Mike O’CONNELL
JEFFERSON County ATTORNEY
600 W. Jefferson Street, Suite 2086
Louisville, KY 40202
(502) 574-6336
Julie Lott Hardesty Fax (502) 574-5366
First Assistant Sayer
nike.oconnell @louisvilleky.gov
Louisville Metro Council Members
Districts 1 to 26
LOUISVILLE METRO COUNCIL
601 West Jefferson Street
Louisville, Kentucky 40202
Steven Ott, Clerk
Louisville Metro Council
601 West Jefferson Street
Louisville, Kentucky 40202
RE: United States Department of Justice Letter Concerning 0-326-17
(The Prospect Cove Development).
Dear Councilmembers and Mr. Ott:
This is a very important matter which demands your full attention. The United
States Department of Justice has launched an investigation into the Louisville Metro Council for
potential race-based discrimination in housing as a result of Ordinance 326-17. As you were
previously informed, the Jefferson County Attorney's Office does not represent Louisville Metro
Council in this particular matter for a variety of reasons. Outside counsel has been retained for
you and he is included on this letter.
It is imperative that you read the attached notice carefully and that it not be
ignored. A response is due, by my calculations Mareh 14, 2018. You should independently
calculate this date yourselves. I have attached a full copy of the DOJ letter to this email.JEFFERSON CouNTY ATTORNEY
Letter to Metro Council
February 19, 2018
Page 2
‘The Department of Justice letter provides, at page 2:
During the course of this investigation, [the US Department of Justice] request
that the Metro Council maintain all records, documents, files, correspondence,
audio and video records, and electronically stored information related to
Ordinance No. 0-326-17, LDG Multifamily, LLC, and Prospect Cove since
January 1, 2016 that is currently in the Metro Council's custody and control, or in
the custody and control of individual Metro Councilmembers, including any
legislative and administrative staff. Any information that is responsive to this
letter should be retained and produced to the Department in its entirety. Do not
alter, destroy, or otherwise dispose of any such items.
Based upon the foregoing, this request will likely apply to your official communication
centers and to your individual email and cellphones and to those of your aides and assistants.
While many of these documents may be within the LDG Multifamily, LLC v, Louisville Metro
Council litigation, you should not assume so and independently review and search for these
records. A document tender to the Department of Justice is not to be taken lightly. You are
strongly advised to comply with the Department of Justice’s direction on this matter by
preserving the applicable information for tender. Consult with your attorney, John Hanley, with
your questions
For your convenience, I have attached a copy of the voting record on the ordinance’s
passage. However, be advised that the individual vote taken on this matter does not obviate
one’s responsibility to respond to the Department of Justice. This request is directed at all
members of Metro Council and their staff.
Mike O*Connell
sincerely,
MOC{ij
Enclosures
ce: John Hanley, Jr.