sunlight of spirit house complaint

CG t4 .))'. .' IN THE UNITED STATES DISTRICT COURT - FOR THE EASTERN DISTRICT OF PENNSYLVANIA

SUNLIGHT OF THE SPIRIT HOUSE, INC., a Pennsylvania not for profit corporation

and

MATTHEW BARTELT

Plaintiffs,

v.

BOROUGH OF NORTH WALES, PENNSYLVANIA, a Pennsylvania municipal corporation,

and

ZONING HEARING BOARD OF NORTH WALES

Defendants.

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO.

COMPLAINT AND DEMAND FOR JURY TRIAL (DAMAGES AND INJUNCTIVE RELIEF REqUESTED)

PRELIMINARY STATEMENT

This action seeks a declaratory judgment, permanent injunctive relief, and damages for

discrimination in zoning on the basis of handicap or disability. Defendants have engaged in a

pattern and practice of conduct with purpoBe, and/or dfect of diBcriminating again:lt

Case 2:16-cv-00909-MSG Document 1 Filed 02/25/16 Page 4 of 23

persons with handicaps or disabilities. This discrimination has been carried out through the use

of, amongst other things, refusal to provide a reasonable accommodation, the Borough's lack of a

reasonable accommodation procedure for zoning matters, arbitrary interpretation of zoning laws

and, even if not arbitrary, unreasonably restrictive zoning policies that have limited Plaintiffs'

ability to rent sober housing to people in recovery. Defendants' conduct have threatened to

deprive Plaintiffs proposed handicapped and disabled residents the benefit of independent

housing opportunities that they so sorely need. This action arises under the Fair Housing Act of

1968 ("FHA"), as amended, 42 U.S.C. 3601, et seq., and the Americans with Disabilities Act

("ADA"), 42 U.S.C. 1213, et seq.

I. JURISDICTION AND VENUE

1. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.

Sections 1331, 1343, 42 U.S.C. 3613, and 42 U.S.C. 12133.

2. Venue is proper in the United States District Court for the Eastern District of

Pennsylvania as all acts complained of occurred within this District.

II. PARTIES

3. Sunlight of the Spirit House, Inc. ("SOSH") is a Pennsylvania not-for-profit

corporation with its principal place of business located in Lansdale, Pennsylvania. The mission

Sunlight of the Spirit House is to provide safe and sober housing for persons in recovery from

alcoholism and drug addiction. Sunlight of the Spirit House rents a single family dwelling

located at 509 East Montgomery Avenue in the Borough of North Wales, Pennsylvania.

4. Plaintiff, Matthew Bartelt owns the property located at 509 East Montgomery

Avenue and leases it to Sunlight of the Spirit House, Inc.


5. The Borough of North Wales ("Borough") is a Pennsylvania municipal

corporation. The Borough is responsible for the acts of its agents and employees, including

enactment and enforcement of its zoning code.

6. The Zoning Hearing Board ("Board") is responsible for the interpretation of the

Borough's zoning code. It hears and decides all applications for special use permits that seek

exceptions and waivers of the Borough's zoning code.

III. STATUTORY AND REGULATORY FRAMEWORK

7. In 1988, Congress amended the Fair Housing Act, 42 U.S.C. Section 3601 et seq.,

to extend the guarantee of fair housing to handicapped individuals. Congress also authorized the

Secretary of the United States Department of Housing and Urban Development to promulgate

regulations to implement the Fair Housing Act. 42 U.S.C. Section 3614a.

8. Under the Fair Housing Act, the term "handicap" means, with respect to a person,

a "physical or mental impairment which substantially limits one or more of such person's major

life activities, a record of such an impairment, or being regarded as having such an impairment."

42 U.S.C. Section 3602(h). The term "physical or mental impairment" includes "alcoholism"

and "drug addiction (other than addiction caused by current, illegal use of a controlled

substance)." 24 C.F.R. Section 100.201.

9.Under the Fair Housing Act, it is unlawful to discriminate against or otherwise make

unavailable or deny a dwelling to any buyer or renter because of a handicap of that buyer, renter,

or person residing in or intending to reside in that dwelling after it is sold, rented, or made

available. 42 U.S.C. Section 3604(f)(l).


10. The Fair Housing Act further provides that it is unlawful to discriminate against

any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the

provision of services or facilities in connection with such dwelling, because of the handicap of

that person or persons residing in or intending to reside in that dwelling after it is sold, rented, or

made available. 42 U.S.C. Section 3604(f)(2).

11. The federal regulations implementing the Fair Housing Act specifically prohibit,

as a discriminatory activity, providing municipal services differently because of handicap. 24

C.F.R. 100.70 (d)(4).

12. The federal regulations implementing the Fair Housing Act further make it

unlawful, because of handicap, "to restrict or attempt to restrict the choices of a person by word

or conduct in connection with seeking, negotiating for, buying or renting a dwelling so as to . . .

discourage or obstruct choices in a community, neighborhood or development." 24 C.F.R.

Section 100.70(a).

13. The American with Disabilities Act requires that no qualified individual with a

disability shall, by reason of such disability, be excluded from participation in or be denied the

benefits of the services, program, or activities of a public entity, or be subjected to discrimination

by any such entity. 42 U.S.C. Section 12132.

14. The federal regulations implementing the Americans with Disabilities Act prohibit

a public entity from administering a licensing program in a manner that subjects qualified

individuals with disabilities to discrimination on the basis of disability, nor may a public entity

establish requirements for the programs or activities of licensees that subject qualified


individuals with disabilities to discrimination on the basis of disability. 28 C.F.R. Section

35.130(6).

15. The federal regulations implementing the Americans with Disabilities Act also

make it unlawful for a public entity, in determining the site or location of a facility, to make

selections that have the purpose or effect of excluding individuals with disabilities, denying them

benefits, or otherwise subjecting them to discrimination. 28 C.F.R. Section 35.130(4)(1).

IV. STATEMENT OF FACTS

A. SUNLIGHT OF THE SPIRIT HOUSE, INC.

15. The mission of SOSH is to provide housing for recovenng alcoholics and

substance abusers that helps establish a foundation for purposeful long term sobriety for up to ten

(10) residents.

16. All of the individuals who participate in the SOSH program and reside in the

sober house located at 509 East Montgomery Avenue in the Borough of North Wales,

Pennsylvania are individuals who are disabled by virtue of their alcohol or chemical dependency

and who are maintaining sobriety while residing in a sober house combined with their

completion of a separate unaffiliated substance abuse treatment program.

17. SOSH does not provide a substance abuse treatment program. There is no

counseling, or therapy offered to the residents. Residents are required to attend meetings of 12

step groups outside of the house.

18. The residents of SOSH voluntarily choose to participate in the program and reside

at 509 East Montgomery Avenue. Residents of the SOSH live together as a family and make

group decisions based on a collaborative basis. SOSH is used as single family home with similar


support and collaborative functions. The residents of the SOSH relate to each other as the

functional equivalent of a single family.

19. All residents of SOSH have access to the entire house, all of the household

facilities, and function together as a single housekeeping unit. There are not any special locks on

the doors of the bedrooms or other rooms in the House. The residents share all household

responsibilities, and live together to create a "family" atmosphere, where all aspects of domestic

life are shared by all the residents.

20. SOSH is not a substance abuse treatment center, halfway house, shelter, or a

community care facility. There are no treatment, counseling, therapy, or any type of health care

services provided at the SOSH. SOSH is not licensed by the Commonwealth of Pennsylvania

nor is not required to be licensed. There are no institutional personnel involved in the

supervision or management of the SOSH. SOSH does not provide a "recovery program" or

services.

23. There is no limit on the amount of time that the Residents can live at SOSH so

long as they follow a simple set of house rules. All residents are required to be alcohol and drug

free which is a condition of continued residency at SOSH.

24. SOSH provides a peer-driven sober living environment designed to increase self-

responsibility and support for persons in recovery. The SOSH program provides a supportive

atmosphere that is designed to increase self-responsibility and support for persons in recovery

from alcoholism and substance abuse. There is no counseling or therapy offered to the residents.

25. The residents of SOSH must freely choose to participate in the SOSH program

and reside at the house located 509 East Montgomery Avenue. Residents of SOSH live together


as a family and make group decisions based on democratic procedures. The dwelling is used as

single family home with similar support and collaborative functions. The residents of the SOSH

relate to each other as the functional equivalent of a single family.

B. THE OPENING OF 509 EAST MONTGOMERY AVENUE AS A SOBER

HOUSE

26. Plaintiff, Matthew Bartelt, purchased 509 East Montgomery Avenue on or about

May 2015. It is part of a twin residential property. The house is a three story structure with five

bedrooms.

27. At the time of the purchase, the property was dilapidated and in disrepair.

28. Mr. Bartelt spent approximately $65,000 to improve the house and make it

livable.

29. During the process of repair and renovation, Mr. Bartelt approached officials of

the Borough to advise them of his plans to use the house as a residence for recovering alcoholics

and substance abusers for up to ten (10) residents. He was advised that the Borough could not

advise him as to whether a sober home could be established at 509 East Montgomery Avenue

under the Borough's zoning code. He was not advised that he had to apply for a special use

permit.

30. Just prior to the opening of the house for SOSH and its residents, Mr. Bartelt

learned that he needed to apply for a special use permit.

31. On or about May 28, 2015, the Borough issued a certificate of occupancy for up

to three unrelated persons.


32. On or about August 5, 2015, Mr. Bartelt entered into a lease with SOSH to rent

the premises at 509 East Montgomery Avenue for use a residence for recovering alcoholics and

substance abusers.

C. THE BOROUGH'S ZONING CODE

33. The Borough's zoning Code governs zoning and land use policy in the Borough.

34. 509 East Montgomery Avenue is located in a residential area that is zoned R-C

Residential, which permits single-family and two-family residential use as a permitted, principle

use. Group Homes, as that term is defined by the Cobb County Code is a permitted use in the

RA-5 zoning district.

35. Section 208-08 of the Borough's zoning code defines "family" as:

(1) Any number of persons living together as a nonprofit and non-transient single

housekeeping unit and having facilities to do their cooking on the premises, when said persons

are related by blood, marriage or adoption, including any number of foster children;

(2) Up to three unrelated persons and their children when living and cooking together as a

single, nonprofit and non-transient housekeeping unit and having facilities to do their cooking on

the premises which constitute a functional family equivalent;

(3) Up to three mentally or physically handicapped persons who suffer from a physical or

a mental impairment that substantially limits one or more major life activities, living in and

occupying a single dwelling unit, as a single, nonprofit and non-transient housekeeping unit

which constitute a functional family equivalent; or

( 4) A greater number of three unrelated persons, occupying a dwelling unit as a family,

provided the Zoning Hearing Board shall grant a special exception after ascertaining that the


dwelling unit has adequate off-street parking facilities, living space, indoor plumbing, and

operating as a single, nonprofit and non-transient housekeeping unit and facilities to do their

cooking on the premises which constitute a functional family equivalent and complying with the

requirements of the Uniform Construction Code.3

B. The definition of family shall not include activities that require treatment regularly

performed on the premises and shall not include uses which meet the definition of

"boardinghouse," "dormitory," "motel" or "hotel," or "treatment center." This definition shall not

include housing persons released from or under the jurisdiction of a government Bureau of

Corrections or similar institution.

36. Section 208-08 of the Borough's zoning code defines "Functional Family

Equivalent" as: "Persons living and cooking together as a single, nonprofit and non-transient

housekeeping unit and having facilities to do their cooking on the premises.

37. The Borough's zoning code does not define the term "transient."

D. SPECIAL USE PERMIT APPLICATION AND HEARINGS BEFORE THE ZONING HEARING BOARD

38. In June, 2015, the Plaintiffs made application for a special use permit to for

"Occupancy by 3 unrelated persons (but not more than 10) occupying the dwelling unit as a

family, which is permitted by Special Exception pursuant to the definition of Family at Section

208-8 of the Zoning Code" The application was for a reasonable accommodation pursuant to

the federal Fair Housing Act to waive the three unrelated rule requirement and to treat the

residents of SOSH as a "Functional Family Equivalent."

39. Two hearings were held before the Board.


40. The first hearing was held on September 1, 2015

41. There were ten (10) citizens and neighbors who were given objector status to

SOSH's special use permit application. The majority of the objectors lived more than 500 feet

from 509 East Montgomery Avenue and did not receive the required written notice of the

hearing.

41. Mr. Bartelt testified that the SOSH residents would be individuals who had

completed residential substance abuse treatment.

42. He also testified that the SOSH would not be providing substance abuse treatment

or counseling, and that residents were encouraged to follow through with their treatment plan,

which may include outpatient treatment.

43. He testified that one of the purposes of SOSH was to provide a housing program

where those residents who just completed treatment would have the opportunity to live with

others who are striving to achieve long-term sobriety instead of returning home to live with

parents or family members.

44. He testified that the benefits of living at SOSH is that the residents were not

around triggers, i.e, those activities or places that would trigger a relapse. He stated it is

beneficial to be around people who were on the same path. SOSH offered easy access to 12 step

recovery meetings, as well as structure, rules and a curfew.

45. All residents are required to participate in 12 step programs, and obtain a 12 step

sponsor.

46. Mr. Bartelt also testified that SOSH was seeking accreditation from the

Pennsylvania Alliance of Recovery Residences ("PARR"). PARR's goal is to help create and


foster a safe living environment for those with substance use disorders by certifying Recovery

Residences that implement empirically-based recovery principles and practice standards. PARR

is the regional resource for recovery residence providers seeking standards, protocols for ethical

practice, training, and state of the art information pertaining to all levels of residential recovery

operations.

46. The Board did not know that alcoholism is a recognized disability and that it is

listed in the DSM-V. The Board Chair wanted to know if the DSM and the disability of

alcoholism had any effect on Pennsylvania state law and zoning regulations. However, counsel

for the Board conceded that the residents of SOSH were disabled under federal law.

4 7. Counsel for Mr. Bartelt explained to the Board that alcoholism is a recognized

disability under the Fair Housing Act, the Americans with Disabilities Act and the Rehabilitation

Act.

48. Mr. Bartelt agreed to limit the number of cars for residents to two (2).

49. Mr. Bartelt testified that the stay at the Property would be from 3 months to a

year, as tenants are permitted to stay as long as they are following the rules and regulations. The

expected stay of a tenant is nine (9) months.

49. After the first hearing, the Plaintiffs amended their special use application as

follows:

"Occupancy by more than 3 unrelated persons with disabilities (but not more than 10)

occupying the dwelling unit as a family, which is permitted by Special Exception pursuant to the

definition of Family at Section 208-8 of the Zoning Code. Reasonable accommodations for

persons with disabilities."


50. At the second hearing held on October 6, 2015, several neighbors and objectors

spoke in opposition to the special use permit application.

51. On objector stated that "I think it's great what you guys are doing. I just don't

want it in the neighborhood."

52. Another objector question SOSH could claim it is a non-profit organization when

it is making money from the rent. He stated "So you get more money by cramming more people

into the house?" He also questioned how SOSH is governed and how it determines how the

money is being spent.

53. The Board chairman also questioned how SOSH would govern its finances. He

stated:

"I'd like to comment on that, because that has come up a couple of times, and you have

mentioned that you've only been around for three months, and you 1 don't know what you're

going to do, you don't know how you're going to pay yourselves, and you believe the money's

going to go back in. At some point, at some point in the actually very calculable near future, if

you're there for ten people, you won't have a mortgage on the house anymore, what's going to

happen with the money? I mean, if you do this for ten years, you will be solvent at that point, so

what are the plans beyond that? Are there any?"

54. Another objector expressed concern for the children in the area.

55. In opposition to the application, an objector stated that it was not a family,

therefore it doesn't happen.

56. The next door neighbor to SOSH also opposed the application. She characterized

the SOSH as a "revolving door of potential residents who didn't make the cut."


57. Another neighbor stated that she was concerned about the safety of her children,

and that her property would be devalued. She also stated that there was not a need for a sober

house in North Wales, and that other communities such as Lansdale had such a need.

58. Counsel for the Board took the position that the SOSH residents were disabled.

59. Mr. Bartelt specifically told the Board that he and SOSH were seeking a

reasonable accommodation by treating the residents of SOSH as a family under the Borough's

zoning code.

60 The Board denied the Plaintiffs' special use permit application.

61. In denying the application, the Board failed to address the Plaintiffs' reasonable

accommodation request.

62. One of the bases for denying the special use permit application was a finding by

the Board that the Plaintiffs did not have adequate off street parking. This finding was made

notwithstanding Mr. Bartelt's agreement to limit the number of cars for residence to two.

63. The Board did not credit Mr. Bartelt's testimony that the household would be

operated on a non-profit basis.

64 The Board made the following findings in denying the special use permit:

A. The tenants' stay at the Property is transient in nature.

B. That the Applicant did not meet its burden to prove that it complies with all of the

specific and objective criteria set forth in A (4) of the definition of Family,

including that the Applicant has adequate off-street parking facilities.


C. That the Applicant did not meet its burden to prove that it complies with all of the

specific and objective criteria set forth inA(4) of the definition of Family,

including that the Applicant is operating as a single nonprofit housekeeping, unit.

D. That the Applicant did not meet its burden to prove that it complies with all of the

specific and objective criteria set forth in A( 4) of the definition of Family,

including that the Applicant is operating as a non-transient housekeeping unit.

E. That the Applicant has not met its burden of proof as required by Section 208-191

of the Zoning Ordinance that the allowance of the special exception will be

contrary to the public interest.

64. The Board also credited the objections and testimony of the neighbors and

objectors by finding the following:

A. That the proposed use was not compatible with the residential neighborhood.

B. That the Neighbor Parties opposed to the Applicant met their duty and burden to

prove that the proposed use will be injurious to the public health, safety and

welfare.

C. That the proposed use will be detrimental and/or injurious to the adjacent property

and the neighborhood and will cause undue congestion of vehicular traffic.

66. Neither of the Defendants have a policy or procedure for processing requests for

reasonable accommodation requests in the application of the Borough's zoning code.

67. On or about January 26, 2016, the Borough's zoning officer issued a cease desist

order to Mr. Bartelt which advised him that he cannot have more than three residents. He was

given 30 days to come into compliance or face daily fines of $500 per day.


68. The effect of Defendant's actions has been to prevent the Plaintiffs from residing

at the dwelling of their choice or in any other home zoned for single family use in the Borough

of North Wales.

69. Plaintiffs are aggrieved persons as they are disabled persons or associated with

disabled persons under the Fair Housing Amendments act of 1988, 42 U.S.C. Section 3602(d)

and (I) who have been injured by Defendant's discriminatory conduct and have suffered

damages, economic loss and a loss of civil rights as a result of the Defendant's conduct.

70. 509 East Montgomery Avenue is a dwelling within the meaning of section 802(b)

of the Fair Housing Act, 42 U.S.C. Section 3602(b).

71. The effect of Defendants actions is to deny needed housing opportunities to

recovering alcoholics and substance abusers within the Borough of North Wales.

72. The effect of the conduct of the Defendants is to limit the housing opportunities of

unrelated disabled persons by denying them the right to live together as a group in any residential

zoning district in within the Borough of North Wales.

73. The Defendants are treating the residents of the aforementioned dwelling in a

discriminatory fashion, and are utilizing its police and zoning powers on this group of unrelated

disabled individuals living together as a common household differently than it imposes upon

individuals living together who are related by blood or marriage or other groups of unrelated

disabled persons.

74. By arbitrarily and illegally describing the activities at 509 East Montgomery

Avenue as a an illegal occupation of a single family dwelling, the Defendants are making single

family housing unavailable to persons recovering from drug and alcohol addiction.


75. The defendants have acted under color of state law in failing to affirmatively

further fair housing in its code enforcement activities with the purpose and effect of

discriminating against Plaintiffs because of their handicap, and applying those codes so as to

deny Plaintiffs the residential opportunities available to persons related by blood, marriage or

adoption, or other groups of similarly situated unrelated disabled persons.

76 Plaintiffs have been denied the opportunity to provide housing for recovering

alcoholics and substance abusers and as a result have suffered economic damages, and other

irreparable harm as a result of Defendant's actions. They have no adequate remedy at law.

77. Plaintiffs are living in fear of losing their home and are suffering anxiety,

emotional distress, pain, setbacks in their efforts at recovery, and other irreparable harm as a

result of Defendant's actions. They have no adequate remedy at law.

78. The Defendants have utilized its police powers to threaten, intimidate, harass and

coerce the Plaintiffs after they have exercised their rights under the Federal Fair Housing Act.

79. The Defendants are intentionally and maliciously harassing, intimidating and

interfering with the plaintiffs and persons associated with the plaintiffs with the intent of

preventing SOSH from existing in a single family neighborhood.

JURY DEMAND

Plaintiffs hereby demand a trial by jury.


above.

V. CLAIMS FOR RELIEF

COUNT I FAIR HOUSING ACT

(Both defendants)

80. Plaintiffs re-allege and incorporate herein by reference paragraphs 1 through 79

81. Defendant, the Borough of North Wales and the Zoning Hearing Board are

violating Plaintiffs' rights under the Fair Housing Act, 42 U.S.C. Sections 3601, et. seq., and its

implementing regulations by:

a. denying and otherwise making housing unavailable to the Plaintiffs because of

their disability;

b. using its police powers as a pretext to exclude the Plaintiffs because of their

disability;

c. interfering with the right of the Plaintiffs to live in the dwelling of their choice;

d. enforcing an ordinance that has the effect of denying housing to persons m

recovery from alcoholism and substance abuse.

e. discriminating in the terms, conditions, or privileges of sale or rental of a

dwelling, or in the provision of services or facilities in connection with such dwelling, because of

the status of the SOSH residents as recovering alcoholics and substance abusers; and,

f. retaliating against Plaintiffs because of their exercise of their fair housing rights.

g. making, printing or publishing, or causing to be made, printed or published a

statement in connection with the sale or rental of housing that indicates a limitation, preference

or discrimination on the basis of disability.


above.

COUNT II AMERICANS WITH DISABILITIES ACT

(Both Defendants

82. Plaintiffs re-allege and incorporate herein by reference paragraphs 1 through 81

83. The Plaintiffs, SOSH Recovery Residence, Inc. and Matthew Bartelt are

associated with, and/or providing housing to people with disabilities as defined in 42 U.S.C.

12102(2).

84. The Defendants, the Borough of North Wales and the Zoning Hearing Board are

public entities under 42 U.S.C. 12131(1).

85. The actions of the Defendants, to exclude 509 East Montgomery Avenue from

residential zones violate the rights of the Plaintiffs under the Americans With Disabilities Act, 42

U.S.C. 12132 et. seq., and the regulations promulgated thereunder by:

a. denying the individual residents of the Plaintiffs who are m recovery from

alcoholism and substance abuse the opportunity to participate in or benefit from the supportive

housing program offered by SOSH Recovery Residence, Inc.;

b. using municipal police powers and methods of administering those powers with

the purpose of subjecting the Plaintiffs to discrimination on the basis of their handicap;

c. subjecting the Plaintiffs, on the basis of their disability, to discrimination;

d. denying the individual residents of SOSH Recovery Residence, Inc., an

opportunity to participate in a program in the most integrated setting appropriate to their needs;


e. denying the individual Plaintiffs and residents of SOSH Recovery Residence, Inc,

who are people with disabilities, an equal opportunity to participate in or benefit from services

and programs equal to those of people without disabilities;

f. utilizing municipal code enforcement services that are not equal to groups of

related non-disabled persons and groups of unrelated disabled persons who are not recovering

alcoholics and drug addicts.

PRAYER FOR RELIEF AS TO EACH COUNT

WHEREFORE, Plaintiffs requests that the Court:

a. Enter a declaratory judgment that Defendants have illegally discriminated against

the Plaintiffs in violation of the FHA and ADA;

b. Provide injunctive relief restraining the Borough of North Wales from

discriminating against the plaintiffs and the SOSH Residents and interfering with plaintiffs

current operation of the 509 East Montgomery Avenue property as a home for disabled

recovering alcoholics and substance abusers, and/or from interfering in SOSH Residents' rights

to reside in the Montgomery Avenue property.;

c. Enter a declaratory judgment stating that SOSH's use of the 509 East

Montgomery Avenue is consistent with classification of the premises as a single-family home

and require the Borough of North Wales to apply all zoning, safety, building, and land use codes

to SOSH's use of 509 East Montgomery Avenue in the same manner as it does to all other single-

family homes or multi family homes;

d. Award the plaintiffs any available damages under the FHA and ADA;

e. Grant an award of reasonable costs and attorneys fees; and,


f. Order other such other relief as the Court deems just and proper.

Respectfully submitted,

3406 Goshen Road Newtown Square, PA 19073 [email protected]

Telephone: 610-213-6303 Facsimile: 609.926.9721

STEVEN G. POLIN 3034 Tennyson Street, NW Washington, D.C. 20015 [email protected]

Telephone: 202.331.5848 Facsimile: 202.537.2986 (pro hac vice application pending)

COUNSEL FOR PLAINTIFFS


sunlight of spirit house complaint

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