Case 1:16-cv-01723-RC Document 43 Filed 06/13/17 Page 1 of 4

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

ADRIANN BORUM, et al.
Plaintiffs,
v.
Case No.: 16-cv-01723-RC
BRENTWOOD VILLAGE, LLC, et al.,
Defendants.

PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION
AND THE APPOINTMENT OF CLASS COUNSEL
Plaintiffs Adriann Borum and Lorretta Holloman, as representatives of the putative class
in this litigation brought under the Fair Housing Act and the D.C. Human Rights Act, hereby
move pursuant to Federal Rule of Civil Procedure 23 for certification of the following class:
All households who reside or have resided at Brookland Manor in a three-,
four-, or five-bedroom unit with one or more minor child, and (i) have been
displaced from a three-, four-, or five-bedroom unit at Brookland Manor
since October 1, 2014 (the date that Defendants proposed their First Stage
PUD to the Zoning Commission), or (ii) are at risk of being displaced from
a three-, four-, or five-bedroom unit at Brookland Manor.
See Complaint at ¶ 122 (Dkt. 2).
Plaintiffs’ motion is supported by a contemporaneously filed Memorandum of Law and
Points of Authorities and accompanying Exhibits. As set forth in these accompanying filings,
the above-identified class warrants certification as it satisfies each of the requirements of Rule
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 Case 1:16-cv-01723-RC Document 43 Filed 06/13/17 Page 2 of 4

23(a) as well as 23(b)(2) and 23(b)(3). Plaintiffs therefore respectfully move the Court for
certification of an injunctive-relief class under Rule 23(b)(2) and a hybrid class under 23(b)(2)
and 23(b)(3) as well as appointment of class counsel under 23(g)(1).
Pursuant to Local Rule 23.1(c), Plaintiffs state that upon certification of any hybrid class,
Plaintiffs, through counsel, will fully comply with the notice provisions of Rule 23(c)(2). In
particular, Plaintiffs’ counsel will provide notice in a form compliant with Rule 23(c)(2) via U.S.
Mail to each resident at Brookland Manor Apartments as well as, upon a review of Defendants’
move out records and historical demographics data, to class members no longer resident at
Brookland Manor at all available current addresses. Plaintiffs’ counsel will accept responses to
the notice described herein and provide a true and correct copy of all such responses to opposing
counsel and the Court. Presuming a finding of liability against Defendants and an award of
damages to class members, Plaintiffs state that payment to class members may be made directly
from any such award in the appropriate amount.
Plaintiffs respectfully request that the Court schedule a hearing on this motion at the
Court’s earliest convenience if such a hearing would be of assistance to the Court.
June 13, 2017

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 Case 1:16-cv-01723-RC Document 43 Filed 06/13/17 Page 3 of 4

Respectfully submitted,
/s/ Maureen F. Browne
Maureen F. Browne (D.C. Bar No. 441440)
(mbrowne@cov.com)
Nooree Lee (D.C. Bar No. 1001687)
(nlee@cov.com)
Samuel Adriance (admitted pro hac vice)
(sadriance@cov.com)
Amber M. Charles (D.C. Bar No. 1035226)
(acharles@cov.com)
COVINGTON & BURLING LLP
One CityCenter
850 10th Street NW
Washington, D.C. 20001
Telephone: (202) 662-6000
/s/ Matthew Handley
Matthew Handley (D.C Bar No. 489946)
(matthew_handley@washlaw.org)
Catherine Cone (D.C. Bar No. 1032267)
(catherine_cone@washlaw.org)
WASHINGTON LAWYERS’ COMMITTEE
FOR CIVIL RIGHTS & URBAN AFFAIRS
11 Dupont Circle, NW, Suite 400
Washington, D.C. 20036
Telephone: (202) 319-1000

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 Case 1:16-cv-01723-RC Document 43 Filed 06/13/17 Page 4 of 4

CERTIFICATE OF SERVICE

This document is being filed with the Court electronically via the ECF system, and thus
the requirements of service and proof of service of this Motion are satisfied by the automatic
notice of filing sent by the CM/ECF software in accordance with the Local Rules of this Court
on this 13th day of June 2017.

/s/ Maureen F. Browne
Maureen F. Browne

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