ALL Turizo/FFHA 

Fair Housing Act Suits

First Name/Entity Name Last Name Role Type Style Case Number/Judge Date Filed Date Closed Motion to Dismiss Filed Disposition

Ryan Turizo Plaintiff Party Turizo v. Camden Summit Partnership, L.P. 0:2019cv62005 - BB

Judge Beth Bloom, Magistrate Alicia 

O. Valle

8/10/2019 9/26/2019 9/4/2019,

MTD Filed, Failure to State a Claim 9/13/2019,

denied as moot per stipulation of dismissal

Stipulation of Dismissal With Prejudice, Pending 

Settlement

Ryan Turizo Plaintiff Party Turizo v. PPF AMLI 5971 Toscana Drive, LP 0:2019cv62006 - CMA

Judge Celia M. Altonaga, Magistrate 

Barry Seltzer

8/10/2019 9/26/2019 9/4/2019, MTD Filed, Failure to State a Claim, 

9/16/2019, denied as moot based on filing of 

First Amended Complaint

Stipulation of Dismissal With Prejudice, Pending 

Settlement

Ryan Turizo Plaintiff Party Turizo v. GS Bayview, LLC 0:2019cv63012 - RS

Judge Raag Singhal, Magistrate 

Alicia O. Valle

12/6/2019 4/28/2020 2/24/2020, MTD Filed, Failure to State a Claim

3/10/2020, denied as moot per stipulation of 

dismissal

Notice of Voluntary Dismissal Without Prejudice

Ryan Turizo Plaintiff Party Turizo v. Tamarac Pointe, LTD.,Limited Partnership 0:2020cv60073 - RAR

Judge Rodolfo A. Ruiz, Magistrate 

Barry S. Seltzer

1/13/2020 4/8/2020 2/28/2020, MTD Filed, Failure to State a Claim

3/16/2020, denied as moot based on filing of 

First Amended Complaint; Renewed Motion to 

Dismiss for failure to state a claim 3/26/2020; 

denied as moot per 4/8/2020 Order Dismissing 

Case with Prejudice

Notice of Voluntary Dismissal and Order Dismissing 

Case With Prejudice

Ryan Turizo Plaintiff Party Turizo v. Rich Metro Group, LLC 0:2020cv60074 - RS

Judge Raag Singhal, Magistrate 

Alicia O. Valle

1/13/2020 4/13/2020 2/28/2020, MTD Filed, Failure to State a Claim

3/16/2020, denied as moot per stipulation of 

dismissal

Notice of Voluntary Dismissal, Pending Settlelment

Ryan Turizo Plaintiff Party Turizo v. Cypress Trail Apartments, LTD 0:2020cv60103 -RAR

Judge Rodolfo A. Ruiz, Magistrate 

Jared M. Strauss

1/16/2020 2/18/2020 NONE Notice of Voluntary Dismissal With Prejudice

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. Coral Haven Apartments 

LLP

0:2020cv60446 - RS

Judge Raag Singhal, Magistrate 

Alicia O. Valle

2/28/2020 3/2/2020 Adminstratively Closed, Reassigned to 

1:2020cv20921AHS

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. Coral Haven Apartments 

LLP

1:2020cv20921 - RS

Judge Raag Singhal, Magistrate Chris 

M. McAliley

2/28/2020 4/21/2020 3/26/2020 MTD Filed, Failure to State a Claim, 

moot per Notice of Settlement

4/21/2020 Notice of Settlement

Notice of Voluntary Dismissal With Prejudice, 

Pending Settlement

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. Japanese Garden Mobile 

Estates, Inc.

1:2020cv21091 - MGC

Judge Marcia G. Cooke, Magistrate 

Jonathan Goodman

3/12/2020 5/29/2020 4/7/2020 MTD Filed, Failure to State a Claim Notice of Voluntary Dismissal 5/1/2020, Order of 

Dismissal 5/29/2020

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. Park East-West Ltd. 1:2020cv21976 - RNS

Judge Robert N. Scola, Jr., 

Magistrate Edwin G. Torres

5/12/2020 Pending Matter 6/9/2020 MTD Filed, Failure to State a Claim and 

Lack of Standing, Denied as moot 6/24/2020 

based on filing of Amended Complaint

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. Top Well, LLC 1:2020cv21994 - KMW

Judge Kathleen M. Williams, 

Magistrate Edwin G. Torres

5/12/2020 Pending Matter NONE

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. Deerpath on the Lake, LLC 1:2020cv22106 - DPG

Judge Darrin P. Gayles, Magistrate 

Alicia M. Otazo-Reyes

5/20/2020 Pending Matter 6/17/2020 MTD Filed, Failure to State a Claim 

and Lack of Standing

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. Catalina Rental 

Apartments, Inc.

1:2020cv22113 - DPG

Judge Darrin P. Gayles, Magistrate 

Alicia M. Otazo-Reyes

5/20/2020 Pending Matter NONE

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. Liberty Apartment 

Highland, LLC

1:2020cv22269 - MKM

Judge Michael K., Moore, 

Magistrate Jacqueline Becerra

6/1/2020 Pending Matter NONE

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. PMG 11th Street Holdings, 

LLC

1:2020cv61120 - FAM

Judge Federico A. Moreno, 

Magistrate Jared M. Strauss

6/5/2020 Pending Matter NONE

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. 601 Ocean Investments, 

LLC

1:2020CV22664-KWM Judge 

Kathleen M. Williams, 

Magistrate Judge Edwin G. Torres

6/26/2020 Pending Matter NONE

Florida Fair Housing Alliance, Inc. Plaintiff Party Florida Fair Housing Alliance, Inc. v. The Palm Bay Grand, LLC 1:2020cv22665 - DPG 

Judge Darrin P. Gayles, Magistrate 

Judge (unassigned as of 7/1/2020)

6/26/2020 Pending Matter NONE

EXHIBIT A

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 1 of 17
EXHIBIT B

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 2 of 17
Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 3 of 17
FHA Matters Filed by Ryan Turizo or Florida Fair Housing Alliance, Inc. in SDFL

Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

8/10/2019 0:2019cv62005 - BB

Judge Beth Bloom, Magistrate Alicia 

O. Valle

Turizo v. Camden Summit 

Partnership, L.P.

(DE1) Complaint ¶4. -

Plaintiff is a tester. Plaintiff seeks to 

enforce fair housing laws to protect 

individuals from discriminatory housing 

practices by, among other things, 

investigating entities governed by the 

Fair Housing Act (“FHA”) and perusing 

enforcement of meritorious claims. 

Without intent to rent or purchase. 

Plaintiff poses as a renter or purchaser for 

the purpose of collecting evidence of 

discriminatory housing practices. At all 

times material, Plaintiff was acting as a 

tester when Plaintiff conducted an 

investigation of Defendant’s 

discriminatory actions and practices. 

No

8/10/2019 0:2019cv62006 - CMA

Judge Celia M. Altonaga, Magistrate 

Barry Seltzer

Turizo v. PPF AMLI 5971 Toscana 

Drive, LP

(DE1) Complaint ¶4. - 

Plaintiff is a tester. Plaintiff seeks to 

enforce fair housing laws to protect 

individuals from discriminatory housing 

practices by, among other things, 

investigating entities governed by the 

Fair Housing Act (“FHA”) and perusing 

enforcement of meritorious claims. 

Without intent to rent or purchase. 

Plaintiff poses as a renter or purchaser 

for the purpose of collecting evidence of 

discriminatory housing practices. At all 

times material, Plaintiff was acting as a 

tester when Plaintiff conducted an 

No

EXHIBIT C

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 4 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

investigation of Defendant’s 

discriminatory actions and practices. 

12/6/2019 0:2019cv63012 - RS

Judge Raag Singhal, Magistrate 

Alicia O. Valle

Turizo v. GS Bayview, LLC (DE1) Complaint ¶4. - 

Plaintiff is a tester. Plaintiff seeks to 

enforce fair housing laws to protect 

individuals from discriminatory housing 

practices by, among other things, 

investigating entities governed by the 

Fair Housing Act (“FHA”) and perusing 

enforcement of meritorious claims. 

Without intent to rent or purchase. 

Plaintiff poses as a renter or purchaser 

for the purpose of collecting evidence of 

discriminatory housing practices. At all 

times material, Plaintiff was acting as a 

tester when Plaintiff conducted an 

investigation of Defendant’s 

discriminatory actions and practices. 

No

1/13/2020 0:2020cv60073 - RAR

Judge Rodolfo A. Ruiz, Magistrate 

Barry S. Seltzer

Turizo v. Tamarac Pointe, LTD., 

Limited Partnership

(DE1) Complaint ¶4. - 

Plaintiff is a tester. Plaintiff seeks to 

enforce fair housing laws to protect 

individuals from discriminatory housing 

practices by, among other things, 

investigating entities governed by the 

Fair Housing Act (“FHA”) and perusing 

enforcement of meritorious claims. 

Without intent to rent or purchase. 

Plaintiff poses as a renter or purchaser 

for the purpose of collecting evidence of 

discriminatory housing practices. At all 

times material, Plaintiff was acting as a 

tester when Plaintiff conducted an 

investigation of Defendant’s 

discriminatory actions and practices. 

No

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 5 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

1/13/2020 0:2020cv60074 - RS

Judge Raag Singhal, Magistrate 

Alicia O. Valle

Turizo v. Rich Metro Group, LLC (DE1) Complaint ¶4. - 

Plaintiff is a tester. Plaintiff seeks to 

enforce fair housing laws to protect 

individuals from discriminatory housing 

practices by, among other things, 

investigating entities governed by the 

Fair Housing Act (“FHA”) and perusing 

enforcement of meritorious claims. 

Without intent to rent or purchase. 

Plaintiff poses as a renter or purchaser 

for the purpose of collecting evidence of 

discriminatory housing practices. At all 

times material, Plaintiff was acting as a 

tester when Plaintiff conducted an 

investigation of Defendant’s 

discriminatory actions and practices. 

No

1/16/2020 0:2020cv60103 -RAR

Judge Rodolfo A. Ruiz, Magistrate 

Jared M. Strauss

Turizo v. Cypress Trail Apartments, 

LTD

(DE1) Complaint ¶4. - 

Plaintiff is a tester. Plaintiff seeks to 

enforce fair housing laws to protect 

individuals from discriminatory housing 

practices by, among other things, 

investigating entities governed by the 

Fair Housing Act (“FHA”) and perusing 

enforcement of meritorious claims. 

Without intent to rent or purchase. 

Plaintiff poses as a renter or purchaser 

for the purpose of collecting evidence of 

discriminatory housing practices. At all 

times material, Plaintiff was acting as a 

tester when Plaintiff conducted an 

investigation of Defendant’s 

discriminatory actions and practices. 

No

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 6 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

2/28/2020 0:2020cv60446 - RS

Judge Raag Singhal, Magistrate 

Alicia O. Valle

Florida Fair Housing Alliance, Inc. v. 

Coral Haven Apartments LLP

Administratively Closed, Reassigned to 

1:2020cv20921 - RS

No

2/28/2020 1:2020cv20921 - RS

Judge Raag Singhal, Magistrate 

Chris M. McAliley

Florida Fair Housing Alliance, Inc. v. 

Coral Haven Apartments LLP

(DE1) Complaint ¶6. and ¶7. – On or 

about February 18, 2020, the FFH Alliance 

investigated the “Coral Haven” 

apartment community, located at 10255 

SW 24th Street, Miami, Florida 33165, 

(the “Complex”) owned by Defendant for 

discriminatory housing practices. As part 

of this investigation, the FFH Alliance 

directed one of its agents/employees, a

Hispanic/Latino male with a felony 

conviction by the name of Ryan Turizo 

(“Mr. Turizo”), to test the Complex for 

unlawful discriminatory housing 

practices. In this capacity, Mr. Turizo 

contacted the Complex, posed as a 

potential rental applicant, and inquired 

into the available rental property 

Defendant holds open to the public for 

rent (the “Dwelling”). 

 As part of Plaintiff FFH Alliance’s 

investigation into potential 

discrimination in the housing market by 

Defendant, Mr. Turizo to (sic) inquired 

into Defendant’s policy regarding the 

criminal record of applicants applying to 

rent the Dwelling, to which Defendant 

responded by stating a felony criminal 

record would result in an automatic 

denial of an applicant seeking to rent the 

Dwelling.

No

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 7 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

3/12/2020 1:2020cv21091 - MGC

Judge Marcia G. Cooke, Magistrate 

Jonathan Goodman

Florida Fair Housing Alliance, Inc. v. 

Japanese Garden Mobile Estates, 

Inc.

(DE1) Complaint ¶6. To ¶8. -

 On March 02, 2020, the FFH Alliance 

investigated the “The Courtyards of 

South Tampa” apartment community, 

located at 3814 W Euclid Ave, Tampa, FL 

33629, (the “Complex”) owned by 

Defendant for discriminatory housing 

practices. 

 As part of this investigation, the FFH 

Alliance directed one of its 

agents/employees, a Hispanic/Latino 

male with a felony conviction by the 

name of Ryan Turizo (“Mr. Turizo”), to 

test the Complex for unlawful 

discriminatory housing practices. In this 

capacity, Mr. Turizo 

contacted the Complex, posed as a 

potential rental applicant, and inquired 

into the available rental property 

Defendant holds open to the public for 

rent (the “Dwelling”). 

 As part of Plaintiff FFH Alliance’s 

investigation into potential 

discrimination in the housing market by 

Defendant, Mr. Turizo to inquired into 

Defendant’s policy regarding the criminal 

record of applicants applying to rent the 

Dwelling, to which Defendant responded 

by stating a felony criminal record would 

result in an automatic denial of an 

applicant seeking to rent the Dwelling. 

No

5/12/2020 1:2020cv21976 - RNS

Judge Robert N. Scola, Jr., 

Magistrate Edwin G. Torres

Florida Fair Housing Alliance, Inc. v. 

Park East-West Ltd.

(DE1) Complaint ¶13. To ¶15. –

 On April 7, 2020, the FFH Alliance 

tested the Complex for unlawful 

No

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 8 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

discriminatory housing practices using a 

field tester. 

 The field tester used by the FFH 

Alliance to test the Complex (“Field 

Tester” or “FT”) is a sui juris Hispanic male 

with a felony conviction. 

 On April 7, 2020, at approximately 

11:57am, FT called the Complex at phone 

number: 407-871-3894. After dialing this 

number, of which was identified as being 

a recorded line, FT was promptly 

connected to an agent of Defendant, a 

man whom identified himself as 

Sheridan, and FT proceeded to ask 

whether rental property was available. 

Defendant, by and through this agent, 

responded without hesitation that 

properly was available, namely, a onebedroom apartment. FT then asked 

whether his (FT’s) rental application 

would be denied due to FT’s record felony 

conviction, to which Defendant, by and 

though Sheridan, told FT “probably.” 

5/12/2020 1:2020cv21994 - KMW

Judge Kathleen M. Williams, 

Magistrate Edwin G. Torres

Florida Fair Housing Alliance, Inc. v. 

Top Well, LLC

(DE1) Complaint ¶13. To ¶15. –

 On March 13, 2020, the FFH Alliance 

tested the Complex for unlawful 

discriminatory housing practices using a 

field tester. 

 The field tester used by the FFH 

Alliance to test the Complex (“Field 

Tester” or “FT”) is a sui juris Hispanic male 

with a felony conviction. 

 On March 13, 2020, at approximately 

12:58 pm, FT called the Complex at phone 

No

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 9 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

number: 561-793-8500. After dialing this 

number, of which was identified as being 

a recorded line, FT was promptly 

connected to an agent of Defendant, an 

individual whom identified herself as 

“Melissa,” and FT proceeded to ask 

whether rental property was available. 

Defendant, by and through this agent, 

responded without hesitation that 

properly was available, namely, a twobedroom apartment. FT then asked 

whether his (FT’s) rental application 

would be denied due to FT’s record felony 

conviction, to which Defendant, by and 

though Melissa, told FT “yes.” 

5/20/2020 1:2020cv22106 - DPG

Judge Darrin P. Gayles, Magistrate 

Alicia M. Otazo-Reyes

Florida Fair Housing Alliance, Inc. v. 

Deerpath on the Lake, LLC

(DE1) Complaint ¶13. To ¶15. –

 As part of the FFH Alliance’ 

investigation, the FFH Alliance tested the 

Complex for unlawful discriminatory 

housing practices using a field tester. 

 The field tester used by the FFH 

Alliance to test the Complex (“Field 

Tester” or “FT”) is a sui juris Hispanic male 

with a felony conviction. 

 On March 13, 2020, at approximately 

12:43 pm, FT called the Complex (at 813-

933-5333) and was connected to an agent 

of Defendant named “Janessa.” FT 

proceeded to ask whether rental 

property was available. Defendant, by 

and through this agent, responded 

without hesitation that property was 

available, namely, a two-bedroom 

apartment. FT then asked whether his 

No

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 10 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

(FT’s) rental application would be denied 

due to FT’s record felony conviction, to 

which Defendant immediately retorted: 

“possibly.” Defendant, however, did not 

perform any investigation or inquiry into 

the felony conviction had by FT. For 

example, Defendant did not inquire into 

the type of felony, the date of conviction, 

the nature of the conviction, let alone the 

circumstances surrounding the felony 

conviction had by FT. Defendant simply 

identified FT as an individual with a felony 

conviction, and without any inquiry or 

investigation, chose to deter FT from 

renting the property Defendant held 

open to the public due to FT’s record 

felony conviction. 

5/20/2020 1:2020cv22113 - DPG

Judge Darrin P. Gayles, Magistrate 

Alicia M. Otazo-Reyes

Florida Fair Housing Alliance, Inc. v. 

Catalina Rental Apartments, Inc.

(DE1) Complaint ¶13. To ¶15. –

 On April 4, 2020, the FFH Alliance 

tested the Complex for unlawful 

discriminatory housing practices using a 

field tester. 

 The field tester used by the FFH 

Alliance to test the Complex (“Field 

Tester” or “FT”) is a sui juris Hispanic male 

with a felony conviction. 

 To test the Complex, FT called the 

Complex and asked Defendant whether 

rental property was available. Defendant 

responded, without hesitation, that 

rental property was available. FT then 

inquired about submitting a rental 

application, and in so doing, disclosed 

that he (FT) had previously been 

No

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 11 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

convicted of a felony. Without any 

explanation, inquiry, investigation, or 

reservation, Defendant immediately told 

FT that applicants with a felony 

conviction are denied. 

6/1/2020 1:2020cv22269 - MKM

Judge Michael K., Moore, 

Magistrate Jacqueline Becerra

Florida Fair Housing Alliance, Inc. v. 

Liberty Apartment Highland, LLC

(DE1) Complaint ¶13. to ¶15 - 

 As part of the FFH Alliance’s 

investigation, the FFH Alliance tested the 

Complex for unlawful discriminatory 

housing practices using a field tester.

 The field tester used by the FFH 

Alliance to test the Complex (“Field 

Tester” or “FT”) is a sui juris Hispanic 

male with a felony conviction

 On May 18, 2020, FT called the 

Complex (at 407-864-6444) and was 

connected to an agent of Defendant 

named “Alex.” FT proceeded to ask 

whether rental property was available. 

Defendant, by and through this agent, 

responded without hesitation that 

property was available, namely, a onebedroom apartment. FT then asked he 

(FT) could rent the available apartment 

due to FT’s record felony conviction. 

Defendant immediately retorted “yeah 

probably not” and promptly hung up on 

FT.

No

6/5/2020 1:2020cv61120 - FAM

Judge Federico A. Moreno, 

Magistrate Jared M. Strauss

Florida Fair Housing Alliance, Inc. v. 

PMG 11th Street Holdings, LLC

(DE1) Complaint ¶13. to ¶15 - 

 As part of the FFH Alliance’s 

investigation, the FFH Alliance tested the 

Complex for unlawful discriminatory 

housing practices using a field tester.

No

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 12 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

 The field tester used by the FFH 

Alliance to test the Complex (“Field 

Tester” or “FT”) is a sui juris Hispanic 

male with a felony conviction. 

 On May 12, 2020, at approximately 

11:01 a.m., FT called the Complex (at 

954- 524-5656) and was connected to an 

agent of Defendant named “Levi.” FT 

proceeded to ask whether rental 

property was available. Defendant, by 

and through this agent, responded 

without hesitation that property was 

available, namely, a one-bedroom 

apartment. FT then asked whether his 

(FT’s) rental application would be denied 

due to FT’s record felony conviction, to 

which Defendant immediately retorted: 

“no unfortunately if you have any 

felonies we are unable to approve you.”

6/26/2020 1:2020CV22664-KWM Judge 

Kathleen M. Williams, 

Magistrate Judge Edwin G. Torres

Florida Fair Housing Alliance, Inc. v. 

601 Ocean Investments, LLC

(DE1) First Amended Complaint ¶15. to 

¶19. - 

 15. On November 12, 2019, the FFH 

Alliance tested the Complex for unlawful 

discriminatory housing practices using a 

field tester. 

 16. The field tester used by the FFH 

Alliance to test the Complex (“Field 

Tester” or “FT”) is a sui juris Hispanic 

male with a felony conviction. 

 17. On November 12, 2019, at 

approximately 3:28 p.m., FT called the 

Complex at phone number 561-391-

5000. After dialing this number FT was 

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 13 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

connected to an agent of Defendant, of 

whom identified herself as “Susanna.” FT 

first asked whether rental property was 

available, to which Defendant 

responded, without hesitation, that 

property was available. FT then asked 

whether his (FT’s) rental application 

would be denied due to FT’s record 

felony conviction, to which Defendant 

retorted: “yes.” 

 18. Defendant’s response to FT 

regarding convicted-felon applicants 

demonstrates that Defendant directs 

individuals convicted of a felony, the 

majority of which are disproportionately 

Black and Hispanic, away from both the 

Dwelling and the Complex. 

 19. Defendant did not perform any 

investigation or inquiry into the felony 

conviction had by FT. For example, 

Defendant did not inquire into the type 

of felony, the date of conviction, the 

nature of the conviction, let alone the 

circumstances surrounding the felony 

conviction had by FT. Defendant simply 

identified FT as an individual with a 

felony conviction, and without any 

inquiry or investigation, chose to deter 

FT from renting the property Defendant 

held open to the public due to FT’s 

record felony conviction. 

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 14 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

6/26/2020 1:2020cv22665 - DPG 

Judge Darrin P. Gayles, Magistrate 

Judge (unassigned as of 7/1/2020)

Florida Fair Housing Alliance, Inc. v. 

The Palm Bay Grand, LLC

(DE1) First Amended Complaint ¶15. to 

¶19. - 

 15. On May 06, 2020, the FFH Alliance 

tested the Complex for unlawful 

discriminatory housing practices using a 

field tester. 

 16. The field tester used by the FFH 

Alliance to test the Complex (“Field 

Tester” or “FT”) is a sui juris Hispanic 

male with a felony conviction. 

 17. On May 06, 2020, at 

approximately 12:16 p.m., FT called the 

Complex at phone number 321-210-

1009. After dialing this number FT was 

connected to an agent of Defendant, of 

whom identified herself as “Julia.” FT 

first asked whether rental property was 

available, to which Defendant 

responded, without hesitation, that 

property was available, namely, a onebedroom apartment. FT then asked 

whether his (FT’s) rental application 

would be denied due to FT’s record 

felony conviction, to which Defendant 

immediately retorted: “yes you would.” 

 18. Defendant’s response to FT 

regarding convicted-felon applicants 

demonstrates that Defendant directs 

individuals convicted of a felony, the 

majority of which are disproportionately 

Black and Hispanic, away from both the 

Dwelling and the Complex. 

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 15 of 17
Date Filed Case Number/Judge Style Complaint Description Rental 

Application 

Submitted

 19. Defendant did not perform any 

investigation or inquiry into the felony 

conviction had by FT. For example, 

Defendant did not inquire into the type 

of felony, the date of conviction, the 

nature of the conviction, let alone the 

circumstances surrounding the felony 

conviction had by FT. Defendant simply 

identified FT as an individual with a 

felony conviction, and without any 

inquiry or investigation, chose to deter 

FT from renting the property Defendant 

held open to the public due to FT’s 

record felony conviction. 

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 16 of 17
EXHIBIT D

Audio Exhibit submitted to chambers via e-mail and 

filed with the Court on June 15, 2020 [ECF No. 11].

Case 1:20-cv-21976-RNS Document 15-1 Entered on FLSD Docket 07/01/2020 Page 17 of 17