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her housing, or participation in the Association’s management of her housing on the basis of her disability, in violation of her civil rights. 4.
Through this lawsuit, Plaintiff seeks compensation for her damages and an injunction compelling Defendants to modify their policies and to establish procedures to ensure the provision of effective communications with Plaintiff concerning Association and housing issues for her homeowner’s association business. Plaintiff also seeks the reasonable attorneys’ fees, costs and litigation expenses incurred for enforcing her fair housing rights.
JURISDICTION & VENUE
This Court has jurisdiction over this action and Plaintiff’s federal claims pursuant to 42 U.S.C. § 3613 and 28 U.S.C. §§ 1331 and 1343. This Court has supplemental jurisdiction pursuant to 28 U.S.C. § 1367 to hear and determine Plaintiff’s state law claims because they are related to her federal claims and arise out of a common nucleus of operative facts. Plaintiff’s state and federal claims form part of the same case or controversy under Article III of the United States Constitution. 6.
Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b) because all of the acts and omissions giving rise to these claims occurred within the County of Sacramento, State of California.
Plaintiff ALICE M. DONOVAN is, and at all times relevant herein was, an individual with a disability as that term is defined by the Fair Housing Amendments Act due to blindness (42 U.S.C. § 3602(h); 24 C.F.R. § 100.201), and California law (Cal. Gov. Code § 12926). Plaintiff is, and at all times relevant herein, was and is a resident of Sacramento County, California, and homeowner with a home in the Woodbridge at Natoma Station. 8.
Defendant Woodbridge Maintenance Association (“Association”) is a nonprofit mutual benefit corporation, incorporated in 1993 for the purpose of
Complaint For Damages And Injunctive Relief 3
Case 2:14-cv-00995-JAM-EFB Document 2 Filed 04/23/14 Page 3 of 17