[PROPOSED] JUDGMENT PURSUANT TO SETTLEMENT AGREEMENT BY AND BETWEEN CRA/LA, A DESIGNATED LOCAL AUTHORITY, SUCCESSOR AGENCY TO THE COMMUNITY REDEVELOPMENT AGENCY OF THE CITY OF LOS ANGELES, AND

FERNANDO M. OLGUIN, District Judge.

WHEREAS, the CRA/LA, a Designated Local Authority, a defendant in this action and the successor agency to the Community Redevelopment Agency of the City of Los Angeles (the "CRA"), and the Independent Living Center of Southern California ("ILCSC"), the Fair Housing Council of the San Fernando Valley ("FHC") and Communities Actively Living Independent and Free ("CALIF") (collectively referred to herein as "Plaintiffs") have entered into a Settlement Agreement and Release of Claims, attached as Exhibit A, which fully resolves claims asserted by Plaintiffs against the CRA; and

WHEREAS, the Court has jurisdiction over the subject matter of this action, the Plaintiffs, the CRA, and the Settlement Agreement; and

WHEREAS, upon consideration, the Court finds the Settlement Agreement to be fair, reasonable, and adequate.

NOW, THEREFORE, IT IS HEREBY ORDERED, ADJUDGED AND DECREED AS FOLLOWS:

1. For the purposes of this Judgment, the Court adopts the terms and definitions set forth in the Settlement Agreement attached as Exhibit A, and all terms of the Settlement Agreement are incorporated herein by reference.

2. This Judgment Pursuant to Settlement completely resolves this civil action between the CRA and Plaintiffs. The claims against the City of Los Angeles were previously resolved by Judgment Pursuant to Settlement Agreement by and between City of Los Angeles and Plaintiffs (Doc. 532, filed August 4, 2016). This does not resolve this action between Plaintiffs and the remaining nominal defendants.

3. In accordance with the terms of the Settlement Agreement, this Court reserves exclusive and continuing jurisdiction to interpret and enforce the terms of the Settlement Agreement during the Settlement Term, and to resolve any disputes that may arise during the Settlement Term.

4. The court determines that there is no reason to delay entry of this Judgment Pursuant to Settlement Agreement By and Between the CRA and Plaintiffs.

IT IS SO ORDERED and ADJUDGED

Exhibit A

Settlement Agreement and Release of Claims

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA (WESTERN DIVISION)

TABLE OF CONTENTS

SETTLEMENT AGREEMENT AND RELEASE OF CLAIMS 1

SETTLEMENT AGREEMENT AND RELEASE OF CLATMS

This Settlement Agreement and Release of Claims (the "Agreement") is entered into between the Defendant CRA/LA, A Designated Local Authority ("CRA/LA") successor to The Community Redevelopment Agency of the City of Los Angeles (the "CRA"), and Independent Living Center of Southern California ("ILCSC"), Fair Housing Council of San Fernando Valley ("FHC"), and Communities Actively Living Independent and Free ("CALIF") (ILCSC, FHC and CALIF are collectively referred to herein as "Plaintiffs"). The CRA/LA, the CRA, and the Plaintiffs arc referred to herein collectively as "the Parties."

I. RECITALS

This Agreement is made and entered into with reference to the following facts:

1. Commencement of Litigation. Plaintiffs commenced litigation against the City of Los Angeles ("City") and the ("CRA"), The case is known as Independent Living Center of Southern California, et al. v. CRA of Los Angeles, et al., filed on January 13, 2012, in the U.S. District Court for the Central District of California, Case No. 2:12-cv-00551-FMO-PJW (the "Litigation"). Plaintiffs also joined, for Rule 19 purposes, a total of 61 owners of multifamily properties that had been assisted by the City or the CRA ("Owner Defendants").

2. Second Amended Complaint. The CRA was dissolved on February 1, 2012 as a result of the dissolution of redevelopment in California. On August 20, 2012, the Plaintiffs filed a Second Amended Complaint ("SAC"), which remains the operative complaint in this proceeding. The SAC named as an additional defendant CRA/LA, the successor agency to the CRA, to which any pending litigation is automatically transferred pursuant to Calif. Health & Safety Code § 34173(g). For purposes of this Agreement, the Parties hereafter use the term CRA to refer collectively to the fonrier agency and its statutory successor, unless specifically noted.

3. Allegations in SAC. As relevant to this Settlement Agreement, the SAC alleges that the CRA engaged in a pattern or practice of discrimination against people with disabilities—in violation of Section 504 of the Rehabilitation Act of 1973 ("Section 504"), 29 U.S.C. § 794; Title II of the Americans with Disabilities Act ("ADA"), 42 U.S.C. § 12132; and California Government Code Section 11135, et seq. ("Section 11135")—by failing to ensure that multifamily housing funded, developed or significantly assisted by the CRA is accessible and made meaningfully available to people with disabilities.

4. CRA. At all relevant times, the CRA has been a public entity within the meaning of the ADA, a recipient of federal financial assistance within the meaning of Section 504. and a recipient of state financial assistance within the meaning of Section 11135.

5. Motion to Dismiss. On November 29, 2012, the Hon. S. James Otero denied the CRA's motion to dismiss with respect to Plaintiffs' claims under Section 504, the ADA and Section 11135. Dkt. 209.

6. Claims. Plaintiffs sought by this Litigation to ensure that multifamily housing developments in Los Angeles built or rehabilitated at least in part with public funds or in connection with CRA housing programs are made accessible and meaningfully available to people with disabilities. They also sought to ensure that the CRA comply with its own Program Access and other obligations to people with disabilities with respect to the operation of multifamily housing programs as they relate to people with disabilities, in accordance with the requirements of Section 504, the ADA, and Section 11135.

7. City Settlement. Plaintiffs settled their claims with the City, as evidenced by a Judgment Pursuant to Settlement Agreement By and Between the City of Los Angeles and Plaintiffs, having been entered on August 4, 2016, at Dkt. 532 (Judgment) and 530-2 (Settlement Agreement and Release of Claims) (collectively referred to as "City Settlement Agreement"). Most of the Owner Defendants remain parties to the Litigation, and their status is not affected by the City Settlement Agreement or by this Agreement.

8. Motion for Judgment on the Pleadings. By Order of August 31, 2016, the Court denied the CRA's motion for judgment on the pleadings, finding, in part, that the California dissolution statute automatically transferred litigation to the successor agency. Dkt. 535, at 7. The Court also found that, because the CRA's accessibility obligations under Section 11135, and Title II of the ADA and its implementing regulations (which are incorporated into Section 11135 by reference) "were imposed by state law and existed prior to June 28. 2011," they were "enforceable obligations" as that term is defined by dissolution statute. Dkt. 535, at 6, citing to Cal. Health & Safety Code § 34171(d)(1)(C).

9. Program Access Allegations. In the SAC, Plaintiffs claim that the CRA failed to comply with the architectural and Program Access obligations imposed by the federal government—pursuant to Section 504 and the ADA and their implementing regulations—and by the State of California, pursuant to Section 11135.

10. CRA's Housing Program. Those claims arise out of the CRA's conduct in operating its housing program under the Redevelopment Statutes and its provision of financial and other assistance, between July 1, 1988 and June 28, 2011, to the properties identified in Exhibit A and Exhibit B.

11. Judicial Findings. The Court found that the legal liabilities arising under those statutes were not part of the "rights, powers, duties and housing assets" transferred to the City under Calif. Health & Safety Code Sees. 34176(a)(1) and (e). See Dkt. 535, at 7.

12. Federally Assisted Buildings. Plaintiffs' federal law claims also specifically address multifamily apartment buildings that received direct Federal financial assistance through the CRA after July 11, 1988, and/or (2) were designed, constructed, altered, operated, administered, or financed, in whole or in part, in connection with a program administered in whole or in part by the CRA since January 26, 1992.

13. Cooperation Agreements. Between 1995 and 2010, the CRA entered into agreements with the City, pursuant to which the City subsequently loaned or provided to the CRA certain federal funds from the U.S. Department of Housing and Urban Development ("HUD") granted or loaned to the City to support the development of affordable housing units in 22 specified Housing Developments. Those agreements between the City and the CRA clearly spelled out that the City was drawing upon federal funds as the source to fund the activities under the agreements and imposed upon the CRA specific development obligations, imposed by HUD grants or loans to ensure that each and every such Housing Development complied with federal Accessibility Standards pursuant to Section 504 and the ADA. Exhibit B is a list of the 22 Housing Developments governed by the agreements, all of which were entered into prior to June 28, 2011.

14. Resolution of Claims. The Parties now wish to effect a complete resolution and settlement of the claims, disputes, and controversies relating to the Plaintiffs' allegations in the Litigation, and to resolve their differences by settling such claims, disputes, and controversies under the terms set forth in this Agreement. Each Party acknowledges that this Agreement affects, among other things, the settlement of claims which are denied and contested by the other, and that nothing contained herein shall be construed as an admission of liability or wrongdoing by or on behalf of any Party, all of which liability is expressly denied.

15. Release of Claims. The Parties intend this Agreement to bind and apply to the CRA and Plaintiffs. Entry of Judgment pursuant to this Agreement shall extinguish all Released Claims (as defined below under Section VI) and constitute final and complete resolution of all issues addressed herein.

16. Settlement Goals. The goal of the Agreement is to significantly enhance the accessibility of multifamily housing in Los Angeles, the availability of fair, affordable and accessible housing for individuals with a variety of disabilities, including mobility, visual and hearing disabilities, and the accessibility of the CRA's housing programs, and to ensure compliance with the CRA's obligations under Section 504, the ADA, and Section 11135.

17. Authorization. In resolving this matter, the CRA represents that it is acting in accordance with the direction of the Governing Board for the CRA/LA pursuant to Calif. Health & Safety Code Section 34177(c) as part of its duty to meet its Enforceable Obligations during the winding-down of the CRA's business.

II. DEFINITIONS

1. Accessible. "Accessible," when used with respect to a Housing Unit or a Housing Development, means and refers to full compliance with the requirements of the Accessibility Standards for purposes of Section 504, the ADA, and Section 11135.

2. Accessible Housing Development. "Accessible Housing Development" means a Housing Development that is Accessible, including Accessible public and common use areas, as required by Section 504 and the ADA, as well as the number and type of Accessible Housing Units that are required to be Accessible by this Agreement.

3. Accessible Housing Units. "Accessible Housing Units" refers collectively to Housing Units with Mobility Features and Housing Units with Hearing/Vision Features.

4. Accessibility Laws. "Accessibility Laws" means Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. §794 et seq,; the Americans with Disabilities Act, 42 U.S.C. §12131 et seq.; California Government Code Section 11135 et seq.; implementing regulations and design standards for each of the preceding statutes; and the California Building Code.

5. Accessibility Standards. For purposes of this Agreement, "Accessibility Standards" means only the following compliance standards:

6. Alternative Accessibility Standard. "Alternative Accessibility Standard'" means and refers to the alternative accessibility standard for new construction set out in HUD's notice at 79 Fed. Reg. 29,671 (May 23, 2014), when used in conjunction with the new construction requirements of 24 C.F.R. pt. 8, 24 C.F.R. § 8.22, and the new construction requirements of 28 C.F.R. pt. 35, including the 2010 Standards for Accessible Design as defined in 28 C.F.R. § 35.104 and as applied to public entities (excluding any elevator exceptions).

7. Auxiliary Aids. "Auxiliary Aids" means and refers to aids, services, or devices that enable persons with vision, hearing, manual, or speech impairments to have an equal opportunity to participate in, or enjoy the benefits of, programs, services, or activities, including housing and other programs, services, and activities subject to the requirements of Section 504 of the Rehabilitation Act and/or the Americans with Disabilities Act. Auxiliary aids include but are not limited to the aids, services, and devices set out in the definition of auxiliary aids auxiliary aids in 24 C.F.R. § 8.3 and the definition of auxiliary aids and services in 28 C.F.R. § 35.104. See also 42 U.S.C. § 12103(1).

8. Certification of Compliance with Accessibility Standards. "Certification of Compliance with Accessibility Standards" means and refers to a Certification issued by the CRA, certifying that the Housing Development and accessible Housing Units meet the Accessibility Standards. Said Certification of Compliance with Accessibility Standards shall be substantially in die form of the attached Exhibit E, as may be modified from time to time by written agreement among the parties.

9. CRA Insurers. "CRA insurers" means and refers to AIG and National Union and all of their executors, assigns and successors, as well as their administrators, agents and representatives acting in their official capacities.

10. Department of Finance. "Department of Finance" means and refers to the State of California Department of Finance.

11. Effective Date. "Effective Date" means and refers to the effective date of this Agreement, which is the date of the latest signature on this Agreement by any of the Parties.

12. Governing Board. "Governing Board" means and refers to the board created by the Governor of California pursuant to Health and Safety Code section 34173(d)(3)(A) to serve as the governing board of CRA/LA.

13. Housing Development or Development. "Housing Development" or "Development" means and refers to the whole of one or more residential structures and appurtenant structures, equipment, roads, walks, and parking lots that (1) received or will receive any Federal financial assistance from or through the CRA and/or (2) were or are designed, constructed, altered, operated, administered, or financed in connection with a program administered by the CRA.

14. Housing Policies. "Housing Policies" means housing management policies adopted pursuant to this Agreement to ensure nondiscrimination, disability preferences, and other legally required practices related to people with disabilities, including any of the Housing Policies adopted as part of the City Settlement Agreement.

15. Housing Unit or Unit. "Housing Unit" or "Unit" means and refers to a single unit of residence that provides spaces for living, bathing, and sleeping, provided such definition shall not be construed to exclude Single Room Occupancy Units. A Housing Unit or Unit is the same as a dwelling unit.

16. Housing Unit with Hearing/Vision Features. "Housing Unit with Hearing/Vision Features" means and refers to a Housing Unit that complies with 24 C.F.R. § 8.22 and all applicable provisions of UFAS or the comparable provisions of the Alternative Accessibility Standard, and shall include but not be limited to section 809.5 of the 2010 Standards for Accessible Design. Hearing/Vis ion Features include but are not limited to visual alarms (UFAS §§ 4.34.10, 4.28.3), auxiliary alarms (UFAS §§ 4.34.10. 4.28.4), telephone volume controls and hearing aid compatibility (UFAS § 4.31.5), protections against protruding objects (UFAS § 4.4), stairway requirements (UFAS §§ 4.9, 4.26.4), protections against exposed pipes and surfaces (UFAS §§ 4.19.4, 4.24.6, 4.34.6.5(8)), audible alarms (UFAS § 4.28.2), signage (UFAS § 4.30), push button controls for telephones (UFAS § 4.31.6), consumer information (UFAS § 4.34.4), and range, cooktop, and oven controls (UFAS §§ 4.34.6.6,4.34.6.7).

17. Housing Unit with Mobility Features. "Housing Unit with Mobility Features" means and refers to a Housing Unit that is located on an accessible route and complies with the requirements of 24 C.F.R. § 8.22 and all applicable provisions of UFAS or the comparable provisions of the Alternative Accessibility Standard including but not limited to sections 809.2 through 809.4 of the 2010 Standards for Accessible Design. A Housing Unit with Mobility Features can be approached, entered, and used by persons with mobility disabilities, including individuals who use wheelchairs.

18. Judgment. "Judgment" means a judgment entered by the District Court in this Litigation, substantially in the form attached to this Agreement as Exhibit D that, among other things, fully approves and incorporates the terms of this Agreement and retains the District Court's jurisdiction to enforce the Agreement throughout the Settlement Term.

19. Operative Date. "Operative Date" means January 2, 2018.

20. Owner. "Owner" means and refers to an owner of a Housing Development listed in Exhibit A or Exhibit B (and such owner's successors and assigns) that (1) received any Federal financial assistance from the CRA after July 11, 1988, (2) was, is, or will be the Owner of a such a Housing Development designed, constructed, altered, operated, administered, or financed, in whole or in part, in connection with a program administered in whole or in part by the CRA since January 26, 1992, and/or (3) is an Owner of a unit remediated, constructed, or otherwise made accessible pursuant to this Agreement.

21. Oversight Board. "Oversight Board" means the Oversight Board established pursuant to California Health & Safety Code §§ 34179, etseq., to approve and/or direct specified activities of the CRA.

22. Person with a Disability. "Person with a Disability" means and refers to a person who has a physical or mental impairment that substantially limits one or more major life activities such as caring for oneself, manual tasks, walking, seeing, hearing, speaking, breathing, or learning; has a record of such impairment; or is regarded as having such an impairment. See 24 C.F.R. § 8.3, as modified by the ADA Amendments Act of 2008, Pub. L. 110-325, §7(2), 122 Slat. 3558 (September 25,2008), amending 29 U.S.C. §705(20). This definition includes people with disabilities as defined in Cal. Gov. Code Sec. 12926 to the extent that provision is more inclusive than federal law.

23. Program Access. "Program Access" means applicable Accessibility Laws directing a public entity to operate each service, program, or activity so that the service, program, or activity, when viewed in its entirety, is readily accessible to and usable by Persons with Disabilities.

24. Reasonable Accommodation. "Reasonable Accommodation" means a change in rules, policies, practices, or procedures that is necessary, pursuant to the Fair Housing Act, to provide a person with a disability an equal opportunity to use and enjoy a Housing Unit.

25. Reasonable Modification. "Reasonable Modification" means a change in rules, policies, practices, or procedures that is necessary, pursuant to Section 504 or the ADA, to provide a person with a disability an equal opportunity to use and enjoy a Housing Unit. Pursuant to the Fair Housing Act, "Reasonable Modification" means any reasonable physical or strucmral change to a Housing Unit or a public or common use area.

26. Recognized Obligation Payment Schedule or ROPS. "Recognized Obligation Payment Schedule" or "ROPS" means a Recognized Obligation Payment Schedule prepared by the CRA under Calif. Health & Safety Code Section § 34177.

27. Settlement Coordinator or Section 504/A DA Coordinator for Accessible Housing. "Settlement Coordinator" or "Section 504/ADA Coordinator for Accessible Housing" means the individual designated by the CRA pursuant to and in accordance with Paragraph III, 18, below,

28. Substantial Rehabilitation. "Substantial Rehabilitation" has the same meaning as in 24 C.F.R, § 8.23.

29. Target Number of Accessible Units. "Target Number of Accessible Units" means the Two Hundred Fifty (250) apartment units the CRA will cause to be Accessible to meet its obligations under this Agreement and federal and state law within three (3) years of the Operative Date.

30. Uniform Federal Accessibility Standards or UFAS. "Uniform Federal Accessibility Standards" or "UFAS" means and refers to a set of scoping requirements and standards for the design and construction of buildings and facilities to ensure that they are readily accessible to and usable by persons with disabilities. See Appendix A to 24 C.F.R. subpart 40 for residential structures and Appendix A to 41 C.F.R. subpart 101-19.6 for general-type. Pursuant to 24 C.F.R. § 8.32(a), effective July 11,1988, the design, construction, or alteration of buildings in conformance with sections 3-8 of UFAS shall be deemed to comply, inter alia, with the requirements of 24 C.F.R. § 8.22.

III. SCOPE AND TERMS OF THE AGREEMENT

NOW, THEREFORE, for good and valuable consideration, the sufficiency and receipt of which is hereby acknowledged, the Parties stipulate, and intend that the District Court will make the following findings as part of the Final Judgment:

1. Recitals. The recitals set forth above are incoiporatcd by reference in this Section and made a part of this Agreement.

2. Jurisdiction. The Court has personal jurisdiction over Plaintiffs and the CRA for purposes of this Litigation and jurisdiction over this Litigation pursuant to 28 U.S.C. §§ 1331 and 1367, and 28 U.S.C. §§ 2201 and 2202. Relief may be granted pursuant to 29 U.S.C. § 794a and 42 U.S.C. § 12132 et seq. Venue is proper in this District.

3. Binding Effect. The provisions of this Agreement shall be binding upon the Parties, and shall become effective on the Effective Date.

4. Purpose of Settlement. To avoid the cost, expense, and uncertainty of protracted litigation, the CRA and Plaintiffs enter into this Agreement, which shall be binding upon the CRA and Plaintiffs and extinguish all Released Claims and shall constitute the final and compete resolution of all issues addressed herein. Pursuant to the terms of this Agreement, the CRA will undertake the actions described below for the purpose of ensuring that CRA-assisted housing programs, services, and activities are in compliance with the accessibility requirements of Section 504, the ADA, and Section 11135.

5. Approval by the District Court. The Parties intend that this Agreement be approved by the District Court, and that the District Court retain jurisdiction for the Term of this Agreement to resolve any dispute regarding compliance with the Agreement that cannot be resolved through the process described in Section VII, below, Furthermore, upon such approval, the District Court shall enter the Judgment under Rule 54(b) of the Federal Rules of Civil Procedure (substantially in the form attached to this Agreement as Exhibit D.)

6. Term of Agreement. The District Court shall have continuing jurisdiction over this Agreement throughout the Settlement Term. This Agreement shall expire when the parties submit a stipulation to the Court acknowledging that CRA has achieved the Target Number of Accessible Units and the Accessibility Covenants required by Section III. 14.(f) and (g) of this Agreement have been recorded on each such unit, or at such other date as the Court shall determine. CRA shall undertake good faith efforts to reach the Target Number of Accessible Units within three (3) years of the Operative Date. Nothing in this Paragraph shall bar any Party from moving for an extension of the Agreement to enforce any obligations herein.

7. CRAs Commitment to Provide Affordable, Accessible Housing.

The CRA shall take the actions set forth in this Agreement to provide accessibility for persons with disabilities in its housing-related programs. Among other things, the CRA shall expend such funds as may be necessary over the Settlement Term to ensure the production of the Target Number of Accessible Units by means of inspecting existing Housing Developments to determine compliance with this Agreement, and taking all other actions necessary to provide for Two Hundred Fifty (250) Accessible Housing Units in Accessible Housing Developments as required by this Agreement by no later than three (3) years after the Operative Date. The failure of the CRA to secure the cooperation of any Owner with efforts to remedy noncompliance with requirements set out in this Agreement shall not excuse the CRA's obligation to achieve the Target Number of Accessible Units but shall not constitute a breach of this Agreement as long as CRA is acting in good faith to achieve the Target Number of Accessible Units. The CRA shall notify the Plaintiffs, within a reasonable timeframe, of non-cooperation by an Owner.

8. Housing Accessibility Fund. The CRA shall establish a Housing Accessibility Fund to be paid for with funds from the Redevelopment Property Tax Trust Fund or other funds available to the CRA/LA in the following amounts:

9. Implementation Costs. In addition to the funds deposited in the Accessible Housing Fund, the CRA shall be responsible for all costs of implementation of this Agreement, including costs of experts, consultants, necessary temporary relocation costs for tenants needed to move during remediation of units, and other expenses.

10. Placement on ROPS. The parties believe that the obligations herein constitute enforceable obligations within the meaning of Cal. Health & Safety Code § 34171 et seq. On June 1, 2017, the Governing Board authorized CRA's Chief Executive Officer and counsel to execute this Settlement Agreement. In order to further comply with the provisions of Paragraph III.7, above, the CRA shall undertake the following:

11. Other Actions. The CRA shall also take the actions set forth in this Agreement and such other actions as may be necessary to ensure that the CRA complies with its obligations under this Agreement, including its obligations with respect to Owner compliance with Housing Policies, to ensure that assisted I lousing Developments operate in accordance with Federal and California law.

12. CRA's Compliance. The CRA shall comply with the requirements of Section 504, the ADA, Section 11135, and other applicable nondiscrimination laws with respect to all aspects of its own housing-related programs, services, and activities, including administration and financing.

13. Reporting of Activities to Ensure Compliance. Pursuant to its reporting obligations set out in Paragraph III. 15, below, and elsewhere in this Agreement, the CRA shall report on the actions it takes to ensure its own compliance and to require and ensure Owners' compliance with Section 504, the ADA. Section 11135. and the terms of this Agreement.

14. Specific Commitments to Achieving Accessibility This Agreement provides for the following:

15. Reporting Requirements. The Settlement Coordinator shall prepare twice-yearly reports containing qualitative and quantitative data detailing the activities carried out under this Agreement for the preceding reporting period pursuant to Paragraphs III. 16 and III. 17., below, to be provided to Plaintiffs' Counsel (as provided for in ¶ X.4., below) and the Monitor on or before June 30 and December 31 of each year beginning December 31, 2018.

16. Report Contents. Reports referenced in Paragraph III. 15, above, shall include, at a minimum, a detailed description of the following:

17. Quantitative Data. Quantitative data referenced in Paragraphs III. 15 and III.16., above, shall include the number of properties inspected; numbers/types of units under construction; number/types of Accessible Units completed; number and addresses of properties with recorded Accessibility Covenants; number/types of Accessible Units occupied by persons with disabilities who need the accessibility features; and number/types of Accessible Units occupied by persons who do not need the accessibility features. The report shall be submitted to the Monitor pursuant to Paragraph III.15, above.

18. Appointment of Settlement Coordinator ("Settlement Coordinator" or "Coordinator"). Within 90 days of the Operative Date, the CRA shall appoint a Settlement Coordinator and provide the individual's name and contact information to Plaintiffs' Counsel and the Monitor. The individual initially appointed as Settlement Coordinator may be replaced with another individual with notice to Plaintiffs. A Settlement Coordinator will coordinate effective implementation of this Agreement, shall be retained throughout the term of this Agreement, and shall be directed and compensated by the CRA, The Settlement Coordinator will report directly to the Chief Executive Officer of the CRA concerning matters relating to this Agreement. The CRA shall commit sufficient resources, authority, and independence so that the Settlement Coordinator can successfully accomplish his or her responsibilities under this Agreement.

19. Responsibilities and Authority of the Settlement Coordinator.

20. Plaintiffs' Rights With Respect to Testing. Nothing in this Agreement shall be construed to diminish Plaintiffs' rights to conduct tests and monitoring to determine that Owners of Housing Developments are complying with federal and state law.

IV. MONITORING

1. Court Appointment of Monitor. Within thirty (30) days of Operative Date, the Parties will ask the District Court to appoint a Monitor to ensure that this Agreement is implemented effectively and to assist the Court in monitoring the CRA's compliance with this Agreement. The Parties shall jointly propose to the District Court one or more candidates to serve as a court-appointed Monitor. The Monitor will assess the CRA's progress toward achieving the Target Number of Accessible Units and implementation of policies and procedures by reviewing plans, policies, procedures, expenditures, staffing, and production of accessible units, among other things. The Monitor shall serve throughout the Settlement Term and shall report to the Court. For the purposes of this Settlement Agreement, the Monitor's authority shall derive from the Court, not the Parties.

V. RECORD KEEPING AND REPORTING

1. Record Keeping and Reporting.

2. CRA's Duty to Retain Documents. The CRA shall maintain all documents and records provided to the Monitor as well as all documents and records maintained and/or generated by the CRA that pertain to the Agreement for a period of five (5) years. For a period not to exceed six (6) months beyond the expiration of this Agreement, Plaintiffs' Counsel shall, upon request, be provided access to any of the records described in the Record-Keeping provisions of this Agreement.

VI. MUTUAL RELEASE OF CLAIMS

1. General Release of CRA Insurers. Upon payment of the Settlement Sum and Attorney's Fees Payments to be paid by CRA's Insurer as set forth below under Section VIII(1) and (2), Plaintiffs, for themselves (and for their executors, assigns, and successors, as well as their administrators, agents and representatives acting in their official capacities on behalf of the Plaintiff Releasing Parties, do hereby fully and finally remise, release, acquit, and forever discharge any and all CRA Insurers and their respective successors, directors, officers, employees, agents, past, present and future departments, boards, commissions, predecessors, and successors-in-interest, from any and all claims and demands of any and every kind, name, nature, or description, and from any rights, disputes, complaints, charges, actions and causes of action, including, without limitation, a cause of action under California Insurance Code Section 11580, suits, debts, injuries, reimbursements, contracts, covenants, liens, liabilities, losses, costs, expenses, obligations, and damages of any nature, kind, and description, whether asserted or unasserted, known or unknown, anticipated or unanticipated, suspected or unsuspected, or actual or contingent, in law or in equity, which the Plaintiff Releasing Parties, did have, now have, or may have in the future, against the CRA Insurers, whether or not the same be now existent or known to the Plaintiff Releasing Parties by reason of or arising out of the claims as more particularly alleged in this Litigation and arising up until the date of Judgment, including but not limited to any claim or cause of action, including but not limited to injunctive, declaratory, or other non-monetary relief, however described, that the Plaintiff Releasing Parries asserted or could have asserted in this Litigation against the Defendant Released Entities, pertaining to accessibility under Section 504, the ADA, and Section 11135, and availability to people with disabilities of any and all of the multifamily housing funded, developed, or significantly assisted by the CRA at any time prior to this Agreement ("Released Claims"). Such Released Claims shall include any claims to enforce the terms of this Agreement, except for provisions in VIII. I. and VIII.2., below, requiring CRA Insurers to make certain payments.

2. Plaintiffs' Release of Claims Against the CRA Defendants Plaintiffs, for and in consideration of this Agreement, including any and all recitals, promises, covenants, and terms herein, for themselves (and for their executors, assigns, and successors, as well as their administrators, agents, and representatives acting in their official capacities on behalf of Plaintiffs) (collectively "Plaintiff Releasing Parties"), do hereby fully and finally remise, release, acquit, and forever discharge the CRA and, in their official capacities, its respective successors, directors, officers, employees, agents, its past, present and future departments, boards, commissions, predecessors, and successors-in-interest, and Governing Board (collectively "Defendant Released Entities" from any and all claims and demands of any and every kind, name, nature, or description, and from any rights, disputes, complaints, charges, actions and causes of action, suits, debts, injuries, reimbursements, contracts, covenants, liens, liabilities, losses, costs, expenses, obligations, and damages of any nature, kind, and description, whether asserted or unasserted, known or unknown, anticipated or unanticipated, suspected or unsuspected, or actual or contingent, in law or in equity, which the Plaintiff Releasing Parties now have against the Defendant Released Entities or any of the Defendant Released Entities, whether or not the same be now existent or known to the Plaintiff Releasing Parties, by reason of or arising out of the claims as more particularly alleged in this Litigation and arising up until the date of Judgment, including but not limited to any claim or cause of action, including but not limited to injunctive, declaratory, or other non-monetary relief, however described, that the Plaintiff Releasing Parties asserted or could have asserted in this Litigation against the Defendant Released Entities, pertaining to accessibility under Section 504, the ADA, and Section 11135, and availability to people with disabilities of any and all of the multifamily housing funded, developed, or significantly assisted by the CRA at any time prior to this Agreement ("Released Claims"). Such Released Claims, however, shall not include any claims to enforce the terms of this Agreement. Such Released Claims also shall not include claims set forth in the case captioned United States of America, ex rel. Ling, et al. v. City of Los Angeles, et al., Case No. 2:11-00974-PSG-(JCx). This Agreement does not extinguish or affect the rights of any third party to pursue his or her individual claims against the CRA.

3. Defendant's Release of Claims. The CRA, for itself and its respective successors, directors, officers, employees, agents, their past, present and future departments, boards, commissions, predecessors, and successors-in-interest, (collectively "Defendant Releasing Parties"), for and in consideration of this Agreement including any and all recitals, promises, covenants, and terms herein, does hereby fully and finally remise, release, acquit, and forever discharge Plaintiffs (and their assigns, and successors, as well as their administrators, agents, and representatives acting in their official capacities on behalf of Plaintiffs) (collectively "Plaintiff Released Entities") from any and all claims and demands of any and every kind, name, nature, or description, and from any rights, disputes, complaints, charges, actions and causes of action, suits, debts, injuries, reimbursements, contracts, covenants, liens, liabilities, losses, costs, expenses, obligations, and damages of any nature, kind, and description, whether asserted or unasserted, known or unknown, anticipated or unanticipated, suspected or unsuspected, or actual or contingent, in law or in equity, which the CRA now has against the Plaintiff Released Entities, whether or not the same be now existent or known to the CRA, by reason of or arising out of the claims as more particularly alleged in this Litigation and arising up until the date of Judgment, including but not limited to any claim or cause of action, including but not limited to injunctive, declaratory, or other nonmonetary relief, however described, that the CRA asserted or could have asserted in the Action, pertaining to the accessibility under Section 504, the ADA, and Section 11135, and availability to people with disabilities of any and all of the multifamily housing funded, developed, or significantly assisted by the CRA at any time prior to this Agreement ("Released Claims"). Such Released Claims, however, shall not include any claims to enforce the terms of this Agreement.

VII. DISPUTE RESOLUTION

1. Meet and Confer Obligation. If any Party believes that a dispute exists relating to any violation of or failure to perform any of the provisions of this Settlement Agreement, it shall notify the other Party in writing and describe the alleged violation or failure to perform with particularity. The Parties shall meet and confer within ten (10) business days of receipt of such notice. If they are unable to resolve their differences, they shall resort to mediation as described below.

2. Mediation. If the Parties are unable to resolve a dispute through the meet and confer process described above, the Parties shall mediate the dispute. The Parties shall have fifteen (15) business days to jointly select a mediator. If the Parties are unable to reach agreement on a mediator, each side may submit three (3) names of proposed mediators to the District Court and the District Court shall select the mediator. The mediation shall be conducted within thirty (30) days of the selection of the mediator, in the manner determined by the mediator, and the Parties shall engage in good faith efforts to resolve the dispute through such mediation.

3. Resolution by the District Court. If the Parties are unable to resolve a dispute through the mediation process described above, any Party may make a motion to the District Court to enforce the Agreement in order to resolve the dispute.

VIII. COMPENSATION AND FEES

1. Compensation to Plaintiffs. The CRA/LA, by and through the CRA Insurers, agrees to pay each Plaintiff organization One Million Dollars ($1,000,000), or a total of Three Million Dollars ($3,000,000) (the "Settlement Sum"), to resolve in mil all claims for monetary damages. The Settlement Sum shall be paid within ten (10) business days after the Judgment entered on the Settlement Agreement becomes final and non-appealable. Payment shall be made by wire transfer to Plaintiffs' Counsel, Relman, Dane & Colfax, PLLC, 1225 19th Street N.W., Suite 600, Washington, D.C. 20036-2456, for distribution to Plaintiffs.

2. Attorneys' Fees. The CRA, by and through the CRA Insurers, agrees to pay the undersigned Plaintiffs' counsel a total of Two Million One Hundred Twenty Five Thousand Dollars ($2,125,000) and CRA/LA shall pay directly One Hundred Twenty Five Thousand Dollars ($125,000) to resolve in full all claims for the attorneys fees, costs and expenses attributable to the CRA in the Litigation. Payment shall be made no later than ten (10) business days after the Judgment entered on the Settlement Agreement becomes final and nonappealable. Payment by CRA Insurers shall be made by wire transfer to Plaintiffs' Counsel, Relman, Dane & Colfax, PLLC, 1225 19th Street N.W., Suite 600, Washington, D.C. 20036-2456, for distribution among counsel. Payment by CRA may be made by check.

3. Prospective Monitoring Fees and Costs for Plaintiffs' Counsel. In addition to the fees described in Paragraph VIII.2, the CRA shall pay directly to Plaintiffs' Counsel their reasonable and necessary monitoring fees and expenses during the Settlement Term not to exceed a total amount of Fifty Thousand Dollars ($50,000). Payment shall be made no later than ten (10) business days after the Judgment entered on the Settlement Agreement becomes final and nonappealable. Payment shall be made by check to Plaintiffs' Counsel, Relman, Dane & Colfax, PLLC, 1225 19th Street N.W., Suite 600, Washington, D.C 20036-2456, for distribution among counsel.

IX. COURT'S RETENTION OF JURISDICTION

1. The Parties agree and intend that the Judgment will provide that the District Court shall retain continuing jurisdiction to interpret and enforce the terms of this Agreement during the Settlement Term, and that the Judgment will incorporate the terms of this Settlement Agreement by reference. The Court thereafter shall retain jurisdiction to resolve any disputes that may arise during the Settlement Term. Only the Parties may seek to enforce the terms of the Agreement through the dispute resolution process provided for in Section VII, above. Three (3) months before the end of the Settlement Tenn, the CRA shall prepare a final report to the Monitor and Plaintiffs showing that it has fully complied with the provisions of this Settlement Agreement, and may move the Court for an Order terminating its jurisdiction of this matter as of a date following the Settlement Term, on the basis that all of its obligations under the Settlement Agreement have been fully discharged.

X. MISCELLANEOUS

1. Entire Agreement; Severability. This Agreement constitutes the entire agreement between the CRA and Plaintiffs and supersedes all prior agreements, written or oral. Each provision and term of this Agreement shall be interpreted in such manner as to be valid and enforceable. In the event any provision or term of this Agreement is determined to be or is rendered invalid or unenforceable, all other provisions and terms of this Agreement shall remain unaffected to the extent permitted by law.

2. Modification of Settlement Agreement.

3. Conditions Precedent. The Parties agree that this Settlement Agreement shall be conditioned upon, and shall become operative only upon, the occurrence of each and every one of the following events:

4. Notice to the Parties. All notices required or permitted hereunder shall be in writing and shall be served on the Parties at the addresses set forth below, Any such notices shall be:

5. Opportunity to Consult with Counsel. The Parties represent that prior to signing this Settlement Agreement, they have read it, consulted with counsel of their choice, and each understood its terms and conditions. The Parties hereto accept this Settlement Agreement as their own free and voluntary act, without duress, and intend to be legally bound by it. This Settlement Agreement is made without reliance upon any statements or representations by the Parties or their representatives that are not contained herein.

6. CRA/LA Assignment of Obligations. The Parties agree that the CRA/LA may subcontract with the City of Los Angeles to carry out any of the obligations of the CRA/LA under this Agreement.

7. Settlement Agreement Binding on Successors and Assigns. This Agreement shall be binding on, and enforceable by, the Parties, their employees, and their successors and assigns.

8. Titles. The titles used in this Settlement Agreement are nonsubstantive descriptions included solely for the Parties' ease of reference and shall not be construed to alter the substantive provisions of this Settlement Agreement.

9. Weekends and Holidays. If a reporting day or other deadline under this Agreement falls on a weekend or state or federal holiday, the report or other required action will be due on the first business day after the weekend or holiday.

10. Counterparts and Facsimiles. This Settlement Agreement may be executed in counterparts and facsimiles, all of which when taken together shall constitute a single instrument.

11. Parties Agree to Cooperate. The Parties agree to cooperate in submitting this Settlement Agreement to the Court for execution, and to cooperate and execute additional documents or take other actions necessary to perform their respective obligations under this Settlement Agreement.

12. Construction. This Settlement Agreement is the result of negotiations and joint drafting, undertaken in good faith and in that regard the rule of contractual construction that an ambiguous term shall be construed against the drafter shall not be employed.

13. Signatures. The Parties represent that the Signators on this Agreement are fully authorized by their respective organizations to sign the Agreement on behalf of their organizations.

Agreed to by the Parties, as evidenced by signatures below.

EXHIBITS

Exhibit A

Older Properties Excluded from City Settlement

Exhibit B

Federally-Funded CRA Properties

Exhibit C

ACCESSIBILITY COVENANT AGREEMENT

Between

CRA/LA, A Designated Local Authority, Successor to Community Redevelopment Agency of the City of Los Angeles

and

[OWNER]

relating to

(NAME OF HOUSING DEVELOPMENT)

Dated as of _________

ACCESSIBILITY COVENANT AGREEMENT

THIS ACCESSIBILITY COVENANT AGREEMENT ("Accessibility Covenant Agreement" or "Agreement") is made, entered into and dated as of [DATE] by and between the CRA/LA. A Designated Local Authority ("CRA/LA") and [NAME OF OWNER] ("Owner").

RECITALS

WHEREAS, Owner is the owner of that certain [# OF UNITS]-unit multifamily rental housing project commonly referred to as [NAME OF HOUSING DEVELOPMENT] and located at [ADDRESS AND LEGAL DESCRIPTION] (the "Project"); and

WHEREAS, CRA/LA is providing Financial assistance to [OWNER] in the amount of [AMOUNT OF ASSISTANCE] for purposes of financing costs of any necessary improvements and equipment to bring the Project into compliance with the Accessibility Requirements, as defined below: and

WHEREAS, Owner has agreed to comply with the terms and provisions of this Accessibility Covenant Agreement upon the date this Agreement is recorded in the Official Records of the County of Los .Angeles (the "Effective Date"); and

WHEREAS, the CRA/LA is subject to Federal and stale civil rights laws and regulations, including but not limited to Section 504 of the Rehabilitation Act of 1973, 29 U.S.C §794. and implementing regulations at 24 CF.R. Part 8 (Section 504); Title II of the Americans with Disabilities Act, 42 U.S.C. §§ 12131-12134, and implementing regulations at 28 C.F.R. pt. 35 ("ADA"); and the Fair Housing Act of 1968, as amended, 42 U.S.C. §§ 3601-3620, and implementing regulations at 24 C.F.R. Parts 100, 103, 108, 110, and 121; and Chapter 11A and 11B of the California Building Code; and

WHEREAS, the CRA/LA as a "public entity" within the meaning of Title II regulations, must ensure that its programs, services and activities, comply with the ADA; and

WHEREAS, the CRA/LA has agreed to provide the financial assistance upon the condition that Owner agrees to enter into this Agreement to comply with theAccessibility Requirements.

NOW, THEREFORE, in consideration of the mutual covenants and undertakings set forth herein, and other good and valuable consideration, the receipt and sufficiency of which hereby are acknowledged, the CRA/LA and Owner hereby agree as follows:

Section 1. Definitions.

"Accessibility Requirements' refers to the accessibility requirements that must be followed in the design, construction or alteration of the Project or an individual housing Unit of the Project (including common use elements), based on all the applicable laws and regulations, including: (1) Title II of the Americans with Disabilities Act ("ADA"), 42 U.S.C. §12101, et seq. and the implementing standards ("2010 ADA Standards") al 28 C.F.R. Part 35 and the 2004 ADA Accessibility Guidelines ("ADAAG"); (2) Section 504 of the Rehabilitation Act of 1973 "Section 504"), 29 U.S.C. §794, the implementing regulations at 24 C.F.R. Part 8, as well as the requirements of the Uniform Federal Accessibility Standards ("UFAS"); (3) the Alternative Accessibility Standard; (4) the Fair Housing Act of 1968, as amended ("FHA"), 42 U.S.C. §§3601-3620; and its implementing regulations at 24 C.F.R. Parts 100, 103, 108, 110, and 121, and (5) the California Building Code, Chapters 11A and 11B.

"Accessible" means when used with respect to a Housing Unit or Housing Development, full compliance with the Accessibility Requirements.

"Accessible Housing Development" means a Housing Development that is Accessible, including Accessible public and common use areas.

"Accessible Housing Units" means, collectively, Housing Units that are on an Accessible Route, are Accessible, and are located in an Accessible Housing Development. The term Accessible Housing Units refers collectively to Housing Units with Mobility Features and Housing Units with Hearing/Vision Features.

"Alternative Accessibility Standard" means and refers to the alternative accessibility standard for new construction set out in a U.S. Department of Housing and Urban Development notice at 79 Fed. Reg. 29.671 (May 23, 2014), when used in conjunction with the new construction requirements of 24 C.F.R. pt. 8, 24 C.F.R. § 8.22. and the new construction requirements of 28 C.F.R. pt. 35, including the 2010 Standards for Accessible Design as defined in 28 C.F.R. § 35.104 and as applied to public entities (excluding any elevator exceptions).

"Fair Housing Policy in Regard to Disability" means the document containing the policy of the City of Los Angeles, as amended periodically, that all City- and CRA-assisted affordable housing developments be constructed and operated in accordance with all applicable disability and lair housing laws and under which the Owner is required to create a Property Management Plan ("Property Management Plan" or "PMP") as described in Section 4 that must comply with the requirements and guidance in the Fair Housing Policy in Regard to Disability. The PMP must be consistent with the Property Management Plan template of the City of Los Angeles Housing + Community Investment Department ("HCID") and must be approved by CRA/LA or its designee.

"Housing Development" means the whole of one or more residential structures and appurtenant structures in the Project, including common walkways and parking lots that were or are designed, constructed, altered, operated, administered or financed in whole or in part in connection with the issuance of CRA/LA assistance,

"Housing Unit" means a single unit of residence in the Housing Development that provides spaces for living, bathing, cooking and sleeping.

"Housing Unit with Hearing/Vision Features" means a Housing Unit that complies with 24 C.F.R § 8.22 and all applicable provisions of UFAS or the comparable provisions of the Alternative Accessibility Standard, and shall include but not be limited to section 809.5 of the 2010 Standards for Accessible Design.

"Housing Unit with Mobility Features" means a Housing Unit that is located on an accessible route and complies with the requirements of 24 C.F.R. § 8.22 and all applicable provisions of UFAS or the comparable provisions of the Alternative Accessibility Standard including but not limited to sections 809.2 through 809.4 of the 2010 Standards for Accessible Design.

"UFAS" means the Uniform Federal Accessibility Standards for the design, construction or alteration of buildings and facilities to ensure that they are readily accessible to and usable by individuals with disabilities, 24 C.F.R §40, Appendix A

Section 2. Requirements of the CRA/LA. As of the Effective Date, the Owner represents, warrants, covenants and agrees as follows:

Section 3. Occupancy of Accessible Units. Owner shall use suitable means to assure that information regarding the availability of Accessible Units reaches eligible individuals with disabilities, and will take reasonable, nondiscriminatory steps to maximize the utilization of such units by eligible individuals whose disability requires the accessibility features of the particular unit. To this end. Owner will take the following steps when an Accessible Unit becomes vacant:

Section 4. Rental Policies. The Owner shall adopt rental policies that meet the requirements of die ADA, other federal regulations as applicable, and the Fair Housing Policy in Regard to Disability of the City, as amended. A copy of the Policy is available from CRA/LA upon request. To that end, Owner shall adopt rental occupancy policies provided by the CRA/LA. Owner shall develop and utilize a PMP approved by the CRA/LA, which describes affirmative marketing, tenanting, and other procedures to ensure that the Housing Development meets all of the fair housing requirements for individuals with disabilities. Within 90 days of the issuance of CRA/LA assistance, the Housing Development must have a PMP approved by CRA/LA or its designee.

Rental applications will include a section to be filled out by applicants requesting a reasonable accommodation or modification, Unless it is an eligibility requirement for a particular Housing Development, applicants will not be required to disclose a disability under any circumstances unless requesting an accommodation or modification and that disclosure shall pertain only to the accommodation being requested. Outreach efforts to the disability community shall include, but not be limited to, notices and other communications describing the availability of such units, specific information regarding the features of accessible units, eligibility criteria, and application procedures. These, and additional procedures, are incorporated into the HCID Fair Housing Policy in Regards to Disability, dated May 12, 2016. as amended over time.

Section 5. Residential Rental Property. The Owner hereby represents, covenants, warrants and agrees as follows:

Section 6. Monitoring Requirements. CRA/LA will monitor, or cause to be monitored, the the compliance of each Housing Development with the requirements of this Agreement. In order to determine compliance with the Accessibility' Requirements, Owner shall submit and CRA/LA shall review and approve a certification report for the Housing Development, conducted by an architect other than the one who designed the project, that identifies the necessary and required design elements to make the units and site accessible for individuals with disabilities. CRA/LA shall inspect the construction/rehabilitation to verify production of the correct number of Accessible Housing Units and appropriate site improvements, in compliance with the Accessibility Standards and Section 2 and supported by an independent-consultant's report.

From the date of this Agreement to the end of the Accessibility Covenant Agreement as set forth in Section 7, CRA/LA will utilize the Housing Development's approved Property Management Plan and the Fair Housing Policy in Regards to Disability, to monitor ongoing occupancy compliance of the Accessible Housing Units and nondiscrimination in regards to individuals with disabilities. Compliance with the Accessibility Requirements shall include, but not be limited to, maintenance of accessibility features, target marketing, establishing and monitoring the waiting list specific to the Accessible Housing Units, reasonable accommodations and modifications, a service animal policy, an effective, communication policy, a policy for re-leasing empty Accessible Housing Units and all elements contained in the Fair Housing Policy in Regard to Disability, as amended over time.

Section 7. Term of the Accessibility Covenant Agreement. This Accessibility Covenant Agreement shall become effective upon the Effective Date and shall terminate Twenty-Five Years following the Effective Date, or at the termination of other affordability or other covenants applying to the Accessible Housing Units, whichever comes later.

Section 8. Covenant To Run With the Land. The Owner hereby subjects the Project to the covenants, reservations and restrictions set forth in this Accessibility Covenant Agreement, CRA/LA and the Owner hereby declare their express intent that the covenants, reservations and restrictions set forth herein shall be deemed covenants running with the land and shall pass to and be binding upon the Owner's successors in title to the Project, provided, however, that on the termination of this Agreement said covenants, reservations and restrictions shall expire. Each and every contract, deed or other instrument hereafter executed covering or conveying the Project or any portion thereof shall conclusively be held to have been executed, delivered and accepted subject to such covenants, reservations and restrictions, regardless of whether such covenants, reservations and restrictions are set forth in such contract, deed or other instruments.

Section 9. Default; Enforcement. As part of ensuring compliance with the Accessibility Requirements, CRA/LA or its agent, may conduct annual on-site visits inspecting the Housing Development, which inspection may include inspecting the Housing Units and common areas, tenant files, logs and other records. Should the Owner fail to comply with the Accessibility Requirements, the CRA/LA or its agent will first issue an Order to Comply ("Order") stating the element of the Housing Development that is out of compliance, and providing a date by which the Owner must comply. The Order shall give the Owner not more than 30 days to correct the violation, or such additional time as the CRA/LA or its agent may grant if the Owner is taking steps to correct the violation ("Compliance Date"), and diligently pursues such action until the default is corrected, which extension is in the sole discretion of the CRA/LA or its agent. The CRA/LA or its agent may reinspect the Housing Development within 10 days of me Compliance Date specified in the Order or any extension, however failure to inspect or reinspect within that time frame does not remove the obligation of the Owner to comply with the Order. If the Order is issued and the violation continues to exist after the Compliance Date, the CRA/LA or its agent may take any one or more of the following steps:

Any other person or entity injured by the Owner's failure to comply with the Accessibility Requirements may bring an action in an appropriate forum to vindicate the rights secured under this Agreement.

Section 10. Americans with Disabilities Act, the Fair Housing Act, and California Law. The Owner hereby certifies that it and its property manager and any subcontractor will comply with the Accessibility Requirements. The Owner and any contractor and subcontractor will provide reasonable accommodations to allow qualified individuals with disabilities to have access to and to participate in its programs, services, and activities in accordance with the applicable provisions of the ADA, the ADAAA, Section 504, the UFAS, the FHA, the California Fair Employment and Housing Act, the California Building Code and all subsequent amendments, and all other applicable stale and federal fair housing laws. The Owner and any contractor and subcontractor will not discriminate against persons with disabilities or against persons due to their relationship to or association with a person with a disability. Any contract and subcontract entered into by the Owner, relating to this Accessibility Covenant Agreement and the Project, to the extent allowed hereunder, shall be subject to the provisions of this paragraph.

Section 11. Governing Law. This Accessibility Covenant Agreement shall be governed by the laws of the State of California.

Section 12. Counterparts. This Accessibility Covenant Agreement may be executed in counterparts, each of which, when the parties hereto have signed the Agreement, shall be one and the same instrument.

Section 13. Recording and Filing. The Owner shall cause this Accessibility Covenant Agreement to be recorded and filed in the real property records of the County of Los Angeles and in such other places as the City may reasonably request.

Section 14. Entire Agreement. The provisions herein constitute the entire agreement between the parties hereto. Each party lo this Agreement acknowledges that no representations, inducements, promises or agreements, orally or otherwise, have been made by any party or anyone acting on behalf of any party, which are not embodied herein. This Accessibility Covenant Agreement shall be amended only by a written instrument executed by the parties hereto or their successors in title, and duly recorded in the real property records of the County of Los Angeles, California,

IN WITNESS WHEREOF, the CRA/LA and the Owner have executed this Accessibility Covenant Agreement by their duly authorized representatives, all as set forth as of the date below.

Exhibit D

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

WHEREAS, the CRA/LA, a Designated Local Authority, a defendant in this action and the successor agency to the Community Redevelopment Agency of the City of Los Angeles (the "CRA"), and the Independent Living Center of Southern California ("ILCSC"), the Fair Housing Council of the San Fernando Valley ("FHC") and Communities Actively Living Independent and Free ("CALIF") (collectively referred to herein as "Plaintiffs") have entered into a Settlement Agreement and Release of Claims, attached as Exhibit 1, which fully resolves claims asserted by Plaintiffs against the CRA; and

WHEREAS, the Court has jurisdiction over the subject matter of this action, the Plaintiffs, the CRA, and the Settlement Agreement; and

WHEREAS, upon consideration, the Court finds the Settlement Agreement to be fair, reasonable, and adequate.

NOW, THEREFORE, IT IS HEREBY ORDERED, ADJUDGED AND DECREED AS FOLLOWS:

1. For the purposes of this Judgment, the Court adopts the terms and definitions set forth in the Settlement Agreement attached as Exhibit 1, and all terms of the Settlement Agreement are incorporated herein by reference.

2. This Judgment Pursuant to Settlement completely resolves this civil action between the CRA and Plaintiffs. The claims against the City of Los Angeles were previously resolved by Judgment Pursuant to Settlement Agreement by and between City of Los Angeles and Plaintiffs (Doc. 532, filed August 4, 2016). This does not resolve this action between Plaintiffs and the remaining nominal defendants.

3. In accordance with the terms of the Settlement Agreement, this Court reserves exclusive and continuing jurisdiction to interpret and enforce the terms of the Settlement Agreement during the Settlement Term, and to resolve any disputes that may arise during the Settlement Term.

4. The court determines that there is no reason to delay entry of this Judgment Pursuant to Settlement Agreement By and Between the CRA and Plaintiffs.

IT IS SO ORDERED and ADJUDGED

Exhibit 1

Settlement Agreement and Release of Claims

Exhibit E

Certification of Compliance with Accessibility Standards

In my capacity as independent licensed architect and California Certified Accessibility Specialist ("CASp"), and having reviewed the Accessibility Laws and Accessibility Standards, as those terms are defined in the Settlement Agreement between the CRA/LA and Plaintiffs in Independent Living Center of Southern California et al v. City of Los Angeles and CRA/LA, 1 [INSERT NAME] hereby certify, based on an on-site accessibility survey that I personally conducted, to the best of my professional knowledge, information and belief, that the Housing Development identified below, including the Housing Units and public and common use areas, complies with the Accessibility Laws and Accessibility Standards, including the Uniform Federal Accessibility Standards, the 2010 Americans with Disabilities Act Accessibility Guidelines and Chapters 11A and 11B of the California Building Code.

A copy of the completed survey instrument, report, documentation, and other supporting information is attached to this certification.

Name, Street Address, and Description of Housing Development Surveyed: