NEAL & ENG
                             ATTORNEYS AT LAW
1361 PEARL STREET                                            DAN E. NEAL
EUGENE, OREGON 97401                                         FERN ENG
(503) 484-7311

August 5, 1992

Office on the Americans With Disabilities Act
Civil Rights Division
U. S. Department of Justice
P. O. Box 66118
Washington, D.C. 20035-6118

                Re:     Compliance with ADA at 1361 Pearl Street
                        Eugene, Oregon

To Whom It May Concern:

        I understand that your office is available to provide
technical assistance and advice on compliance with the ADA. In
reviewing the ADA, I believe that our law office is in compliance
but I would be most grateful if you would review the situation, as
I outline it in this letter, and provide me with your comments.
Our law office normally employs three individuals for staff support
in addition to serving as the office for four attorneys. The
office is the sole occupant of a two story building with
approximately 2000 square feet. Two of the attorney's offices are
located on the second floor which is accessible by a staircase.
The office has one doorway which is open to the public. Entrance
to the doorway requires one to climb two steps. I believe that the
width of the doorway is less than would be required in new
construction. The building itself is nearly 100 years old and is
of a somewhat Victorian style. I have been contacted by the local
government's Historic Review Board on several occasions about the
possibility of having the property formally listed as a historic
structure, but thus far, I have been reluctant to ask for the
property to be so listed. However, I am quite sensitive about
preserving the building. Such structures are rare in Eugene and I
believe that it is of value to the community at large to preserve
historic structures such as this office.

        Our office engages in the private practice of law. In
addition, we offer services as court appointed counsel for
qualified members of the public. The City of Eugene provides an
office at City Hall where we can perform public defender services.
This alternative location is in full compliance with the ADA, as I
understand it.

        My review of the Act leads me to conclude that we are under no
obligation to modify our telephone system (i.e., because there are
no pay phones in our building, TDD's aren't required, correct?),
install a handicap access ramp, modify our bathroom or widen any


Office on the Americans With Disabilities Act
August 5, 1992
Page 2

doorways. In addition, I understand that we are under no
obligation to undertake any other revisions. If you believe that
this conclusion may be incorrect, please let me know as soon as
possible. Please feel free to call and you certainly may call
collect if you wish. Thank you for your assistance in this matter.
I look forward to hearing from you.

Sincerely,

Dan E. Neal

DEN:pap
01-01517