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2024年3月25日发(作者：css预处理器)
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF ALABAMA
NORTHERN DIVISION
YOLANDA M. BOSWELL, )
)
PLAINTIFF, )
)
v. ) CIVIL CASE NO. 2:07-cv-135
)
JAMARLO K. GUMBAYTAY, )
DBA/THE ELITE REAL ESTATE )
CONSULTING GROUP )
and, )
)
MATTHEW W. BAHR, )
)
DEFENDANTS.
FIRST AMENDED COMPLAINT
COMES NOW, Plaintiff, YOLANDA M. BOSWELL, by and through undersigned
Counsel, and brings this complaint to enforce the provisions of Title VIII of the Civil
Rights Act of 1968, as amended by the Fair Housing Amendments Act of 1988, 42
U.S.C. §§ 3601, et seq. (the Fair Housing Act), and in support thereof states the
following:
JURSIDICTION
1. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331, 28
U.S.C. § 1343, and 42 U.S.C. § 3613(a).
2. Venue is proper under 28 U.S.C. § 1391(b) because the actions giving rise to the
Plaintiff’s allegations occurred in the Northern Division of the Middle District of
Alabama, the subject property is located in the Northern Division of the Middle
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District of Alabama, and all parties either reside or do business in the Northern
Division of the Middle District of Alabama.
PARTIES
3. The Plaintiff, YOLANDA L, is a twenty-seven-year-old female who
rents property located at 964 North Gap Loop, Montgomery, Alabama. Other
residents at the subject property are her four children and her mother, Jennette
Boswell.
4. The Defendant, Jamarlo K. GumBayTay, is a real estate manager doing business
under the name of The Elite Real Estate Consulting Group. He is a resident of
Montgomery, Alabama. He acts as the agent for the Defendant Matthew W.
Bahr, the owner of the subject property. GumBayTay manages the subject
property.
5. The Defendant, Matthew W. Bahr, is a resident of Orlando, Florida. He owns the
property located at 964 North Gap Loop, Montgomery, Alabama, subject of this
action.
STATEMENT OF FACTS
6. During the period of time relevant to this action, the Defendants either owned or
managed, or both, the rental property (dwelling) located at 964 North Gap Loop,
Montgomery, Alabama, where the Plaintiff currently resides.
7. The Plaintiff’s rental house located at 964 North Gap Loop, Montgomery,
Alabama, constitutes a “dwelling” within the meaning of 42 U.S.C. § 3602(b).
8. Defendants have violated the Fair Housing Act, 42 U.S.C. §§ 3601, et seq., as
amended, by discriminating against the Plaintiff, and possibly others, on the basis
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