UNITED STATES OF AMERICA,
     Plaintiff,

v.

CIVIL ACTION NO. 01-0046-CB-L

SATYAM, L.L.C., d/b/a Selma
Comfort Inn; NAVINABHAI
PATEL; and HINANAVINABHAI
PATEL,
     Defendants.

______________________________

1. INTRODUCTION

   On January 18, 2001, the United States filed a complaint in this action alleging that Defendants Satyam, L.L.C., d/b/a Selma Comfort Inn, Navinabhai Patel, and Hina Patel ("Defendants") violated Title II of the Civil Rights Act of 1964, 42 U.S.C. § 2000a et seq., by discriminating against African Americans in the provision of public accommodations. Defendant Satyam presently owns and operates the Comfort Inn ("Comfort Inn") in Selma, Alabama. Defendants Navinabhai Patel and Hina Patel previously worked at the Comfort Inn and continue to work in the hotel industry at the Plaza Motel in Ellisville, Mississippi. In its complaint, the United States alleges that Defendants have engaged in a pattern or practice of denying African Americans, on the basis of their race or color, the full and equal use and enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of the Comfort Inn.

   Specifically, the United States alleges that Defendants implemented this policy and practice by, among other things:

   1. Steering African American guests to rooms on the second floor of the hotel towards the back solely on the basis of race or color;

   2. Denying African American guests an opportunity to rent rooms on the first floor of the hotel while making these rooms available to white persons;

   3. Denying African American guests an opportunity to rent suites - which have more amenities and are more desirable than regular rooms at the hotel - while making suites available to white persons;

   4. Falsely telling African American guests that suites and first floor rooms were not available while telling white patrons that these rooms were available;

   5. Charging African American guests higher prices for renting rooms at the hotel than they charged white persons for the same type of room; and

   6. Denying African American guests access to facilities and services of the hotel, such as the pool, on the same terms and conditions as these facilities and services were provided to white guests.

   Defendants have at all times denied and continue to deny each of the allegations set forth in the United States' complaint and any allegations specifically made in Paragraphs A-F above.

   The parties have agreed that, to avoid protracted and costly litigation, this controversy should be resolved voluntarily. This Order is not an admission of liability and shall not be construed as an admission of liability as to any of the allegations of the United States, whether in the complaint or in any other document connected with this case.

   The parties have agreed to the following terms upon which this action will be fully and finally resolved and, as indicated by the signature of Satyam, L.L.C., Navinabhai Patel, and Hina Patel at the end of this document, have consented to the entry of this Order by the Court.

   The parties agree to abide by all of the terms of this Order in good faith, to support it fully, and to use their best efforts to defend this Order from any legal challenge, whether by appeal or collateral attack.

2. PURPOSES OF ORDER

   The parties have entered into this Order for the following purposes:

   1. To ensure that guests and visitors of the Selma Comfort Inn are, regardless of race or color, provided equal treatment, service, and access; and

   2. To provide finality to the resolution of all of the United States' claims and the Defendants' defenses asserted in this action.

3. JURISDICTION, SCOPE, AND TERM OF ORDER
   1. Jurisdiction. The parties stipulate and the Court finds that: (1) the Comfort Inn is a place of public accommodation within the meaning of 42 U.S.C. § 2000a(b)(1); (2) the Comfort Inn's operations affect interstate commerce within the meaning of 42 U.S.C. § 2000a(c)(1); and (3) this Court has personal jurisdiction over Defendants for purposes of this action and jurisdiction over this action pursuant to 42 U.S.C. § 2000a-6 and 28 U.S.C. §§ 1331, 1343 and 1345.

   2. Scope. All provisions of this Order shall apply to Defendants and their employees and agents at the Comfort Inn or any other place of public accommodation, as defined in Title II of the Civil Rights Act of 1964, in which Defendants presently have or subsequently acquire any ownership or management interest. At the present time, the public accommodations in which Defendants have an ownership or management interest are, for Satyam, the Comfort Inn; and for Navinabhai Patel and Hina Patel, the Plaza Motel in Ellisville, Mississippi.

   3. Term. The provisions of this Decree are effective immediately upon the entry of the Order by the Court. The Order shall be effective for a period of four (4) years. Upon entry of this Order the case will be dismissed with prejudice and the Court will retain jurisdiction solely to enforce this Order.

4. DEFINITIONS
   1. "Complaint" - includes any oral or written, formal or informal complaint, to any administrative or official body, 1-800 Complaint line, or to any officer, shareholder, employee, or agent of Comfort Inn.

   2. "Defendants" - Satyam, L.L.C., d/b/a Selma Comfort Inn, Navinabhai Patel, and Hina Patel.

   3. "Minority" - actual or perceived members of the following racial/ethnic categories: African Americans, Asian/Pacific Islanders, Latinos or Hispanics, and Native Americans.

   4. "Public accommodations as defined in Title II of the Civil Rights Act of 1964," - establishments affecting interstate commerce or supported in their activities by State action as places of public accommodation including but not limited to places of lodging (e.g. hotels and motels), restaurants, bars, clubs, lounges, gasoline stations, places of exhibition or entertainment and all the facilities or outlets owned or operated by a place of lodging, restaurants, bars, clubs, lounges, or places of exhibition or entertainment as public accommodations.

   5. "Family"- any father, mother, sibling, sibling-in-law, child, stepchild, uncle, aunt, first cousin or grandparent.

5. GENERAL PROVISIONS
   1. Defendants, together with their employees and agents at the Comfort Inn or any other place of public accommodation, as defined in Title II of the Civil Rights Act of 1964, including but not limited to hotel or motel establishments, restaurants, bars, clubs, and lounges, in which Defendants presently have or subsequently acquire any ownership or management interest, agree to be enjoined from:
      1. Denying to any person the full and equal enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of its hotel(s) based on the race or color of that person or anyone associated with that person;

      2. Denying lodging, or offering less favorable terms and conditions of lodging, to any person based on the race or color of that person or anyone associated with that person;

      3. Representing to any person that lodging is unavailable, when lodging is in fact so available, based on the race or color of that person or anyone associated with that person;

      4. Denying to any person the opportunity to rent a certain type of room, or a certain type of room in a certain location in a hotel, based on the race or color of that person or anyone associated with that person;

      5. Representing to any person that a certain type of room is unavailable, when it is in fact so available, based on the race or color of that person or anyone associated with that person;

      6. Assigning any person to a particular room or area of the hotel based on the race or color of that person or anyone associated with that person;

      7. Segregating any person to particular locations in a hotel based on the race or color of that person or anyone associated with that person;

      8. Conditioning availability of rooms or the quality of rooms assigned and/or provided on the guest's actual or perceived racial membership;

      9. Charging different room rates to any person based on the race or color of that person or anyone associated with that person;

      10. Imposing different requirements on any person for use of a hotel pool based on the race of that person or anyone associated with that person; and

      11. Adopting practices, policies or procedures in the management of a public accommodation that are designed to exclude, or have the effect of excluding, persons from lodging at the Comfort Inn or other hotel on the basis of their race or color or that are designed to discourage persons from patronizing such public accommodation on the basis of their race or color.

   2. Remedies
      1. Defendants agree that, for the duration of this Order, they will keep posted a sign that presently is posted behind the registration desk at the Comfort Inn in Selma. Any such signs currently posted behind desks shall be reprinted to reflect the correct mailing address and telephone number. The written text of the sign is attached hereto as Exhibit 1. The Defendants also agree that, for the duration of this Order, they will post equivalent signs and prominently display them behind each registration desk of any other place of public accommodation in which Defendants presently have or subsequently acquire any management or ownership interest.

      2. Defendants Navinabhai Patel and Hina Patel shall not conduct any of the duties and responsibilities of a manager, any other supervisory position, or employee at Comfort Inn for a period of three (3) years from the entry of this Order. Accordingly, Defendants Navinabhai Patel and Hina Patel shall not participate in or conduct training; participate in creating or implementing any policies regarding the Comfort Inn; or review, report, monitor, or supervise any Comfort Inn employees' compliance with this Order or any other job-related duties or responsibilities. At the end of the three year period, Defendants shall provide, in writing, to the United States a request, if applicable, for Defendant Navinabhai Patel's and Hina Patel's reinstatement to supervisory or managerial positions at Comfort Inn. Such request shall include certification of the training, detailed duties and responsibilities that Navinabhai Patel and Hina Patel are expected to undertake, and detailed provisions for the management and oversight of them during their reinstatement.

      3. Within thirty (30) days of the date of entry of this Order, Defendants shall submit for the United States approval, a procedure by which room assignments and reservations will be made without regard to the prospective guests race, color or national origin, including but not limited to, a provision whereby the assignment of rooms is predetermined and consistently applied, prospective guests are provided such room assignments on a first-come, first-serve basis and the rates of rooms are predetermined and consistently applied, subject to other applicable laws. This procedure shall include detailed records of such room assignments and prices charged, and the name, address and telephone number of the guest; date of reservation; date of arrival and departure; manner by which the reservation was made (e.g., walk in or telephone); and the name of the employee or agent taking the reservation, registering and checking out the guest.

         Additionally, a separate procedure shall be established for accepting reservations over the telephone or walk in. The necessary information requests for reserving a room shall be outlined. Defendants shall maintain a detailed record of all reservation inquiries and the dates for which the Comfort Inn was partially or fully occupied and the percentage of rooms occupied, including the dates and times when the 1-800 line for Choice Hotels International, Inc., franchisees was "closed out" or notified by Defendants that they were no longer accepting reservations made over the Choice Hotels International, Inc. 1-800 line.

         The United States shall have the right to inspect all records that Defendants maintain pursuant to the terms of this Order and all other records relevant to Defendants' compliance with this Order, including but not limited to, reservation inquiries, reservations, and guest lodging at the Comfort Inn and any other public accommodation in which any Defendants have an ownership or management interest, any time during the term of this Order upon reasonable notice to Navinabhai Patel, Hina Patel, or the then managing member of Satyam, L.L.C.

      4. Within sixty (60) days of the date of entry of this Order or by such date as the parties agree to be mutually satisfactory in light of the availability of the training resources referred to in this paragraph, Navinabhai Patel, Hina Patel, the current manager, assistant managers, desk clerks and those whose duties include taking or making reservations or assigning rooms at the Selma Comfort Inn, and a member of Satyam, L.L.C., in a representative capacity only, who is currently active in the management of the hotel, shall attend a program of educational training concerning the provisions of this Order, including the procedures established in paragraph 3 above, the substantive provisions of federal, state and local civil rights laws, regulations or ordinances applicable to places of public accommodation, and their responsibilities under such laws. The Fair Housing Center of Central Alabama shall conduct this training, which will be paid for and videotaped by Defendants. Defendants shall have the option of determining whether the training will take place in Montgomery or Selma. If in Montgomery, the cost of the program is $300. If in Selma, the cost is $500. All persons attending such a program shall have their attendance certified in writing by the person conducting the program.

         After the initial training of the above persons is conducted, new employees or agents of Defendants with responsibility for the management or provision of guest services shall be shown a copy of the videotape of this training when their employment commences. All persons watching this videotape shall sign a statement in the form of Exhibit 2 acknowledging that he or she has watched the video within fourteen (14) days of their employment's commencement.

      5. The Defendants shall, no later than ten (10) days after entry of this Order, apprize each of their employees, and agents, of Comfort Inn or any other place of public accommodation in which any Defendants have any ownership or management interest, of their obligations under this Order and under Title II of the Civil Rights Act of 1964. The Defendants shall furnish each such employee, and agent, covered by this paragraph with a copy of this Order. Each employee, and agent, covered by this paragraph shall sign a statement in the form of Exhibit 3 acknowledging that he or she has received, read, and understood a copy of this Order, and declaring that he or she will perform his or her duties in accordance with this Order and Title II of the Civil Rights Act of 1964. New employees of Defendants shall be apprized of the contents of this Order and of their obligations under Title II of the Civil Rights Act of 1964 when their employment commences, shall be provided a copy of this Order, and shall execute the statement appended hereto as Exhibit 3 no later than five (5) days following their first day of employment.

      6. Within sixty (60) days of the date of entry of this Order or by such date as the parties agree to be mutually satisfactory in light of the availability of the testing organization referred to in this paragraph, Defendants shall retain the Fair Housing Center of Central Alabama to conduct public accommodations testing at the Comfort Inn. "Testing" refers to an investigative process in which a similarly situated pair of individuals, or a group of individuals, is sent to and/or telephones the Comfort Inn under controlled circumstances to determine if Comfort Inn employees at that location are discriminating on the basis of race or color. Testing shall be conducted to include telephone reservations, walk-in reservations, room assignments, room rates, and other services and procedures in order to obtain information regarding the testers' full and equal use and enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of the Comfort Inn. The costs and expense of all tests shall be borne by Defendants, up to $3,000.00.

      7. The results of all tests conducted pursuant to this section and supporting documentation shall be reported to the United States within fifteen (15) days of the conclusion of completed tests. The United States retains the right to conduct its own testing of Comfort Inn or any other places of public accommodation owned or managed wholly or in part by any of the Defendants at any time. Where such results indicate a possible violation of this Order, the United States shall provide copies of all tests that the United States has conducted thus far to Defendants at least thirty days before presenting any such information to the Court.

      8. The Defendants shall pay for six (6) advertisements during the first twelve (12) months from the date of entry of this Order, in the Selma Times Journal. The Defendants shall place these advertisements approximately once every two (2) months during this period. These advertisements shall be no less than one eighth of one page of the newspaper, and shall indicate, inter alia, that the Comfort Inn provides lodging accommodations to all members of the public on an equal basis, without regard to race, color, religion, or national origin. The text for the advertisement shall include the language set forth in Exhibit 4. They may also contain any information about the hotel that Satyam, L.L.C., wants to advertise.

         For the duration of this Order, the Defendants shall include in any advertisement for Comfort Inn which are placed in any newspaper, billboard, trade publication, hotel or motel guide, or magazine or on radio or television or in any other media, the language set forth in Exhibit 4.

         For at least twelve (12) months from the date of approval of this decree, Satyam, L.L.C., shall pay for a billboard advertisement in Selma, Alabama, that contains, among other things, the language in Exhibit 4, in 8-inch letters and the name and location of the Selma Comfort Inn. If Satyam ceases to pay for this billboard advertisement, including the language in Exhibit 4, after the initial twelve months have elapsed, Satyam shall pay for three (3) additional advertisements in the Selma Times Journal. These second set of newspaper advertisements shall meet the same size and form specifications described above in this Section and shall be placed between twelve (12) and twenty-four (24) months following the date of entry of this Order.

6. REPORTING
   1. The Defendants, jointly, shall, no later than ninety (90) days after the date of entry of this Order, serve upon counsel for the United States a report explaining their efforts to comply with this Order. This report shall consist of the following:
      1. A photograph of the signs required under Section VB1 of this Order behind each registration desk at all public accommodations as defined under Title II of the Civil Rights Act of 1964, as described in the scope of this agreement;

      2. A list of all advertisements made public in any manner since the entry of this Order, pursuant to VB8 of this Order, together with representative samples of such advertisements, including a photograph of the billboard required under VB8 of this decree;

      3. Copies of the statements signed by any and all employees pursuant to Sections VB4 and VB5 of this Order;

   2. Six (6) months after the date of entry of this Order, and every six months thereafter for a period of four (4) years from the date of entry of this Order, the Defendants, jointly, shall serve on counsel for the United States a written report outlining their efforts to comply with this Order. In this report, the Defendants shall:
      1. Provide copies of all advertisements placed in any media in the preceding six-month period;

      2. Provide copies of all statements, required under Sections VB4 and VB5, which have been executed by new employees in the preceding six-month period;

      3. Notify counsel for the United States of any complaint which involves discrimination on the basis of race, color, religion, or national origin at Comfort Inn or at any other place of public accommodation, as defined in Title II of the Civil Rights Act of 1964, in which any of the Defendants presently have or subsequently acquire an ownership or management interest, and which has come to the attention of the Defendants or any of their employees, agents or other representatives in the preceding six-month period. The Defendants shall include a copy of all written complaints based upon race, color, religion or national origin in the report. If the complaint is oral, the Defendants shall provide a written summary of it in the report and shall include in the report the complainant's name, address and telephone number (if it can be obtained), which shall be documented in a log kept by the hotel to address such oral complaints. Defendants will make all reasonable efforts to provide such written information about oral complaints. With respect to each complaint, Defendants shall describe any action taken or proposed by the Defendants in response to the complaint;

      4. Notify counsel for the United States of any new ownership or management interest any of the Defendants have acquired or developed, or intend to acquire or develop, in any place of public accommodation, as defined in Title II of the Civil Rights Act of 1964, during the preceding six-month period. Such notification shall include the name of the establishment in which any of the Defendants have acquired or developed such interest, the address of such establishment, the goods and/or services provided by such establishment and the dates of operation of such establishment. Upon reasonable request, the Defendants shall provide to the United States copies of pertinent records or documents; and

      5. Notify counsel for the United States whether, during the preceding six-month period, the Defendants have ceased operating, or intend to cease operating, the Comfort Inn or any other place of public accommodation. Within ten (10) days following receipt of any written request from the United States to provide records or documents related to the selling or ceasing of operations, the Defendants shall provide to the United States copies of the requested records or documents.

7. ADMINISTRATION
   1. This Order shall not prevent Defendant Satyam, L.L.C., from selling the Comfort Inn or Navinabhai Patel or Hina Patel from selling any ownership interest they have in a place of public accommodation for value to a bona fide purchaser, provided that at least thirty (30) days before any such sale is closed, the Defendants shall notify counsel for the United States in writing of the transfer and provide sworn certification that (i) no individual Defendant, nor any officer or member of Satyam, nor any member of their family, will maintain any managerial, ownership, or other interest in the hotel; and (ii) the sale is an arms length transaction for value to a bona fide purchaser, not to include family, officers, or members of Satyam. This Order will not be binding on any person or entity that is a bona fide purchaser of the Selma Comfort Inn from Satyam, L.L.C., unless one or more of the members of Satyam, L.L.C., are members of the purchasing entity. This Order shall be binding on any other hotel operated by Satyam, L.L.C., Navinabhai Patel, or Hina Patel for the duration of this Order.

   2. This Order shall not be utilized as evidence in other cases, but can be used only to enforce the agreements entered into herein, or be admissible otherwise only by court order.

   3. This Court shall retain jurisdiction of this case solely for the purpose of enforcing this Order. The parties shall endeavor to resolve informally any differences regarding interpretation of or compliance with this Order prior to bringing such matters to the Court for resolution. Before any party brings such matter to the Court, the moving party shall file with the Court a certification that the parties have conferred in an attempt to resolve the dispute.

   4. This case is hereby dismissed with prejudice. Each party to this action shall bear his or her own costs of Court, expenses, and attorney fees.

It is so ORDERED, ADJUDGED and DECREED.

UNITED STATES DISTRICT JUDGE

FOR THE PLAINTIFF:
RALPH F. BOYD Assistant Attorney General JOAN A. MAGAGNA Chief Deputy Chief ISABELLE M. THABAULT Deputy Chief ELLEN M. BOWDEN Trial Attorney United States Department of Justice Civil Rights Division Housing and Civil Enforcement Section P.O. Box 65998 Washington, D.C. 20035-5998 (202) 305-0835 (202) 514-1116 (fax)	PATRICIA N. BEYER (BEYEP 0254) for DAVID P. YORK U.S. Attorney's Office for the Southern District of Alabama 63 South Royal Street, Suite 600 Mobile, AL 36602 (334) 441-5845 (334) 441-5277 (fax)
FOR THE DEFENDANTS:
Satyam, L.L.C d/b/a Comfort Inn By its registered agent 1812 Highway 14 East Selma, Al 36703 (334) 875-5700
Navinabhail ("Nick") Patel 5464 Highway 11 North Ellisville, MS 39437 (601) 426-2952
	Signature only for purposes of indicating approval as to form and substance:
Hina Patel 5464 Highway 11 North Ellisville, MS 39437 (601) 426-2952	GEORGE B. AZAR (AZARG3992) ELIZABETH C. WIBLE (WIBLE1925) AZAR & AZAR, L.L.C. Attorneys for Defendants

I have viewed a copy of videotape of civil rights training given by the Fair Housing Center of Central Alabama pursuant to the Order to Settle All Claims entered in United States v. Satyam, L.L.C., d/b/a Comfort Inn, Navinabhai Patel, and Hina Navinabhai Patel, Southern District of Alabama, Civil Action No. 01-0046-CB-L.

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Signature
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Name
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Home Address and Phone Number
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Date

I have been given and I have read a copy of the Consent Order to Settle All Claims entered in United States v. Satyam, L.L.C., d/b/a Comfort Inn, Navinabhai Patel, and Hina Navinabhai Patel, Southern District of Alabama, Civil Action No. 01-0046-CB-L. I understand the terms of that Order, and I further understand that federal law guarantees that no person may be denied, on account of their race, color, religion, or national origin the full use and enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of the Comfort Inn, or any other place of public accommodation owned or managed, in whole or in part, by any Defendant. With that understanding, I agree that, as a condition of my providing goods and/or services in the provision of accommodations on behalf of the Comfort Inn or any other place of public accommodation owned or managed, in whole or in part, by Defendants, neither I nor any other person who serves as my agent in any capacity, shall discriminate in any manner on account of race, color or national origin in the provision of such goods and/or services.

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Signature
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Name
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Home Address and Phone Number
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Date

Document Filed: April 3, 2002.

Document Entered: 2002.