SETTLEMENT AGREEMENT
BETWEEN
THE UNITED STATES OF AMERICA
AND
HARTFORD, CONNECTICUT
UNDER THE AMERICANS WITH DISABILITIES
ACT
DJ 204-14-130
BACKGROUND
SCOPE OF THE INVESTIGATION
The United States Department of Justice (Department) initiated this
matter as a compliance review of Hartford, Connecticut, under title II of the
Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. §§ 12131-12134, and the
Department’s implementing regulation, 28 C.F.R. Part 35. Because the City receives financial
assistance from the Department of Justice, the review was also conducted under
the authority of section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794,
and the Department’s implementing regulation, 28 C.F.R. Part 42, Subpart G.
The review was conducted by the Disability Rights Section of the
Department’s Civil Rights Division and focused on the City’s compliance with the
following title II requirements:
C
to conduct a self-evaluation of its services, policies, and practices by
July 26, 1992, and make modifications necessary to comply with the Department’s
title II regulation, 28 C.F.R. § 35.105;
C
to notify applicants, participants, beneficiaries, and other interested
persons of their rights and the City’s obligations under title II and the
Department’s regulation, 28 C.F.R. § 35.106;
C
to designate a responsible employee to coordinate its efforts to comply
with and carry out the City’s ADA responsibilities, 28 C.F.R. §
35.107(a);
C
to establish a grievance procedure for resolving complaints of violations
of title II, 28 C.F.R. § 35.107(b);
C
to operate each program, service, or activity so that, when viewed in its
entirety, it is readily accessible to and usable by individuals with
disabilities, 28 C.F.R. § 35.150, by:
C delivery of services, programs, or activities in alternate ways, including, for example, redesign of equipment, reassignment of services, assignment of aides, home visits, or other methods of compliance or, if these methods are not effective in making the programs accessible,
C physical changes to buildings (required to have been made by January 26, 1995), in accordance with the Department’s title II regulation, 28 C.F.R. § 35.151, and the ADA Standards for Accessible Design (Standards), 28 C.F.R. pt. 36, App. A, or the Uniform Federal Accessibility Standards (UFAS), 41 C.F.R. § 101-19.6, App. A.
C
to ensure that facilities for which construction or alteration was begun
after January 26, 1992, are readily accessible to and usable by people with
disabilities, in accordance with 1) the Department’s title II regulation and 2)
the Standards or UFAS, 28 C.F.R. § 35.151;
C
to ensure that communications with applicants, participants, and members
of the public with disabilities are as effective as communications with others,
including furnishing auxiliary aids and services when necessary, 28 C.F.R. §
35.160;
C
to provide direct access via TTY (text telephone) or
computer-to-telephone emergency services, including 9-1-1 services, for persons
who use TTY’s and computer modems, 28 C.F.R. § 35.162;
C
to provide information for interested persons with disabilities
concerning the existence and location of the City’s accessible services,
activities, and facilities, 28 C.F.R. § 35.163(a); and
C
to provide signage at all inaccessible entrances to each of its
facilities, directing users to an accessible entrance or to information about
accessible facilities, 28 C.F.R. § 35.163(b).
As part of its compliance review, the Department reviewed the following
facilities, which – because construction or alterations commenced after January
26, 1992 – must comply with the ADA’s new construction or alterations
requirements: Central Library at 500 Main Street; North End Senior Center at 80
Coventry Street; Police Station North at 636 Albany Avenue; Police Station South
at 134 Affleck Street; Pope Park Recreation Center at 30 Pope Park Drive; Campfield
Branch Library at 30 Campfield Avenue; Colt Park Pool and Bathhouse at
Wethersfield Avenue; Cronin Park and Field House at Granby and Durham Streets;
Elizabeth Park Greenhouses and Information Center at Asylum Avenue; Elizabeth
Park Pond House and Pond House Café at Asylum Avenue; Fire Training Academy at 1
Fischer Road; Goodwin Branch Library at 460 New Britain Avenue; Goodwin Park, Bucior Pool, and
Bathhouse at Hubbard Road and South Street; Keney Park - Barbour Field House at
Barbour and Tower Avenues; Keney Park - Waverly Field House at Vine and Edgewood
Streets; Keney Park Pool and Bathhouse at 323 Edgewood Street; and Willie Ware
Recreation Center at 697 Windsor Avenue.
The Department’s program access review covered those of the City’s
programs, services, and activities that operate in the following facilities:
Albany Branch Library at
1250 Albany Avenue; Anderson Recreation Center and Indoor Pool at 2621 Main Street; Blue Hills
Recreation Center at 9 Lebanon
Street; City Hall at 550 Main
Street; City Hall Annex at 525 Main
Street; Colt Park Administration Building at 25 Stonington Street; Dillon
Stadium at 250 Huyshope Avenue; Fire Headquarters at 275 Pearl Street; Fire
Station - Engine Co. 1 at 197 Main Street; Fire Station - Engine Co. 2 at 1515 Main Street; Fire
Station - Engine Co. 5 at 129 Sigourney Street; Fire Station - Engine Co. 7 at
181 Clark Street; Fire Station - Engine Co. 8 at 721 Park Street; Fire Station - Engine Co. 9 at 655 New
Britain Avenue; Fire Station - Engine Co. 10 at 510 Franklin Avenue; Fire
Station - Engine Co. 11 at 150 Sisson Avenue; Fire Station - Engine Co. 14 at 25
Blue Hills Avenue; Fire Station - Engine Co. 15 at 8 Fairfield Avenue; Fire
Station - Engine Co. 16 at 636 Blue Hills Avenue; Goodwin Park Pond House at
Hubbard Road and South Street; Goodwin Park Golf Course at 1192 Maple Avenue;
Horse Stables at the Keney Service
Yard; Hyland Recreation and Day Care Center at 35 New Britain Avenue; Keney Park
Golf Course at 280 Tower Avenue; Keney Park Pond House at 323 Edgewood Street; McCook Day
Care Center at 36 Coventry Street;
McCook Family Center at 2 Coventry
Street; McCook Health and Human Services Department at 2 Holcomb Street; Metzner
Recreation Center and Day Care at 680 Franklin Street; Police Headquarters at 50 Jennings Road; Pope Park Pool
and Bathhouse at 338 Park Terrace; Public Works Yard at the 40 Jennings Road; and Rocky
Ridge Park at Zion
Street.
The Department’s program access review covered those of the City’s
programs, services, and activities that are operated by the City at facilities
owned or controlled by other entities, including: 250 Constitution Plaza; 260
Constitution Plaza; Burgdorf - Fleet Health Center at 131 Coventry Street; and
Park Branch Library at 744 Park
Street.
The Department reviewed the City’s policies and procedures regarding
notification of ADA policies, effective communication, emergency management and
disaster prevention, sidewalk maintenance, and accessibility of web-based
programs to evaluate whether persons with disabilities have an equal opportunity
to utilize these programs.
Finally, the Department reviewed the City’s Police Department’s policies
and procedures regarding providing effective communication to persons who are
deaf or hard-of-hearing.
JURISDICTION
1. The ADA applies to the City because it is a “public entity” as defined by title II. 42 U.S.C. § 12131(1).
2.
The Department is authorized under 28 C.F.R. Part 35, Subpart F, to
determine the compliance of the City with title II of the ADA and the
Department's title II implementing regulation, to issue findings, and, where
appropriate, to negotiate and secure voluntary compliance agreements. Furthermore, the Attorney General is
authorized, under 42 U.S.C. § 12133, to bring a civil action enforcing title II
of the ADA should the Department fail to secure voluntary compliance pursuant to
Subpart F.
3.
The Department is authorized under 28 C.F.R. Part 42, Subpart G, to
determine the City’s compliance with section 504 of the Rehabilitation Act of
1973, to issue findings, and, where appropriate, to negotiate and secure
voluntary compliance agreements.
Furthermore, the Attorney General is authorized, under 29 U.S.C. § 794
and 28 C.F.R. §§ 42.530 and 42.108-110, to suspend or terminate financial
assistance to the City provided by the Department of Justice should the
Department fail to secure voluntary compliance pursuant to Subpart G or to bring
a civil suit to enforce the rights of the United States under applicable
federal, state, or local law.
4.
The parties to this Agreement are the United States of America and the
City of Hartford, Connecticut.
5.
In order to avoid the burdens and expenses of an investigation and
possible litigation, the parties enter into this Agreement.
6.
In consideration of, and consistent with, the terms of this Agreement,
the Attorney General agrees to refrain from filing a civil suit in this matter
regarding all matters contained within this Agreement, except as provided in the
section entitled “Implementation and Enforcement.”
ACTIONS TAKEN BY
CITY
7.
The City has adopted and implemented a public notice regarding the
ADA. The Notice advises the public
that the City does not discriminate against persons with disabilities and
informs the public that reasonable accommodations and publications in alternate
formats, such as Braille, large print, cassette tapes, etc., are available upon
request. The Notice advises the
public of the ADA Coordinator’s contact information, which includes a voice/TYY
telephone number.
8.
The City is firmly committed to the ideal and spirit of the ADA. It has a designated ADA Coordinator and
adopted a City Ordinance that created a Commission on Disability Issues
(Commission) in 1977. The
Commission is comprised of interested citizens that meet regularly to discuss
issues and concerns. Its function
is to advise the City Council and the Mayor, and provide guidance to City
departments, on all matters related to program and physical access for persons
with disabilities to City programs, services, and activities. Similarly, the Commission also reviews
proposed construction designs to ensure that newly constructed residential and
commercial buildings comply with Federal, State, and local accessibility
requirements.
9.
The City’s Human Relations Commission, Disability Issues Unit, conducted
a self-evaluation in 1987 in an on-going effort to ensure that the City is in
compliance with Section 504 of the Rehabilitation Act of 1973. In November of 1989 the City had thirty
five City buildings surveyed for physical accessibility and completed its
transition plan, which contains recommendations for physical modifications and
installation of equipment to these buildings. As a result, the City has systematically
increased the number of programs, services, and activities accessible to
individuals with disabilities.
10. The City
has adopted and implemented an ADA Grievance Procedure in order to help ensure
that persons with disabilities have access to all City programs, services, and
activities. Any person who feels
they have been unfairly denied access to, or the benefits of any City program,
service, or activity based upon a disability, may submit a complaint to the
responsible Department Head who shall respond to such complaint in writing
within 10 days.
11. Beginning
in 1978, the vast majority of City sidewalks and street-level pedestrian
walkways were built or modified to be accessible under the Standards and/or the
Uniform Federal Accessibility Standards (UFAS) as part of the City’s sidewalk
accessibility improvement projects and the streetscape accessibility improvement
projects.
REMEDIAL
ACTION
NOTIFICATION
12. Within
three months of the effective date of this Agreement, the City will distribute
its “Public Notice: Americans with Disabilities Act” to all agency heads;
publish the Notice in a local newspaper of general circulation serving the City;
post the Notice on its Internet Home Page; and post copies in conspicuous
locations in its public buildings.
It will refresh the posted copies, and update the contact information
contained on the Notice, as necessary, for the life of this Agreement. Copies will also be provided to any
person upon request.
GENERAL EFFECTIVE COMMUNICATION
PROVISIONS
13. Within six
months of the effective date of this Agreement, the City will identify sources
of qualified sign language and oral interpreters, real-time transcription
services, and will implement and report to the Department its written
procedures, with time frames, for fulfilling requests from the public for sign
language or oral interpreters and real-time transcription services. The City will continue to provide
documents in alternate formats (Braille, large print, cassette tapes,
etc.).
14. The City
will take steps to ensure that all appropriate employees are trained and
practiced in using the Connecticut Relay Service to make and receive
calls.
9-1-1
15. The City
will incorporate correct TTY call-taking procedures into 9-1-1 call takers’
performance evaluations and will amend its personnel policies to include written
disciplinary procedures for call takers who fail to perform TTY call-taking
consistent with the training and procedures. The City will implement and report to
the Department its evaluation and procedures within three months of the
effective date of this Agreement.
LAW ENFORCEMENT AND EFFECTIVE
COMMUNICATION
16. Within
three months of the effective date of this Agreement, the City
will distribute to all police
officers the Guide for Law
Enforcement Officers When in Contact with People Who are Deaf or Hard of
Hearing [Attachment D].
17. Throughout
the term of this Agreement, the City will continue to ensure that oral/sign
language interpreting services are available on a priority basis, twenty-four
hours per day, seven days a week, to its police department.
18. Within six
months of the effective date of this Agreement, the City
will ensure that each police station or substation and each jail
is equipped with a working TTY to enable persons who are deaf, hard of hearing,
or who have speech impairments to make outgoing telephone calls. Where inmate telephone calls are
time-limited, the City will adopt policies permitting inmates who use TTY’s a
longer period of time to make those calls, due to the slower nature of TTY
communications compared with voice communications.
VOTING
19. This
agreement does not address the accessibility of voting equipment or voting
systems, including polling place accessibility, or any modifications to
polling-related policies and procedures that may be necessary to ensure access
for persons with disabilities.
EMERGENCY MANAGEMENT PROCEDURES AND
POLICIES
20. If the City
contracts with another entity, such as the American Red Cross or another local
government, to provide its emergency preparedness plans and emergency response
services, the City will ensure that the other entity complies with the following
provisions on its behalf.
21. Within one
year of the effective date of this Agreement, the City will implement and report
to the Department its written procedures that ensure that it regularly solicits
and incorporates input from persons with a variety of disabilities and those who
serve them regarding all phases of its emergency management plan (preparation,
notification, response, and clean up).
22. Within one
year of the effective date of this Agreement, the City will implement and report
to the Department its written procedures that ensure that its community
evacuation plans enable those who have mobility impairments, vision impairments,
hearing impairments, cognitive disabilities, mental illness, or other
disabilities to safely self-evacuate or be evacuated by others. Some communities are instituting
voluntary, confidential registries of persons with disabilities who may need
individualized evacuation assistance or notification. If the City adopts or maintains such a
registry, its report to the Department will discuss its procedures for ensuring
voluntariness, appropriate confidentiality controls, and how the registry will
be kept updated, as well as its outreach plan to inform persons with
disabilities of its availability.
Whether or not a registry is used, the City plan should address
accessible transportation needs for persons with disabilities.
23. Within one
year of the effective date of this Agreement, the City will implement and report
to the Department its written procedures that ensure that if its emergency
warning systems use sirens or other audible alerts, it will also provide ways to
inform persons with hearing impairments of an impending disaster. The use of auto-dialed TTY messages to
pre-registered individuals who are deaf or hard of hearing, text messaging,
e-mails, open-captioning on local TV stations and other innovative uses of
technology may be incorporated into such procedures, as well as lower-tech
options such as dispatching qualified sign language interpreters to assist with
emergency TV broadcasts.
24. Within one
year of the effective date of this Agreement, the City will implement and report
to the Department its written procedures that ensure that at least one emergency
shelter has a back-up generator and a way to keep medications refrigerated (such
as a refrigerator or a cooler with ice).
Such shelter(s) will be made available to persons whose disabilities
require access to electricity and refrigeration, for example, for using
life-sustaining medical devices, providing power to motorized wheelchairs, and
preserving certain medications, such as insulin, that require
refrigeration. The written
procedures will include a plan for notifying persons of the location of such
shelter(s).
25. Within one
year of the effective date of this Agreement, the City will implement and report
to the Department its written procedures that ensure that persons who use
service animals are not separated from their service animals when sheltering
during an emergency, even if pets are normally prohibited in shelters. The procedures will not unnecessarily
segregate persons who use service animals from others but may take into account
the potential presence of persons who, for safety or health reasons, should not
be in contact with certain types of animals.
26. Some of the
of the City’s emergency shelters may be owned or operated by other public
entities subject to title II or by public accommodations subject to title III,
such as Weaver High School, Hartford High School, and Bulkeley High School, and
are subject to the obligation to provide program access or remove barriers to
accessibility under the ADA. This
Agreement does not limit such future enforcement action against the owners or
operators of these facilities by any person or entity, including the
Department.
27. To the
extent that the City provides opportunities for post-emergency temporary housing
to its residents, within three months of the effective date of this Agreement,
it will develop, implement, and report to the Department its plans for providing
equivalent opportunities for accessible post-emergency temporary housing to
persons with disabilities. Within
one year of the effective date of this Agreement, the City will ensure that
information it makes available regarding temporary housing includes information
on accessible housing (such as accessible hotel rooms within the community or in
nearby communities) that could be used if people with disabilities cannot
immediately return home after a disaster if, for instance, necessary accessible
features such as ramps or electrical systems have been
compromised.
SIDEWALKS
28. Within six
months of the effective date of this Agreement, the City will implement and
report to the Department its written process for soliciting and receiving input
from persons with disabilities regarding the accessibility of its sidewalks,
including, for example, requests to add curb cuts at particular
locations.
29. Within one
year of the effective date of this Agreement, the City will identify and report
to the Department all remaining streets, roads, and highways that were not built
or modified to be accessible as part of the City’s sidewalk accessibility
projects. Within nine years of the
effective date of this Agreement, the City will provide curb ramps or other
sloped areas complying with the Standards or UFAS at all remaining intersections
of the streets, roads, and highways having curbs or other barriers to entry from
a street level pedestrian walkway.
30. Beginning
no later than six months after the effective date of this Agreement, the City
will provide curb ramps or other sloped areas complying with the
Standards or UFAS at any intersection having curbs or other barriers to entry
from a street level pedestrian walkway, whenever a new street, road, or highway
is constructed or altered.
31. Within one
year of the effective date of this Agreement, the City will identify and report
to the Department all remaining street level pedestrian walkways that were not
built or modified to be accessible as part of the City’s streetscape
accessibility projects. Within nine
years of the effective date of this Agreement, the City will provide curb ramps
or other sloped areas complying with the Standards or UFAS at all places where a
street level pedestrian walkway intersects with a street, road, or
highway.
32. Beginning
no later than six months after the effective date of this Agreement, the City
will provide curb ramps or other sloped areas complying with the Standards or
UFAS at all newly constructed or altered pedestrian walkways where they
intersect a street, road, or highway.
WEB-BASED SERVICES AND
PROGRAMS
33. Within
three months of the effective date of this Agreement, and on subsequent
anniversaries of the effective date of this Agreement, the City will distribute
to all persons – employees and contractors – who design, develop, maintain, or
otherwise have responsibility for content and format of its website(s) or third
party websites used by the City (Internet Personnel) the technical assistance
document, “Accessibility of State and Local Government Websites to People with
Disabilities,” which is Attachment H to this Agreement (it is also available at
www.ada.gov/websites2.htm).
34. Within one
year of the effective date of this Agreement, and throughout the life of the
Agreement, the City will do the following:
A.
Establish, implement, and post online a policy that its web pages will be
accessible and create a process for implementation;
B.
Ensure that all new and modified web pages and content are
accessible;
C.
Develop and implement a plan for making existing web content more
accessible;
D.
Provide a way for online visitors to request accessible information or
services by posting a telephone number or e-mail address on its home page;
and
E.
Periodically (at least annually) enlist people with disabilities to test
its pages for ease of use.
PHYSICAL CHANGES TO
FACILITIES
35. The
elements or features of the City’s facilities that do not comply with the
Standards, including those listed in Attachments E,
G, I, J, and K, prevent
persons with disabilities from fully and equally enjoying the City’s services,
programs, or activities and constitute discrimination on the basis of disability
within the meaning of 42 U.S.C. § 12132 and 28 C.F.R. §§ 35.149 and
35.150.
36. The City
will comply with the cited provisions of the Standards when taking the actions
required by this Agreement.
37. Within
fourteen months of the effective date of this Agreement, the City will install
signage as necessary to comply with 28 C.F.R. § 35.163(b), after having surveyed
all facilities that are the subject of this Agreement for the purpose of
identifying those that have multiple entrances not all of which are
accessible.
38. Newly
Constructed Facilities: In
order to ensure that the following spaces and elements in City facilities, for
which construction was commenced after January 26, 1992, are readily accessible
to and usable by persons with disabilities, the City will take the actions
listed in Attachment I.
39. Altered
Facilities: In order to ensure
that the following spaces and elements in City facilities, for which alterations
commenced after January 26, 1992, are readily accessible to and usable by
persons with disabilities, the City will take the actions listed in
Attachment
J.
40. Program
Access in City Existing Facilities:
In order to ensure that each of the City’s programs, services, and
activities operating at a facility that is the subject of this Agreement, when
viewed in its entirety, is readily accessible to and usable by persons with
mobility impairments, the City will take the actions listed in
Attachment K.
PROGRAM MODIFICATIONS
41. Access
to City Programs Housed in Others’ Facilities: In order to ensure that the City
programs, services, and activities that are the subject of this Agreement and
that are operated by the City at facilities owned or controlled by other
entities, when viewed in its entirety, are readily accessible to and usable by
persons with mobility impairments, the City will take the actions listed in
Attachment L.
SERVICE ANIMALS
Reserved.
MISCELLANEOUS
PROVISIONS
42. Except as
otherwise specified in this Agreement, at yearly anniversaries of the effective
date of this Agreement until it expires, the City will submit written reports to
the Department summarizing the actions the City has taken pursuant to this
Agreement. Reports will include
detailed photographs showing measurements, architectural plans, work orders,
notices published in the newspaper, copies of adopted policies, and proof of
efforts to secure funding/assistance for structural renovations or
equipment.
43. Throughout
the life of this Agreement, consistent with 28 C.F.R. § 35.133(a), the City will
maintain the accessibility of its programs, activities, services, facilities,
and equipment, and will take whatever actions are necessary (such as routine
testing of accessibility equipment and routine accessibility audits of its
programs and facilities) to do so.
This provision does not prohibit isolated or temporary interruptions in
service or access due to maintenance or repairs. 28 C.F.R. § 35.133(b).
44. Within six
months of the effective date of this Agreement, the City will develop or procure
a two-hour training program on the requirements of the ADA and appropriate ways
of serving persons with disabilities.
The City will use the ADA technical assistance materials developed by the
Department and will consult with interested persons, including individuals with
disabilities, in developing or procuring the ADA training
program.
45. Within one
year of the effective date of this Agreement, the City will deliver its training
program to all City employees who
have direct contact with members of the public. At the end of that period, the City will
submit a copy of its training curriculum and materials to the Department, along
with a list of employees trained and the name, title, and address of the
trainer.
IMPLEMENTATION AND
ENFORCEMENT
46. If at any
time the City desires to modify any portion of this Agreement because of changed
conditions making performance impossible or impractical or for any other reason,
it will promptly notify the Department in writing, setting forth the facts and
circumstances thought to justify modification and the substance of the proposed
modification. Until there is
written Agreement by the Department to the proposed modification, the proposed
modification will not take effect.
These actions must receive the prior written approval of the Department,
which approval will not be unreasonably withheld or delayed.
47. The
Department may review compliance with this Agreement at any time. If the Department believes that the City
has failed to comply in a timely manner with any requirement of this Agreement
without obtaining sufficient advance written agreement with the Department for a
modification of the relevant terms, the Department will so notify the City in
writing and it will attempt to resolve the issue or issues in good faith. If the Department is unable to reach a
satisfactory resolution of the issue or issues raised within 30 days of the date
it provides notice to the City, it may institute a civil action in federal
district court to enforce the terms of this Agreement, or it may initiate
appropriate steps to enforce title II and section 504 of the Rehabilitation
Act.
48. For
purposes of the immediately preceding paragraph, it is a violation of this
Agreement for the City to fail to comply in a timely manner with any of its
requirements without obtaining sufficient advance written agreement with the
Department for an extension of the relevant time frame imposed by the
Agreement.
49. Failure by
the Department to enforce this entire Agreement or any provision thereof with
regard to any deadline or any other provision herein will not be construed as a
waiver of the Department's right to enforce other deadlines and provisions of
this Agreement.
50. This
Agreement is a public document. A
copy of this document or any information contained in it will be made available
to any person by the City or the Department on request.
51. This
Agreement constitutes the entire agreement between the parties on the matters
raised herein, and no other statement, promise, or agreement, either written or
oral, made by either party or agents of either party, that is not contained in
this written Agreement (including its Attachments, which are hereby incorporated
by reference), will be enforceable.
This Agreement does not purport to remedy any other potential violations
of the ADA or any other federal law.
This Agreement does not affect the City’s continuing responsibility to
comply with all aspects of the ADA and section 504 of the Rehabilitation
Act.
52. This
Agreement will remain in effect for nine years.
53. The person
signing for the City represents that he or she is authorized to bind the City to
this Agreement.
54. The
effective date of this Agreement is the date of the last signature below.
For the City of
Hartford:
MAYOR
EDDIE PEREZ City
of Hartford
By:
____________________________ 550
Main Street Hartford,
Connecticut 06103
Date: ___________________________ |
For the United
States:
BRADLEY J.
SCHLOZMAN Acting Assistant
Attorney General Civil Rights
Division
By:_____________________________
JOHN L. WODATCH,
Chief JEANINE WORDEN,
Deputy Chief MARY LOU MOBLEY,
Senior Counsel JOSH MENDELSOHN,
Supervisory Attorney NATALIE T.
SINICROPE, Investigator MICHELE ANTONIO
MALLOZZI, Architect U.S. Department
of Justice Civil Rights
Division 950 Pennsylvania
Avenue, N.W. Disability
Rights Section - NYA Washington, DC
20530
Date:
______________________________
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