep the bad people out.
e. Charlotte Jensen was advised that the rent would be $1,350 for a two (2)

bedroom, two (2) bathroom apartment with a washer and dryer and $1,195 for a two (2) bedroom, one (1) bathroom apartment.
21.

In carrying out the aforementioned actions, Yillianis Lima and Yuly acted

with the consent of, under the control of and/or within their actual and/or apparent authority as agents of SPV Realty LC.
22.

Defendant's unlawful practices were designed with the intent to

discourage, deny and limit available housing based on race or color. Plaintiff Testers INDIA BAZEMORE, DONNTAY COOPER, MICHAEL GOLDWIRE, and YOLANDA GODFREY have been the object of misrepresentations made unlawful under the Fair

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 11 of 20 Housing Act and have suffered injury in precisely the form the statute was intended to guard against.
23.

By engaging in the unlawful conduct described above, Defendants' acted

intentionally, and maliciously to damage the rights and feelings of Plaintiffs in violation of the Fair Housing Act.
24.

In support of its goals, HOPE engages in a variety of educational,

counseling and referral services, as well as community monitoring activities. The Education and Outreach Program offers to housing industry providers, Condominium and Home Owner Association, public housing authorities and not-for-profit Community Development Corporations, the most current information and technical assistance necessary to fully comply with fair housing laws, consent decrees, enforcement agreements, Community Reinvestment Act regulations and affirmative marketing requirements.
25.

HOPE's time and scarce resources have been severely diverted and its

mission frustrated in order to address the allegations outlined in this complaint, and has resulted in expenditures which should have been used to affirmatively further fair housing without the cost of litigation.
26.

HOPE has been, and continues to be, adversely affected by the

discriminatory acts, policies, and practices of the Defendants. 25. As a result of the acts and conduct of the defendants, Plaintiff HOPE has

suffered and continues to suffer interference with its mission, diversion of its resources and obstruction of its purpose of ensuring equal housing opportunities throughout South

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 12 of 20 Florida free from race and color discrimination. Plaintiff H.O.P.E has been, and continues to be adversely affected by the acts, policies, and practices of the Defendant and/or their agents. 26. Defendants discriminatory actions have (1) interfered with the efforts and

programs of HOPE which are intended to bring about equality of opportunity for all persons regardless of race or color; (2) forced HOPE to devote scarce resources to identify and counteract Defendants' unlawful housing practices and to otherwise divert those same resources from its education, counseling, and referral services; (3) interfered with the right of HOPE's constituents to enjoy the benefits of living in a community which does not discriminate against persons based on race or color; and, (4) frustrated HOPEs mission and purpose of promoting the equal availability of housing to all persons without regard to race, color, religion, gender, national origin, familial status, or disability. 27. Plaintiffs have retained the Law Offices of Matthew W. Dietz, P.L., and

have agreed to pay the Law Offices for their reasonable fees and costs incurred herein.

CAUSE OF ACTION COUNT ONE- VIOLATION OF THE FAIR HOUSING ACT Section 804(a) 28. Plaintiff HOPE repeats the allegations contained in paragraphs (1) through

(27) as fully set forth herein. 29. Defendant has engaged in discrimination on the basis of race or color by

otherwise making unavailable or denying, a dwelling to any person because of race and color.

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 13 of 20 30. Defendant has outright advised African American persons of color that

units were unavailable, when, in fact, units were available for prospective tenants who were White. 31. Defendants made dwellings unavailable by engaging in unlawful steering

activities, including: a) failing to inform African American testers of desirable features of a dwelling or of a community, neighborhood, or development; b) advising White testers that SPV Realty charged more to keep out the bad persons from Little Haiti, in an attempt to perpetuate, segregated housing patterns; c) failing to obtain demographic and contact information from African American prospective tenants, but obtaining such information from White tenants. d) failing to provide to African-American persons information about the availability of apartments that is as full, complete, and consistent with the information they provide to White persons. 32. Because of race and color, Defendant SPV Realty has restricted the

choices of Black and African-Americans by word or conduct in connection with seeking, negotiating for, and renting dwellings. Such acts perpetuate segregated housing patterns in the City of Miami, and discourage and obstruct choices in the community. 33. As a result of the acts and conduct of the defendants, Plaintiff HOPE has

suffered and continues to suffer interference with its mission, diversion of its resources

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 14 of 20 and obstruction of its purpose of ensuring equal housing opportunities throughout South Florida free from race and color discrimination. Plaintiff H.O.P.E has been, and continues to be adversely affected by the acts, policies, and practices of the Defendant and/or their agents. 34. Defendant's discriminatory actions have (1) interfered with the efforts and

programs of HOPE which are intended to bring about equality of opportunity for all persons regardless of race or color; (2) forced HOPE to devote scarce resources to identify and counteract Defendants' unlawful housing practices and to otherwise divert those same resources from its education, counseling, and referral services; (3) interfered with the right of HOPE's constituents to enjoy the benefits of living in a community which does not discriminate against persons based on race or color; and, (4) frustrated HOPEs mission and purpose of promoting the equal availability of housing to all persons without regard to race, color religion, gender, national origin, familial status, or disability. COUNT TWO- VIOLATION OF THE FAIR HOUSING ACT Section 804(b) 35. Plaintiff HOPE repeats the allegations contained in paragraphs (1) through

(34) as fully set forth herein. 36. Defendant has discriminated against HOPE by discriminating against it

and its constituents in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith, because of their race and color, by imposing different rental charges for the rental of a dwelling upon any person because of race and color.

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 15 of 20 37. As a result of the acts and conduct of the defendants, Plaintiff HOPE has

suffered and continues to suffer interference with its mission, diversion of its resources and obstruction of its purpose of ensuring equal housing opportunities throughout South Florida free from race and color discrimination. Plaintiff H.O.P.E has been, and continues to be adversely affected by the acts, policies, and practices of the Defendant and/or their agents. 38. Defendant's discriminatory actions have (1) interfered with the efforts and

programs of HOPE which are intended to bring about equality of opportunity for all persons regardless of race or color; (2) forced HOPE to devote scarce resources to identify and counteract Defendants' unlawful housing practices and to otherwise divert those same resources from its education, counseling, and referral services; (3) interfered with the right of HOPE's constituents to enjoy the benefits of living in a community which does not discriminate against persons based on race or color; and, (4) frustrated HOPEs mission and purpose of promoting the equal availability of housing to all persons without regard to race, color religion, gender, national origin, familial status, or disability. COUNT THREE- VIOLATION OF THE FAIR HOUSING ACT Section 804(c) UNTRUE INFORMATION 39. Plaintiffs, HOPE, INDIA BAZEMORE, DONNTAY COOPER,

MICHAEL GOLDWIRE, and YOLANDA GODFREY repeats the allegations contained in paragraphs (1) through (38) as fully set forth herein. 40. It is unlawful for a person to convey false or inaccurate information

regarding the availability of a dwelling for sale or rental to any person, including testers,
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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 16 of 20 regardless of whether such person is actually seeking housing, because of race, color, religion, sex, handicap, familial status, or national origin. 41. Because of race and color, SPV Realty provided inaccurate or untrue

information to Plaintiffs INDIA BAZEMORE, DONNTAY COOPER, MICHAEL GOLDWIRE, and YOLANDA GODFREY about the availability of dwellings for rental. 42. Further, Defendant SPV Realty limited the type of information to

Plaintiffs regarding suitably priced dwellings available for inspection or rental, solely because of race and color. 43. Plaintiffs HOPE, INDIA BAZEMORE, DONNTAY COOPER,

MICHAEL GOLDWIRE, and YOLANDA GODFREY were damaged as a result of the inaccurate, limited and untrue information. 44. INDIA BAZEMORE, DONNTAY COOPER, MICHAEL GOLDWIRE,

and YOLANDA GODFREY suffered mental pain and anguish by facing such discrimination based upon their race and color. 45. As a result of the acts and conduct of the defendants, Plaintiff HOPE has

suffered and continues to suffer interference with its mission, diversion of its resources and obstruction of its purpose of ensuring equal housing opportunities throughout South Florida free from race and color discrimination. Plaintiff H.O.P.E has been, and continues to be adversely affected by the acts, policies, and practices of the Defendant and/or their agents. 46. Defendant's discriminatory actions have (1) interfered with the efforts and

programs of HOPE which are intended to bring about equality of opportunity for all

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 17 of 20 persons regardless of race or color; (2) forced HOPE to devote scarce resources to identify and counteract Defendants' unlawful housing practices and to otherwise divert those same resources from its education, counseling, and referral services; (3) interfered with the right of HOPE's constituents to enjoy the benefits of living in a community which does not discriminate against persons based on race or color; and, (4) frustrated HOPEs mission and purpose of promoting the equal availability of housing to all persons without regard to race, color religion, gender, national origin, familial status, or disability. COUNT FOUR- VIOLATION OF THE FAIR HOUSING ACT Section 804(c) 47. Plaintiff HOPE repeats the allegations contained in paragraphs (1) through

(46) as fully set forth herein. 48. It is discriminatory and unlawful to make, print or publish, any

advertisement with respect to the rental of a dwelling which indicates any preference, limitation or discrimination because of race or color. 49. Defendant SPV Realty publishes a brochure for Design Place which uses

photographs which convey that dwellings are available or not available to a particular group of persons because of race, color. 50. Defendant SPV Realtys brochure contains [x] photographs in total [y] of All of the models in all [y]

the photographs have models in such photographs. photographs are White.

WHEREFORE, Plaintiffs, HOUSING OPPORTUNITIES PROJECT FOR EXCELLENCE, INC., INDIA BAZEMORE, DONNTAY COOPER, MICHAEL

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 18 of 20 GOLDWIRE, and YOLANDA GODFREY, demands judgment against the Defendant, SPV REALTY LC d/b/a DESIGN PLACE RENTAL APARTMENTS to enjoin Defendant from discriminating against persons based upon race and color, and to grant the following relief: a. That the Court declare that the actions of the Defendant violated the Fair Housing Act by discriminating against persons of color and AfricanAmericans; b. That the Court enjoin Defendants from discriminating against Plaintiffs or any other person, because of because of their race or color; c. That the Court award INDIA BAZEMORE, DONNTAY COOPER, MICHAEL GOLDWIRE, and YOLANDA GODFREY, compensatory and punitive damages; d. That the Court award appropriate compensatory and punitive damages to Plaintiff HOUSING OPPORTUNITIES PROJECT FOR EXCELLENCE, INC. and against Defendants to compensate it for the drain on its resources that can be reasonably attributed to the frustration of HOPE, INC.s purpose of enforcing the Fair Housing laws in Florida and to educate the public to combat the effects of the discrimination perpetrated to such victims of housing discrimination; e. That the Court award appropriate injunctive relief to disclose the tenants of SPV Realty who have paid additional amounts because of their race and color and provide appropriate relief to such victims of discrimination. appropriate

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 19 of 20 f. That the Court award appropriate injunctive relief to disclose the names of those who did not rent at Design Place due to the discriminatory acts of SPV Realty and provide appropriate relief to such victims of discrimination. g. That the Court declare that the Defendants acts were willful and wanton and in reckless disregard of the Plaintiffs civil rights under law; h. That the Court order Defendant to provide a notice to all current and prospective tenants of Design Place of their rights under the Fair Housing Act; i. That the Court order Defendant to publish appropriate notices of their duties under the Fair Housing Act in appropriate local and national publications. j. That the Court order that the Defendant instruct all of its employees, principals, agents, independent contractors and/or other persons who deal with the rental or management of any and all housing currently managed and/or controlled by Defendant or any parent or affiliated entity, of the terms of the Courts Order and the Fair Housing Act, Fair Housing Act and implementing regulations; k. That the Court order that the Defendant shall maintain for inspection by Plaintiffs and all other tenants or owners at its rental offices, copies of the Fair Housing Act, Fair Housing Amendments Act and implementing regulations;

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HOPE, Inc. v. SPV REALTY LC COMPLAINT Page 20 of 20 l. Find that Plaintiffs are entitled to an award of attorneys fees and costs, and reserve ruling as to the amounts and the applicable multiplier until the conclusion of the trial on this matter; m. And grant any other such relief as this Court deems just and equitable.

THE PLAINTIFFS DEMAND A JURY TRIAL FOR ALL SUCH ISSUES SO TRIABLE IN THIS MATTER. Respectfully submitted on this 16th day of November, 2012. Law Offices of Matthew W. Dietz, P.L. 2990 Southwest 35th Avenue Miami, Florida 33133 Tel: (305) 669-2822 Fax: (305) 442-4181 Email: MatthewDietz@USDisabilityLaw.com

By: s/ Matthew W. Dietz MATTHEW W. DIETZ, ESQ. Florida Bar No.: 0084905

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