complaint in united states v brooklyn park (d. minn.) · 6/18/2015 · case 0:15-cv-02489-pjs-hb...

CASE 015-cv-02489-PJS-HB Document 1 Filed 051815 of12

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Civil No 15shy

United States of America

Plaintiff

v COMPLAINT

Brooklyn Park 73rd Leased Housing Associates LLC Dominium Management Servjces LLC Susan Meyer and Gina Estrem

Defendants

The United States of America for its complaint against Defendants Brooklyn Park

73rd Leased Housing Associates LLC Dominium Management Services LLC Susan

Meyer and Gina Estrem alleges

NATURE OF ACTION

1 This is an action brought by the United States to enforce the provisions of

Title VIII of the Civil Rights Act of 1968 as amended by the Fair Housing Amendments

Act of 1988 42 USC sectsect 3601 through 3619 (the Act)

2 The United States alleges that Defendants engaged in discriminatory refusal

to rent discrimination in the terms conditions or privileges of rental refusal to make

reasonable accommodations in rules policies practices or services when such

accommodations may be necessary to afford a person equal opportunity to enjoy a

dwelling and unlawful retaliation in the form of interference with the enjoyment of a

CASE 015-cv-02489-PJS-HB Document 1 Filed 051815 Page 2 of 12

dwelling on account of the exercise of protected rights in violation of the Fair Housing

Act 42 USC sectsect 3604(plusmn)(l)(A) (plusmn)(2)(A) (plusmn)(3)(B) and 3617

3 Complainant Raelynn Gonzalez filed a complaint of discrimination with the

United States Department of Housing and Urban Development (HUD)

4 HUD charged the Defendants with discrimination on the basis of disability

failure to make a reasonable accommodation and retaliation in violation of the Fair

Housing Act

5 Complainant elected to have the claims stated in the HUD charge

determined in a civil action per her rights under the Fair Housing Act 42 USC sect

3612(a)

6 The United States therefore brings this action for injunctive relief and

monetary damages on behalf of Raelynn Gonzalez pursuant to the Fair Housing Act 42

usc sect 3612(0)

STATEMENT OF JURISDICTION AND VENUE

7 This Court has jurisdiction pursuant to 28 USC sectsect 1331 and 1345 and 42

usc sect 3612(0)

8 Venue is proper in this District pursuant to 28 USC sect 1391 and 42 USC

sect 3612(0)

2


PARTIES

9 Plaintiff is the United States of America

10 Defendant Brooklyn Park 73rd Leased Housing Associates LLC

(Brooklyn Park) doing business as Huntington Place Apartments is the owner of

Huntington Place Apartments

11 Defendant Dominium Management Services LLC (Dominium) acts as

the authorized management agent for the owner

12 Defendant Susan Meyer is an employee of Dominiun and serves as the

Community Manager for Brooklyn Park In this capacity she oversees a staff of 23

employees and is responsible for giving employees direction doing inspections and

making sure that employees are trained on company policies

13 Defendant Gina Estrem is a Regional Manager of Dominium Ms Estrem

supervises eight community managers including Ms Meyer

14 Complainant Raelynn Gonzalez was a tenant of Brooklyn Park Ms

Gonzalez has been diagnosed with mental health disabilities These disabilities stem at

least in part from traumatic events she has suffered including witnessing her boyfriends

death due to a self-inflicted gunshot in 2007 and from witnessing her mothers murder in

2008

15 Her disabilities substantially impair major life activities including sleeping

interacting with others learning concentrating and caring for herself

16 Ms Gonzalez is therefore a person with disabilities under the Act 42

USC sect 3602(h)

3


17 In about January 2012 Ms Gonzalezs brother gave her a young pit

bull Subsequently Ms Gonzalezs treating psychologist recognized that Ms Gonzalezs

relationship with the dog was extremely beneficial in helping to alleviate the symptoms

of her disabilities The psychologist has verified that the dog is a major and required

part of her treatment progran1

18 Her treating psychologist has informed the Defendants of the critical role

that her dog plays in her treatment plan and that [h ]aving the dog living with her has

made it possible for her to live in her apartment work at her job and support herself and

pay her bills including her apartment

19 Ms Gonzalezs dog is therefore a required part of her treatment for her

disabilities and it ameliorates the effects of her disabilities by providing emotional

support and helping her engage in major life activities

FACTS

20 Ms Gonzalez was a tenant at the subject property at 5817 73rd Avenue

North Brooklyn Park Minnesota from December 1 2012 through November 30 2013

21 Defendants allow pets and service animals at the subject property but have

a no dangerous breeds policy which prohibits pit bulls

22 In February 2013 Defendants learned that Ms Gonzalez was keeping a pit

bull in her apartment

4

CASE 015-cv-02489-PJS-HB Document 1 Filed 051815 Page 5of12

23 On March 1 2013 Ms Gonzalez asked the Defendants for a reasonable

accommodation to their pet policy so that she could keep the emotional support animal in

her apartment

24 Defendants tlumiddotough counsel denied Ms Gonzalezs request for a

reasonable accommodation and directed her to remove her dog from the apartment within

five days or be subject to a potential sanction for breach of lease

25 Defendants based this determination upon the breed of the animal not

because of any evidence that the dog in question posed a threat of harm or would cause

substantial physical damage to the property of others

26 On April 23 2013 Ms Gonzalez tlu-ough her attorneys at Mid-Minnesota

Legal Aid provided documentation confirming that the requested accommodation would

help alleviate the symptoms of her disabilities thereby permitting her equal opportunity

to enjoy the Defendants prope1iy She again requested a reasonable acconm10dation

27 Defendants again denied the requested accommodation and threatened

eviction

28 On May 3 2013 Ms Gonzalez through her attorney provided a second

letter from her treating psychologist verifying her specific disabilities the need for an

emotional support animal and indicating that retaining this specific animal was important

to her in alleviating the symptoms of her disabilities The psychologist wrote among

other things that being permitted the accommodation of having her current dog living

with her in her apartment is absolutely necessary for her to be able to live in the

apartment and to be able to function in he[r] life including the necessity of her being able

5


to sleep at night Having the dog living with her is essential to her program in her

recovery from the severe trauma she suffered

29 On May 6 2013 Ms Gonzalez through counsel provided Defendants with

the HUD-DOJ Joint Statement on Reasonable Accommodations guidance relating to

assistance animals for persons with disabilities

30 Defendants attorney insisted that the May 3 letter was insufficient to

establish the need for Ms Gonzalez to keep her emotional support dog and demanded to

speak directly to Ms Gonzalez treating psychologist upon threat of eviction On May

20 2013 Defendants attorney wrote that he was no longer interested in continuing to

correspond with Ms Gonzalezs attorney and would file an eviction action against Ms

Gonzalez that week

31 On May 22 2013 Ms Gonzalez fi led in Minnesota state district court a

disability discrimination complaint against the Defendants for their refusal to grant her

reasonable accommodation and a motion for a temporary restraining order to prevent the

Defendants from evicting her before the court ruled on the disability discrimination

complaint

32 On May 29 2013 the Minnesota state district court judge denied her

request for a temporary restraining order and ordered expedited informal discovery of

Ms Gonzalezs psychologist to allow Defendants to assess the need for a reasonable

accommodation

6


33 Ms Gonzalez dismissed her disability discrimination complaint without

prejudice and aiTanged for an interview of her psychologist before a court reporter on

June 6 2013

34 During the interview the psychologist described the imp01tance of the

relationship Ms Gonzalez had with her dog and its role in her hmiddoteatment and recovery

from trauma and stated that losing her dog would be hugely traumatic for her

35 On June 18 2013 in lieu of granting her requested accommodation

Defendants gave Ms Gonzalez two options to avoid eviction (1) immediately terminate

her lease with the return of her June rent and security deposit or (2) keep the dog through

the end of the lease but with the additional burdens of purchasing an insurance pol icy to

cover the dog with Defendants listed as a co-insured acquiring an emotional suppo1i

animal vest to be worn by her dog at all times outside her apartment keeping the dog

leashed when outside her apartment and executing an indemnification and hold harmless

waiver indemnifying the Defendants from any harn1 caused by the dog

36 On June 21 2013 Ms Gonzalez accepted the second option and agreed to

perform the obligations under the agreement

37 On June 30 2013 Ms Gonzalez executed an indemnification agreement

and provided proof of liability insurance policy to Defendants

38 On September 13 2013 Defendants informed Ms Gonzalez that her lease

would not be renewed and she was required to vacate her apartment by November 30

20 13

7


39 On October 1 2013 Ms Gonzalez through her attorney sent Defendant a

letter stating that the notice to terminate her tenancy was in retaliation for her attempt to

enforce her rights under the Act

40 In response Defendants asserted that the accommodation of Ms

Gonzalezs request allowed her to stay in her apartment only until the end of her thenshy

current lease term

41 On October 8 2013 Ms Gonzalez offered a voluntary mediation relating

to this disagreement in hopes of being allowed to remain in her apaiiment

42 On November 19 2013 Defendants requested in exchange for a 15-day

extension of Ms Gonzalezs tenancy while the patiies mediated the issue a full release of

any claims she might have against the Defendants

43 On November 21 2013 Ms Gonzalez informed Defendants that she would

not release her claims and that she planned to vacate her apaiiment by November 30

2013

PROCEDURAL BACKGROUND

44 As required by the Fair Housing Act 42 USC sect 3610(a) and (b) the

Secretary of HUD conducted an investigation of the complaint made by Ms Gonzalez

attempted conciliation without success and prepared a final investigative report

45 Based on the information gathered in bis investigation the Secretary

pursuant to 42 USC sect 3610(g) determined that reasonable cause exists to believe that

illegal disc1iminatory housing practices occurred On April 14 2015 the Secretary

8


issued a Determination of Reasonable Cause and Charge of Discrimination pursuant to 42

USC sect 3610(g) charging the Defendants with discrimination under the Fair Housing

Act under 42 USC sectsect 3604(f)(l)(A) (f)(2)(A) (f)(3)(B) and 3617

46 On April 17 2015 Complainant Raelynn Gonzalez timely elected to have

the claims asserted in HUDs Charge of Discrimination resolved in a federal civil action

pursuant to 42 USC sect 3612(a)

47 On April 20 2015 a HUD Administrative Law Judge issued a Notice of

Election and terminated the administrative proceedings on the HUD complaint filed by

Ms Gonzalez Following the Notice of Election the Secretary of HUD authorized the

Attorney General to commence a civil action pursuant to 42 USC sect 3612(0)

48 The United States now timely files this Complaint pursuant to the Fair

Housing Act 42 USC sect 3612(0)

FAIR HOUSING ACT VIOLATIONS

49 The United States incorporates by reference the preceding paragraphs of

this Complaint

50 Defendants discriminated against Ms Gonzalez a person with disabilities

in the rental of a dwelling to Ms Gonzalez by denying her the opportunity to renew her

lease because of her assistance animal required because of her disabilities in violation of

42 USC sect 3604(f)(l)(A)

9



in the terms conditions or privileges of rental of a dwelling because of her disabilities in

violation of 42 U SC sect 3604(f)(2)(A)

52 Defendants refused to make a reasonable accommodation in rules policies

practices or services when such an accommodation was necessary to afford a person

with a disability equal opportunity to use and enjoy a dwelling in violation of 42 USC

sect 3604(f)(3)(B)

53 Defendants terminated Ms Gonzalez tenancy in retaliation for her exercise

of her right to a reasonable accommodation in the fonn of an assistance animal in

violation of 42 USC sect 3617

54 Ms Gonzalez is an aggrieved person as defined in 42 USC sect 3602(i) and

has suffered injuries as a result of Defendants actions

55 Defendants discriminatory actions were intentional willful and taken in

disregard of the rights of Ms Gonzalez

REQUEST FOR RELIEF

WHEREFORE the United States requests that this Court

1 Declare that Defendants discriminatory housing practices as set forth

above violate the Fair Housing Act

2 Enjoin and restrain Defendants their officers employees agents

successors and all other persons or corporations in active concert or participation with

Defendants from

10


A Discriminating in the sale or rental or othe1wise making unavailable

or denying a dwelling to any buyer or renter because of disability in

violation of42 USC sect 3604(f)(l )

B Discriminating against any person m the terms conditions or

privileges of sale or rental of a dwelling or in the provision of

services or facilities in connection with such dwelling because of

disability in violation of 42 USC sect 3604(f)(2)

C Refusing to make reasonable accommodations in rules policies

practices or services when such accommodations may be necessary

to afford a person with a disability equal opportunity to use and

enjoy a dwelling in violation of 42 USC sect 3604(f)(3)(B) and

D Coercing intimidating threatening or interfering with any person in

the exercise or enjoyment of or on account of his or her having

exercised or enjoyed or on account of his or her having aided or

encouraged any other person in the exercise or enjoyment of any

right granted or protected by the Fair Housing Act in violation of 42

USC sect 3617

3 Order Defendants to take such affirmative steps as may be necessary to

restore as nearly as practicable Ms Gonzalez to the position she would have been in but

for the discriminatory conduct

4 Order Defendants to take such actions as may be necessary to prevent the

recurrence of any disc1iminatory conduct in the future and to eliminate to the extent

11


practicable the effects of their unlawful conduct including implementing policies and

procedures to ensure that no applicants or residents are discriminated against because of

disability

5 Award monetary damages to Ms Gonzalez pursuant to 42 USC sectsect

3612(0)(3) and 3613(c)(l) and

6 Order such additional relief as the interests of justice require

DATE May 18 2015 ANDREWM LUGER United States Attorney

s Craig R Baune

BY CRAIG R BAUNE Assistant US Attorney Attorney ID No 33 1727 600 United States Courthouse 300 South Fourth Street Minneapolis MN 55415 Phone 612-664-5600

12

JS 44 (Rev 1212) CASE 015-cv-02489-PCiiJlfL e~YlSBEJfjed 051815 Page 1of1

The JS 44 civil cover sheet and the infonnation contained herein neither replace nor supplement the fil ing and serYice of pleadings or other papers as required by law except as provided by local rules ofcourt This fonn approved by the Judicial Conference of the United States in September 1974 is required for the use of the Clerk ofCourt for the purpose of initiating the civil docket sheet (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM)

I (a) PLAJNTIFFS United States of America

(b) County of Res idence ofF irst Listed Plaintiff

(EXCEPT IN US PLAINTIFF CASES)

c) Attorneys (Firm Name Address and Telephone Number)

DEFENDANTS Brooklyn Park 3rd Leased Housing Associates LLC Dominium Management Services LLC Susan Meyer and Gina Estrem

County of Residence of First Listed Defendant Hennepin County (IN US PLAINTIFF CASES ONLY)

NOTE IN LA 1D CONDEMNATION CASES USE THE LOCATION OF THE TRACT OF LAND INVOLVED

Attorneys (If KnoHn)

II BASIS OF JURISDICTION (Place an XinOneBoxOnlJ~

~I US Govenm1ent 0 3 Federal Question

Plain1iff (US Go1bullemment Not a Party)

0 2 US Govenm1em 04 Diversity Dcfendanl (Indicate Ci1i=enship ofParties in Item Ill)

Ill CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in one Boxor Plaintiff (For Dfrersity Cases Only) and One Box or Defendant)

PTF DEF PTF DEF Citizen ofllus Stale 0 1 O I lncorpora1cd or Principal Place O 4 O 4

of Business In This State

Citizen ofAnother Stale 0 2 0 2 Incorporated and Principal Place 0 5 0 5 of Business In Anod1er State

Citizen or Subject of a 0 3 0 3 Foreign Nation 0 6 06 Forei1m Countrv

IV NATURE OF SUTT (Place an XinOneBoxOnl1) I CONTRAC l TORTS FORFEITUREPENALTY BAN KRUPTC Y OTH ER STATUTES I

0 0 0 0 0

110 Insurance 120 Marine 130 Miller ct 140 Negotiable lnstn uncnt 150 Rccolcry oiOvervaymenl

amp Enforccmclll of Judgment

PERSONAL INJURY 0 310 Airplane 0 315 Airplane Product

Liability Cl 3~0 Assauh Libel amp

Slander

PERS O NAL INJ URY 0 365 Personal Injury -

Product Liabili1y 0 367 llealth Care

Pl rnrmaccuticnl Personal l nJ lll)

0 625 Dmg Related Seizure of Prope1ty 2 1 USC 88 J

0 690 Otl1er

0 0

422 Appeal 28 USC 158 423 Withdrawal

28 USC 157

0 375 False Claims Act 0 400 Stale Reappo11ionment 0 410 An1it111st 0 430 Banks and Banking 0 -1 0 Co1111nerce 0 460 Depo11auon

PROPFRTY IHGHTS 0 820 Copynglns

0 15 1 Medicare Act 0 330 Federal Employers Producl Liability 0 830 Pa1en1 0 4 70 Racketeer Influenced and 0

0

0 0 0 0

152 llccovcry of Dc fouhcd Student Loms (Excludes Veterans)

153 Recovery of Ovcrpaymcn1 of Vc1erans Benelils

160 Stockholders Suits 190 Otl1er Conlract 195 Contract Product Liability 196 F ranchisc

Liability 0 340 Marine 0 345 Marine Product

Liability 0 350 Motor Vehicle 0 355 Motor Vehicle

Product Liability 0 360 Od1er Personal

Injury 0 362 Personal lnjwy shy

Medical Maloractice

0 368 Asbestos Pcrsonnl Injury Product Liability

PERSONAL PROPERTY 0 370 Other Fraud 0 37 1 Tni1h in Lending 0 380 01her Personal

Propeny Damage 0 385 Property Damage

Producl Liability

0 840 Trntlemark Comtpt Organizations 0 480 Consumer Credit 0 490 CableSat TV 0 850 SecuritiesCommodities

Exchange 0 890 Other Sl3tutory Actions 0 891 Agricultural Acts 0 893 Environmental Mailers 0 895 Freedom o f lnfomJation

Act 0 896 Arbitration

a 899 Administrative Procedure

ActReview or Appeal of Agency Decision

0 950 Constitutionality of State Statulcs

LABOR SOC AL SEC URITY 0 710 Fair Labor Standards

Act 0 720 Labor1 lanagement

Relations 0 740 Railway Labor Act 0 75 1 Family and Medical

Leave Act 0 790 01her Labor Litigation 0 791 Employee Retirement

Income Security Act

0 0 0 0 0

861 HIA ( 139511) 862 Black Lung (923) 863 DI WCDJ WW (405(g)) 864 SSID Title XVI 865 RSI (405(g))

I REAL PROPERTY CIVIL RIGHTS PRJSON ER PETITIONS FEDE RAL TAX SUITS 0 0 0 0 0 0

210 Land Condemnation

220 Foreclosure 230 Rent Lease amp Ejecunent 240 Torts to Land 245 Tort Produc1 Liability 290 All Otl1er Real Propcny

0 440 Other Civi l Rights 0 441 Voting 0 442 Employment Jll 443 Housing

Accommodations 0 445 Amer wDisabilities shy

Employment 0 446 Am er wDisabilities shy

Other 0 448 Education

Habeas C orpus 0 463 Alien Detainee O 510 Motions to Vacate

Sentence 0 530 General 0 535 Dead1 Penalty

Other 0 540 Mandamus amp Other 0 550 Civil Rights 0 555 Prison Condition 0 560 Civil Detainee -

Conditions of Con_fi nemcnt

0

0

870 Taxes (US Plaintiff or Defendan1)

871 IRS-Third Pany 26 use 7609

IMMIG RATION -0 462 Naturalization Application 0 465 0 1her Immigrat ion

Actions

V ORIGIN (Placean Xin011eBoxOnly)

~ I Original 0 2 Removed from 0 3 Remanded from 0 4 Reinstated or 0 5 Transferred from 0 6 Multidistrict Proceeding State Court Appellate Court Reopened Another District Litigation

(speciM

Cite the US Civil Statute under which you are filing (Do not citej11risdicrio11al statutes 1111 less dfrcrsity)

VI CAUSE OF ACTION t-T_it_le__lll_C _ i - -1 -e- bF osin---Amn entA 42U-S _60 9V i_viI _R_ hts_Ac-tof -9-6-8--amen-d d- airH u e dm s cto--f19c88 C 31to361_Briefdescription ofcause Discrimination under the Fair Housing Act on the basis of disability

VII REQUESTED IN 0 CHECK IF THIS IS A C LASS ACTION DEMAND $ CHECK YES only if demanded in complaint

COMPLAINT UNDER RULE 23 FRCvP JURY DEMAND 0 Yes l( No

VIII RELATED CASE(S) (See ns tructions) IF ANY JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

05182015 s Craig R Baune FOR O FFICE USE O NLY

RECEIPT AMOUNT APPL YING IFP JUDGE MAG JUDGE

CASE 015-cv-02489-PJS-HB Document 1 Filed 051815 of 12

dwelling on account of the exercise of protected rights in violation of the Fair Housing

Act 42 USC sectsect 3604(plusmn)(l)(A) (plusmn)(2)(A) (plusmn)(3)(B) and 3617

3 Complainant Raelynn Gonzalez filed a complaint of discrimination with the

United States Department of Housing and Urban Development (HUD)

4 HUD charged the Defendants with discrimination on the basis of disability

failure to make a reasonable accommodation and retaliation in violation of the Fair

Housing Act

5 Complainant elected to have the claims stated in the HUD charge

determined in a civil action per her rights under the Fair Housing Act 42 USC sect

3612(a)

6 The United States therefore brings this action for injunctive relief and

monetary damages on behalf of Raelynn Gonzalez pursuant to the Fair Housing Act 42

usc sect 3612(0)

STATEMENT OF JURISDICTION AND VENUE

7 This Court has jurisdiction pursuant to 28 USC sectsect 1331 and 1345 and 42

usc sect 3612(0)

8 Venue is proper in this District pursuant to 28 USC sect 1391 and 42 USC

sect 3612(0)

2


PARTIES

















2008




USC sect 3602(h)

3














FACTS







4




her apartment












eviction








5












Gonzalez that week





complaint




accommodation

6




June 6 2013


















20 13

7







current lease term








2013








8
















this Complaint





9








sect 3604(f)(3)(B)








REQUEST FOR RELIEF






Defendants from

10


















USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM










PARTIES

















2008




USC sect 3602(h)

3














FACTS







4




her apartment












eviction








5












Gonzalez that week





complaint




accommodation

6




June 6 2013


















20 13

7







current lease term








2013








8
















this Complaint





9








sect 3604(f)(3)(B)








REQUEST FOR RELIEF






Defendants from

10


















USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM






















FACTS







4




her apartment












eviction








5












Gonzalez that week





complaint




accommodation

6




June 6 2013


















20 13

7







current lease term








2013








8
















this Complaint





9








sect 3604(f)(3)(B)








REQUEST FOR RELIEF






Defendants from

10


















USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM












her apartment












eviction








5












Gonzalez that week





complaint




accommodation

6




June 6 2013


















20 13

7







current lease term








2013








8
















this Complaint





9








sect 3604(f)(3)(B)








REQUEST FOR RELIEF






Defendants from

10


















USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM




















Gonzalez that week





complaint




accommodation

6




June 6 2013


















20 13

7







current lease term








2013








8
















this Complaint





9








sect 3604(f)(3)(B)








REQUEST FOR RELIEF






Defendants from

10


















USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM












June 6 2013


















20 13

7







current lease term








2013








8
















this Complaint





9








sect 3604(f)(3)(B)








REQUEST FOR RELIEF






Defendants from

10


















USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM















current lease term








2013








8
















this Complaint





9








sect 3604(f)(3)(B)








REQUEST FOR RELIEF






Defendants from

10


















USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM
























this Complaint





9








sect 3604(f)(3)(B)








REQUEST FOR RELIEF






Defendants from

10


















USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM
















sect 3604(f)(3)(B)








REQUEST FOR RELIEF






Defendants from

10


















USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM


























USC sect 3617






11




disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM












disability


3612(0)(3) and 3613(c)(l) and



s Craig R Baune


12





















0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM





























0 0 0 0 0





Slander





0 690 Otl1er

0 0


28 USC 157




0

0 0 0 0








Medical Maloractice




Producl Liability











Income Security Act

0 0 0 0 0













0

0




Actions



(speciM









complaint in united states v brooklyn park (d. minn.) · 6/18/2015 · case 0:15-cv-02489-pjs-hb...

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