A. SCOPE OF THE INVESTIGATIONThis matter was initiated by a complaint filed under title II of the Americans with Disabilities Act of 1990 ("ADA"), 42 U.S.C. §§ 12131-12134, with the United States Department of Justice ("Department") against the City of Springfield, Missouri, ("City"). The complaint was received by the Civil Rights Division of the Department of Justice under the authority of 28 C.F.R. Part 35, Subpart F. The complainant alleges that several of the City's buildings are not accessible to people with mobility impairments.
Because the City receives financial assistance from the Department of Justice, the investigation was also conducted under the authority of § 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 Department expanded the scope of the investigation to include the City's compliance with the following title II requirements:
The Department limited its program access review to those of the City's programs, services, and activities that operate in the following facilities: Busch Municipal Building, Solid Waste Management Office, Vision 20/20 Building, Police Department, Springfield-Greene County Public Health Center, Old City Hall, Springfield Art Museum, Human Rights/Job Council of the Ozarks, Battlefield Mall Substation, Grant Beach Police Substation, Commercial Street Police Substation, Animal Shelter, Parks and Recreation Administration Building, Silver Springs Park Pool, Horton Smith Golf Course, Nathanael Greene Park, L.E. Meador Park and Pool, and Oak Grove Community Center. In addition, construction or alterations commenced after January 26, 1992, on the following facilities and thus must comply with the ADA's new construction or alterations requirements: Division of Purchases Building, Municipal Court Building, Springfield Art Museum (Musgrave Wing), Park Central Substation and Museum, Dickerson Park Zoo, Fire Station Number 5, Fire Station Number 11, Silver Springs Park, Nichols Park, Living Memorial, and Cooper Park and Sports Complex Tennis Center. The Department also reviewed the accessibility of three of the City's 74 polling locations.
B. 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 investigate the complaint in this matter to determine the compliance of the City with title II of the ADA and the Department's implementing title II 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 investigate the complaint in this matter to determine the City's compliance with § 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, 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 bring a civil suit to enforce the rights of the United States under applicable federal, state, or local law.
C. ACTIONS TAKEN BY THE CITY
4. The City has two ADA Coordinators, one for title I matters and another for title II.
5. The City's employment applications contain a notification statement to persons with disabilities that reasonable accommodations are provide for testing and application purposes with advanced notice.
6. The City provides interpreters for Police and Health Department services immediately or upon 24-hour notice.
7. City Council Meetings are re-broadcasted on a local cable access channel with captions. City Council Minutes and other City printed materials are available in large print and Braille upon request.
8. The City's 911 Emergency Response System is automated to receive TTY calls and record all voice and TTY calls.
9. The City has a grievance procedure in place to respond to complaints of discrimination in the City's employment practices and policies and provisions of programs, services, and benefits by the City of Springfield.
The parties to this Agreement are the United States of America and the City of Springfield, Missouri. In order to avoid the burdens and expenses of possible litigation, the parties hereby agree as follows:
REMEDIAL ACTION
10. In consideration of, and consistent with, the terms of this Agreement as set forth below, the Attorney General agrees to refrain from filing a civil suit in this matter regarding the areas covered by ¶¶s 12 through 35 of this Agreement.
11. The Parties agree that the technical requirements and, where appropriate, the scoping requirements of the Standards are used as a guide for determining whether a program or activity held in an existing facility is "readily accessible to and usable by" persons with disabilities, and for determining what changes are necessary to make this program or activity accessible if it continues to be provided in the existing facility in question. See 28 C.F.R. §§ 35.150(b)(1), 35.151. The Standards appear at 28 C.F.R. Part 36, Appendix A.
A. POLICIES AND PROCEDURES
12. Within 60 days of the effective date of this Agreement, the City will include on all meeting notices and agendas that reasonable accommodations will be provided to anyone wishing to attend and participate in City Council and other City Committee meetings upon 3 days prior notice.
13. Within 6 months of the effective date of this Agreement, the City will train its employees who interact or communicate with the public, who establish or implement programs, or who maintain facilities, regarding the City's responsibilities under the ADA, such as responding to inquiries from individuals with disabilities who require accommodations to participate in the City's programs or services.
B. POLLING PLACES
14. Within 180 days of the effective date of this Agreement, the City will insure that all polling sites are accessible and in compliance with the Standards.
C. PHYSICAL CHANGES
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 following actions.
15. The City shall complete the following alteration to the Busch Municipal Building within 3 months of the effective date of this Agreement:
a. The top of the service counter in the Building Permits Department is 42 inches above the finish floor. Provide a portion of the counter that is at least 36 inches wide and no more than 36 inches high, or provide an auxiliary counter with a maximum height of 36 inches in compliance with the Standards, or provide access to services transacted at this counter through alternate means. Standards § 7.2(2).
16. The City shall, within 3 months of the effective date of this Agreement, provide sample documents in the Busch Building of what is available in the resource library. Persons not able to access the Solid Waste Management Office can call from the Busch Building for more information and have materials from the resource library brought to the Busch Building upon request. A sign shall be posted in the Busch building and near the entrance to the Solid Waste Management Office informing the public of this procedure. 28 C.F.R. § 35.150.
17. The City is scheduled to demolish the Vision 20/20 Building. Until such time, the City agrees that no public services or functions shall be held in this building.
18. The City shall complete the following alterations to the Police Department within 3 months of the effective date of this Agreement:
a. At the accessible entrance, there is a buzzer intercom for controlled access. Provide an informational sign adjacent to the buzzer explaining its use. Standards § 4.30.2, 4.30.3, 4.30.5.
b. The top of the front reception service counter is 44 inches above the finish floor. Provide a portion of the counter that is at least 36 inches wide and no more than 36 inches high, or provide an auxiliary counter with a maximum height of 36 inches in compliance with the Standards, or provide access to services transacted at this counter through alternate means. Standards § 7.2(2).
c. The holding cell does not have adequate clear floor space. The City will continue its practice of using the new County holding facility for persons with mobility impairments. Standards § 4.2.4, Figure 4.
19. The City shall complete the following alterations to the Springfield-Greene County Public Health Center within 6 months of the effective date of this Agreement:
a. The top of the service and information counter is 43 inches above the finish floor. Provide a portion of the counter that is at least 36 inches wide and no more than 36 inches high, or provide an auxiliary counter with a maximum height of 36 inches in compliance with the Standards, or provide access to services transacted at this counter through alternate means. Standards § 7.2(2).
b. The top of the counter in the Birth and Death Certificates Department is 42 inches above the finish floor. Provide a portion of the counter that is at least 36 inches wide and no more than 36 inches high, or provide an auxiliary counter with a maximum height of 36 inches in compliance with the Standards, or provide access to services transacted at this counter through alternate means. Standards § 7.2(2).
20. The City shall complete the following alterations to Old City Hall:
a. The City will make the following modifications to Old City Hall within 12 months of the effective date of this Agreement:
(1) The ramp to the accessible entrance does not have edge protection, and the handrails have no horizontal extensions at the end of the ramp. Provide a ramp with a curb, wall, railing or projecting surface that prevents people from slipping off the ramp. Provide handrails extensions that continue horizontally to at least 12 inches beyond the end of the ramp. Two parking spaces may share a single access aisle that is at least 96 inches wide. Standards §§ 4.8.7, 4.8.5(6), 4.8.5(2).
(2) Both the men's and women's toilet rooms are inaccessible. The City agrees to alter an existing first floor toilet room into an accessible unisex toilet room that is in compliance with the Standards. The City shall also post directional signs at all inaccessible toilet rooms indicating the location of this toilet room. Standards §§ 4.13, 4.17, 4.18, 4.19, 4.26, 4.27, 4.30.1, 4.30.4, 4.30.6, Figure 30, Figure 31.
(3) The elevator car is 53 1/2 inches wide and 52 3/4 inches deep. The controls are 53 inches above the finish floor with a front approach. Modify the controls to be accessible and assure that a person using a wheelchair can enter the car, maneuver within reach of the controls, and exit the car. Standards §§ 4.1.6(3)(c), 4.10.12.
21. The City shall complete the following alterations to the Auditorium in the original building of the Springfield Art Museum within 9 months of the effective date of this Agreement:
a. There is space for two wheelchairs at the two ends of a row, but only one of the pair has a fixed companion seat alongside. Modify the wheelchair seating so that each wheelchair space has a fixed companion seat adjacent. Standards § 4.33.3.
b. Provide a handrail meeting the requirements of the Standards on the wall side of each ramped aisle in the auditorium. Standards § 4.8.5.
22. The City shall complete the following alterations to the Grant Beach Park Police Substation within 6 months of the effective date of this Agreement:
a. The maneuvering clearance at the door and the screen door does not comply with minimum dimensions and is not level. Modify the walkway to the front entrance that complies with the Standards. Standards §§ 4.3, 4.5, 4.13.5, Figure 25.
b. The top of the service counter is 43 1/2 inches above the finish floor. Provide a portion of the counter that is at least 36 inches wide and no more than 36 inches high, or provide an auxiliary counter with a maximum height of 36 inches in compliance with the Standards, or provide access to services transacted at this counter through alternate means. Standards § 7.2(2).
c. There is a 9 1/2 inch change in level at the door to the back office from the front area. The City will designate this area as "Employee Only." Standards §§ 4.5.2, 4.8.
23. The Commercial Street Police Substation is not accessible to persons with mobility impairments. The Department understands that the owners, the Commercial Club of Springfield, plan to renovate the building, including providing an accessible entrance for the Police Department. Until the substation is renovated so as to be accessible to people with disabilities, the Police Department will continue to meet with members of the public in alternate accessible locations.
24. The City shall complete the following alterations to the unisex toilet room in the Parks and Recreation Administration Building within 9 months of the effective date of this Agreement:
a. The unisex toilet room does not have an accessible sign. Install a sign, using raised characters and Braille, on the wall adjacent to the latch side of the door so that the centerline of the sign is 60 inches above the ground and a person can approach within 3 inches of sign without encountering protruding objects or standing within the swing of a door. Standards §§ 4.30.4, 4.30.5, 4.30.6.
b. The toilet flush valve control is mounted on the narrow side of the toilet. Alter the flush valve so that it is on the open (wide) side of the stall or so that it operates automatically. Standards § 4.16.5.
c. The mirror is mounted so that the bottom of the reflecting surface is 55 1/2 inches above the finish floor. Provide a mirror so that the bottom of the reflecting surface is no higher than 40 inches above the finish floor. Standards § 4.19.6.
d. The paper towel dispenser is mounted 55 1/2 inches above the finish floor. Provide a paper towel dispenser so that the highest operable part is no higher than 54 inches above the finish floor for a side approach. Standards §§ 4.2.6, 4.27.3.
25. The City shall complete the following alterations to the Horton Smith Golf Course:
a. The spaces and elements in the men's and women's toilet rooms on the fourth green do not comply with the Standards. Within 6 months of the effective date of this Agreement, renovate the men's and women's toilet rooms so that the spaces and elements in each room, including the door, water closet, grab bars, urinal (men's only), lavatory, mirror, controls and dispensers, and signs comply with the Standards. Alternatively, provide a portable toilet that is accessible. However, this alternative does not remove the City's obligation to make the permanent toilet rooms fully accessible if and when they are remodeled. Standards §§ 4.13, 4.17, Figure 30, 4.18, 4.19, Figure 31, Figure 32, 4.26, 4.27, 4.30.
b. The spaces and elements in the men's and women's toilet rooms at the pro shop do not comply with the Standards. Within 12 months of the effective date of this Agreement, renovate the men's and women's toilet rooms so that the spaces and elements in each room, including the door, water closet, grab bars, urinal (men's only), lavatory, mirror, controls and dispensers, and signs comply with the Standards. Standards §§ 4.13, 4.17, Figure 30, 4.18, 4.19, Figure 31, Figure 32, 4.22, 4.26, 4.27, 4.30.
26. The City shall complete the following alterations to Nathanael Greene Park within 9 months of the effective date of this Agreement:
a. Toilet Rooms
(1) The openings of the second doorways to the men's and women's toilet rooms are 29 1/2 inches wide. Widen the doorways so that they have at least a 32 inch clear opening width measured from the face of the door to the opposite door stop with the door open 90 degrees. Standards § 4.13.5.
(2) The lavatories in the men's and women's toilet rooms have twist-type hardware. Replace the hardware on the accessible lavatories with controls that do not require tight grasping, pinching or twisting of the wrist to operate. Standards §§ 4.19.5, 4.27.4.
(3) The designated accessible stalls in men's and women's toilet rooms are less than 60 inches wide. Provide a "standard" accessible toilet stall in each room at least 60 inches wide and at least 59 inches deep (or at least 56 inches deep with a wall-mounted toilet) such that all of the stall's elements, including entry door, water closet, size and arrangement, toe clearances, grab bars, controls and dispensers comply with the Standards. Standards §§ 4.17, Figure 30(a), 4.26, 4.27.
b. The Gray-Campbell demonstration farm buildings are not accessible. Develop a written policy to make the programs and services offered at the farm building accessible to persons with disabilities. 28 C.F.R. § 35.150.
27. The public telephone at L.E. Meador Park and Pool does not comply with the Standards. Within 6 months of the effective date of this Agreement, the City shall provide a public telephone that is hearing aid compatible, has volume control with complying symbol, and has its highest operable part no higher than 48 inches for a front reach or 54 inches for a side reach. Standards §§ 4.31, 4.2.5, 4.2.6, 4.30.7(2).
28. The City shall complete the following alterations to the Oak Grove Community Center men's and women's toilet rooms within 6 months of the effective date of this Agreement:
a. The designated accessible stall in each room is 35 inches wide. Provide a "standard" accessible toilet stall in each room that is at least 60 inches wide and at least 59 inches deep (or at least 56 inches deep with a wall-mounted toilet) such that all of the stall's elements, including entry door, water closet, size and arrangement, toe clearances, grab bars, controls and dispensers comply with the Standards. Standards §§ 4.13, 4.17, 4.26, 4.27, Figure 30(a).
b. The lavatories have twist-type hardware and the hot water and drain pipes beneath the lavatories are exposed. Replace the hardware with controls that do not require tight grasping, pinching or twisting of the wrist to operate. Install insulation on the hot water and drain pipes. Standards §§ 4.19.5, 4.27.4, 4.19.4.
c. The mirrors are mounted so that the bottom of the reflecting surfaces are 47 1/2 inches above the finish floor. Provide a mirror in each room so that the bottom of the reflecting surface is no higher than 40 inches above the finish floor. Standards § 4.19.6.
d. The shower in each room has an area of 33 inches by 31 inches. There are no grab bars, or benches, and the thresholds are 1 3/4 inches high. Provide or alter each shower stall so that all of the stall's elements, including size and arrangement, controls, and grab bars, comply with the Standards. Standards § 4.21, Figure 35, Figure 36, Figure 37.
e. There is 24 3/4 inches clearance between the stall partition and the urinal partition. Provide a clear floor space of at least 30 inches by 48 inches in front of the urinal. Standards § 4.18.3.
In order to ensure that the following spaces in City facilities for which alterations commenced after January 26, 1992, are readily accessible to and usable be individuals with disabilities, the City will take the following actions:
29. The men's and women's toilet rooms in the Division of Purchases Building are inaccessible. Within 3 months of the effective date of this Agreement, the City will designate both the men's and women's toilets as "Employee Only" and will direct the public to use the toilet rooms in the Busch Building adjacent to the Division of Purchases. The City will also insure that the route from the Division of Purchases to the Busch Building complies with the Standards. Standards §§ 4.1.2(1), 4.3, 4.5.
30. The City shall complete the following alterations to the Municipal Court Building within 12 months of the effective date of this Agreement:
a. The top of the counters at the Deputy Clerk's and the Pre-Trial Bond's windows are 40 1/2 inches above the finish floor. Provide a portion of each counter that is at least 36 inches wide and no more than 36 inches high, or provide an auxiliary counter with a maximum height of 36 inches in compliance with the Standards, or provide access to services transacted at these counters through alternate means. Standards § 7.2(2).
b. The top of the counter of the Probation Office's window is 41 1/4 inches above the finish floor. Provide a portion of the counter that is at least 36 inches wide and no more than 36 inches high, or provide an auxiliary counter with a maximum height of 36 inches in compliance with the Standards, or provide access to services transacted at this counter through alternate means. Standards § 7.2(2).
c. The top of the counter at the Prosecutor's Office window is 41 1/4 inches above the finish floor. Provide a portion of the counter that is at least 36 inches wide and no more than 36 inches high, or provide an auxiliary counter with a maximum height of 36 inches in compliance with the Standards, or provide access to services transacted at this counter through alternate means. Standards § 7.2(2).
31. The City shall complete the following alterations to the public toilet rooms in Dickerson Park Zoo within 9 months of the effective date of this Agreement:
a. The toilet room signs are incorrectly mounted. Install signs, using raised characters and Braille on the wall adjacent to the latch side of each door so that the centerline of the sign is 60 inches above the ground and a person can approach within 3 inches of the signs without encountering protruding objects or standing within the swing of the door. Standards §§ 4.1.6(1)(b), 4.1.3(16), 4.30.4, 4.30.6.
b. The centerline of the toilet is 21 inches from the side wall. Reposition the toilet or, if minimum width can be maintained, fur out the wall from above the grab bar to the floor, so that the centerline is 18 inches from the side wall. Standards §§ 4.1.6(1)(b), 4.1.3(11), 4.22.4, 4.16.2, Figure 28.
c. The side grab bar does not extend at least 54 inches from the back wall. Reposition the grab bar so that it begins no more than 12 inches from the wall, is at least 42 inches long, and it extends at least 54 inches from the back wall. Standards §§ 4.1.6(1)(b), 4.1.3(11), 4.22.4, 4.17.6, Figure 30(a).
d. The toilet paper dispenser, mounted above the grab bar, interferes with use of the grab bar. Reposition the dispenser below the grab bar with at least 1 1/2 inch clearance between the grab bar and the top of the dispenser and with the paper outlet at least 9 inches above the finish floor. Standards §§ 4.1.6(1)(b), 4.16.6, Figure 39(d).
In order to ensure that the following spaces in City facilities for which construction commenced after January 26, 1992, are readily accessible to and usable be individuals with disabilities, the City will take the following actions:
32. The City shall complete the following alterations to the Silver Springs Park within 9 months of the effective date of this Agreement:
a. There is no accessible route from the parking lot to the picnic pavilion. Establish an accessible route from the accessible parking spaces to the picnic pavilion that complies with the Standards. See Standards §§ 4.1.2(1), 4.3, 4.5.
b. There is no accessible route from the parking lot to the playground. Establish an accessible route from the accessible parking spaces to the playground that complies with the Standards. Standards §§ 4.1.2(1), 4.3, 4.5.
c. There is no accessible route from the parking to the basketball court. Establish an accessible route from the accessible parking spaces to the basketball court that complies with the Standards. Standards §§ 4.1.2(1), 4.3, 4.5.
33. The height of the toilet seats in the men's and women's toilet rooms in the Dickerson Park Zoo's Administration Building are 15 1/2 inches from the finish floor to the top of the seat. The City shall, within 6 months of the effective date of this Agreement, replace the toilet or install a riser to increase the height of the seat so that the top of the seat is between 17 and 19 inches from the finish floor. Standards §§ 4.1.3(11), 4.16.3, 4.22.4, Figure 29(b).
34. The City shall complete the following alterations to Nichols Park:
a. The City shall complete the following alterations to Nichols Park within 9 months of the effective date of this Agreement:
(1) There is no accessible route from the parking lot to the picnic shelter and toilet rooms. Remove the concrete parking blocks so that persons using wheelchairs can access the picnic pavilion and toilet rooms. Standards §§ 4.1.2(1), 4.3.8, 4.5.2.
(2) There is no accessible route from the parking lot to the tennis courts. Establish an accessible route from the accessible parking spaces to the tennis courts that complies with the Standards. Standards §§ 4.1.2(1), 4.3, 4.5.
35. The City shall complete the following alterations to Living Memorial Park within 9 months of the effective date of this Agreement:
a. There is no accessible route from the parking lot to the picnic shelter. Establish an accessible route from the street to the picnic shelter that complies with the Standards. Standards §§ 4.1.2(1), 4.3, 4.5.
b. There is no accessible route to the drinking fountain. Provide an accessible route to the fountain or provide an accessible drinking fountain elsewhere that is located along an accessible route. Standards §§ 4.1.3(10), 4.3, 4.5, 4.15.
c. There is no accessible route to the playground. Establish an accessible route from the street to the playground. Standards §§ 4.1.2(1), 4.3, 4.5.
IMPLEMENTATION AND ENFORCEMENT
36. Except as otherwise specified in this Agreement, at 90 and 180 days after the effective date of this Agreement, and thereafter at yearly anniversaries of the effective date, the City will submit written reports to the Department summarizing the actions the City has taken pursuant to this Agreement. Reports will include photographs, architectural plans, notices published in the newspapers (where specifically required herein), copies of adopted policies, and proof of efforts to secure funding/assistance for structural renovations.
37. 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 shall not be unreasonably withheld or delayed.
38. The Department may review compliance with this Agreement at any time. If the Department believes that this Agreement or any portion of it has been violated, it 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 90 days of the date it provides notice to the City, it may institute a civil action in federal district court directly to enforce title II or to enforce the terms of this Agreement, or it may initiate appropriate steps to enforce section 504 of the Rehabilitation Act.
39. Failure by the Department to enforce this entire Agreement or any provision thereof with regard to any deadline or any other provision herein shall not be construed as a waiver of the Department's right to enforce other deadlines and provisions of this Agreement.
40. In the event that the City fails to comply in a timely manner with any requirement of this Agreement without obtaining sufficient advance written agreement with the Department for a temporary modification of the relevant terms of this Agreement, the Department may file suit in an appropriate federal court to enforce the terms of the Agreement, may declare the Agreement null and void and file suit to enforce title II of the ADA, or may initiate appropriate steps to enforce section 504 of the Rehabilitation Act. In such event, the City shall also be entitled to raise all defenses, avoidance and counterclaims that it would be entitled to raise in the absence of the Agreement, and such defenses, avoidances and claims are considered reserved in such event by the parties.
41. The Settlement Agreement is also binding on the United States Department of Justice. Accordingly, the United States agrees not to be a party to any lawsuit filed against the City regarding the access issues in this Agreement so long as all modifications required herein are made.
42. This Agreement is a public document. A copy of this document or any information contained in it may be made available to any person by the City or the Department on request.
43. The effective date of this Agreement is the date of the last signature below.
44. 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, shall 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.
45. The parties agree that this Agreement is not an admission of violation and should not be construed as an admission by the City of Springfield of any violation.
46. This Agreement will remain in effect for five years from the effective date of this Agreement, or until the parties agree that full compliance with this Agreement by the City has been achieved.
47. The person signing for the City of Springfield represents that he or she is authorized to bind the City to this Agreement.
For the City: For the United States:
By:__________________________
TOM FINNIE, City Manager
Dated:__Sep 10, 2001__________________
RALPH F. BOYD, JR.
Assistant Attorney General for Civil Rights
By:__________________________
JOHN L. WODATCH, Chief
SUSAN B. REILLY, Deputy Chief
NAOMI MILTON, Supervisory Attorney
AMELIA M. EDUARDO, Investigator
Disability Rights Section
Civil Rights Division
U.S. Department of Justice
P.O. Box 66738
Washington, D.C. 20035-6738
Dated: _9/19/01______________________
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October 9, 2001