Plaintiffs' move to challenge adequacy of defendant's responses to requests to admit

 Complete refusals to admit or deny

That, in the City’s judgment, the existence of racial and ethnic segregation in NYC schools is a major problem, is contrary to the City’s interests, and that it is important to reduce such segregation; and that Mayor de Blasio has believed this to be true throughout his mayoralty. 81-83

That a significant portion of the racial and ethnic segregation that exists at the elementary school level has been and remains a function of racially and ethnically segregated neighborhoods; that such segregation contributes to material differences in the elementary school education that New York City children receive; and that Mayor de Blasio believes that existing residential demographic patterns limit the extent to which the problem of school segregation can be fully solved in NYC. 84, 86, 87

That the City (and Mayor de Blasio) have known for many years of the phenomenon of community opposition to greater racial or ethnic integration in schools. 95

That when proposals to change school admissions policies or to change the catchment area from which a school draws its students bring the prospect of a change in school demographics (a reduction in the level of dominance of the racial or ethnic group that, up to that point, had been demographically most dominant in the school), in defendant’s judgment, it is often the case that strong opposition arises. 88

That Mayor de Blasio has believed since at least the beginning of his mayoralty and continues to believe that NYC is characterized by a substantial level of residential racial segregation. 33

Admit that Mayor de Blasio believed and believes that any effective effort to confront residential racial segregation and to take action to overcome it would require the expenditure of significant political capital. 120

That that an outsider, non-disability household may be in equal or greater need of a lottery unit for which that household is income- and household-size eligible than the household who was awarded the apartment because of the operation of the community preference policy. 10

Admit that, in the New York City context, a community district can be measured as relatively diverse on the racial diversity index yet have an African American population sharply below the citywide percentage of African Americans. 36

That Mayor de Blasio believes that, in the course of the Giuliani and Bloomberg administrations, defendant’s efforts to fight negative impacts of gentrification and to fight involuntary displacement were materially inadequate. 135

That, if a Council Member were to oppose an affordable housing development or action needed to facilitate affordable housing development only because the “community preference” policy had been reduced or eliminated by Court order, that opposition would be contrary to the City’s interest and contrary to the interests of the Council Member’s constituents. 22



That community preference is not limited to insiders who:

     a. Have been long-term residents of the community preference area;

     b. Have had to persevere through years of difficult conditions;

     c. Are at risk of involuntary displacement from their household’s existing residence; or

     d. Are at risk of involuntary displacement from their household’s existing neighborhood.

(The City wouldn’t recite the language as posed, but the substance is admitted.) 1

That prior to 2014, even in its federally-required “Affirmatively Furthering Fair Housing” statements, the City did not analyze citywide the extent to which the community preference policy may cause a disparate impact on the basis of race in affordable housing lotteries or may perpetuate segregation on the basis of race. 37, 38