19.   Mr. and Ms. Lewis moved into the Complex in March 2007.  It was the first  home that they had purchased together.      20.  They chose to purchase in the Complex because it appeared to be a nice place to  raise children, it was close to their immediate family, and Mrs. Lewis was expecting their first  child.  Shortly after they moved in, their son, E.L., was born.    22.  The common areas of the Complex—including the quads and swimming pool— are designed and designated for use by all residents in the CC&Rs.  There is no restriction  against children, and no restriction against outdoor play in the common areas.  In fact, the basic  configuration of the Complex, with individual condominium homes each facing into an open,  common quad area, naturally invite community interaction, including play among resident  children.   23.  There are no parks or playgrounds in the immediate area around the Complex; the  nearest park is the Warm Springs Park about half a mile away, which requires crossing a street  with high traffic volume to reach.  It is a dangerous street for children to cross, especially young  children, even when accompanied by an adult.  It is also an inconveniently long walk for young  children.   24.  Mr. and Mrs. Lewis were unaware at the time they purchased and moved into the  Complex that the Association had a long history of discrimination against children and families  with children; in particular, a history of rules that forbid children to play in the common areas of  the Complex, including the quad areas.  The History of Discrimination Against Families with Children at Silvertree Mohave   25.  The Association publishes a monthly newsletter for the residents and homeowners  called the “Silvertree Mohave Newsletter” (the “Newsletter”).  Among other things, the  Newsletter purports to provide “legal notice” to all members of the Association.  Resolutions  passed by the Board are published in the Newsletter.    26.  The Newsletter is published by Management Solutions and sent to all Association  members by Management Solutions.  The Board requires nonresident homeowners to provide the  information in the Newsletter to their tenant residents in the Complex.    28.  For example, on information and belief, as of at least August 30, 2000, the  Association has enforced rules prohibiting children under the age of 14 from playing in all  common areas of the Complex, including swimming in the pool without adult supervision, and  playing outside with or without adult supervision.      29.  For example, in response to occurrences of children playing in the common areas  in September 2003, the Board passed a resolution prohibiting “all sports play within the quad  areas.”  The 2003 Resolution, as passed, reads:   97.  The Lewis Plaintiffs who, as of the date of filing this complaint, reside at the  Complex, seek to bring this case on behalf of themselves and on behalf of a class of similarly  situated individuals pursuant to Federal Rule of Civil Procedure 23.     Background   Violation of the California Fair Employment and Housing Act on the basis of familial  status  All Plaintiffs vs. All Defendants  119.  Plaintiffs re-allege and incorporate herein by reference each and every allegation  contained in all paragraphs above.  120.  Defendants have injured Plaintiffs in violation of the California Fair Employment  and Housing Act by:  a. Discriminating against or harassing Plaintiffs because of family status in violation  of Cal. Gov’t Code §§ 12955(a), 12955(d), 12955(k); and   b. Making statements of discrimination, limitation, or preference based on family  status, in violation of Cal. Gov’t Code § 12955(c);   c. Aiding, abetting, or inciting in the discrimination of residents because of family  status in violation of Cal. Gov’t. Code § 12955(g).   121.  As a proximate cause of Defendants’ conduct, Plaintiffs have been damaged and  continue to suffer damages, as set forth above.  122.  Wherefore, Plaintiffs pray for relief and judgment as set forth below. 