IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA ATHENS DIVISION UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) ) No.: v. ) HLS ENTERPRISES, INC., ) ) Defendant. ) CONSENT ORDER AND JUDGMENT A. Background 1. On September 4, 1996, the United States filed an action to enforce title III of the Americans with Disabilities Act of 1990 (the "ADA"), 42 U.S.C. SS 12181 through 12189, against HLS Enterprises, Inc. (HLS), the owner of a Days Inn hotel at 302 Elbert Street, Elberton, Georgia ("the hotel" or the "Elberton Days Inn"). 2. On or about December 29, 1994, representatives of the United States Department of Justice, Civil Rights Division, visited and inspected the Elberton Days Inn, as part of an investigation of the hotel conducted pursuant to the Department of Justice's authority to review the compliance of entities covered by title III of the ADA, 42 U.S.C. S 12188. 28 C.F.R. S 36.502(c). 3. As a result of its investigation, including its inspection of the hotel, the Department of Justice identified 01-01155 several features, elements, and spaces of the Elberton Days Inn which failed to comply with the ADA's Standards for Accessible Design, 28 C.F.R. Part 36, Appendix A ("the Standards"). A list of the features, elements, and spaces of the hotel which did not comply with the Standards is attached hereto as Exhibit 1. 4. The parties have engaged in good faith negotiations in an effort to resolve this dispute expeditiously, without resort to litigation. The parties have agreed to enter into this agreement to be filed simultaneously with the United States' complaint. 5. As specified below, defendant has agreed to remedy the violations of the Standards set out in Exhibit 1. B. Agreement of the Parties Accordingly, by consent of the parties, it is hereby ORDERED and DECREED that: 1. This court has jurisdiction of this action under 42 U.S.C. S 12188(b)(1)(B) and 28 U.S.C. SS 1331 and 1345. The court may grant declaratory and other relief pursuant to 28 U.S.C. SS 2201 and 2202. 2. Venue is proper in this district. 3. The Elberton Days Inn is a non-residential facility whose operations affect commerce. As such, it is a commercial facility within the meaning of section 303(a) of the Act. 42 U.S.C. S 12183(a). In addition, because the Elberton Days Inn is - 2 - 01-01156 a place of lodging, it is also a public accommodation within the meaning of section 303(a) of the Act. Id. 4. The last building permit for the Elberton Days Inn was applied for on or about September 7, 1993. 5. The first certificate of occupancy for the Elberton Days Inn was issued on or about March 21, 1994. 6. Defendant HLS is a private entity which owns the Elberton Days Inn. Defendant HLS initiated, contracted for, and/or participated in the design and construction of the hotel. Defendant HLS contracted with an architect and a contractor for the design and construction of the Elberton Days Inn. 7. The Elberton Days Inn is not readily accessible to or usable by individuals with disabilities, as required by section 303(a)(1) of the Act, 42 U.S.C. S 12183(a)(1). The hotel fails in numerous respects to comply with the Department of Justice's regulation implementing title III of the ADA, 28 C.F.R. Part 36, including the Standards. See 28 C.F.R. SS 36.401, 36.406. 8. For the purpose of this agreement, the parties stipulate that the failures of defendant to design and construct the Elberton Days Inn to be readily accessible to and usable by individuals with disabilities constitute a pattern or practice of discrimination within the meaning of 42 U.S.C. S 12188(b)(1)(B)(i) and 28 C.F.R. S 36.503(a). 9. For the purpose of this agreement, the parties stipulate that the failures of the defendant to design and construct the Elberton Days Inn to be readily accessible to and - 3 - 01-01157 usable by individuals with disabilities constitute unlawful discrimination that raises an issue of general public importance within the meaning of 42 U.S.C. S 12188(b)(1)(B)(ii) and 28 C.F.R. S 36.503(b). 10. HLS contends that it believed that the hotel complied with the ADA, has never knowingly violated the Standards, and considers the hotel to be generally accessible to individuals with disabilities. Since being notified of the position of the Department of Justice, HLS has attempted to remedy the alleged violations that could be remedied quickly and to develop a plan for addressing all alleged violations. Although HLS disputed some of the findings of the Department of Justice concerning the alleged violations at the hotel, HLS enters into this Consent Order and Judgment for the purpose of avoiding litigation, and shall not dispute the validity of this Consent Order and Judgment, the jurisdiction of the court to enter it, or the authority of the Department of Justice to institute this action. This Consent Order and Judgment shall not constitute an admission by HLS of any wrongdoing or liability. 11. Not later than February 1, 1997, defendants will remedy each and every failure to comply with the Standards identified in Exhibit 1. The specific actions to be taken, and, where appropriate, the architectural plans to be followed, by the defendants to remedy the failures to comply with the Standards identified in Exhibit 1 are set forth in Exhibit 2. - 4 - 01-01158 12. Not later than March 1, 1997, the defendants shall provide to counsel for the United States a report on the status of their compliance with this Order. The report shall indicate which steps specified in Exhibit 2 have been completed. If any steps have not been completed, the report shall so indicate and explain why such steps have not been completed. 13. The parties shall negotiate in good faith to resolve any dispute relating to the interpretation or implementation of this Order before bringing the matter to the Court's attention. 14. The Court shall retain jurisdiction of this action to enforce the provisions of this Order through December 31, 1998, after which time all of its provisions shall be terminated, unless the Court determines it is necessary to extend any of its requirements, in which case those requirements shall be extended. 15. This agreement shall govern the compliance of defendant HLS with the ADA's Standards for Accessible Design at the Elberton Days Inn. This agreement does not address, and shall not be construed to address, any other issues of ADA compliance at the Elberton Days Inn, or at any other commercial facility or place of public accommodation designed and constructed by defendant HLS or owned, operated, leased, or leased by the HLS or any other violations of federal law. 16. Defendant HLS shall comply with the ADA Standards in any future involvement in the design and construction of a public accommodation or commercial facility. - 5 - 01-01159 17. This Consent Order shall be binding on HLS as well as any successor in interest. 18. This instrument reflects the entire agreement between the parties. SO ORDERED this day of , 1996. United States District Judge AGREED AND CONSENTED TO: For Plaintiff United States of America: ALYSE S. BASS Attorney Disability Rights Section Civil Rights Division United States Department of Justice Post Office Box 66738 Washington, D.C. 20035-6738 (202) 616-9511 For Defendant HLS: ROBERT LEVERETT Attorney for HLS Enterprises Inc. Heard, Leverett, Phelps, Weaver & Campbell 25 Thomas Street P.O. Drawer 399 Elberton, Georgia 30635-0399 (706) 283-2651 - 6 - 01-01160 EXHIBIT 1 Failures of the Elberton Days Inn to comply with the ADA's Standards for Accessible Design as identified by the U.S. Department of Justice 1. Parking and passenger loading zone violations a. There are no accessible parking spaces. There are 38 spaces in the lot; the Standards require two accessible spaces, including at least one van accessible space. Standards S 4.1.2(5). While two spaces are designated accessible, neither complies with the requirements of the Standards, as specified in items 1.b., c., d., e., f., and g., below. b. Neither of the parking spaces designated accessible is on the shortest route from the parking lot to the lobby entrance. Standards S 4.6.2. c. Neither of the parking spaces designated accessible is on an accessible route to the lobby entrance; from either space, a guest must traverse a sloping area of the hotel's exterior walkway that does not comply with the requirements for ramps. (See item 2.a., below.) Standards S 4.6.2. d. Both parking spaces designated accessible are too narrow. Standards S 4.6.3. e. Neither of the parking spaces designated accessible has an adequate access aisle; the access aisles provided are too narrow, and have slopes exceeding 1:50. Standards S 4.6.3. f. The parking space designated accessible at the front of the hotel has a slope exceeding 1:50. Standards S 4.6.3. g. Neither of the spaces designated accessible has a sign marking the space that will not be obscured by a vehicle parked in the space. Standards S 4.6.4. h. The passenger loading zone at the front entrance to the hotel lobby does not have a demarcated access aisle. Standards S 4.6.6. 2. Exterior route violations a. There is no accessible route connecting either the lobby or the swimming pool to either of the guest rooms designated accessible. At both the front and rear of 01-01161 the hotel, there is a portion of the exterior walkway with a slope of more than 1:12. These portions of the walkways do not comply with the requirements for ramps in that they are too steep, have no handrails, and have inadequate landings. Standards SS 4.3.8, 4.8. b. The light fixtures along most portions of the hotel's exterior walkways protrude more than 4" into the walkways. Standards S 4.4.1. 3. Violations at exterior and interior stairs and areas of rescue assistance a. The handrails on each of the hotel's stairways are too large in diameter, too far from the wall, and do not have adequate horizontal extensions at the top and bottom risers. Standards S 4.9.4. b. The design of the stairways at the front and rear of the hotel reduces vertical clearance adjacent to an accessible route to less than 80", but no barrier to warn blind or visually-impaired persons is provided. Standards S 4.4.2. c. There are no areas of rescue assistance on the second floor of the hotel. Standards SS 4.1.3(9), 4.3.11. 4. Entrance and exit violations a. The exterior entrance to the manager's apartment (which is being used as a storage area and employee lunch room) is not accessible, in that the door has hardware which requires tight grasping, pinching, or twisting of the wrist, and the threshold is too high. Standards SS 4.1.3(8), 4.13.8, 4.13.9. b. The exterior entrance to the hospitality suite (also designated guest room 104) is not accessible, in that the threshold is too high. Standards SS 4.1.3(8), 4.13.8. c. The door at the exterior entrance to the hotel laundry has hardware that requires tight grasping, pinching, or twisting of the wrist. Standards SS 4.1.3(8), 4.13.9. 5. Front lobby violations a. The registration desk is too high. Standards S 7.2. b. The light fixtures on the wall protrude more than 4" into the lobby. Standards S 4.4.1. 2 01-01162 6. Interior route violations a. The door to the storage area behind the front desk is too narrow. Standards S 4.13.5. b. There is inadequate maneuvering clearance for the side approach to the door from the lobby area to the area behind the front desk. Standards S 4.13.6. c. The hardware on the door from the lobby to the hospitality suite (also designated guest room 104) requires tight grasping, pinching, or twisting of the wrist, and is mounted too high. Standards S 4.13.9. 7. Violations with respect to public and common use toilet rooms a. The sign for the lobby restroom is not mounted on the wall adjacent to the door of the restroom. Standards S 4.30.6. b. The toilet in the lobby restroom is too far from the wall. Standards S 4.16.2. c. The grab bars for the toilet in the lobby restroom do not comply with the requirements of the Standards, in that the rear wall grab bar is too short, and the side wall grab bar does not project far enough from the rear wall. Standards S 4.16.4. d. The hot water and drain pipes under the lavatory in the lobby restroom are not insulated or otherwise configured to protect against contact. Standards S 4.19.4. e. The restroom used by guests or visitors using the hospitality suite (also designated guest room 104) is a standard hotel guest room bathroom, and is inaccessible. Standards S 4.1.3(11). 8. Violations with respect to public and common use rooms and spaces a. There are no visual alarms in the hospitality suite (also designated guest room 104). Standards S 4.28.1. 9. Violations with respect to guest rooms generally a. The guest room number signs are not mounted on the wall adjacent to the door for each guest room. Standards S 4.30.6. 3 01-01163 b. The guest rooms designated accessible are not dispersed among the various classes of sleeping accommodations available to patrons of the hotel, as specified below. Standards S 9.1.4. i) The hotel has at least one suite with a large whirpool tub, but none of the guest rooms designated accessible has such a tub. ii) Both of the guest rooms designated accessible are non-smoking rooms. The hotel has approximately 20 rooms where smoking is allowed, but none of those rooms is accessible. c. The hotel has no rooms with visual alarms and too few rooms with notification devices. The Standards require a hotel with 35 rooms to have four rooms with visual alarms and notification devices. The hotel has notification devices for only one room. Standards SS 9.1.2, 9.1.3, 9.3. d. The doors to the bathrooms in the guest rooms not designated accessible are too narrow. Standards SS 4.13.5, 9.4. 10. Violations with respect to guest rooms designated accessible -- Rooms 103 and 114 a. The thresholds at the doors to guest rooms 103 and 114 are too high. Standards S 4.13.8. b. In guest room 103 there is inadequate maneuvering space alongside and between the beds. Standards S 9.2.2. c. The deadbolts and locks on the connecting doors in guest rooms 103 and 114 require tight grasping, pinching, or twisting of the wrist, and are mounted too high. Standards S 4.13.9. d. The operating controls for the lamps and drapes in guest rooms 103 and 114 are too high, and require tight grasping, pinching, or twisting of the wrist. Standards S 4.27.4. e. The shelf above the clothes rod in guest rooms 103 and 114 is too high. Standards S 4.25.3. f. The bathroom doors in guest rooms 103 and 114 swing into the clear floor space required at both the lavatory and toilet. Standards S 4.23.2. 4 01-01164 g. The towel racks in the bathrooms in guest rooms 103 and 114 do not have adequate clear floor space, and are too high. Standards SS 4.25.2, 4.25.3. h. The toilets in the bathrooms in guest rooms 103 and 114 are too far from the side walls. Standards S 4.16.2. i. The grab bars for the toilets in guest rooms 103 and 114 do not comply with the requirements of the Standards, in that the rear wall grab bar is too short, and the side wall grab bar does not project far enough from the rear wall. Standards S 4.16.4. j. Use of the grab bar on the wall behind the toilet in the bathrooms in guest rooms 103 and 114 is obstructed by the towel rack mounted directly above the grab bar. Standards S 4.26.2. k. The grab bars in the bathtubs in guest rooms 103 and 114 do not comply with the requirements of the Standards, in that the grab bar at the foot of the tub is too short, and there is only one grab bar on the rear wall of the tub. Standards S 4.20.4. l. The controls for the bathtubs in guest rooms 103 and 114 are improperly located. Standards S 4.20.5. m. The hot water and drain pipes under the lavatories in guest rooms 103 and 114 are not insulated or otherwise configured to protect against contact. Standards S 4.19.4. 5 01-01165 EXHIBIT 2 Actions to be taken by HLS Enterprises, Inc. to remedy failures to comply with the ADA's Standards for Accessible Design, ("Standards") to remedy violations set out in Exhibit 1 1. Parking and passenger loading zone violations a. Two accessible parking spaces, including at least one van accessible space, with access aisles and signage will be provided, consistent with the Standards, SS 4.1.2(5), 4.6.2, 4.6.3, 4.6.4. An architect's drawing showing the accessible parking spaces is attached. b. One of the parking spaces designated accessible will be located on the shortest accessible route from the parking lot to the lobby entrance, consistent with the Standards, S 4.6.2. An architect's drawing showing the accessible parking spaces and accessible route is attached. c. Both accessible parking spaces will be modified to have a slope which does not exceed that allowed by the Standards, and both accessible parking spaces will be widened to 96", and will have the required access aisles, consistent with the Standards, S 4.6.3. An architect's drawing showing the modified accessible parking spaces and access aisles is attached. d. A demarcated access aisle and signage will be provided at the passenger loading zone at the front entrance at the hotel lobby, consistent with the Standards, S 4.6.6. An architect's drawing showing the demarcated access aisle is attached. e. A curb ramp will be installed at the lobby entrance, consistent with the Standards, SS 4.6.6, 4.7. An architect's drawing showing the accessible curb ramp is attached. 2. Exterior route violations a. The route from the swimming pool to the accessible guest rooms will be made accessible, consistent with the Standards, SS 4.1.2(2), 4.3. An architect's drawing showing the modified accessible route is attached. 01-01166 b. A ramp with the required slope, signage, and handrails will be installed at the accessible walkway adjacent to accessible guest room 103, consistent with the Standards, SS 4.3.8, 4.8. An architect's drawing showing the modified accessible walkway, parking space and guest room is attached. 3. Violations at exterior and interior stairs a. Handrails between 1 1/4 inches to 1 1/2 inches in diameter will be installed not more than 1 1/2 inches from the wall with rail extensions returning in the direction of egress traffic for the required length at the top and bottom risers in each of the hotel's stairways, consistent with the Standards, SS 4.9.4, 4.26. An architect's drawing showing the handrails with horizontal extensions is attached. b. Barriers to warn blind or visually impaired persons will be provided at the underside of the existing stairs, consistent with the Standards, S 4.4.2. An architect's drawing showing the cane-detectable barriers is attached. 4. Entrance and exit violations a. The existing hardware on the door to the employee lunch room and storage area will be replaced with hardware that is consistent with the Standards, and the threshold will be lowered to a height that is consistent with the Standards, SS 4.1.3(8), 4.13.8, 4.13.9. b. A threshold to the guest room formerly designated as a hospitality suite will be installed that is consistent with the Standards, SS 4.1.3(8), 4.13.8. c. The existing hardware on the door at the exterior entrance to the hotel laundry will be replaced with hardware that is consistent with the Standards, SS 4.1.3(8), 4.13.9. 5. Front lobby violations a. An additional registration table of the required height will be provided in the lobby, and a house telephone with volume control will be located at the required height, consistent with the Standards, SS 7.2, 4.31. An architect's drawing showing the modified accessible front desk area and house telephone is attached. 2 01-01167 b. The door between the lobby and the staff area will be relocated to allow for the required maneuvering space, consistent with the Standards, S 4.13. An architect's drawing showing the modified accessible door is attached. c. A visual fire alarm will be installed in the lobby, and will be tied in to the building-wide fire alarm system, consistent with the Standards, S 4.28. An architect's drawing showing the lobby visual fire alarm is attached. 6. Interior route violations a. The door to the storage area behind the front desk will be removed, and the doorway enlarged to a width that is consistent with the Standards, S 4.13.5. An architect's drawing showing the modified accessible doorway is attached. 7. Violations with respect to public and common use toilet rooms a. The sign for the lobby restroom will be mounted on the wall adjacent to the restroom door, consistent with the Standards, S 4.30.6. b. The existing rear and side grab bars in the lobby restroom will be replaced with grab bars of the required length, mounted at the required heights, and at the required distance from the bathroom walls, consistent with the Standards, S 4.16.4. An architect's drawing showing the modified accessible lobby restroom and grab bars is attached. c. The drain and hot water pipes in the lobby restroom will be insulated against contact, consistent with the Standards, S 4.19.4. d. A visual fire alarm will be installed in the lobby restroom and will be tied in to the building-wide fire alarm system, consistent with the Standards, SS 4.1, 4.28. 8. Violations with respect to public and common use rooms and spaces a. The hardware on the pool gate will be mounted at the required height, consistent with the Standards, SS 4.3.1, 4.13.9. An architect's drawing showing the placement of the pool gate hardware is attached. 3 01-01168 9. Violations with respect to guest rooms generally a. Guest room number signs will be mounted on the wall adjacent to the latch side of the door for each guest room, consistent with the Standards, S 4.30.6. b. Visual alarms and notification devices will be installed in 4 guest rooms and will be tied into the building-wide system, including visual fire alarm strobes in two guest rooms, consistent with the Standards, SS 9.1.2, 9.1.3, 9.3. An architect's drawing showing the required visual alarms and notification devices is attached. c. Doors to bathrooms in all the first floor standard guest rooms will be modified to have the required 32" clear opening width, consistent with the Standards, SS 4.13.5, 9.4. An architect's drawing showing the modified accessible bathroom doors is attached. 10. Violations with respect to guest rooms designated accessible -- Rooms 103 and 114 a. The thresholds in guest rooms 103 and 114 will be modified to have heights that are consistent with the Standards, S 4.13.8. b. One of the guest rooms designated accessible will have two double beds, and the other will have one king size bed, consistent with the Standards, S 9.1.4. An architect's drawing showing the modified accessible guest rooms is attached. c. The beds in the accessible guest room with two double beds will be reconfigured to provide the required maneuvering space alongside and between the beds, consistent with the Standards, S 9.2.2. An architect's drawing showing the modified accessible guest room is attached. d. The existing hardware on the connecting doors between guest rooms 103 and 114 will be replaced with hardware that is easy to grasp with one hand and does not require tight grasping, pinching or twisting of the wrist to operate, consistent with the Standards, S 4.13.9. e. The existing operating controls on the lamps and drapes in guest rooms 103 and 114 will be replaced with operating controls that are consistent with the Standards, S 4.27.4. 4 01-01169 f. The shelf above the clothes rod in guest rooms 103 and 114 will be mounted at a height that is consistent with the Standards, S 4.25.3. An architect's drawing showing the modified accessible shelf is attached. g. The bathroom doors in guest rooms 103 and 114 will be modified so as not to swing out into the required clear floor space at the lavatory and toilet, consistent with the Standards, S 4.23.2. An architect's drawing showing the modified accessible bathroom doors and clear floor space is attached. h. The towel racks in the bathrooms in guest rooms 103 and 114 will be remounted so as not to encroach on required clear floor space and at a height that is consistent with the Standards, SS 4.25.2, 4.25.3. An architect's drawing showing the modified accessible bathrooms and towel racks is attached. i. The toilets in the bathrooms in guest rooms 103 and 114 will be repositioned to the required distance from the sidewall to the center, consistent with the Standards, S 4.16.2. An architect's drawing showing the modified accessible toilets is attached. j. The existing rear and side grab bars in the toilets in guest rooms 103 and 114 will be replaced with grab bars of the required length, and will be mounted at the required height, consistent with the Standards, S 4.16.4. An architect's drawing showing the modified accessible toilets and grab bars is attached. k. The towel rack above the grab bar in guest rooms 103 and 114 will be mounted so as not to interfere with use of the rear grab bar, consistent with the Standards, S 4.20.4. An architect's drawing showing the modified accessible towel rack is attached. l. The existing foot and rear grab bars in the bathtubs in guest rooms 103 and 114 will be replaced with grab bars of the required length, and will be mounted at the required height, consistent with the Standards, S 4.20.4. An architect's drawing showing the accessible grab bars is attached. m. The operating controls for the bathtubs in guest rooms 103 and 114 will be repositioned, consistent with the Standards S 4.20.5. An architect's drawing showing the placement of the accessible operating controls is attached. 5 01-01170 n. The drain and hot water pipes at the lavatories in guestrooms 103 and 114 will be protected from contact, consistent with the Standards, S 4.19.4. o. The security devices on the doors in guestrooms 103 and 114 will be mounted at the required height, consistent with the Standards, S 4.13.9. p. The guest rooms designated accessible will have signs with both raised lettering and Braille mounted on the wall adjacent to the door at the required height, consistent with the Standards, S 4.30. An architect's drawing showing the placement of the signs is attached. 6 01-01171 SOUTHERN DESIGNS L I M I T E D July 24, 1996 Alyse S. Bass, Esq. U.S. Department of Justice Civil Rights Division 1425 New York Avenue, Suite 4039 P.O. Box 66738 Washington, D.C. 20035-6738 Re: Days Inn Elberton, Georgia Dear Ms. Bass: As per our conversation last week, the following items shall be noted; 1. Slope arrow shall be shown on all ramps. (revision # 28) 2. The side flare on the ramps shall be dimensioning. (revision # 29) 3. Handicap accessible ramp at rooms 103 and 104 shall have handrails. (revision # 30) 4. Stair handrails shall be 34" to 38" AFF. (revision # 31) 5. Grab bars shall be L-shape 36" x 54". (revision # 32) 6. No special signage is needed for handicap rooms. (revision # 33) 7. The visual alarm shall be mounted 6" below finish ceiling and between 80" and 96" AFF. (revision # 34) 8. Layout of the beds in handicap rooms 103 and 114 are satisfactory. (revision # 35) 9. The door at lobby/office shall have no door closure. (revision # 36) 10. Addendum shall be made to the specifications stating hardware shall be single leaver type. (revision # 37) 1 1 8 EAST EARLE STREET SUITE A ANDERSON, S.C. 29621 (864) 225-0141 01-01172 Ms Bass Page 2 July 24, 1996 Thank you for working with us on this project. If you shall have any further questions or concerns please call me. Look forward to your response. Sincerely, Ray E. Cox, Jr. REC:tc cc: Mr Ricky Patel Mr Robert Leverett Enclosure 01-01173 ADDENDUM NUMBER ONE Days Inn Elberton, Ga. Architect: Southern Design Anderson, South Carolina Architects Project Number 18 July 1996 Addendum number one consists of modifications/changes to the specification and drawings. SPECIFICATIONS/DRAWINGS In section 8 DOORS AND WINDOWS for the clear meaning all lock/latch operations shall be leaver handles, no knobs are to be allowed. Leavers to be brushed, stainless steel finish to match existing on site. All other information contained on the drawings and in the specifications is to remain as is. END OF ADDENDUM NUMBER ONE. 01-01174 THE DAYS INN ELBERTON, GA. RENOVATION TO EXISTING DAYS INN ELBERTON, GA. FOR AMERICANS WITH DISABILITIES ACT COMPLIANCE AND U.S. DEPARTMENT OF JUSTICE SETTLEMENT PURPOSES DRAWING INDEX A COVER SHEET A-1 SITE PLAN A-2 FLOOR PLANS AND DETAILS 01-01175 (MAP) SITE PLAN 01-01176 (MAP) FLOOR PLAN ROOMS 102, 103, 113 & 114 01-01177