Professional Documents
Culture Documents
Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section
SSM:MSM:JLB:kds U.S. Mail: 950 Pennsylvania Avenue, NW• GSl.
Washington, DC 20530
DJ 175-11-361 Overnight: 1800 G Street. NW
Suite 7002
Telephone:
Washington, DC 20006
(202) 514-4713
received
Facsimile: (202) 514-1116
f"® i 3 2018
This letter is to inform you that the Civil Rights Division of the United States Department
of Justice has initiated an investigation into potential discrimination on the basis of race by the
Louisville Metro Council in violation of the Fair Housing Act ("FHA"), 42 U.S.C. §§ 3601-3619.
The FHA prohibits discrimination on the basis of race and other protected classes in zoning
decisions. The focus of our investigation will be whether the Metro Council has unlawfully
discriminated on the basis of race in the enactment of Ordinance No. 0-326-17, which rejected the
rezoning application of LDG Multifamily, LLC.
The Department is committed to a fiill and fair investigation of this matter. Our
investigation is preliminary, and we have not reached any conclusion concerning the legality of
the Metro Council's conduct and Ordinance No. 0-326-17. In order to conduct a full and fair
investigation, it is essential that we have complete and accurate information about the Metro
Council's consideration of the ordinance. To facilitate our investigation, we ask that the Metro
Council provide us the documents and information requested in the enclosure with this letter. We
also encourage the Metro Council to provide any additional documents and information it may
consider relevant to our investigation.
Once we have had an opportunity to review the documents and information provided in
response to this letter, we will contact you to discuss any additional documents that may be useful
to our investigation and to schedule any interviews of Metro Councilmembers and staff. Please
respond to the enclosed requests for documents and data within 30 days from the date ofthis letter.
If you have any questions or wish to discuss this letter, then please contact Civil Rights Division
Trial Attorney Junis L. Baldon at (202) 305-1806.
Sincerely,
Request No. 3; Describe and provide all documents that refer or relate to the zoning
history of the real property located at 6500 Forest Cove Lane and 7301 River Road, Louisville,
Kentucky.
Request No. 5: Describe and provide all documents that refer or relate to LDG
Multifamily, LLC, Prospect Cove, and Prospect Development, LLC.
Request No. 6: Provide copies of all attendance lists and sign-in sheets maintained
by the Metro Council documenting the attendance of residents and publicofficials at anyhearings
or meetings related to LDG Multifamily, LLC, Prospect Cove, and Prospect Development, LLC.
In addition, provide copies of all such attendance lists and sign-in sheets maintained by the
Louisville Metro Planning Commissionand the Planning/Zoning, Land Design, and Development
Committee.
Request No. 9: Provide copies of all documents related to Prospect Cove from the
Prospect City Council, including any individual Prospect City Councilmembers as well as any of
its agents, employees, consultants, representatives, attorneys, and legislative and administrative
staffs.
Request No. 10: Provide copies of all documents, including correspondence, emails,
petitions,letters,and any other documents from citizensor other entities that refer or relateto LDG
Multifamily, LLC, Prospect Cove, or ProspectDevelopment, LLC. This request also includes any
correspondence, emails, or other documents provided by Metro Councilmembers, including
legislative and administrative staff, in response.
Request No. 12: Provide the most recent demographic data, including any maps or
reports, that the Metro Council has obtained, commissioned, or maintained from any consultant
regarding: (1) the breakdown ofresidents by race in multifamily housingwithin Louisville; (2) the
breakdown of residents by race in single-family housingwithin Louisville; and (3) the geographic
placement of residents by race within Louisville.