SETTLEMENT AGREEMENT AMONG
THE UNITED STATES OF AMERICA,
INTERMOUNTAIN FAIR HOUSING COUNCIL,
AND
SYRINGA PROPERTY MANAGEMENT, INC.


  1. INTRODUCTION

The United States of America, Intermountain Fair Housing Council ("IFHC"), and Syringa Property Management, Inc. ("Syringa") voluntarily enter into this Settlement Agreement ("Agreement") to resolve allegations that Syringa violated the Fair Housing Act, 42 U.S.C. §§ 3601-3619 ("the Act"), by requiring deposits for support and service animals for disabled tenants. This Agreement is intended to resolve fully and finally all claims by the United States and IFHC relating to the matters referred to in this Agreement. The claims being settled by this Agreement are disputed by Syringa, and this Agreement does not constitute, and should not be construed as, an admission of liability by Syringa.
  1. STATEMENT OF AGREEMENT

The parties agree that this matter should be resolved without judicial action. Accordingly, the parties enter into this Agreement in full resolution of the United States' and IFHC's allegations that Syringa violated the Act by requiring deposits for support and service animals for disabled tenants.
This Agreement constitutes the entire agreement among the parties on the matters raised herein, and no other statement, promise or agreement, either written or oral, made by any party is enforceable under its provisions. This Agreement is limited to the allegations described herein and encompassed within HUD case nos. 10-00-0397-8, 10-00-0401-8, 10-00-0402-8, 10-00-0403-8, 10-00-0404-8, 10-00-0405-8, 10-00-0435-8, 10-00-0447-8, and 10-00-0448-8. It does not purport to remedy any other potential or unknown violations of the Act or any other Federal, State or local law. Nor does this Agreement affect the rights of any individuals as against Syringa. Syringa acknowledges its continuing responsibilities to comply with all aspects of the Act.
The "date of this Agreement" shall be the date of the last signature listed below and the Agreement shall be effective as of such date.
  1. REMEDIAL PROVISIONS

Syringa, and its officers, employees, agents, successors and assigns and all other persons in active concert or participation with each, agree:
  1. To comply with the Act;
  2. Not to charge deposits or fees to disabled tenants in connection with their maintenance of service or support animals necessary to afford those persons full enjoyment of the premises; and
  3. To disseminate, within thirty (30) days of the date of this Agreement, a written notice to all employees who would otherwise be in a position to charge or collect such deposits, stating that such deposits will not be charged.

  1. ENFORCEMENT

  1. Except as otherwise specifically provided for herein, the undertakings imposed pursuant to this Agreement shall terminate one (1) year after the date of this Agreement provided that all actions required by the Agreement have been performed.
  2. This Agreement may be modified at any time by written agreement of all parties. Any and all such written modifications shall be considered to be part of this Agreement. Upon any failure by Syringa to perform in a timely manner any act required by this Agreement, or in the event of any other act by Syringa that violates any provision of this Agreement, the United States may initiate an action to seek to enforce this Agreement in the United States District Court for the District of Idaho. Syringa agrees that it will not object to the jurisdiction of the court to hear such action. Notwithstanding the foregoing, the parties shall endeavor in good faith to resolve informally any differences regarding interpretation of, or compliance with, this Agreement prior to petitioning a court for a judicial resolution of any such differences.

  1. COSTS AND FEES

Each party to this Agreement will bear its own costs and attorneys' fees associated with this matter.
  1. SIGNATURES

It is so agreed and stipulated by the parties as evidenced by the signatures below.


For the United States: For Syringa Prperty Management, Inc:

Timothy J. Moran
Deputy Chief
Richard A. Koffman
Trial Attorney
Housing and Civil Enforcement Section
Civil Rights Division
U.S. Department of Justice
P.O. Box 65998
Washington, D.C. 20035-5998
(202) 305-3102
James G. Reid, Esquire
Ringert Clark
Chartered Lawyers
455 South Third Street
P.O. Box 2773
Boise, ID 83701
(208) 342-4591
For Intermountain Fair Housing Council:
Richard Mabbutt
Executive Director
Intermountain Fair Housing Council
310 North 5th Street
Boise, ID 83701
(208) 383-0695

Document Filed: August 15, 2001.