UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

____________________________________

)

UNITED STATES OF AMERICA,

)

)

Plaintiff,

)

)

v.

)

Civil Action No. __________________

)

STONECLEAVE VILLAGE

)

ASSOCIATION, INC.; PROPERTY

)

MANAGEMENT OF ANDOVER, INC.; )

and ELAINE ROMANO,

)

)

Defendants.

)

)

COMPLAINT AND DEMAND FOR JURY TRIAL

INTRODUCTION

The United States of America, by and through its attorney, Carmen M. Ortiz, United

States Attorney for the District of Massachusetts, brings this suit against Stonecleave Village

Association, Inc., Property Management of Andover, Inc., and Elaine Romano (collectively,

"Defendants") for violation of the Fair Housing Act based on familial status. Defendants

discriminated against residents with children and coerced, intimidated, threatened, or

interfered with their rights under the Fair Housing Act by, among other things, fining them

when their children played wiffle ball or tag in the common areas but not fining adult

residents for similar alleged rules violations and charging attorney’s fees of nearly $500.00

per family to residents with children, despite the fact that Stonecleave had not previously

charged attorney’s fees to other residents when they were fined. Defendants also retaliated

against one resident with a child by charging her $1,000.00 for the cost of attorney’s fees

Stonecleave incurred in responding to a complaint of discrimination she filed with the Massachusetts Commission Against Discrimination.
NATURE OF ACTION 1. This is a civil action brought by the United States to enforce the Fair Housing Act, 42
U.S.C. § 3601, et seq. (the “Act”). It is brought on behalf of Lauren Kibildis and her child; Tracey Hamilton and her three children; Brenda Soucy and her two children; Troy and Melanie Medeiros and their three children; and Julie Stewart and her two children (collectively, “Complainants”).
JURISDICTION AND VENUE 2. This court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 1345,
and 42 U.S.C. §§ 3612(o) and 3614(a). 3. Venue is proper under 28 U.S.C. § 1391(b), in that the events giving rise to this action
occurred in this judicial district. PARTIES
4. Plaintiff is the United States of America. The United States brings this action on behalf of the complainants as follows: a. Complainant Lauren Kibildis owns the unit in which she and her son live at Stonecleave Village. Ms. Kibildis and her son are “aggrieved persons” as defined by the Fair Housing Act, 42 U.S.C. § 3602(i). b. Complainant Tracey Hamilton rents the unit in which she and her three children live at Stonecleave Village. Ms. Hamilton and her children are
2

“aggrieved persons” as defined by the Fair Housing Act, 42 U.S.C. § 3602(i). c. Complainant Brenda Soucy owns the unit in which she and her two children
live at Stonecleave Village. Ms. Soucy and her children are “aggrieved persons” as defined by the Fair Housing Act, 42 U.S.C. § 3602(i). d. Complainants Troy and Melanie Medeiros rent the unit in which they live with their three children at Stonecleave Village. The Medeiroses and their children are “aggrieved persons” as defined by the Fair Housing Act, 42 U.S.C. § 3602(i). e. Julie Stewart rents the unit in which she and her two children live at Stonecleave Village. Ms. Stewart and her children are “aggrieved persons” as defined by the Fair Housing Act, 42 U.S.C. § 3602(i). 5. Defendant Stonecleave Village Association, Inc. (“Stonecleave”) is the governing body of Stonecleave Village Condominium (“Stonecleave Village”), a complex of seventy-eight independently owned townhouses located at 20 Washington Street in Methuen, Massachusetts. As of 2009, approximately ten of the seventy-eight townhouses housed families with children. 6. Stonecleave Village’s townhouses are dwellings within the meaning of the Fair Housing Act, 42 U.S.C. § 3602(b). 7. At all times relevant to the complaint, Defendant Property Management of Andover, Inc. (“PMA”) has been Stonecleave’s management agent. PMA is a Massachusetts corporation with a principal place of business at 439 South Union Street, Lawrence,
3

Massachusetts. 8. At all times relevant to the complaint, Defendant Elaine Romano was an employee of
PMA and served as Stonecleave’s property manager. FACTUAL ALLEGATIONS
9. Stonecleave Village’s bylaws prohibit, among other things, damaging the common areas or causing unreasonable embarrassment, disturbance, or annoyance to other owners. The bylaws also prohibit “organized sports activities, picknicking or fires, except in areas approved by the Board.”
10. Stonecleave's Board of Directors consists of five members, each of whom is a unit owner and resident of Stonecleave Village. Based upon information and belief, none of the five board members has children under the age of eighteen living in his or her unit.
11. In July 2008, Stonecleave informed residents that it would be “forced to actively engage in enforcement" of Stonecleave Village’s rules because of children running from yard to yard and the unacceptable noise created when children played organized sports in the common areas at Stonecleave Village.
12. During an August 2008 meeting, Stonecleave advised residents that organized sports could not be played on the common area and designated a field in the back of the complex as an appropriate place for recreational activity. The field is surrounded by woods on two sides and is removed from most of the units, making it difficult for parents to supervise their children.
13. After the meeting, Complainant Lauren Kibildis filed a complaint of discrimination
4

against Stonecleave with the Massachusetts Commission Against Discrimination (“MCAD”). The MCAD investigated Ms. Kibildis’s complaint and dismissed it on March 13, 2009 for lack of probable cause. 14. In April 2009, Stonecleave issued a memorandum to residents reminding them of the complaints about organized sports on the common area from the previous summer and reminding residents that, with summer approaching, they must abide by all applicable rules. The April 2009 memorandum also noted the MCAD’s lack of probable cause finding regarding Ms. Kibildis’s complaint of discrimination. 15. Between June 3 and June 6, 2009, a resident and member of Stonecleave’s board of directors took approximately forty-five photographs of children playing wiffle ball on the common area. 16. On June 8, 2009, a resident complained to Defendant Romano that children were playing and screaming on the common area on Saturday, June 6, 2009. In the email, the resident suggested “trick[ing]” children into using a different area to play and complained that, “I feel like we are living in the projects.” 17. Upon information and belief, Defendants Stonecleave, PMA, and Romano retained an attorney to issue fines to certain Stonecleave Village residents whose children were playing wiffle ball in the common area. 18. At the behest of Defendants Stonecleave, PMA, and/or Romano, Stonecleave’s attorney issued letters to each Complainant on June 9, 2009 informing them that they were each being fined the following amounts:
$10 per day for two days for children playing on the common;
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$10 per day for two days for actions allegedly causing damage to the common; $25 for damage to the common area lawn; and $427.50 for attorneys fees “incurred in this matter.” 19. Complainants had not received any previous fines or written warnings regarding their children violating Stonecleave Village’s rules. 20. Based upon information and belief, Stonecleave and PMA never involved attorneys – or charged attorney’s fees for drafting fine letters – when fines were issued for any other violation of Stonecleave Village’s rules. Indeed, from 2005, when Stonecleave hired PMA, to June 9, 2009, when Complainants received their fine letters, PMA had sent out all notices of fines or warnings of violations without the involvement of attorneys. 21. After receiving the June 9, 2009 fine letter, Complainant Kibildis wrote a letter, dated June 17, 2009, challenging the fines and attorney's fees she was assessed. On June 29, 2009, the attorney replied to Complainant Kibildis's letter, explaining that the $437.50 he charged to her was a "flat fee" and that "further involvement, including the drafting of this letter, will occur at my hourly rate of $175.00 per hour." 22. When the families who received the June 9, 2009 fine letters requested evidence of the violations, they were refused despite the existence of approximately forty-five photographs on which the fines were based. 23. When Complainant Stewart was fined on July 10, 2009 for having multiple items in her patio area, she was provided with photographic evidence of the rule violation. 24. On July 28, 2009, Defendant Romano, acting on PMA’s behalf, charged Ms. Kibildis
6

$1,000.00, “which is the cost [Stonecleave] bore to hire the attorney” to respond to Ms. Kibildis’s MCAD complaint. 25. During Memorial Day weekend of 2008, when an adult resident held a barbeque on the common area in violation of Stonecleave’s policy prohibiting gatherings of over ten people without prior approval, the resident was not fined for violating Stonecleave Village’s rules. 26. In an effort to thwart children from playing, Stonecleave had trees planted in the common areas in the summer of 2009 under the guise of “a tree project” approved by Stonecleave’s board of directors almost fifteen years ago. 27. Defendants treated Complainants differently in singling them out for the imposition of fines and attorney’s fees and in refusing to provide them with photographic evidence of their alleged rules violations. 28. On July 28, 2009, Complainants Kibildis, Soucy, Hamilton, and Medeiros and their respective children filed timely complaints with the United States Department of Housing and Urban Development (“HUD”), pursuant to the Fair Housing Act, alleging discrimination on the basis of familial status. 29. On December 8, 2009, Complainant Stewart and her children filed a timely complaint with HUD pursuant to the Fair Housing Act, alleging discrimination on the basis of familial status. 30. Pursuant to 42 U.S.C. § 3610(a) and (b), the Secretary of HUD conducted and completed an investigation of the complaints, attempted conciliation without success, and prepared final investigative reports. Based on the information gathered in the
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investigation, the Secretary determined, pursuant to 42 U.S.C. § 3610(g)(1), that reasonable cause existed to believe that illegal discriminatory housing practices had occurred. Therefore, on December 1, 2009 and on January 11, 2010, the Secretary issued Charges of Discrimination, pursuant to 42 U.S.C. § 3610(g)(2)(A), charging the Defendants with engaging in discriminatory practices on the basis of familial status in violation of the Fair Housing Act. 31. On December 8, 2009 and January 12, 2010, Defendants elected to have the claims asserted in HUD’s two Charges of Discrimination resolved in a civil action, pursuant to 42 U.S.C. § 3612(a). 32. On December 9, 2009 and January 13, 2010, the Administrative Law Judge presiding over each administrative proceeding issued a Notice of Election to Proceed in United States District Court and terminated the administrative proceeding. 33. Following this Notice of Election, the Secretary of HUD authorized the Attorney General to commence a civil action, pursuant to 42 U.S.C. § 3612(o).
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COUNT I (Disparate Treatment of Families with Children in Violation of 42 U.S.C. § 3604(b)) 34. Defendants, through the above-referenced actions, discriminated against Lauren
Kibildis and her child; Tracey Hamilton and her three children; Brenda Soucy and her two children; Troy and Melanie Medeiros and their three children; and Julie Stewart and her two children 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 familial status, in violation of 42 U.S.C. § 3604(b). 35. Defendants treated Complainants differently from other Stonecleave residents in singling them out for the imposition of fines, including attorney’s fees, for alleged violations of Stonecleave Village’s rules. 36. Defendants’ actions and statements described in the preceding paragraphs were intentional, willful, and taken in disregard for the rights of Complainants and their children.
COUNT II (Interference, Coercion, or Intimidation in Violation of 42 U.S.C. § 3617) 37. Defendants, through the above-referenced actions, coerced, intimidated, threatened, or interfered with Complainants’ exercise or enjoyment of their right to be treated in the same manner as families without children, in violation of 42 U.S.C. § 3617. 38. The June 9, 2009 fine letters charging complainants nearly $500.00 per family for violating Stonecleave Village’s rules and for attorney’s fees constitutes coercion, intimidation, and interference with Complainants’ exercise of their rights under the Fair Housing Act.
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39. Defendants’ requirement that Complainant Kibildis pay an additional $1,000.00 for Stonecleave’s costs relating to the MCAD complaint Kibildis filed constitutes coercion, intimidation, and interference with Complainant’s exercise of her rights under the Fair Housing Act.
40. Defendants PMA and Romano were agents acting on Stonecleave’s instructions in levying the $1,000.00 fee against Complainant Kibildis and are therefore liable for violating 42 U.S.C. § 3617.
41. Defendants’ actions described in the preceding paragraphs were intentional, willful, and taken in disregard for the rights of Complainants and their children. COUNT III (Retaliation in Violation of 42 U.S.C. § 3617)
42. Defendants, through the above-referenced actions, retaliated against Complainant Kibildis for engaging in protected activity, namely filing a complaint with the MCAD.
43. Defendants’ requirement that Complainant Kibildis pay an additional $1,000.00 for Stonecleave’s costs relating to the MCAD complaint Kibildis filed constitutes retaliation under the Fair Housing Act.
44. Defendants PMA and Romano were agents acting on Stonecleave’s instructions in levying the $1,000.00 fee against Complainant Kibildis and are therefore liable for violating 42 U.S.C. § 3617.
45. Defendants’ actions described in the preceding paragraphs were intentional, willful, and taken in disregard for the rights of Complainants and their children.
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COUNT IV (Pattern or Practice of Discrimination) 46. The Defendants’ discrimination on the basis of familial status, as described above, constitutes: a. A pattern or practice of resistance to the full enjoyment of rights granted by the Fair Housing Act, in violation of 42 U.S.C. § 3614(a); and/or b. A denial to a group of persons of rights granted by the Fair Housing Act, which raises an issue of general public importance, in violation of 42 U.S.C. § 3614(a). 47. In addition to Complainants and their children, there may be other victims of Defendants’ discriminatory actions and practices who are “aggrieved persons” as defined in 42 U.S.C. § 3602(i). These persons may have suffered damages as a result of Defendants’ discriminatory conduct. 48. Defendants’ actions and statements described in the preceding paragraphs were intentional, willful, and taken in disregard for the rights of others.
PRAYER FOR RELIEF WHEREFORE, the United States prays that the Court enter an order that: A. Declares that Defendants’ discriminatory policies and practices, as set forth above, violate the Fair Housing Act, 42 U.S.C. § 3601, et seq.; B. Enjoins Defendants, their agents, employees, successors, and all other persons in active concert or participation with any of them from discriminating on the basis of familial status, in violation of the Fair Housing Act; C. Awards monetary damages to Lauren Kibildis and her child; Tracey Hamilton and her
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three children; Brenda Soucy and her two children; Troy and Melanie Medeiros and their three children; and Julie Stewart and her two children, pursuant to 42 U.S.C. §§ 3612(o)(3) and 3614(d)(1)(B), and each other person injured by Defendants’ conduct, pursuant to 42 U.S.C. § 3614(d)(1)(B); D. Assesses civil penalties against Defendants in the amounts authorized by 42 U.S.C. § 3614(d)(1)(C), to vindicate the public interest. The United States further prays for such additional relief as the interests of justice may require.
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The United States demands trial by jury.

Respectfully submitted,

CARMEN M. ORTIZ United States Attorney District of Massachusetts

ERIC H. HOLDER, JR. Attorney General of the United States

/s/ Jennifer A. Serafyn JENNIFER A. SERAFYN Assistant United States Attorney One Courthouse Way, Suite 9200 Boston, MA 02210 (617) 748-3100 (telephone) (617) 748-3969 (fax) jennifer.serafyn@usdoj.gov
Date: February 19, 2010

/s/ Thomas E. Perez THOMAS E. PEREZ Assistant Attorney General Civil Rights Division
/s/ Elizabeth A. Singer STEVEN H. ROSENBAUM Chief ELIZABETH A. SINGER Director, U.S. Attorneys’ Fair Housing
Program Housing & Civil Enforcement Section
Civil Rights Division U.S. Department of Justice 950 Penn. Ave., NW -- NWB Washington, DC 20530 (202) 514-6164 (telephone) (202) 514-1116 (fax) Elizabeth.Singer@usdoj.gov

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 Case 1:10-cv-10294-JLT Document 19 Filed 12/06/10 Page 1 of 7 Case 1:1 O-cv-10294-JLT Document 18 Filed 11/23/10 Page 1 of 17

UNITED STATES DISTRICT COl"'RT FOR TIlE DISTRICT OF MASSACHUSETTS

)

UNITED STATES OF AMERICA,

)

)

Plaintiff,

)

)

v.

)

)

STONECLEAVE VILLAGE

)

ASSOCIATION, INC.; PROPERTY

)

MANAGEMENT OF ANDOVER. INC.; )

and ELAINE ROMAt"l"O,

)

)

Defendants.

)

)

Civil Action ~o. 10-10294-llJT

CONSENT ORDER

A. Factual and Procedural Background

1. The United States initiated th:s action to enforce the provisions of the Fair

Housing Act, 42 U.S.C. § 3601, et seq. The United States alleges that Defendant Stonecleave

Village Association, Ine. (the "Association"), the governing body of Stonecleave Village

Condominiums, a complex of seventy-eight independently owned townhouses located at 20

Washington Street in Methuen, Massachusetts, has unlawfully discriminated on the basis of

familial status in the selective enforcement of its rules regarding the use of the common areas.

2. Specifically, the United States alleges that the Association has engaged in housing

practices that discriminate on the basis of familial status by:

a. Fining and charging attorney's fees to residents with childn:n because their

children engaged in recreational activities on the outdoor common areas,

even though playing on the common areas does not violate the

Association's rules, and adults who were in violation of the Association's

Case 1:10-cv-10294-JLT Document 19 Filed 12/06/10 Page 2 of 7 Case 1:1 O-cv-10294-JLT Document 18 Filed 11/23/10 Page 2 of 17
rules were not fined; and b. Charging $1,000 to a resident who filed a complaint of discrimination
with the Massachusetts Commission Against Discrimination to cover the costs of hiring an attorney to respond to her complaint. 3. The United States alleges that, through this conduct, the Association has: a. Violated 42 U.S.C. § 3604(b) by discriminating against parents and their children 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 familial status; b. Violated 42 U.S.C. § 3617 by coercing, intimidating, threatening, or interfering with the exercise or enjoyment offair housing rights by residents with children; and c. Violated 42 U.S.C. § 3614(a) by engaging in a pattern or practice of resistance to the full enjoyment of rights granted by the Fair Housing Act, F~d/or denying fair housing rights to a group of persons, raising an issue of general public importance. 4. The defendant denies the United States' allegations. 5. The parties have voltmtarily agreed to the entry of this Consent Order in connection with the settlement of this lawsuit, as indicated by 6e signatures below. This Consent Order shall not be deemed an admission of wrongdoing or liability by the Defendant. Therefore, it iis ORDERED that:
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Case 1:10-cv-10294-JLT Document 19 Filed 12/06/10 Page 3 of 7 Case 1:1 O-cv-10294-JLT Document 18 Filed 1'1123/10 Page 3 of 17
B. Injunction 6, Defendant, its agents, employees, successors, ane all persons in active concert or participation with it, are hereby enjoined, with respect to the enforcement of the Association's rules, from:
a, Discriminating in the terms, conditions, or privileges of sale or rental of a dwelling, cr in the provision of services or facilities in C;ollicction therewith, because of familial status;
b, Enforcing the Association's rules on the basis offamilial status in a manner that prevents, discourages, or penalizes families with children from using the common areas for play or recreation; and
c. Coercing, intimidating, threatening, interfering with, or retaliating against any person in connection with the exercise or enjoyment of any right granted or protected by the Fair Housing Act. C. Escalation Policy and Processing Compllaints
7. Effective upon the entry of this Order by the Court, the Association shall adopt and abide by the "path of escalation" policy, as set forth in Exhibit A, regarding violations of its rules.
D. Mandatory Training 8, Within 60 days of the entry of this Consent Order, the current Board of Dil'ectors ofthe Association shall undergo in-person training on the Fair Housing Act, ,\\1tll1 specific emphasis on discrimination on the basis of familial status. The training shall be (;onducted by an independent, qualified third party, approved in advance by the United States. The trainer shall

Case 1:10-cv-10294-JLT Document 19 Filed 12/06/10 Page 4 of 7 Case 1: 1O-cv-1 0294-JLT Document 18 Filed 11/23/10 Page 4 of 17
provide the Board of Directors of the Association with certifications of attendance that shall include the name of the course, the date the course was taken, and the length ofthe course.
E. Reporting Requirements 9. During the period in which this Order is in effect, Defendant shall notify counsel for the United States! in writing within fifteen (15) days of receipt of any written comr:laint against Defendant or Defendant's officers regarding familial status discrimination in housing. Defendant shall provide a copy of the \witten complaint with the notification. The notification shall include the full det.ails of the complaint, including the complainant's name, address, and telephone number, if known. Defendant shall also infonn the Cnited States within fifteen (15) days of any resolution of such complaint.
F. Settlement Payment 10. Within 30 days after entry of this Consent Order, Defendant shall cause to be paid the total sum of one hundred and fifty thousand dollars ($150,000) to Plaintiff. The United States \vill be responsible for using this settlement payment to compensate the aggrieved persons listed in Exhibit B in the manner and amounts listed in Exhibit B. The remaining twenty thousand dollars ($20,000) will remain with the United States as a settlement payment pu::suant to 42 U.S.C. § 3614(d)(1)(C). The patties agree that no monies shall be paid pursuant to this paragraph beinre the aggrieved persons listed in Exhibit B have each executed a v;'ritten release regarding the claims asserted in this lav.,uit. A copy of the Release is attached as Exhibit C.
I All documents or ott.er communications required by this Order to be se:1t to counsel for the United States shall be addressed as follows: .Termifer A. SerafYn, Assistant United States Attorney, Civil Division, Moakley Federal Courthouse, 1 Courthouse Way, Suite 9200, Boston, M~ 02210.
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Case 1:10-cv-10294-JLT Document 19 Filed 12/06/10 Page 5 of 7 Case1:10-cv··10294-JLT Document18 Filed11/23/10 Page50f17
G. Scope and Duration of Consent Order 11. The provisions of this Consent Order shall apply to Defendant, its employees, agents, successors, and all persons acting in active concert or participation with it. 12. This Consent Order is effective immediately upon its entry by the Court and shall remain in effect for two years. 13. The Court shall retain jurisdiction for the duration of this Order to enfo~ce the terms of the Order, after \vhich time the ease shall be dismissed with prejudice.
14. All parties shall be responsible for their 0'-"11 attorney's fees and court costs,
except as provided for in Seetion H below. H. Remedies for Non-Compliance, Time for Performance, and Modifications 15. 'The Unhed States may move the Court to extend the period in which this Order is
in effect if Defendant materially violates one or more terms of the Order. In the event the Cnited States so mOVES, it will provide Defendant with notice of its intentions and an opportunity to respond.
16. Any time limits for performance imposed by this Order may be extended by mutual wTitten agreement of the parties.
17. The parties to this Order shall endeavor in good faith to resolve inforn1ally any differences regarding interpretation of and compliance \"Ilith this Order prior to bringing such matters to the Court for resolution. In the event the United States eontends th.ere has been a failure by Defendant to perform in a timely manner any act required by this Order or otherwise to comply with any provision thereof, the United States may move this Court to impose any remedy authorized by law or equity, including, but not limited to, an order requiring
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Case 1:10-cv-10294-JLT Document 19 Filed 12/06/10 Page 6 of 7 Case 1:10-cv-10294-JLT Document 18 Filed 11/23/10 Page 6 of 17 performance of such act or deeming such act to have been performed, and an award of any damages, costs, and attorney's fees which may been occasioned by Defendant's violation or failure to perform. 18. Each party to this Consent Order shall bear its own costs and attorney's fees associated with this litigation. IT IS SO ORDERED:
This~daYOf~(C 2010.
States DistTict Judge
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Case 1:10-cv-10294-JLT Document 19 Filed 12/06/10 Page 7 of 7 Case UO-cv-10294"JLT Document 18 filed 11/23/10 Page 7 ofTI

By their signatures below, the parties consent to the entry of this Consent Order. For the United States:

CARMEN M. ORTIZ United States Attorney District of Massachusetts

THOMAS E. PEREZ Assistant Attomey General Civil Rights Division

J NIFER A. SEFN
Assistant United States Attomey
One Courthouse Way, Suite 9200 Boston, MA 02210 (617) 748-3100 (telephone) (617) 748-3969 (fax)
iennifer.seraf~'n@usdoj·9ov
For the Defendant:

~oAti Q ·it,TIt" 1;1'r~

ST N H. ROSENBA

//

Chief

ELIZABETH A. SINGER

Director, U.S. Attomey's Fair Hou~~ing

Program

Housing & Civil Enforcement Section

Civil Rights Division

U.S. Department of Justice

950 Penn. Ave., NW - NWB

Washington, DC 20530

(202) 514-6164 (telephone)

(202) 514-1116 (fax)

Elizabeth.Singer@usdoj.gov

AMESJ.DUANE,III
JOSHUA B. WALLS Taylor Duane Barton & Gilman LLP Boston Office
160 Federal Street Boston, MA 02110 P: 617.654.8200 (phone) F: 617.482.5350 (fax)
jwalls@taylorduane.com

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Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 1 of 10 Case 1:10-cv-10294-JLT Document 18 Filed 11/23/~O Page 8 of 17
EXHIBIT A Path of Escalation Policv
Pursuant to Paragraph 7 of the Consent Decree, effective upon the entry ofthi~ Order by tr~e Court, the Association shall adopt and abide by the following "path of escalation" policy:
Level One: Written Warning The unit owner(s) and resident(s) will receive a written warning from the propewj manager documenting each rule violation.
Level Two: Second Notice and Fine If the violation(s) that were the subject ofthe Level One written warning have not been resolved or rectified within 48 hours of receipt of the notice, or if a second violation of the same or similar nature has occurred, the unit owner(s) and resident(s) will receive a second notice of the violation(s) from the property manager and a fine of no more than $10.00 per day per violation.
Level Three: Third Notice and Fine and Opportunity to Meet with Board If the violation(s) that were the subject of the Level Two notice and fine have not been resolved or rectified within 48 hours of receipt of the notice, or if a third violation of the same or similar nature has occlIrred, the unit owner(s) and/or resident(s) will receive a third notice of the violation(s) from the property manager and a fine of no more than $10.00 per day per violation and will be afforded an opportunity to meet with members of the Association's Board of Directors or, in the alternative, to submit a wlitten statement for the Board's review. The meeting must be requested, or the written sta.tement must be provided, within ten days of the date of receipt of the Level Three notice and fine. If the ovvner and/or resident does not request a meeting or provide a written statement "ithin this ten day period, he/she will be deemed to have waived his or her right to address the matter vvith the Board of Directors. In the event of such a waiver, the Board of Directors may proceed immediately to Level Four.
Level Four: Fourth Notice and Additional Penalties If the violation(s) that were the subject of the Level Three notice and fine have not been resolved or rectified afr<:r the Level Three processes are complete, or if a fourth violation of the same or similar nature has occurred, the Board may assess fines and penalties to the unit owner including but not limited to fees, attorney's fees, charges, late charges, fines, costs of collection and enforcement, court costs, and interest.
The "path of escalation" policy does not preclude the Board from charging a unit owner for property damage expenses at the time that the property damage occurs, regardless of whether the unit owner has received prior notice about a violation. Additionally, the "path of escalation" policy does not preclude the Board from taking immediate action, including but not li:nited to retaining counsel and filing suit, to address any violations that pose a significant risk to the health, safety, .and welfare of Stonecleave Village or its residents.
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Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 2 of 10 Case 1:1 O-cv-10294-JLT Document 18 Flied 11/23/10 Page 9 of 17

EXHIBITB Payment Schedule

Pursuant to Paragraph 10 of the Consent Decree, the following individuals shall be compensated in the following amounts:

l. Laurin Kibildis

2. Tracey Hamilton

"~.

Brenda Soucy

4. Troy and Melanie (Bradish) Medeiros

5. Julie Stewart

6. Ashish and Bhavlla Patel

$40,000 $20,000 $20,000 $20,000 $20,000 $10,000

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Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 3 of 10 Case 1:1 0-cv-10294-JlT Document 18 Filed 11/23/10 Page 10 of 17 EXHIBITC
Release

In cOn!lideration of the payment of the sum of ! t) I ? Q Q dollars ($

.00),

.rh pursuant to the Consent Order entered in United States v. §itonecleave Village
Association, Inc., Civil Action No. 10-10294-JLT (D, Mass.), I, tbb ... M a l

individually, as the my minor children,

custodia! parent and
(initials) 'Sip. 14' Ii1

guardian of my minor children, and on behalf
eo> \ , hereby release and forever discharge

of

Stonecleave Village Association, Inc., Its past and present Trustees and Directors,

Property Management of Andover, !nc., Elaine Romano, and each of their respeotive

insurers and attorneys, of and from any and all liability for any claims, legal or equitable,

I may have and have had against them arising out of the [ssues that were alleged or

could have been alleged in the lawsuit referenced above. I fully acknowledge and

agree that this release shall be binding on my heirs, spouses, representatives,

executors, successors, administrators, and assigns. I further acknowledge that my

receipt of the sum specified herein does not constitute or equate with an admission of

wrongdoing or liability by Stonecleave Village Association, Inc., its past and present

Trustees and Directors, Property Management of Andover, Ino., Elaine Romano and

their respective Insurers and attorneys. I also acknowledge that by receipt of the sum

specified herein, I waive my right to seek reimbursement for any fines or charges that I

have paid in connection with the events at issue in this lawsuit I hereby acknowledge

that I have read and understand this release and have executed it voluntarily and with

full knowledge of its legal consequences.

I further warrant that I will be responsible for determining the tax consequences of

the payment above. and that I will indemnity and hold harmless Stonecleave VUlage

Association, Inc., its past and present Trustees and Directors, Property Ma,nagement of

Andover. Inc., Elaine Romano andlor their respective insurers and attorneys of ar:d

from any taxEls, interest, lawsuits, claims, or penalties imposed by taxing authorities or

lien holders with respect to my receipt of this payment.

Jt Executed this day of N 0\1 ~Wl bR-rf , 2010.

itS'ht'S' h PC! T"- f

~~ ____

Full Name as. it appears on

Signature

Social Security card

------- Date ofBirth

~ [) ( Uq sh I''1b=1:xJ ~1 { b-r

tv1 Q.#II.~"l'l M A () 1f54V

Address

I

l"l~
Gender

i 1

, '.

Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 4 of 10 Case 1:10-cv-10294-JLT Document 18 Filed 11/23/10 Page 11 of 17

EXHIBITC Release

In consideration of the payment of the sum of '1Q71loi(,a"'£doUars ($HDi6~,00),

pursuant to the Consent Order entered in United States v. Stonecleave Village
Association, Inc., Civil Action No. 10-10294-JLT (D. Mass.), I, /..a.v.tulI<A'!feli;,

individually, as the custodial parent and guardian of my minor children, and on behalf of

t= my minor children, (initials)_:J::~

, hereby release and forever discharge

Stonecleave Village Association, Inc., its past and present Trustees and Directors,

Property Management of Andover, Inc., Elaine Romano, and each of their respective

insurers and attorneys, of and from any and all liability for any claims. legal or equitable,

I may have and have had against them arising out of the issues that were alleged or

could have been alleged in the lawsuit referenced above. I ful:y acknowledge and

agree that this release shall be binding on my heirs, spouses, representatives,

executors, successors, administrators, and assigns. I further acknowledge that my

receipt of thE' sum specified herein does not constitute or equate with an admission of

wrongdoing or liability by Stcnecleave Village Association, Inc., its past and present

Trustees and Directors, Property Management of Andover, Inc., Elaine Romano and

their respective insurers and attorneys, I also acknowledge that by receipt of the sum

specified herein, I waive my right to seek reimbursement for any fines or charges that I

have paid in connection with the events at issue in this lawsuit. I hereby acknowledge

that I have read and understand this release and have executed it Voluntarily and with

full knowledge of its legal consequences.

I furth,;}r warrant that I will be responsible for determining the tax consequences of

the payment above, and that I will indemnify and hold harmless Stonecieave Village

Association, Inc., its past and present Trustees and Directors, Property Management of

Andover, Inc., Elaine Romano and/or their respective insurers and attorneys of and from any taxes, interest, lawsuits, claims, or penalties imposed by taxing authorities or

lien holders with respect to my receipt of this payment.

E,."",dlh. ~tI>d~Y LO.JAA'() E. Kd)( /dd

of

tVD~01"tf
" ~_

Full Name a's it appears on

ignature

Social Security card

f:c..maJ£-
Gender

11

Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 5 of 10 Case 1:1O-cv-1 0294-JLT Document 18 Filed 11/23/10 Page 12 of 17

EXHIBIT C
Release
In consideration of the payment of the sum of _ tl.ue~ VlW dollars (~IOW.OO),
pursuant to the Consent Order entered in United States v. Stonecleave Viilage
Association, Inc., Civil Action No. 10-10294-JLT (D. Mass.), I, Y"~ MeJ~l~
individually, as the custodial parent and guardian of my minor children, and on behalf of
my minor children, (initials) ';:]:/Y1 ,I)'lm, om, hereby release and forever discharge
Stonecleave Village Association, Inc., its past and present Trustees and Directors., Property Management of Andover, Inc., Elaine Romano, and each of their respective insurers and attorneys, of and from any and aJlliability fo~ any claims, legal or equitable, I may have and have had against them arising out of the issues that were alleged or could have been alleged in the lawsuit referenced above. I fully acknowl~:,dge and agree that this release shall be binding on my heirs, spouses, representatives, executors, successors, administrators, and assigns. I further acknowledge that my receipt of the sum specffied herein does not constitute or equate with an admission of wrongdoing or liability by Stonecleave Village Association, Inc., its past and present Trustees and Directors, Property Management of Andover, Inc., Elaine Romano and their respective insurers and attorneys. I also acknowledge that by receipt of the sum specified herein, I waive my right to seek reimbUrsement for any fines or charges that I have paid in connection with the events at issue in this lawsuit. I hereby acknowledge that I have read and understand this release and have executed it voluntarily and with full knowledge of its legal consequences.

I further warrant that I will be responsible for determining the tax consequences of the payment above, and that I will indemnify and hold harmless Stone cleave Village Association, Inc., its past and present Trustees and Directors, Property Management of Andover, InG.. Elaine Romano andlor their respective insurers and attorneys of and from any taxes, interest, laWSUits, claims, or penalties imposed by taxing authorities or lien holders with respect to my receipt of this payment.

NovefVlbU- Executed thI,S .I::/:tLhday of

,2010.

Iro'j ~C.HA£L ~

q~~

Full Name as it appears on

Signa ure

Social Security card

Social Security N':7t:;;;:---
.90 WQShll\!ltoll.st~_"_3_
rv1e-W,~ I ¥V"\Q, O('8t{Y
Address

11

Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 6 of 10 Case 1:1 0-cv-1 0294-JLT Document 18 Filed 1'jf23/1 0 Page 13 of 17

EXHIBITC Release

In considerat[on of the payment of the sum of _

dollars ($_~.OO),

pursuant to the Consent Order entered in United States v. Stonecleave Viffage

AssogiatiQ!1..\nc., Civil Action No. 10-10294-JLT (D. Mass,), I, YVle\c.nfL,__,

individuafly, as the custodial parent and guardian of my minor children, and on behalf of
my minor children, (initials):r:.m, o,m, m,m ,hereby release and forever discharge

Stonecleave Village Association, Inc., its past and present Trustees and Directors,

Property Management of Andover, Inc., Elaine Romano, and each of their respective

insurers and attorneys, of and from any and all liability for any claims, legal or equitable,

I may have and have had against them arising out of the issues that wem alleged or

could have been alleged in the lawsuit referenced above, I fully acknowledge and

agree that this release shall be binding on my heirs, spouses, representatives,

executors, successors, administrators, and assigns. I further acknowledge that my

receipt of the sum specified herein does not constitute or equate with an admission of

wrongdoing or liability by Stone cleave Village Association, Inc., its past and present

Trustees and Directors, Property Management of Andover, Inc" Elaine Romano and

their respective insurers and attorneys. I also acknowledge that by receipt of the sum

specified herein, I waive my right to seek reimbursement for any fines or charges that I

have paid in connection with the events at issue in this lawsuit. ! hereby acknowledge

that I have n~ad anci understand this release and have executed it voluntarily and with

full knowledge of its legal consequences.

I further warrant that I will be responsible for determining the tax consequences of the payment above, and that [ will indemnify and hold harmless Stonecleave Villag!e Association, Inc., its past and present Trustees and Directors, Pmperty Management of
Andover, Inc., Elaine Romano and/or their respective insurers and attorneys of and
from any taxes, interest, lawsuits, claims, or penalties imposed by taxing authorities or
lien holders with respect to my receipt of this payment.

Executed this ~ j I fhday of -Novta1ber

,2010.

mel(',O(~· i,eub 'Bcud,ili
Full Name as it appears on Social Security card

yv!ti--'Y)Il,gcl,,-,-=
Signature

Date of Birth
hery10lR
Gender

11

Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 7 of 10 Case 1:1 O-cv-10294-JLT Document 18 Filed 11/23/10 Page 14 of 17

EXHIBITC Release

In consideration of the payment of the sum of I~111/i1t~, dollars ($ 2D,OOJ.OO),

pursuant to the Consent Order entered in United States v. Slone eave Villa e

Association. Inc., Civil Action No. 10-10294-JLT (D. Mass.), I,

,,-,SoUU-f,

individually, as the custodial parent and guardian of my minor children, and on behalf of

my minor children, (Initials) JhWoj- mAS , hereby release and forever discharge

Stonecleave Village Association, Inc., its past and present Trustees and Directors,

Property Management of Andover, Inc., Elaine Romano, and each of their n3ispective

insurers and attomeys, of and from any and all liability for any claims, legal or equitable,

I may have and have had against them arising out of the issues that were alleged or

could have been alleged in the lawsuit referenced above. I fully acknowledge and

agree that this release shall be binding on my heirs, spouses, representatives,

executors, successors, administrators, and assigns. I further acknowledge that my

receipt of the sum specified herein does not constitute or equate with an admission of

wrongdoing or liability by Stonecleave Village Association, Inc., its past and present

Trustees and Directors, Property Management of Andover, Inc., Elaine Romano and

their respective insurers and attorneys. I also acknowledge that by receipt of the sum

specified hereir, I waive my right to seek reimbursement for any fines or charges that I

have paid In connection with the events at issue in this lawsuit. J hereby acknowledge

that I have read and understand this release and have executed it voluntarily and with

full knowledge of its lega! consequences.

I further warrant that I will be responsible for determining the tax consequences of the payment above, and that I will indemnify and hold harmless Stonecleave Village
Association, lne., its past and present Trustees and Directors, Property Management of Andover, Inc., Elaine Romano and/or their respective insurers and attorneys of and
from any taxes, interest, lawsuits, claims, or penalties imposed by taxing authorities or lien holders with respect to my receipt of this payment.

Executed this ~ day of hfovervtber

brtMtl Je~ SOltGy

~

Full Name as It appears on

Q

Social Security card

Social Security Number
21J Wlliliil\jhv1 Sj-, ~ Uhtt 31
rY\eJhutn '{1M 018114
Address

Gender

11

Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 8 of 10 Case 1:10-cv-10294-JLT Document 18 Filed 11/23/10 Page 15 of 17

EXHIBIT C
Release
In con:,ideration of the payment of the sum of '-/l-<-.h)/Q..It'<.lkS/aY1~dollars ($m.Ct'YlOO),
pursuant to the Consent Order entered in United States v. Stonecleave Villagti Association, Inc., Civil Aclion No.1 0-1 0294-JLT (D. Mass.), I, ,lV' k Sft~,.lt1t';t­ individually, as the custodial parent and guardian of my minor chlldren, anj on behalf of
my minor children, (initials) S.:;.,.."A nt.$., hereby release and forever discharge
Stonecleave Village Association, Inc., its past and present Trus,tees and Directors, Property Management of Andover, Inc., Elaine Romano, and each of thei, respective insurers and attorneys, of and from any and aI/liability for any claims, legal or equitable, I may have and have had against them arising out of the issues that were alleged or could have been alleged in the lawsuit referenced above. I fully acknowledge and agree that this release shall be binding on my heirs, spouses, representattves, executors, successors, administrators, and assigns. 1furiher acknowledge that my receipt of the sum specified herein does not constitute or equate with an admission of wrongdoing or liability by Stonecleave Village Association, Inc., its past and present Trustees and Directors, Property Management of Andover, Inc., Elaine Romano and their respective insurers and attorneys, I also acknowledge that by receipt of the sum specified herein, I waive my right to seek reimbursement for any fines or charges that I have paid in connection with the events at issue in this lawsuit I hereby acknowledge that I have read and understand this release and have executed it voluntarily and with full knowledge of its legal consequences.

I further warrant that I will be responsible for determining the tax cons.equences of the payment above, and that I will indemnify and hold harmless Stonecleave Village Association, Inc., its past and present Trustees and Directors, Property Management of Andover, Inc., Elaine Romano and/or their respective insurers and attorneys of and from any taxes, interest, lawsuits, ciaims, or penalties imposed by taxing authorities or lien holders with respect to my receipt of this payment.

7 \ ' .~.1 allWcl , Executed this ~day of .ih(c..~

2010.

0011(" S. 511...,.)0/+
Full Name as It appears on

~

Social Security card

~ tJ(tSh;n~6n Sf- #SI
. f1d MWI HA 01111
Address

Date of Birth

11

Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 9 of 10 Case 1:1 O-cv-10294-JLT Document 18 Filed 11/23/10 Page 16 of 17

EXHIBITC Release

In consideration of the payment of the sum of

Q6,OOil,ad

dollars

($

2/1 J

0

000),

pursuant to the Consent Order entered In United States v: StonepleavE1"{illage

Association, Inc" Civil Action No, 10-10294-..ILT (D. Mass,), I, '?Ca.c£t; /!wII//kh

individually, as the custodial par tan uardian of my minor children, and on behalf of

my minor children, (initials)

M areby release and forever discharge

Stonecleave Village Associatio, C., its ast and present Trustees and Directors,

Property Management of Andover, Inc., Elaine Romano, and each of their respective

insurers and attorneys, of and from any and aU liability for any claims, legal or equitable,

I rr,ay have and have had against them arising out of the Issues that were alleged or

could have been alleged in the lawsuit referenced above. I fully acknowledge and

agree that this release shall be binding on my heirs, spouses, representatives,

executors, successors, administrators, and assigns. I further acknowledge that my

receipt of the sum specified herein does not constitute or equate with an admission of

wrongdoing or liability by Stonecleave Village Association, Inc., its past and present

Trustees and Directors, Property Management of Andover, Inc., Elaine Romano and

their respective insurers and attorneys. I also acknowledge that by receipt of the sum

specified herein, I waive my right to seek reimbursement for any fines or charges that I

have paid in connection with the events at issue in this lawsuit. I hereby acknowledge

that I have read and understand this release and have executed It volunti~rny and with

full knowledge of its legal consequences.

I further warrant that I will be responsible for determining the tax consequences of the payment above, and that I will indemnify and hold harmless Stonecleave Village Association, Inc., its past and present Trustees and Directors, Property Management of Andover, Inc., Elaine Romano and/or theirrespective insurers and attorneys of and from any taxes, interest, lawsuits, claims, or penaitfes imposed by taxhg authorities or lien holders with respect to my receipt of this payment.

1- Executed this

day of '-='-'-"r.L.J..""-''""'---H

~C~ m·e /lo.rndlon

Full Nirfe as it appears on

Socia! Security card

oOlClal Security N,';;~~--

2Q~f:lnh i U!1tJ}J

r}1:e ~m, nit ollYl

Address

"

,

F-ej'hatH=
Gender

11

Case 1:10-cv-10294-JLT Document 19-1 Filed 12/06/10 Page 10 of 10 Case1:10-cv-10294-JLT Document18 Filed11/23/10 Page1lof17

EXHIBIT C
Release

In consideration of the payment of the sum of le'il 7k~q~dollars ($ t%W.ao),
pursuant to the Consent Order entered in U 1 tat v. Sio cleave Vi a e Msociation. Inc., Civil Action No. 10-10294-JLT (D. Mass.), I. B v~
Individually, as the custodial parent and guardian of my minor children, and on behalf of
my minor children, (initials) .~ f. a {YIP , hereby release and forever discharge
Stonec!eav,e Village Association, inc., its past and present Trustees aM Directors, Property Management of Andover, Inc., Elaine Romano, and each of their respective insurers and attorneys, of and from any and ali liabifity for any claims, legal or equitable, I may have and have had against them arising out of the Issues. that were al/eged or
could have been alleged in the lawsuit referenced above. I fully acknowledge and agree that Ihls release shall be binding on my heirs, spouses, representatives, executors, successors, administrators, and assigns. I further aoknowledge that my
receipt of the sum specified herein does not constitute or equate with an admission of wrongdoIng or liability by Stonecleave Village Association, Inc., its past and present Trustees and Direolors, Property Management of Andover, Inc., ElaIne Romano and their respectlve insurers and attorneys. I also acknowledge that by receipt of Ihe sum specified herein, 1waive my right to seek reimbursement for any fines or charges that I have paid In connection with the events at issue in this lawsuit. I hereby acknowledge that I have read and understand this release and have eXi9cuted it voluntarily and with full knowledge of Its legal consequences.

I further warrant that I will be responsible for determining the tax consequences of
the payment above, and that I will indemnify and hold harmless Stonecleave Village
Association, Inc., I!s past and present Trustees and Directors, Property Ma.nagement of Andover, Inc., Elaine Romano and/or their respective insurers and attorneys of and from any taxes, interest, lawsuits, claims, or penalties imposed by taxing authorities or
lien holder:s with respect to my receipt of this payment.

Executed this ~ day of
~~I-tf) A$HJi1:i PATf:L
Full Name as it appears on Social Security card .

Signa

&0 U'<M!jJ~e>'!) St. :/-M<f
M·iIthIIe-n , mA. (!)Ig-q lL
Address

. fe<r(loJ e'----_ Gender
11

 
 Case: 1:10-cv-10294 As of: 12/10/2011 08:34 PM EST 1 of 3
United States District Court District of Massachusetts (Boston) CIVIL DOCKET FOR CASE #: 1:10−cv−10294−JLT

CLOSED

United States of America v. Stonecleave Village Association, Inc. et al Assigned to: Judge Joseph L. Tauro Cause: 42:405 Fair Housing Act
Plaintiff

Date Filed: 02/19/2010 Date Terminated: 11/17/2010 Jury Demand: Plaintiff Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Plaintiff

United States of America

represented by Jennifer A. Serafyn United States Attorney's Office 1 Courthouse Way Boston, MA 02210 617−748−3188 Fax: 617−748−3969 Email: jennifer.serafyn@usdoj.gov ATTORNEY TO BE NOTICED

V. Defendant Stonecleave Village Association, Inc.
Defendant Property Management of Andover, Inc.
Defendant Elaine Romano

represented by James J. Duane , III Taylor, Duane, Barton &Gilman, LLP 160 Federal Street 5th Floor Boston, MA 02110 617−654−8200 Fax: 617−482−5350 Email: jduane@taylorduane.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Joshua B. Walls Taylor, Duane, Barton &Gilman, LLP 160 Federal Street 5th Floor Boston, MA 02110 617−654−8200 Fax: 617−482−5350 Email: jwalls@taylorduane.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by James J. Duane , III (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Joshua B. Walls (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by James J. Duane , III (See above for address) LEAD ATTORNEY

Case: 1:10-cv-10294 As of: 12/10/2011 08:34 PM EST 2 of 3
ATTORNEY TO BE NOTICED
Joshua B. Walls (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Mediator Judge Leo T. Sorokin TERMINATED: 09/30/2010

Date Filed 02/19/2010
02/22/2010
02/22/2010
03/09/2010 03/09/2010 03/09/2010 03/15/2010 03/15/2010 03/15/2010 03/15/2010 03/15/2010 03/15/2010 03/15/2010 03/15/2010

# Docket Text
1 COMPLAINT against all defendants, filed by United States of America. (Attachments: # 1 Civil Cover Sheet, # 2 Category Form)(Serafyn, Jennifer) (Additional attachment(s) added on 2/22/2010: # 3 Corrected Non−Fillable Civil Cover Sheet, # 4 Corrected Non−Fillable Category Form) (Paine, Matthew). (Entered: 02/19/2010)
ELECTRONIC NOTICE of Case Assignment. Judge Joseph L. Tauro assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Collings (Paine, Matthew) (Entered: 02/22/2010)
2 Summons Issued as to Stonecleave Village Association, Inc., Property Management of Andover, Inc., Elaine Romano. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (Paine, Matthew) (Entered: 02/22/2010)
3 SUMMONS Returned Executed Stonecleave Village Association, Inc. served on 3/8/2010, answer due 3/29/2010. (Serafyn, Jennifer) (Entered: 03/09/2010)
4 SUMMONS Returned Executed Property Management of Andover, Inc. served on 3/8/2010, answer due 3/29/2010. (Serafyn, Jennifer) (Entered: 03/09/2010)
5 SUMMONS Returned Executed Elaine Romano served on 3/8/2010, answer due 3/29/2010. (Serafyn, Jennifer) (Entered: 03/09/2010)
6 NOTICE of Appearance by Joshua B. Walls on behalf of Stonecleave Village Association, Inc., Property Management of Andover, Inc. (Walls, Joshua) (Entered: 03/15/2010)
7 NOTICE of Appearance by Joshua B. Walls on behalf of Elaine Romano (Walls, Joshua) (Entered: 03/15/2010)
8 CORPORATE DISCLOSURE STATEMENT by Property Management of Andover, Inc.. (Walls, Joshua) (Entered: 03/15/2010)
9 CORPORATE DISCLOSURE STATEMENT by Stonecleave Village Association, Inc.. (Walls, Joshua) (Entered: 03/15/2010)
10 NOTICE of Appearance by James J. Duane, III on behalf of Stonecleave Village Association, Inc., Property Management of Andover, Inc., Elaine Romano (Duane, James) (Entered: 03/15/2010)
11 Joint MOTION Joint Request for Reference to Mediation by United States of America.(Serafyn, Jennifer) (Entered: 03/15/2010)
12 Joint MOTION For Reference to Mediation (Corrected Version to Replace Docket Entry# 11) re 11 Joint MOTION Joint Request for Reference to Mediation by United States of America.(Serafyn, Jennifer) (Entered: 03/15/2010)
13 Assented to MOTION for Extension of Time to File Answer or Otherwise Respond to Plaintiff's Complaint Until 20 Days After the Completion of Mediation, if Necessary by Stonecleave Village Association, Inc., Property Management of

Case: 1:10-cv-10294 As of: 12/10/2011 08:34 PM EST 3 of 3

03/16/2010 03/24/2010 03/26/2010 03/30/2010
04/05/2010
09/30/2010 09/30/2010 11/16/2010 11/17/2010 11/23/2010 12/06/2010

Andover, Inc., Elaine Romano.(Walls, Joshua) (Entered: 03/15/2010)
Judge Joseph L. Tauro: Electronic ORDER entered granting 12 Motion for Reference to Mediation; granting 13 Motion for Extension of Time to Answer (Abaid, Kimberly) (Entered: 03/18/2010)
14 Judge Joseph L. Tauro: ORDER entered. REFERRING CASE to Alternative Dispute Resolution.(Geraldino−Karasek, Clarilde) (Entered: 03/24/2010)
Electronic Notice of assignment to ADR Provider. Mag. Judge Leo T. Sorokin appointed. The court will contact counsel with regard to scheduling.(Tyler, Rebecca) (Entered: 03/26/2010)
ELECTRONIC NOTICE of ADR Conference. Alternative Dispute Resolution Hearing set for JUNE 18, 2010 AT 9:30 AM in Courtroom 24 before Magistrate Judge Leo T. Sorokin. INSTRUCTIONS − Counsel and principals are directed to be present and have full settlement authority. A brief mediation memoranda should be submitted BY HAND OR MAIL WITH THE COURT no later than five (5) days prior to the mediation and marked "Confidential − Not for Docketing". Counsel are requested to try and accommodate this date. In the event that you believe the case is not ripe for mediation at this time, or the date poses a serious conflict, counsel are to notify opposing counsel and FILE AN ASSENTED TO MOTION to continue the mediation as soon as possible. Questions regarding this mediation or the mediation process should be directed to Yvonne Franklin at 617−748−9224.(Franklin, Yvonne) (Entered: 03/30/2010)
ELECTRONIC NOTICE OF RESCHEDULING. JUNE 18, 2010 HEARING IS CANCELLED. Alternative Dispute Resolution Hearing RESCHEDULED FOR JUNE 14, 2010 AT 9:30 AM in Courtroom 24 before Magistrate Judge Leo T. Sorokin. INSTRUCTIONS − Counsel and principals are directed to be present and have full settlement authority. A brief mediation memoranda should be submitted BY HAND OR MAIL WITH THE COURT no later than five (5) days prior to the mediation and marked "Confidential − Not for Docketing". Counsel are requested to try and accommodate this date. In the event that you believe the case is not ripe for mediation at this time, or the date poses a serious conflict, counsel are to notify opposing counsel and FILE AN ASSENTED TO MOTION to continue the mediation as soon as possible. Questions regarding this mediation or the mediation process should be directed to Yvonne Franklin at 617−748−9224.(Franklin, Yvonne) (Entered: 04/05/2010)
15 REPORT of Alternative Dispute Resolution Provider. Magistrate Judge Leo T. Sorokin reports case has settled and recommends the Court stay case for 60 days. Within that time period parties will file proposed consent judgment for District Judges review. (Franklin, Yvonne) (Entered: 09/30/2010)
16 Judge Joseph L. Tauro: SETTLEMENT ORDER OF DISMISSAL entered. (Geraldino−Karasek, Clarilde) (Entered: 10/01/2010)
17 STIPULATION of Dismissal as to Defendants Property Management of Andover, Inc. and Elaine Romano by United States of America. (Serafyn, Jennifer) (Entered: 11/16/2010)
Civil Case Terminated. (Geraldino−Karasek, Clarilde) (Entered: 11/17/2010)
18 Proposed Document(s) submitted by United States of America. Document received: Consent Order. (Serafyn, Jennifer) (Entered: 11/23/2010)
19 Judge Joseph L. Tauro: CONSENT ORDER entered. (Attachments: # 1 Exhibit A−C)(Geraldino−Karasek, Clarilde) (Entered: 12/07/2010)