R. Alexander Acosta
Assistant Attorney General
Steven H. Rosenbaum
Donna M. Murphy
S.E. Pietrafesa
Attorneys
U.S. Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section - NWB
950 Pennsylvania Ave
Washington, D.C. 20530
202-616-2217
202-514-1116 - fax
Daniel G. Bogden
United States Attorney
Blaine T. Welsh
Assistant U.S. Attorney
333 Las Vegas Boulevard
Suite 5000
Las Vegas, NV 89101
702-388-6336
702-388-6787 - fax
Attorneys for Plaintiff United States
CLARK COUNTY LEGAL SERVICES PROGRAM, INC.
Daniel D. Ebihara (NV Bar No. 6280)
Sara V. Winter (NV Bar No. 6174)
800 South Eighth Street
Las Vegas, NV 89101-7051
702-386-1070
702-366-0569 - fax
BRANCART & BRANCART
Christopher Brancart (CA Bar No. 128475)
Elizabeth Brancart (CA Bar No. 122092)
Post Office Box 686
Pescadero, California 94060
650-879-0141
650-879-1103 - fax
Attorneys for Plaintiff Nevada Fair Housing Center, Inc.
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
UNITED STATES OF AMERICA,
Plaintiff,
Civil Action No.
v.
CV-S-02-1468-LRH(RJJ)
WILMARK DEVELOPMENT CO.;
MARK SCHMIDT CONSTRUCTION;
WLW of NEVADA, INC.; DE LUNA,
INC.; and GREEN VALLEY COUNTRY
CLUB LIMITED PARTNERSHIP,
Defendants.
___________________________________
NEVADA FAIR HOUSING
CENTER, INC.; et al.,
Plaintiffs,
vs.
Civil Action No. CV-S-01-0996-JCM(RJJ)
PARTNERSHIP, etc., et al.,
Defendants.
___________________________________
CONSENT DECREE
Plaintiffs United States and Nevada Fair Housing Center
(plaintiffs) and defendants Wilmark Development Co.; Mark Schmidt
Construction; WLW of Nevada, Inc.; Green Valley Country Club
Limited Partnership; Wilmark Corporation of Nevada; and Wilmark
Management Services (defendants) agree to the terms of this
Consent Decree resolving the Complaint filed by the United States
in case number CV-S-02-1468-LRH(RJJ) and the Complaint filed by
Nevada Fair Housing Center in case number CV-S-01-0996-JCM(RJJ).
INTRODUCTION
On August 23, 2001, Nevada Fair Housing Center and Frances
Verso and Ettilio Verso filed their Complaint alleging violations
of Sections 804(f)(1), (f)(2), (f)(3)(B) and (f)(3)(C) of the
Fair Housing Act, 42 U.S.C. §§ 3604(f)(1)(C), (f)(2), (f)(3)(B)
and (f)(3)(C) as amended by the Fair Housing Amendments Act of
1988, 42 U.S.C. §§ 3601-3619 (the Act). Specifically, these
plaintiffs' Complaint alleges that defendants Wilmark Development
Co.; Mark Schmidt Construction; Wilmark Corporation of Nevada;
Wilmark Management Services; and Green Valley Country Club
Limited Partnership have engaged in a pattern or practice of
discrimination by failing to make reasonable accommodations and
by failing to design and construct Green Valley Country Club
Apartments in accordance with the design and construction
requirements of the Act. Mr. and Mrs. Verso have settled and
dismissed their claims. (See Docket No. 55.)
On November 7, 2002, the United States filed its Complaint
alleging violations of Sections 804(f)(1), (f)(2), and (f)(3)(C)
of the Fair Housing Act, 42 U.S.C. §§ 3604(f)(1)), (f)(2) and
(f)(3)(C) as amended by the Fair Housing Amendments Act of 1988,
42 U.S.C. §§ 3601-3619. Specifically, the United States
Complaint alleges that defendants Wilmark Development Co.; Mark
Schmidt Construction; WLW of Nevada, Inc.; and De Luna, Inc. have
engaged in a pattern or practice of discrimination by failing to
design and construct Green Valley Country Club Apartments (Green
Valley) with the features of accessible and adaptable design set
forth in 42 U.S.C. § 3604(f)(3)(C). Green Valley Country Club
Limited Partnership, which currently owns Green Valley, is named
as a defendant in this action solely as a necessary party for
relief.
Green Valley is an apartment complex located in Henderson,
Nevada, containing a total of 412 apartments. The complex was
built in two phases. Phase I consists of 22 buildings and was
constructed for first occupancy before March 13, 1991. Phase I
of Green Valley contains no units which are covered units and
subject to the Fair Housing Act. Phase II consists of nineteen
buildings containing 204 units, 90 of which are located on the
ground-floor. All of the dwelling units in Phase II of Green
Valley that are the subject of this lawsuit were designed and
constructed for first occupancy after March 13, 1991. These
units and the public and common use areas of Phase II of Green
Valley are subject to the design and construction requirements of
42 U.S.C. § 3604(f)(3)(C).
The ground-floor apartments of Phase II at Green Valley are
"covered multi-family dwellings" within the meaning of the Act,
42 U.S.C. § 3604(f)(7)(B). In general, the Act requires that,
for residential buildings with four or more units, all ground-floor units in non-elevator buildings include certain basic
accessibility and adaptability design features intended to make
housing usable or adaptable by a person who is or who becomes
disabled. Accordingly, 90 of the 204 units of Phase II at Green
Valley are "covered"units under the Act.
The Act provides that all ground-floor units, in non-elevator buildings (with four or more units) designed and
constructed for first occupancy after March 13, 1991, are
"covered units" and must include certain basic features of
accessible and adaptable design to make such units usable by a
person who is or who becomes disabled. 42 U.S.C.
§§ 3604(f)(3)(C) and (f)(7)(B). The features of accessible and
adaptable design required by the Act include: (a) public and
common use areas that are readily accessible to and usable by
persons with disabilities; (b) doors for passage into and within
all premises that are sufficiently wide to allow passage by
persons using wheelchairs; (c) an accessible route into and
through the dwelling; (d) light switches, electrical outlets,
thermostats, and environmental controls in accessible locations;
(e) reinforcements in bathroom walls to allow later installation
of grab bars; and (f) usable kitchens and bathrooms such that an
individual in a wheelchair can maneuver about the space.
42 U.S.C. § 3604(f)(3)(C).
Wilmark Development Company was the owner and developer of
Phase II of Green Valley. Mark Schmidt Construction built Phase
II of Green Valley. WLW of Nevada, Inc. provided certain
architectural design for all of Green Valley. De Luna, Inc.
provided the civil engineering services for and designed Phase II
of Green Valley. Green Valley Country Club Limited Partnership
now owns Green Valley.
The parties agree that this Court has jurisdiction over the
subject matter of this case. During the course of the
proceedings, defendants raised various defenses to portions of
the above claims. The parties negotiated a settlement such that
the controversy will be resolved without further proceedings and
without an evidentiary hearing. Therefore, the parties have
jointly consented to the entry of this Consent Decree as
indicated by the signatures appearing below.
It is hereby ORDERED, ADJUDGED and DECREED:
I. GENERAL INJUNCTION
Defendants, their officers, employees, agents, successors
and assigns and all other persons in active concert or
participation with any of them are enjoined from discriminating
on the basis of disability as prohibited by the Fair Housing Act,
42 U.S.C. § 3604(f)(1)-(3).
II. CORRECTIVE ACTIONS
Defendants Wilmark Development Co., Mark Schmidt
Construction, and WLW of Nevada, Inc. recognize that certain
features of the ground-floor apartments and public and common use
areas of Phase II at Green Valley have not met the Act's design
and construction requirements. To address these deficiencies,
Green Valley Country Club Limited Partnership (GVCCLP) agrees to
take the following corrective actions with respect to the covered
ground-floor dwellings and the public and common use areas of
Phase II at Green Valley.
Defendants Wilmark Development Co.; Mark Schmidt
Construction; WLW of Nevada, Inc.; and GVCCLP have agreed to pay
the sum of SEVEN HUNDRED EIGHTEEN THOUSAND DOLLARS ($718,000)
(the Corrective Cost) in order to settle the violations of the
Act alleged by the United States. Within thirty (30) days from
the date of entry of this Decree, these defendants shall deposit
the Corrective Cost in a separate interest-bearing escrow account
(the Fund), and will provide the United States with the name of
the depository institution and any information it requests
periodically on the Fund. As to the allocation of the Corrective
Cost, GVCCLP will contribute the sum of ONE HUNDRED FORTY THREE
THOUSAND FIVE HUNDRED DOLLARS ($143,500) and WLW of Nevada, Inc.
will contribute the sum of FIVE HUNDRED SEVENTY FOUR THOUSAND
FIVE HUNDRED DOLLARS ($574,500). Defendant GVCCLP has contracted
with an entity (Entity) approved by plaintiffs to administer the
Fund and to assist in contracting with licensed contractors to
take the corrective actions described in this Section and
Appendices A and B with respect to the public and common use
areas and the covered ground-floor dwellings. (See Appendix G.)
The actual contracts with licenced contractors to perform the
work provided for herein shall be contracts which give standard
contracting protections to GVCCLP on forms reasonably acceptable
to GVCCLP. The Entity has provided Defendant GVCCLP with a
guarantee that the corrective cost is adequate to perform the
required corrective actions referred to above. The Entity will
be required to obtain appropriate lien releases before making any
payments from the Fund for services, labor, and/or materials.
The parties agree that the items described in this Section and
Appendices A and B are the only actions necessary in order to
bring the common areas and covered units into substantial
compliance with the requirements of the Act and the Guidelines.
The parties agree that the actions by defendants to pay the
Corrective Cost and to contract and cooperate with the Entity to
perform the repairs will satisfy the repair requirements set
forth herein. The parties also agree that defendants will not be
required to pay more for the Corrective Cost even if ultimately
the cost to complete all scheduled work should be greater than
such amount. Defendant GVCCLP shall cooperate with the Entity to
carry out the corrective actions specified herein.
A. Public and Common Use Areas
Within sixty (60) days of the entry of this Decree, GVCCLP
shall provide written notice to all residents of Green Valley
that the modifications specified at Appendix A will be performed
to the public and common use areas at Green Valley. Such notice
shall conform with Appendix C.
Within 90 (ninety) days from the date of entry of this
Decree, modifications to the public and common use areas of Green
Valley shall commence as specified in Appendix A. These
modifications shall be completed within six months thereafter.
B. Dwelling units
Within fifteen (15) days prior to commencing work on any
occupied covered ground-floor unit, GVCCLP, in conjunction with
the Entity, shall provide written notice to the affected ground-floor unit residents at Green Valley that the modifications
specified at Appendix B will be performed to their units. Such
notice shall conform with Appendix D and shall be sent with a
self-addressed postage prepaid envelope and a list specifying
what alterations will be made in their specific unit. A copy of
the notice shall be simultaneously provided to The United States.
Retrofits of all ground-floor units shall be completed
expeditiously but no later than three (3) years from the date of
entry of the Consent Decree. It is the intent of the parties to
complete the repairs in a methodical fashion and to the extent
possible to perform repairs in vacant units between tenancies.
In this regard, the Entity will be required to perform all
repairs in a given unit within fifteen (15) days of receiving
written notification of an available unit by GVCCLP.
C. Sale or Transfer of an Ownership Interest in the
Subject Property
The sale or transfer of ownership, in whole or in part, of
Green Valley shall not affect defendants' continuing obligations
to retrofit the property as specified in this Consent Decree.
Should defendant GVCCLP decide to sell or transfer ownership, in
whole or in part, of any of Green Valley prior to the completion
of the retrofits specified in Appendices A and B, it will, at
least thirty (30) days prior to completion of the sale or
transfer, (a) provide to each prospective buyer written notice
that the complexes are subject to this Consent Decree, including
specifically defendants' obligations to complete required
retrofit work, along with a copy of this Consent Decree; and (b)
provide to the United States, by facsimile and first class mail,
written notice of its intent to sell or transfer ownership, along
with a copy of the notice sent to each buyer, and each buyer's
name, address and telephone number.
III. NON-DISCRIMINATION IN FUTURE DESIGN AND CONSTRUCTION
For a period of four (4) years from the date of entry of
this Consent Decree, defendants Wilmark Development Co. and Mark
Schmidt Construction; WLW of Nevada, Inc. shall each submit to
the United States information regarding any covered multifamily
dwellings that defendants design and/or intend to build. (1) The
following information shall be submitted: a) the name and
address of the project; b) a description of the project and the
individual units, including number and type of dwellings and
amenities in the project; c) the names and addresses of all
architects and site engineers; d) when the site engineer is
specifically employed by any of the above defendants, a statement
from the site civil engineer(s) involved with the project
acknowledging and describing his/her knowledge of and training in
the requirements of the Fair Housing Act and in the field of
accessible site design and certifying that he/she has reviewed
the engineering documents for the project and that the design
specifications therein fully comply with the accessibility
requirements of 42 U.S.C. § 3604(f)(3)(C) and the Guidelines; and
e) when the architect is specifically retained by any of the
above defendants, a statement from the architect acknowledging
and describing his/her knowledge of and training in the
requirements of the Fair Housing Act and in the field of
accessible design and certifying that he/she has reviewed the
plans and that the design specifications therein fully comply
with the accessibility requirements of 42 U.S.C. § 3604(f)(3)(C)
and the Guidelines.
IV. EDUCATIONAL PROGRAM
A. Within thirty (30) days of the entry of this Decree,
defendants shall provide to all their upper level supervisory
employees and site managers involved in the actual design or
construction of multi-family dwellings covered by the Act: (1) a
copy of this Consent Decree and (2) instruction on (I) the terms
of this Consent Decree, (ii) the requirements of the Act with
regard to non-discrimination against persons with disabilities
and design and construction, and (iii) their responsibilities and
obligations under each. All upper level supervisory design or
construction personnel and site managers at Green Valley shall be
required to attend training as provided in Section VII(B) below.
The training shall be conducted by a qualified person or
organization unconnected to defendants, their employees, agents,
or counsel. Any expenses associated with this training shall be
borne by the applicable defendants. This training may be
conducted as part of the first annual training session required
by Paragraph VII(B)(3), so long as it occurs within the thirty
(30) days specified in this Paragraph.
B. Within thirty (30) days after each new upper level
supervisory employee or site manager involved in the actual
design or construction of multi-family dwellings covered by the
Act commences an employment, agency, or contractual relationship
with defendants, defendants will provide such employees a copy of
this Consent Decree and shall secure and deliver to counsel for
the United States a signed statement from each such employee or
site manager that he or she has received, read, and understands
this Decree.
V. PUBLIC NOTICE OF NON-DISCRIMINATION POLICY
A. During the term of this Decree, defendant GVCCLP shall
post and prominently display the federal Fair Housing Poster as
described by 24 C.F.R. 110.15 and 110.25 in the sales or rental
offices of all dwellings owned or operated by them, if any, and
in any other place in which persons may inquire about renting
dwellings from them.
B. For the duration of this Consent Decree, in all future
advertising in newspapers where the advertisement is more than
two square inches, and on pamphlets, brochures and other
promotional literature regarding Green Valley or any new covered
complexes that any defendant may develop or construct, defendants
shall place, in a conspicuous location, a statement that the
dwelling units include features for persons with disabilities
required by the federal Fair Housing Act.
VI. ADDITIONAL MONITORING REQUIREMENTS
A. For the duration of this Decree, defendants shall
advise counsel for the United States in writing within fifteen
(15) days of receipt of any new and initial formal or informal
complaint against them, their employees or agents, regarding
discrimination regarding housing on the basis of disability under
the Act. These defendants shall also promptly provide the United
States all non-privileged information it may request concerning
any such complaint. Within fifteen (15) days of the resolution
of any such complaints, defendants shall advise counsel of the
United States of such resolution.
B. For the duration of this Decree, defendants are
required to preserve all records related to this Decree regarding
Green Valley and all future covered multifamily dwellings to be
designed, constructed, owned, operated or acquired by them. Upon
reasonable notice to defendants, representatives of the United
States shall be permitted to inspect and copy any of defendants'
non-privileged records or inspect any covered dwelling or any
covered public and common use areas under defendants' control at
reasonable times so as to determine compliance with the Consent
Decree.
C. Within 180 days after the entry of this Decree, and
thereafter on the anniversary of entry of this Decree throughout
the term of the Decree, defendants shall submit a report that
includes the following information:
- The signed statement of each upper level supervisory
employee, or site managers acknowledging that he/she
has received the required information and training
under the Decree;
- A signed copy of Appendix F by each employee involved
in site or rental management at Green Valley; and
- All current advertising in excess of two square inches
or other promotional literature regarding these
defendants' covered multifamily dwellings.
D. Provided that GVCCLP commences to perform hereunder and
continues to pursue the completion of the repairs called for here
in, plaintiff NFHC, on behalf of itself, agrees not to file any
future private claim or complaint with the U.S. Department of
Housing and Urban Development under the Fair Housing Act on
behalf of itself or any individual, arising out of any claim
regarding whether the covered
between the parties. The parties, and each of them, acknowledge
that they are aware that they may hereafter discover facts inunits or common area of Green
Valley were designed or constructed in compliance with 42 U.S.C. § 3604(f)(3)(C) of the Act.
VII. PROVISIONS REGARDING
PLAINTIFF NEVADA FAIR HOUSING CENTER
The provisions in this section of the Consent Decree shall
not apply to the United States.
A. Monetary Provisions
GVCCLP in case number CV-S-01-0996-JCM(RJJ), except De Luna,
Inc., shall make a payment of ONE HUNDRED THREE THOUSAND DOLLARS
($103,000) to plaintiff Nevada Fair Housing Center (NFHC) in the
form of checks made payable to the Attorney-Client Trust Account
of Brancart & Brancart. This payment shall be made within
fifteen (15) days of the date of entry of this Consent Decree.
This payment shall consist of a settlement amount of TWENTY
THOUSAND DOLLARS ($20,000) to NFHC, and a settlement amount of
EIGHTY THREE THOUSAND DOLLARS ($83,000) in payment of NFHC's
attorneys' fees and costs. (2)
Except for any obligations or duties created herein, the
parties in Case No. CV-S-01-0996-JCM(RJJ), except De Luna, Inc.,
on their own behalf, and on behalf of their respective heirs,
estates, successors, assignees, administrators, executors,
officers, directors, partners, principals, employees, agents,
attorneys, affiliates, parent or subsidiary corporations, and any
other person or entity acting on their behalf, release each
other, from any and all actions, causes of action, judgments,
liens, objections, indebtedness, costs, damages, losses, claims,
liabilities, and demand of any kind whatsoever which they
heretofore had, now has or hereafter may have against the others
by reason of any act, omission, event, contract, condition,
agreement, representation, misrepresentation, report, disclosure,
failure to disclose, warranty or transaction arising out of or in
any way connected with Green Valley. Nothing contained herein is
intended to act as a release with respect to any other project
addition to or different from those which they now know or
believe to be true with respect to the subject matter of this
Agreement, but it is their intention hereby to fully and finally
forever settle and release any and all matters, disputes, and
differences, known or unknown, now existing or which heretofore
have existed between them, and that in furtherance of this
intention, the releases herein given shall remain in effect as
full and complete releases notwithstanding discovery or existence
of any such additional or different facts.
Each party in Case No. CV-S-01-0996-JCM(RJJ) declares and
represent that this Agreement is being made without relying on
any statements or representations by any other party which are
not contained herein. Each party further declares and represents
that he or she has made such investigation of the facts relating
to the matters addressed in this Consent Decree as he or she
deems necessary.
In entering into this Agreement and the settlement provided
for herein in Case No. CV-S-01-0996-JCM(RJJ), each party assumes
the risk of any misrepresentation, concealment or mistake. If
any party should subsequently discover that any fact relied upon
by it in entering into this Agreement was untrue, or that any
fact was concealed from it, or that its understanding of the
facts or of the law was incorrect, such party shall not be
entitled to any relief in connection therewith, including,
without limitation on the generality of the foregoing, any
alleged right or claim to set aside or rescind this Agreement.
This Agreement is intended to be and is final and binding between
the parties hereto, regardless of any claims of
misrepresentation, promise made without the intention to perform,
concealment of fact, mistake of fact or law, or of any other
circumstance whatsoever.
B. Affirmative Relief
Defendants Green Valley County Club Partnership, Wilmark
Development Company, Mark Schmidt Construction, Wilmark Corp. of
Nevada, and Wilmark Management Services, Inc. in case number CV-S-01-0996-JCM(RJJ) (NFHC defendants), their employees, agents and
all others acting on its behalf shall comply with the following
terms during the duration of this decree:
- The NFHC defendants shall adopt a written policy
regarding reasonable modifications and reasonable
accommodations for Green Valley; specifically, the
policy shall be reviewed and approved by plaintiff
NFHC, and once it is reviewed and approved, shall be
distributed to each current and future household that
occupies a dwelling at Green Valley during the duration
of this decree.
- The NFHC defendants shall distribute an official Form
HUD-903.1 pamphlet to each current and future household
that occupies a dwelling at Green Valley during the
duration of this decree.
- The NFHC defendants shall require fair housing training
once per year for each of the next three years,
conducted by NFHC, for all persons involved in site or
rental management at Green Valley and require each
attendee to execute a copy of Appendix F hereto. The
duration of each annual training session shall be less
than one day with a total cost of $500.00 per training
group.
- Within thirty (30) days after the entry of the
Consent Decree, the NFHC defendants shall
distribute information to each household that
occupies a dwelling at Green Valley explaining
their rights under the Fair Housing Act, including
the rights of persons with disabilities to
reasonable accommodations and reasonable
modifications. Distribution of the information in
subparagraph VI(B)(1) and (2) above will satisfy
this requirement.
VIII. DURATION OF DECREE AND TERMINATION OF LEGAL ACTION
A. This Consent Decree shall remain in effect for four and
one-half (4 ½) years after the date of its entry.
B. By consenting to entry of this Decree, the United
States and defendants agree that in the event that defendants
engage in any future violation(s) of the disability provisions of
the Fair Housing Act, 42 U.S.C. § 3604(f)(3)(A)-(C), in any
construction or ownership beginning after entry of the Decree,
such violation(s) shall constitute a "subsequent violation"
pursuant to 42 U.S.C. § 3614(d)(1)(C)(ii).
C. The parties agree that the complaint against De Luna,
Inc. may be dismissed without prejudice and that no releases are
being granted to De Luna, Inc. The Court shall retain
jurisdiction for the duration of this Consent Decree to enforce
the terms of the Decree as to all other parties, after which time
the case shall be dismissed as to such parties with prejudice.
Plaintiffs may move the Court to extend the duration of the
Decree in the interests of justice.
D. The plaintiffs and defendants shall endeavor in good
faith to resolve informally any differences regarding
interpretation of and compliance with this Decree prior to
bringing such matters to the Court for resolution. However, in
the event of a failure by defendants to perform in a timely
manner any act required by this Decree or otherwise to act in
conformance with any provision thereof, plaintiffs may move this
Court to impose any remedy authorized by law or equity,
including, but not limited to, an order requiring performance of
such act or deeming such act to have been performed, and an award
of any damages, costs, and reasonable attorneys' fees which may
have been occasioned by the violation or failure to perform.
IX. TIME FOR PERFORMANCE
Any time limits for performance imposed by this Consent
Decree may be extended by the mutual agreement of plaintiffs and
the relevant defendants.
X. COSTS OF LITIGATION
The United States and defendants shall bear their own costs
and attorney's fees associated with this litigation.
IT IS SO ORDERED:
This ______ day of _________________, 2004.
________________________________
United States District Judge
Agreed to by the parties as indicated by the signatures of
counsel below.
FOR THE PLAINTIFF UNITED STATES:
DANIEL G. BOGDEN
United States Attorney
BLAINE T. WELSH
Assistant United States Attorney
______________________________
STEVEN H. ROSENBAUM
Chief
DONNA M. MURPHY
Deputy Chief
SUNNY E. PIETRAFESA
Attorney
United States Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section - G St.
950 Pennsylvania Avenue, NW
Washington, D.C. 20530
202-616-2217
202-514-1116 - fax
______________
Date
FOR PLAINTIFF NEVADA FAIR HOUSING CENTER:
_______________________________
DANIEL D. EBIHARA (NV Bar No. 6280)
CLARK COUNTY LEGAL SERVICES PROGRAM, INC.
800 South Eighth Street
Las Vegas, NV 89101-7051
702-386-1070
702-366-0569 - fax
__________________
Date
_______________________________
CHRISTOPHER BRANCART
BRANCART & BRANCART
Post Office Box 686
Pescadero, California 94060
650-879-0141
605-879-1103 - fax
___________________
Date
FOR DEFENDANTS WILMARK DEVELOPMENT CO., MARK SCHMIDT
CONSTRUCTION, WILMARK CORPORATION OF NEVADA, WILMARK MANAGEMENT
SERVICES, AND GREEN VALLEY COUNTRY CLUB LIMITED PARTNERSHIP:
_______________________________
JOHN SMAHA, Esq.
Smaha & Daley
7860 Mission Center Court, Suite 100
San Diego, CA 92108
619-688-1557
619-688-1558 - fax
________________
Date
FOR DEFENDANT WLW of NEVADA, INC.:
_______________________________
RICHARD E. DESRUISSEAUX, Esq.
MAX CORRICK, Esq.
Rawlings, Olson, Cannon, Gormley & Desruisseaux
9950 West Cheyenne
Las Vegas, NV 89129
702-384-4012
702-383-0701 - fax
_____________
Date
1. All submissions to the United States or its counsel
shall be made to: U.S. Department of Justice, Civil Rights
Division, Housing and Civil Enforcement Section - G St., 950
Pennsylvania Avenue, NW, Washington, D.C. 20530. Attn: DJ No.
175-46-108 or as otherwise directed by the United States.
2. The parties do not include the Versos who have settled
with defendants and whose complaint has been dismissed with
prejudice.
Document Filed: May 20, 2004.
