make illegal changes to the property andsignificant alterations and repairs.Because changes that were neither licensed nor inspected were made to the
building before Plaintiff occupied it, the District of Columbia’s Department of
Regulatory Affairs issued a stop-work order on the property. That means Plaintiff was unable, to acquire a permanent Certificate of Occupancy or a permanentliquor license until January 2012 for part of the Building and still cannot acquire apermanent Certificate of Occupancy or a permanent liquor license for the otherpart of the building.9.
Upon information and belief Defendant has leased his properties to members
outside of Plaintiff’s protected class and has not treated
those persons they waythat Plaintiff has been treated.10.
Defendant is discriminating against Plaintiff because of Plai
ntiff’s race (African
COUNT IVIOLATION OF THE CIVIL RIGHTS ACT OF 1866, 42 U.S.C. § 1981
Plaintiff re-pleads and re-alleges paragraphs 1-10, with the same force and effectas if set forth separately at length herein.12.
Plaintiff is a member of a protected class (African-Americans).13.
Defendant, themselves and/or by and through agent(s), employee(s), and/orrepresentative(s), acted in a discriminatory manner that a reasonable person wouldfind objectively unreasonable.14.
Plaintiff did not enjoy the services, privileges, benefits and protections offered to
other persons outside of Plaintiff’s protected class.