2025-01-17 DOJ SDNY pdf 28,620 chars

U.s. V. Lettire Consent Decree

Exhibit of United States Files Fair Housing Act Lawsuit Against Lettire Construction Corp. And Related Entities For Failure To Construct Apartments With Features Accessible To Persons With Disabilities

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summary

Lettire Construction Corp. and UBC Chestnut Commons LLC agreed to a consent decree to resolve allegations of Fair Housing Act violations, including accessible design and construction requirements, and will pay civil penalties totaling $60,000 within 45 days.

paragraph

The United States has filed lawsuits against several companies, including Lettire Construction Corp., for allegedly violating the Fair Housing Act by not designing and constructing rental complexes in New York City with accessible design and construction requirements. Lettire has agreed to a consent decree, which includes a three-year term during which they must retain an FHA compliance adviser, maintain records, and pay civil penalties totaling $50,000 within 45 days. Additionally, UBC Chestnut Commons LLC has agreed to a $10,000 civil penalty for a Fair Housing Act violation, with provisions for retrofits and accessibility enhancements at The Tapestry.

narrative

Enriched metadata

Scheme: health-care-fraud (100%)
Court: Southern District of New York

Classified health-care-fraud(confidence 100%). No EDGAR filing fingerprint (criminal/DOJ-side scheme). detection rule →

Extracted insights

Dollar amounts 2

$30K $30,000 $10K–$100K
$10K $10,000 $10K–$100K

Entities 1

location United States

Triples 5

United States brought the Action to enforce provisions of the Fair Housing Act
United States’ Complaint alleges defendants participated in the design, construction, or ownership of the Properties
Lettire engaged an FHA accessibility consultant to review construction documents, conduct compliance inspections, and provide technical assistance
Government seeks no civil penalties or other monetary relief with respect to the Atrium
Lettire has fully cooperated with the Government’s investigation into this matter

PDF

U.s. V. Lettire Consent Decree · Source

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Extracted body text (28,620c)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,

Plaintiff,

LETTIRE CONSTRUCTION CORP; LETTIRE 124TH
STREET LLC; EAST 124TH STREET LLC; UBC
CHESTNUT COMMONS LLC; UBC SUMNER LLC;
CHESTNUT COMMONS HOUSING DEVELOPMENT
FUND CORP.; and MHANY MANAGEMENT, INC.,

Defendants.

25 Civ. 483 (____)

CONSENT DECREE AS TO
LETTIRE CONSTRUCTION
CORP., LETTIRE 124th
STREET LLC, UBC
CHESTNUT COMMONS
LLC, and UBC SUMNER LLC

WHEREAS, the United States brought the above-captioned action (the “Action”) to

enforce provisions of the Fair Housing Act (“FHA”), codified at 42 U.S.C. §§ 3601–3619;

WHEREAS, the United States’ Complaint alleges that defendants participated in the

design, construction, or ownership of a certain rental complexes in New York City, including The

Tapestry located at 245 East 124th Street in Manhattan; The Parkline located at 626 Flatbush

Avenue in Brooklyn; Chestnut Commons, located at 3269 Atlantic Avenue in Brooklyn; and

Atrium at Sumner located at 57 Marcus Garvey Boulevard in Brooklyn (collectively, the

“Properties”);

WHEREAS, the Properties are subject to the accessible design and construction

requirements of the FHA, 42 U.S.C. § 3604(f)(3)(c);

WHEREAS, the FHA provides that residential buildings with four or more dwelling units,

and one or more elevators, designed and constructed for first occupancy after March 13, 1991, are

Covered Multifamily Dwellings and must include certain basic features of accessible design as set

forth in 42 U.S.C. §§ 3604(f)(3)(C) and (f)(7)(A);

WHEREAS, the accessible and adaptive design provisions of the FHA require that for

Covered Multifamily Dwellings: (i) the public use and common use portions of such dwellings are

readily accessible to and usable by persons with a disability; (ii) all the doors designed to allow

passage into and within all premises within such dwellings are sufficiently wide to allow passage

by persons with a disability using wheelchairs; (iii) all premises within such dwellings contain the

following features of adaptive design: (I) an accessible route into and through the dwelling; (II)

light switches, electrical outlets, thermostats, and other environmental controls in accessible

locations; (III) reinforcements in bathroom walls to allow later installation of grab bars; and (IV)

usable kitchens and bathrooms such that an individual using a wheelchair can maneuver about the

space. See 42 U.S.C. § 3604(f)(3)(c) (these provisions of the FHA are referred to herein as the

“Accessible Design Requirements”);

WHEREAS, the parties to this Consent Decree agree that this Court has jurisdiction over

the subject matter of this case, and further agree that, to avoid protracted and costly litigation, and

without Lettire or any other party admitting liability, this controversy should be resolved without

further proceedings and without an evidentiary hearing or a trial;

WHEREAS, Lettire has fully cooperated with the Government’s investigation into this

matter; and

WHEREAS, with respect to the Atrium, Lettire engaged an FHA accessibility consultant

prior to the commencement of construction to review construction documents, conduct compliance

inspections, and provide technical assistance to Lettire; the Government’s later inspection of the

property found relatively few issues requiring attention; Lettire has already completed remediation

of most such issues and Lettire has committed to completing the remaining retrofits promptly; and

the Government accordingly seeks no civil penalties or other monetary relief with respect to the

Atrium;

It is hereby AGREED, by and between the parties, as follows:

I. The Parties and the Properties

1. Plaintiff is the United States of America.

2. Defendant Lettire Construction Corp. (“Lettire”) was the general contractor for The

Tapestry, The Parkline, Chestnut Commons, and Atrium.

3. Defendant Lettire 124th Street LLC is a co-developer for the Tapestry.

4. Defendant UBC Chestnut Commons LLC is a co-developer for Chestnut

Commons.

5. Defendant UBC Sumner LLC is a co-developer for the Atrium.

6. Defendants Lettire, Lettire 124th Street LLC, UBC Chestnut Commons, and UBC

Sumner are referred to as the “Settling Defendants.”

7. The Tapestry, The Parkline, Chestnut Commons, and Atrium are referred to as the

“Properties.” Lettire did not own, operate, or develop the Properties.

II. Compliance with the FHA

8. The parties agree that this Court has jurisdiction over the subject matter of this case

pursuant to 28 U.S.C. §§ 1331 and 1345, and 42 U.S.C. § 3614(a).

9. The Settling Defendants and each of their officers, employees, agents, successors,

and assigns are hereby enjoined from discriminating on the basis of disability as prohibited by the

FHA, 42 U.S.C. § 3604.

III. Non-Discrimination in Other Design and Construction

10. Lettire shall design and/or construct all new Covered Multifamily Dwellings in full

compliance with either (i) the Guidelines, or (ii) a standard designated as an FHA safe harbor by

the Department of Housing and Urban Development (each a “Standard”), where each such

Standard has been used in its entirety. For the avoidance of doubt, the phrase “new Covered

Multifamily Dwellings” means future projects, i.e., projects pursuant to construction management

agreements that Lettire enters into with an owner/developer after the date of this Consent Decree

for which work is performed during the three-year period of the Consent Decree. The obligations

outlined in this Consent Decree shall apply only during the term of this Consent Decree.

11. For any new Covered Multifamily Dwelling that Lettire designs and/or constructs

during the term of this Consent Decree, Lettire shall retain or employ, as an independent contractor

or employee, a compliance adviser (“FHA Adviser” or “Advisor”) to advise Lettire regarding

compliance with the FHA’s Accessible Design Requirements, unless the owner and/or developer

has retained its own independent, third-party compliance consultant to advise the owner and/or

developer to help ensure compliance with the FHA’s Accessible Design Requirements. The FHA

Adviser, which may be an individual or a firm, including an existing Lettire employee or consultant

with the requisite expertise and experience, shall have expertise and experience with the Accessible

Design Requirements. For the duration of the Consent Decree, the FHA Adviser shall submit to

the United States annual reports within 15 days of the anniversary of the entry of the Consent

Decree certifying that in the course of the year preceding the submission of the report the FHA

Adviser has advised on FHA accessibility issues at the property consistent with Paragraph 7 of this

Consent Decree, and summarizing the areas in which the Adviser gave advice with reference to

each of the requirements of 42 U.S.C. § 3604(f)(3)(C). The FHA Adviser may engage such staff

or third-party contractors as he or she deems appropriate to satisfy the Adviser’s responsibilities

fully.

12. Lettire shall pay all reasonable costs of the FHA Adviser, including the cost of his

or her time and the costs of any staff or contractors. Lettire shall direct its employees, agents,

and/or contractors to seek the FHA Adviser’s advice regarding the effect of deviations from the

architects’ plans on the accessibility of conditions at the property, as well as other issues that may

arise during construction that affect accessibility. Lettire shall require the FHA Adviser, as the

FHA Adviser deems appropriate, and with consultation and coordination with Lettire, to make

recommendations to the owner and/or developer regarding any FHA accessibility issues that may

arise during construction.

13. The agreement or contract between Lettire and the FHA Adviser shall specify that

the FHA Adviser is being retained or employed pursuant to this Consent Decree. Further, within

30 days of retaining, the acceptance of an offer of employment by, or the agreement of an existing

Lettire employee with the requisite expertise and experience to serve as the FHA Adviser, Lettire

shall provide a copy of this Consent Decree to the FHA Adviser and secure the signed statement

from the FHA Adviser acknowledging that he or she has received and read the Consent Decree

and has had an opportunity to have questions about the Consent Decree answered. This statement

shall be substantially similar to the form of Appendix A.

14. During the term of this Consent Decree, in each year in which Lettire has a new

Covered Multifamily Dwelling under construction, Lettire shall submit, within 15 days of the

anniversary of the entry of the Consent Decree, a certification to the United States affirming either

that it has retained or employed an FHA Adviser or the owner and/or developer has retained or

employed its own independent, third-party FHA compliance consultant, for each new Covered

Multifamily Dwelling under construction by Lettire during that year and specifying each new

Covered Multifamily Dwelling for which an FHA Adviser was retained by Lettire to provide

advice and the identity (and affiliation, if applicable) of the FHA Adviser.

15. For the term of this Consent Decree, Lettire shall maintain, and provide to the

United States or FHA Adviser upon request, the following information and statements regarding

any new Covered Multifamily Dwellings as to which Lettire is the construction manager:

 the name and address of the project;

 a description of the project and the individual units;

 to the extent known, the name, address, and telephone number of the lead civil

engineer(s) who are employed or retained by the owner and/or developer involved

with the project;

 to the extent known, the name, address and telephone number of the lead

architect(s) who are employed or retained by the owner and/or developer involved

with the project.

IV. Educational Program

16. Within 90 days of the entry of this Consent Decree, Lettire shall provide a copy of

this Consent Decree to all of its current employees involved in the design or construction of any

new Covered Multifamily Dwellings and secure the signed statement from each such current

employee acknowledging that he or she has received and read the Consent Decree, and has had an

opportunity to have questions about the Consent Decree answered. This statement shall be

substantially similar to the form of Appendix A.

17. During the term of this Consent Decree, any new agent or supervisor of Lettire who

will have any supervisory authority in the design or construction of new Covered Multifamily

Dwellings shall, within 90 days after the date he or she commences an employment relationship

with Lettire, be given a copy of this Consent Decree by Lettire, and Lettire shall require each such

new employee to sign a statement, acknowledging that he or she has received and read the Consent

Decree, and has had an opportunity to have questions about the Consent Decree answered. This

statement shall be substantially similar to the form of Appendix A.

18. In lieu of providing individuals or entities with copies of the Consent Decree as

required by the preceding paragraphs of this Section, Lettire may instead provide a summary of

the Consent Decree with the United States’ advance written approval of the form and content of

any proposed summary.

19. Lettire shall also ensure that its employees who have supervisory authority over the

design and/or construction of new Covered Multifamily Dwellings have a copy of, are familiar

with, and personally have reviewed, the Fair Housing Accessibility Guidelines, 56 Fed. Reg. 9472

(1991), and the United States Department of Housing and Urban Development, Fair Housing Act

Design Manual, A Manual to Assist Builders in Meeting the Accessibility Requirements of the

Fair Housing Act (August 1996, Rev. April 1998).

20. Within 180 days of the date of entry of this Consent Decree, Lettire and all its

employees whose duties, in whole or in part, involve or will involve supervision over the

development, design and/or construction of multifamily dwellings shall undergo training on the

design and construction requirements of the FHA. The training shall be conducted by a qualified

third-party individual, not associated with Lettire or its counsel, and approved by the United States;

and any expenses associated with this training shall be paid by Lettire. Lettire shall provide to the

United States, 30 days before the training, the name(s), address(es) and telephone number(s) of the

trainer(s); and copies of any training outlines and materials to be distributed by the trainers. Lettire

shall provide to the United States, 30 days after the training, certifications executed by Lettire and

covered employees confirming their attendance, in a form substantially equivalent with respect to

the applicable subject matter to Appendix B.

V. Preservation of Records

21. For the term of this Consent Decree, Lettire is required to preserve all records

related to this Consent Decree for the Properties and any other new Covered Multifamily

Dwellings designed or constructed by Lettire during the term of this Consent Decree. Upon

reasonable notice to Lettire, representatives of the United States shall be permitted to inspect and

copy any non-privileged records of Lettire bearing on compliance with this Consent Decree at any

and all reasonable times, provided, however, that the United States shall endeavor to minimize any

inconvenience to Lettire from such inspections.

VI. Civil Penalty

22. Within 45 days of the entry of this Consent Decree, Lettire shall pay a civil penalty

of $30,000 (Thirty Thousand Dollars) pursuant to 42 U.S.C. § 3614(d)(1)(C) to vindicate the public

interest. Lettire shall pay said sum by submitting a check made payable to the “United States of

America” to the United States or by electronic fund transfer pursuant to instructions to be provided

by the United States.

23. Within 45 days of the entry of this Consent Decree, Lettire 124th Street LLC shall

pay a civil penalty of $10,000 (Ten Thousand Dollars) pursuant to 42 U.S.C. § 3614(d)(1)(C) to

vindicate the public interest. Lettire 124th Street LLC shall pay said sum by submitting a check

made payable to the “United States of America” to the United States or by electronic fund transfer

pursuant to instructions to be provided by the United States.

24. Within 45 days of the entry of this Consent Decree, UBC Chestnut Commons LLC

shall pay a civil penalty of $10,000 (Ten Thousand Dollars) pursuant to 42 U.S.C. § 3614(d)(1)(C)

to vindicate the public interest. UBC Chestnut Commons shall pay said sum by submitting a

check made payable to the “United States of America” to the United States or by electronic fund

transfer pursuant to instructions to be provided by the United States.

VII. Responsibility for Retrofits and Aggrieved Persons at The Tapestry

25. Defendant East 124th Street LLC having agreed to assume responsibility for all

retrofits and aggrieved persons payments at The Tapestry, and Lettire having agreed to pay a civil

penalty relating to The Tapestry, all claims of the United States against Lettire arising from the

design and construction of The Tapestry are dismissed, without prejudice to reinstatement in

accordance with Paragraph 31.

VIII. Reservation of Rights as to Chestnut Commons and the Parkline

26. Except as to any claim for civil penalties as against Lettire, the United States

reserves all its rights and remedies as against any party, including Lettire, that was involved in the

design and construction of the Parkline. Neither Lettire 124th Street LLC, UBC Chestnut

Commons, nor UBC Sumner played any role in the design or construction of the Parkline.

27. Except as to any claim for civil penalties as against Lettire and UBC Chestnut

Commons, the United States reserves all its rights and remedies as against any party, including

Lettire and UBC Chestnut Commons, that was involved in the design and construction of Chestnut

Commons. Neither Lettire 124th Street LLC nor UBC Sumner played any role in the design or

construction of Chestnut Commons.

IX. Enhancements to Accessibility: Atrium at Sumner

28. While Atrium was still in the process of being constructed and completed, in

consultation with an FHA accessibility consultant, the Government conducted a survey of the

property and proposed certain retrofits to accessibility at the Atrium, which retrofits have either

been completed or are in the process of being completed by Lettire in consultation with the

Government. As soon as reasonably possible, but no later than six (6) months after the entry of

this Consent Decree by the Court, Lettire shall use commercially reasonable efforts to finish all

the retrofits listed in Appendix C. Lettire shall make reasonable efforts to minimize inconvenience

to residents of Atrium in making such retrofits. Upon completion of the retrofits, the consultant

shall inspect these remaining retrofits and prepare a report to the Government certifying that they

have been completed. The United States shall have the right to inspect the property to ensure that

the retrofits have been completed.

X. Duration of Consent Decree and Termination of Legal Action

29. The term of this Consent Decree shall commence upon entry of this Consent Decree

and, expire two (2) years following such entry or 30 days from the date that all of the necessary

modifications required by Paragraph 21 have been made, whichever date is later. The parties agree

that in the event that Lettire engages in any future conduct occurring during the term of this

Consent Decree that leads to a determination of a violation of the FHA’s accessible design and

construction provisions, such conduct shall constitute a “subsequent violation” pursuant to 42

U.S.C. § 3614(d)(1)(C)(ii).

30. The Complaint in this action is hereby dismissed as to Lettire 124th Street LLC and

UBC Sumner, without prejudice to reinstatement in accordance with Paragraph 31. Nothing in

this paragraph or the dismissal of the Complaint to the extent herein shall affect the Government’s

reservation of rights as against any party relating to The Parkline, as set forth in Paragraph 27.

31. The Complaint in this Action shall be reinstated as to any Settling Defendant at any

time during the term of this Consent Decree if the Court determines that such Settling Defendant

has failed to perform, in a timely manner, any act required by this Consent Decree or has otherwise

failed to act in conformity with any provision of this Consent Decree. Any delay attributable to

the United States shall not be a basis to reinstate the Complaint in this action.

32. The Court shall retain jurisdiction for the duration of this Consent Decree to enforce

the terms of the Consent Decree. The United States may move the Court to extend the duration of

the Consent Decree in the interests of justice. The duration of the Consent Decree also may be

extended by the mutual written agreement of the United States and the Settling Defendants.

33. The United States and the Settling Defendants shall endeavor, in good faith, to

resolve informally any differences regarding interpretation of and compliance with this Consent

Decree prior to seeking judicial relief. However, in the event of a material breach of this Consent

Decree, and if the parties are unable to informally resolve such a dispute, any party shall have the

right to submit an application to the Court to reinstate this action at any time prior to the expiration

of the term of this Consent Decree to seek enforcement of the terms of this Consent Decree by

amending its pleading(s) pursuant to Rule 15(a)(2) of the Federal Rules of Civil Procedure to

include a claim or counter-claim for breach of this Consent Decree.

34. Upon the expiration of the Consent Decree and all obligations thereunder, the

United States shall seek an order dismissing the Complaint with prejudice as to the Settling

Defendants.

XI. Miscellaneous

35. The Settling Defendants are hereby notified that, in the event that any of them fails

to comply with any of the terms of this Consent Decree and the United States obtains an order

establishing such noncompliance, the United States may take any appropriate action, including but

not limited to notifying the appropriate state housing finance agency of the violation. See 26 U.S.C.

§ 42(m)(1)(B)(iii).

36. Any time limits for performance imposed by this Consent Decree may be extended

by the mutual written agreement of the United States and the Settling Defendant(s), the consent to

which shall not be unreasonably denied or withheld.

37. The United States and the Settling Defendants shall each bear their own costs and

attorney’s fees associated with this litigation.

38. The United States and the Settling Defendants understand and agree that this

Consent Decree and the appendices thereto contain the entire agreement between them, and that

any statements, representations, promises, agreements, or negotiation, oral or otherwise, between

the parties or their counsel that are not included herein shall be of no force or effect.

The undersigned apply for and consent to the entry of this Consent Decree:

DATED: January 16, 2025

New York, New York

For the United States:

EDWARD Y. KIM
Acting United States Attorney

By: ___________________________
DANIELLE J. MARRYSHOW
AMANDA LEE
Assistant United States Attorneys
86 Chambers Street, 3rd Floor
New York, New York 10007
Tel.: (212) 637-2689/2781
[email protected]
[email protected]

DATED: _______ __, 2025

New York, New York

SO ORDERED:

________________________________

UNITED STATES DISTRICT JUDGE

DATED: January 16, 2025

New York, New York

LETTIRE CONSTRUCTION CORP.
LETTIRE 124th STREET LLC
UBC CHESTNUT COMMONS LLC
UBC SUMNER LLC

By: ___________________________
Kan M. Nawaday
VENABLE LLP
151 West 42nd Street
New York, NY 10036
Telephone No. (212) 370-6240

By: ___________________________
Andrew W. Schilling

SCHILLING LAW LLC
1345 Avenue of the Americas
New York, NY 10105
Telephone No. (212) 551-7880
[email protected]

Attorneys for Lettire Construction Corp., Lettire
124th Street LLC, UBC Chestnut Commons LLC,
and UBC Sumner LLC

APPENDIX A

ACKNOWLEDGMENT OF RECEIPT OF CONSENT ORDER

I ___________________, am a _____________ of/for _______________________ and my

duties include __________________________ . I have received and read a copy of the Consent
Decree in United States of America v. Lettire Construction Corp. et al., 25 Civ. __ (_) (S.D.N.Y.),
and have been given instruction on (1) the terms of this Consent Decree, (2) the requirements of
the Fair Housing Act, particularly related to the Act’s design and construction requirements, and
(3) my responsibilities and obligations under the Consent Decree and the Fair Housing Act. I
have had all of my questions concerning the Consent Decree answered to my satisfaction.

__________, 20___

_____________________________
Employee Signature

APPENDIX B

CERTIFICATION OF FAIR HOUSING TRAINING

On ___________, I attended training on the design and construction requirements of the federal
Fair Housing Act. I have had all of my questions concerning the Fair Housing Act answered to my
satisfaction.

___________________________
Employee Signature

____________________________
Print Name

___________________
Date

APPENDIX C

PUBLIC AND COMMON USE AREAS AT ATRIUM

As soon as reasonably possible, but no later than six (6) months from the entry of this Consent Decree, Lettire shall complete the
retrofits identified in this Appendix C

EXTERIOR

ELEMENT CONDITION AGREED UPON RETROFIT
Where the underside of an object is more

than 27” and less than 80” above the floor,
the object may not protrude into the

circulation path by more than 4”.

The front and rear facades have angled
walls that protrude into the circulation
path. Above the 27” high portion of the

wall, it protrudes about 14 ½”.

Install truncated domes at all similar
protruding objects along all exterior

circulation paths in public and common
spaces. Truncated domes must be at least
24” deep and installed for a depth of at
least 24” in the direction of travel. Once
the retrofit is complete, provide proof of

completion for Government’s expert.

The top of the threshold cannot be more
than ½” above the landing on both sides of
the door. If it is taller than ¼”, it must be

beveled 1:2.

At building entrance, the top of the
threshold is ¾” above the carpet.

Raise floor surface of landings on either
side of threshold so top of threshold is not
greater than ½ inch, and provide proof of

retrofit for Government’s expert.

COMMON AREAS

ELEMENT CONDITION AGREED UPON RETROFIT
The top of the threshold cannot be more

than ½” above the landing on both sides of
the door. If it is taller than ¼”, it must be

beveled 1:2.

At the Community Room exterior exit,
entrance, the top of the threshold is ¾”

above the landing.

Raise floor surface of landings on either
side of threshold so top of threshold is not
greater than ½ inch, and provide proof of

retrofit for Government’s expert.
The top of the threshold cannot be more

than ½” above the landing on both sides of
the door. If it is taller than ¼”, it must be

beveled 1:2.

At the smaller portion of the Community
Room exterior exit, entrance, the top of
the threshold is 1 ¼ ” above the landing.

Raise floor surface of landings on either
side of threshold so top of threshold is not
greater than ½ inch, and provide proof of

retrofit for Government’s expert.
The top of the threshold cannot be more

than ½” above the landing on both sides of
the door. If it is taller than ¼”, it must be

At the exterior entrance to the Bicycle
Storage corridor, the top of the threshold

is ¾” above the landing.

Raise floor surface of landings on either
side of threshold so top of threshold is not
greater than ½ inch, and provide proof of

APPENDIX C

COMMON AREAS

beveled 1:2. retrofit for Government’s expert.
Where the underside of an object is more

than 27” and less than 80” above the floor,
the object may not protrude into the

circulation path by more than 4”.

In the Bicycle Storage corridor, the
bottom of the bicycle rack is 42” above

the floor and protrudes about 24”.

Relocate the wall-hung bicycle racks to
eliminate protrusion into circulation path.

Once the retrofit is complete, provide
proof of completion for Government’s

expert.
There is a common use table or work

surface. Knee and toe space must be at
least 30” wide. The knee space must be at

least 27” high for a depth of at least 8”.
The toe space must be at leas 9” high and

extend 17” underneath.

There are tables in the Library. One must
be made accessible. The knee space is

only 26” tall and 27” wide.

Relocate the accessible table in the
Library, and provide proof of retrofit for

Government’s expert.

The accessible route must be at least 36”
wide. Accessible route may narrow to 32”

for a distance of no more than 24”.

In the Exercise Room, the accessible route
to the thermostat is only 31 ¼” wide.

Adjust the fitness equipment to meet the
required width, and provide markings on

the floor or wall to keep the necessary
floor space clear of equipment. Once the

retrofit is complete, provide proof of
completion for Government’s expert.

APPENDIX C

UNIT RETROFITS AT THE TAPESTRY

Lettire shall provide these retrofits on demand to any tenant of Atrium.

GRAB BAR REINFORCEMENT

FAIR HOUSING ACCESSIBILITY GUIDELINES REQUIREMENT 6

UNIT(S) CONDITION AGREED UPON RETROFIT
All unit(s) Unclear if reinforcement installed in

bathroom walls to allow later installation
of grab bars around the toilet, tub, shower,

and shower seat.

Install reinforcement in walls around
toilet. Shower seats have been installed,
but replace shower seats with grab bars

and reinforce wall, unless existing tenant
objects and requests shower seat.

USABLE KITCHENS
FAIR HOUSING ACCESSIBILITY GUIDELINES REQUIREMENT 7

UNIT(S) CONDITION AGREED UPON RETROFIT
All unit(s) A 30”-wide accessible work surface must

be provided in the kitchen counter that is
no higher than 34”. It must have knee and
toe space underneath that is 30” wide and

27” tall. A removable cabinet may be
installed.

Upon request, replace inaccessible table
with accessible table.

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