US Department of Justice Civil Rights Division - Letter - diga1

8/14/2019 US Department of Justice Civil Rights Division - Letter - diga1

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IN THE UNITED STATES DISTRICT COURTFOR THE MIDDLE DISTRICT OF GEORGIA

ATHENS DIVISION

UNITED STATES OF AMERICA, ))

Plaintiff, ))) No.:

v. )HLS ENTERPRISES, INC., )

)Defendant. )CONSENT ORDER AND JUDGMENT

A. Background1. On September 4, 1996, the United States filed an actionto enforce title III of the Americans with Disabilities Act of 1990 (the "ADA"), 42 U.S.C. SS 12181 through 12189, against HLSEnterprises, Inc. (HLS), the owner of a Days Inn hotel at 302Elbert Street, Elberton, Georgia ("the hotel" or the "ElbertonDays Inn").

2. On or about December 29, 1994, representatives of theUnited States Department of Justice, Civil Rights Division,visited and inspected the Elberton Days Inn, as part of aninvestigation of the hotel conducted pursuant to the Departmentof Justice's authority to review the compliance of entitiescovered by title III of the ADA, 42 U.S.C. S 12188. 28 C.F.R.S 36.502(c).

3. As a result of its investigation, including itsinspection of the hotel, the Department of Justice identified01-01155


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several features, elements, and spaces of the Elberton Days Innwhich failed to comply with the ADA's Standards for AccessibleDesign, 28 C.F.R. Part 36, Appendix A ("the Standards"). A listof the features, elements, and spaces of the hotel which did notcomply with the Standards is attached hereto as Exhibit 1.

4. The parties have engaged in good faith negotiations inan effort to resolve this dispute expeditiously, without resortto litigation. The parties have agreed to enter into thisagreement to be filed simultaneously with the United States'complaint.

5. As specified below, defendant has agreed to remedy theviolations of the Standards set out in Exhibit 1.

B. Agreement of the PartiesAccordingly, by consent of the parties, it is hereby ORDERED

and DECREED that:1. This court has jurisdiction of this action under42 U.S.C. S 12188(b)(1)(B) and 28 U.S.C. SS 1331 and 1345.The court may grant declaratory and other relief pursuant to 28U.S.C. SS 2201 and 2202.

2. Venue is proper in this district.3. The Elberton Days Inn is a non-residential facility

whose operations affect commerce. As such, it is a commercialfacility within the meaning of section 303(a) of the Act. 42U.S.C. S 12183(a). In addition, because the Elberton Days Inn is

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a place of lodging, it is also a public accommodation within themeaning of section 303(a) of the Act. Id.

4. The last building permit for the Elberton Days Inn wasapplied for on or about September 7, 1993.

5. The first certificate of occupancy for the ElbertonDays Inn was issued on or about March 21, 1994.6. Defendant HLS is a private entity which owns the

Elberton Days Inn. Defendant HLS initiated, contracted for,and/or participated in the design and construction of the hotel.Defendant HLS contracted with an architect and a contractor forthe design and construction of the Elberton Days Inn.

7. The Elberton Days Inn is not readily accessible to orusable by individuals with disabilities, as required by section303(a)(1) of the Act, 42 U.S.C. S 12183(a)(1). The hotel failsin numerous respects to comply with the Department of Justice'sregulation implementing title III of the ADA, 28 C.F.R. Part 36,including the Standards. See 28 C.F.R. SS 36.401, 36.406.

8. For the purpose of this agreement, the partiesstipulate that the failures of defendant to design and constructthe Elberton Days Inn to be readily accessible to and usable byindividuals with disabilities constitute a pattern or practice of discrimination within the meaning of 42 U.S.C.S 12188(b)(1)(B)(i) and 28 C.F.R. S 36.503(a).

9. For the purpose of this agreement, the partiesstipulate that the failures of the defendant to design and


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construct the Elberton Days Inn to be readily accessible to and- 3 -

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usable by individuals with disabilities constitute unlawfuldiscrimination that raises an issue of general public importancewithin the meaning of 42 U.S.C. S 12188(b)(1)(B)(ii) and 28C.F.R. S 36.503(b).

10. HLS contends that it believed that the hotel compliedwith the ADA, has never knowingly violated the Standards, andconsiders the hotel to be generally accessible to individualswith disabilities. Since being notified of the position of theDepartment of Justice, HLS has attempted to remedy the allegedviolations that could be remedied quickly and to develop a planfor addressing all alleged violations. Although HLS disputedsome of the findings of the Department of Justice concerning thealleged violations at the hotel, HLS enters into this ConsentOrder and Judgment for the purpose of avoiding litigation, andshall not dispute the validity of this Consent Order andJudgment, the jurisdiction of the court to enter it, or the


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authority of the Department of Justice to institute this action.This Consent Order and Judgment shall not constitute an admissionby HLS of any wrongdoing or liability.

11. Not later than February 1, 1997, defendants will remedyeach and every failure to comply with the Standards identified inExhibit 1. The specific actions to be taken, and, whereappropriate, the architectural plans to be followed, by thedefendants to remedy the failures to comply with the Standardsidentified in Exhibit 1 are set forth in Exhibit 2.

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12. Not later than March 1, 1997, the defendants shallprovide to counsel for the United States a report on the statusof their compliance with this Order. The report shall indicatewhich steps specified in Exhibit 2 have been completed. If anysteps have not been completed, the report shall so indicate andexplain why such steps have not been completed.


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13. The parties shall negotiate in good faith to resolveany dispute relating to the interpretation or implementation of this Order before bringing the matter to the Court's attention.

14. The Court shall retain jurisdiction of this action toenforce the provisions of this Order through December 31, 1998,after which time all of its provisions shall be terminated,unless the Court determines it is necessary to extend any of itsrequirements, in which case those requirements shall be extended.

15. This agreement shall govern the compliance of defendantHLS with the ADA's Standards for Accessible Design at theElberton Days Inn. This agreement does not address, and shallnot be construed to address, any other issues of ADA complianceat the Elberton Days Inn, or at any other commercial facility orplace of public accommodation designed and constructed bydefendant HLS or owned, operated, leased, or leased by the HLS orany other violations of federal law.

16. Defendant HLS shall comply with the ADA Standards inany future involvement in the design and construction of a publicaccommodation or commercial facility.

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17. This Consent Order shall be binding on HLS as well asany successor in interest.

18. This instrument reflects the entire agreement betweenthe parties.

SO ORDERED this day of , 1996.United States District Judge

AGREED AND CONSENTED TO:For Plaintiff United States of America:ALYSE S. BASSAttorneyDisability Rights SectionCivil Rights DivisionUnited States Department of JusticePost Office Box 66738Washington, D.C. 20035-6738(202) 616-9511For Defendant HLS:ROBERT LEVERETTAttorney for HLS Enterprises Inc.Heard, Leverett, Phelps, Weaver & Campbell

25 Thomas StreetP.O. Drawer 399Elberton, Georgia 30635-0399(706) 283-2651

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EXHIBIT 1Failures of the Elberton Days Inn to comply with the ADA'sStandards for Accessible Design as identified by the U.S.

Department of Justice1. Parking and passenger loading zone violations

a. There are no accessible parking spaces. There are 38spaces in the lot; the Standards require two accessiblespaces, including at least one van accessible space.Standards S 4.1.2(5). While two spaces are designatedaccessible, neither complies with the requirements of the Standards, as specified in items 1.b., c., d., e.,

f., and g., below.b. Neither of the parking spaces designated accessible ison the shortest route from the parking lot to the lobbyentrance. Standards S 4.6.2.

c. Neither of the parking spaces designated accessible ison an accessible route to the lobby entrance; fromeither space, a guest must traverse a sloping area of the hotel's exterior walkway that does not comply withthe requirements for ramps. (See item 2.a., below.)Standards S 4.6.2.

d. Both parking spaces designated accessible are toonarrow. Standards S 4.6.3.

e. Neither of the parking spaces designated accessible hasan adequate access aisle; the access aisles providedare too narrow, and have slopes exceeding 1:50.Standards S 4.6.3.

f. The parking space designated accessible at the front of the hotel has a slope exceeding 1:50. StandardsS 4.6.3.

g. Neither of the spaces designated accessible has a signmarking the space that will not be obscured by a


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vehicle parked in the space. Standards S 4.6.4.h. The passenger loading zone at the front entrance to the

hotel lobby does not have a demarcated access aisle.Standards S 4.6.6.

2. Exterior route violationsa. There is no accessible route connecting either the

lobby or the swimming pool to either of the guest roomsdesignated accessible. At both the front and rear of

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the hotel, there is a portion of the exterior walkwaywith a slope of more than 1:12. These portions of thewalkways do not comply with the requirements for rampsin that they are too steep, have no handrails, and haveinadequate landings. Standards SS 4.3.8, 4.8.

b. The light fixtures along most portions of the hotel'sexterior walkways protrude more than 4" into thewalkways. Standards S 4.4.1.

3. Violations at exterior and interior stairs and areas of rescue assistancea. The handrails on each of the hotel's stairways are too

large in diameter, too far from the wall, and do nothave adequate horizontal extensions at the top andbottom risers. Standards S 4.9.4.

b. The design of the stairways at the front and rear of the hotel reduces vertical clearance adjacent to anaccessible route to less than 80", but no barrier towarn blind or visually-impaired persons is provided.Standards S 4.4.2.

c. There are no areas of rescue assistance on the secondfloor of the hotel. Standards SS 4.1.3(9), 4.3.11.


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4. Entrance and exit violationsa. The exterior entrance to the manager's apartment (which

is being used as a storage area and employee lunchroom) is not accessible, in that the door has hardwarewhich requires tight grasping, pinching, or twisting of the wrist, and the threshold is too high. StandardsSS 4.1.3(8), 4.13.8, 4.13.9.

b. The exterior entrance to the hospitality suite (alsodesignated guest room 104) is not accessible, in thatthe threshold is too high. Standards SS 4.1.3(8),4.13.8.

c. The door at the exterior entrance to the hotel laundryhas hardware that requires tight grasping, pinching, ortwisting of the wrist. Standards SS 4.1.3(8), 4.13.9.

5. Front lobby violationsa. The registration desk is too high. Standards S 7.2.b. The light fixtures on the wall protrude more than 4"

into the lobby. Standards S 4.4.1.2

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6. Interior route violationsa. The door to the storage area behind the front desk is

too narrow. Standards S 4.13.5.b. There is inadequate maneuvering clearance for the side

approach to the door from the lobby area to the areabehind the front desk. Standards S 4.13.6.

c. The hardware on the door from the lobby to thehospitality suite (also designated guest room 104)requires tight grasping, pinching, or twisting of thewrist, and is mounted too high. Standards S 4.13.9.

7. Violations with respect to public and common use toilet


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roomsa. The sign for the lobby restroom is not mounted on the

wall adjacent to the door of the restroom. StandardsS 4.30.6.

b. The toilet in the lobby restroom is too far from thewall. Standards S 4.16.2.

c. The grab bars for the toilet in the lobby restroom donot comply with the requirements of the Standards, inthat the rear wall grab bar is too short, and the sidewall grab bar does not project far enough from the rearwall. Standards S 4.16.4.

d. The hot water and drain pipes under the lavatory in thelobby restroom are not insulated or otherwiseconfigured to protect against contact. StandardsS 4.19.4.

e. The restroom used by guests or visitors using thehospitality suite (also designated guest room 104) is astandard hotel guest room bathroom, and isinaccessible. Standards S 4.1.3(11).

8. Violations with respect to public and common use rooms andspacesa. There are no visual alarms in the hospitality suite

(also designated guest room 104). Standards S 4.28.1.9. Violations with respect to guest rooms generally

a. The guest room number signs are not mounted on the walladjacent to the door for each guest room. StandardsS 4.30.6.

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b. The guest rooms designated accessible are not dispersed


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among the various classes of sleeping accommodationsavailable to patrons of the hotel, as specified below.Standards S 9.1.4.i) The hotel has at least one suite with a large

whirpool tub, but none of the guest roomsdesignated accessible has such a tub.

ii) Both of the guest rooms designated accessible arenon-smoking rooms. The hotel has approximately20 rooms where smoking is allowed, but none of those rooms is accessible.

c. The hotel has no rooms with visual alarms and too fewrooms with notification devices. The Standards requirea hotel with 35 rooms to have four rooms with visualalarms and notification devices. The hotel hasnotification devices for only one room. StandardsSS 9.1.2, 9.1.3, 9.3.

d. The doors to the bathrooms in the guest rooms notdesignated accessible are too narrow. StandardsSS 4.13.5, 9.4.

10. Violations with respect to guest rooms designated accessible-- Rooms 103 and 114a. The thresholds at the doors to guest rooms 103 and 114

are too high. Standards S 4.13.8.b. In guest room 103 there is inadequate maneuvering space

alongside and between the beds. Standards S 9.2.2.c. The deadbolts and locks on the connecting doors inguest rooms 103 and 114 require tight grasping,pinching, or twisting of the wrist, and are mounted toohigh. Standards S 4.13.9.

d. The operating controls for the lamps and drapes inguest rooms 103 and 114 are too high, and require tightgrasping, pinching, or twisting of the wrist.Standards S 4.27.4.

e. The shelf above the clothes rod in guest rooms 103 and114 is too high. Standards S 4.25.3.

f. The bathroom doors in guest rooms 103 and 114 swinginto the clear floor space required at both thelavatory and toilet. Standards S 4.23.2.

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g. The towel racks in the bathrooms in guest rooms 103 and114 do not have adequate clear floor space, and are toohigh. Standards SS 4.25.2, 4.25.3.

h. The toilets in the bathrooms in guest rooms 103 and 114are too far from the side walls. Standards S 4.16.2.

i. The grab bars for the toilets in guest rooms 103 and114 do not comply with the requirements of theStandards, in that the rear wall grab bar is too short,and the side wall grab bar does not project far enoughfrom the rear wall. Standards S 4.16.4.

j. Use of the grab bar on the wall behind the toilet in

the bathrooms in guest rooms 103 and 114 is obstructedby the towel rack mounted directly above the grab bar.Standards S 4.26.2.

k. The grab bars in the bathtubs in guest rooms 103 and114 do not comply with the requirements of theStandards, in that the grab bar at the foot of the tubis too short, and there is only one grab bar on therear wall of the tub. Standards S 4.20.4.

l. The controls for the bathtubs in guest rooms 103 and114 are improperly located. Standards S 4.20.5.

m. The hot water and drain pipes under the lavatories inguest rooms 103 and 114 are not insulated or otherwiseconfigured to protect against contact. StandardsS 4.19.4.

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EXHIBIT 2Actions to be taken by

HLS Enterprises, Inc. to remedy failures to complywith the ADA's Standards for Accessible Design, ("Standards")

to remedy violations set out in Exhibit 11. Parking and passenger loading zone violations

a. Two accessible parking spaces, including at least one

van accessible space, with access aisles and signagewill be provided, consistent with the Standards,SS 4.1.2(5), 4.6.2, 4.6.3, 4.6.4. An architect'sdrawing showing the accessible parking spaces isattached.

b. One of the parking spaces designated accessible will belocated on the shortest accessible route from theparking lot to the lobby entrance, consistent with theStandards, S 4.6.2. An architect's drawing showing theaccessible parking spaces and accessible route isattached.

c. Both accessible parking spaces will be modified to havea slope which does not exceed that allowed by theStandards, and both accessible parking spaces will bewidened to 96", and will have the required accessaisles, consistent with the Standards, S 4.6.3. Anarchitect's drawing showing the modified accessibleparking spaces and access aisles is attached.

d. A demarcated access aisle and signage will be providedat the passenger loading zone at the front entrance atthe hotel lobby, consistent with the Standards,


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S 4.6.6. An architect's drawing showing the demarcatedaccess aisle is attached.

e. A curb ramp will be installed at the lobby entrance,consistent with the Standards, SS 4.6.6, 4.7. Anarchitect's drawing showing the accessible curb ramp isattached.

2. Exterior route violationsa. The route from the swimming pool to the accessible

guest rooms will be made accessible, consistent withthe Standards, SS 4.1.2(2), 4.3. An architect'sdrawing showing the modified accessible route isattached.

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b. A ramp with the required slope, signage, and handrailswill be installed at the accessible walkway adjacent toaccessible guest room 103, consistent with theStandards, SS 4.3.8, 4.8. An architect's drawingshowing the modified accessible walkway, parking spaceand guest room is attached.

3. Violations at exterior and interior stairsa. Handrails between 1 1/4 inches to 1 1/2 inches in

diameter will be installed not more than 1 1/2 inchesfrom the wall with rail extensions returning in thedirection of egress traffic for the required length atthe top and bottom risers in each of the hotel'sstairways, consistent with the Standards, SS 4.9.4,4.26. An architect's drawing showing the handrailswith horizontal extensions is attached.

b. Barriers to warn blind or visually impaired personswill be provided at the underside of the existingstairs, consistent with the Standards, S 4.4.2. Anarchitect's drawing showing the cane-detectable


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barriers is attached.4. Entrance and exit violations

a. The existing hardware on the door to the employee lunchroom and storage area will be replaced with hardwarethat is consistent with the Standards, and thethreshold will be lowered to a height that isconsistent with the Standards, SS 4.1.3(8), 4.13.8,4.13.9.

b. A threshold to the guest room formerly designated as ahospitality suite will be installed that is consistentwith the Standards, SS 4.1.3(8), 4.13.8.

c. The existing hardware on the door at the exteriorentrance to the hotel laundry will be replaced withhardware that is consistent with the Standards,SS 4.1.3(8), 4.13.9.

5. Front lobby violationsa. An additional registration table of the required height

will be provided in the lobby, and a house telephonewith volume control will be located at the requiredheight, consistent with the Standards, SS 7.2, 4.31.An architect's drawing showing the modified accessiblefront desk area and house telephone is attached.

201-01167

b. The door between the lobby and the staff area will berelocated to allow for the required maneuvering space,consistent with the Standards, S 4.13. An architect'sdrawing showing the modified accessible door isattached.

c. A visual fire alarm will be installed in the lobby, andwill be tied in to the building-wide fire alarm system,consistent with the Standards, S 4.28. An architect'sdrawing showing the lobby visual fire alarm is


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attached.6. Interior route violations

a. The door to the storage area behind the front desk willbe removed, and the doorway enlarged to a width that isconsistent with the Standards, S 4.13.5. Anarchitect's drawing showing the modified accessibledoorway is attached.

7. Violations with respect to public and common use toiletroomsa. The sign for the lobby restroom will be mounted on the

wall adjacent to the restroom door, consistent with theStandards, S 4.30.6.

b. The existing rear and side grab bars in the lobbyrestroom will be replaced with grab bars of therequired length, mounted at the required heights, andat the required distance from the bathroom walls,consistent with the Standards, S 4.16.4. Anarchitect's drawing showing the modified accessiblelobby restroom and grab bars is attached.

c. The drain and hot water pipes in the lobby restroomwill be insulated against contact, consistent with theStandards, S 4.19.4.

d. A visual fire alarm will be installed in the lobbyrestroom and will be tied in to the building-wide fire

alarm system, consistent with the Standards, SS 4.1,4.28.8. Violations with respect to public and common use rooms and

spacesa. The hardware on the pool gate will be mounted at the

required height, consistent with the Standards,SS 4.3.1, 4.13.9. An architect's drawing showing theplacement of the pool gate hardware is attached.

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9. Violations with respect to guest rooms generallya. Guest room number signs will be mounted on the wall

adjacent to the latch side of the door for each guestroom, consistent with the Standards, S 4.30.6.

b. Visual alarms and notification devices will beinstalled in 4 guest rooms and will be tied into thebuilding-wide system, including visual fire alarmstrobes in two guest rooms, consistent with theStandards, SS 9.1.2, 9.1.3, 9.3. An architect'sdrawing showing the required visual alarms andnotification devices is attached.

c. Doors to bathrooms in all the first floor standardguest rooms will be modified to have the required 32"clear opening width, consistent with the Standards,SS 4.13.5, 9.4. An architect's drawing showing themodified accessible bathroom doors is attached.

10. Violations with respect to guest rooms designated accessible-- Rooms 103 and 114a. The thresholds in guest rooms 103 and 114 will be

modified to have heights that are consistent with theStandards, S 4.13.8.b. One of the guest rooms designated accessible will have

two double beds, and the other will have one king sizebed, consistent with the Standards, S 9.1.4. Anarchitect's drawing showing the modified accessibleguest rooms is attached.

c. The beds in the accessible guest room with two doublebeds will be reconfigured to provide the requiredmaneuvering space alongside and between the beds,consistent with the Standards, S 9.2.2. An architect'sdrawing showing the modified accessible guest room isattached.

d. The existing hardware on the connecting doors betweenguest rooms 103 and 114 will be replaced with hardwarethat is easy to grasp with one hand and does notrequire tight grasping, pinching or twisting of thewrist to operate, consistent with the Standards, S4.13.9.

e. The existing operating controls on the lamps and drapesin guest rooms 103 and 114 will be replaced with


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operating controls that are consistent with theStandards, S 4.27.4.

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f. The shelf above the clothes rod in guest rooms 103 and114 will be mounted at a height that is consistent withthe Standards, S 4.25.3. An architect's drawingshowing the modified accessible shelf is attached.

g. The bathroom doors in guest rooms 103 and 114 will bemodified so as not to swing out into the required clearfloor space at the lavatory and toilet, consistent withthe Standards, S 4.23.2. An architect's drawingshowing the modified accessible bathroom doors andclear floor space is attached.

h. The towel racks in the bathrooms in guest rooms 103 and114 will be remounted so as not to encroach on requiredclear floor space and at a height that is consistent

with the Standards, SS 4.25.2, 4.25.3. An architect'sdrawing showing the modified accessible bathrooms andtowel racks is attached.

i. The toilets in the bathrooms in guest rooms 103 and 114will be repositioned to the required distance from thesidewall to the center, consistent with the Standards,S 4.16.2. An architect's drawing showing the modifiedaccessible toilets is attached.

j. The existing rear and side grab bars in the toilets inguest rooms 103 and 114 will be replaced with grab barsof the required length, and will be mounted at therequired height, consistent with the Standards,S 4.16.4. An architect's drawing showing the modifiedaccessible toilets and grab bars is attached.

k. The towel rack above the grab bar in guest rooms 103and 114 will be mounted so as not to interfere with useof the rear grab bar, consistent with the Standards,S 4.20.4. An architect's drawing showing the modifiedaccessible towel rack is attached.

l. The existing foot and rear grab bars in the bathtubs inguest rooms 103 and 114 will be replaced with grab bars


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of the required length, and will be mounted at therequired height, consistent with the Standards,S 4.20.4. An architect's drawing showing theaccessible grab bars is attached.

m. The operating controls for the bathtubs in guest rooms103 and 114 will be repositioned, consistent with theStandards S 4.20.5. An architect's drawing showing theplacement of the accessible operating controls isattached.

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n. The drain and hot water pipes at the lavatories inguestrooms 103 and 114 will be protected from contact,

consistent with the Standards, S 4.19.4.o. The security devices on the doors in guestrooms 103 and114 will be mounted at the required height, consistentwith the Standards, S 4.13.9.

p. The guest rooms designated accessible will have signswith both raised lettering and Braille mounted on thewall adjacent to the door at the required height,consistent with the Standards, S 4.30. An architect'sdrawing showing the placement of the signs is attached.

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SOUTHERN DESIGNSL I M I T E D

July 24, 1996Alyse S. Bass, Esq.U.S. Department of JusticeCivil Rights Division1425 New York Avenue, Suite 4039P.O. Box 66738Washington, D.C. 20035-6738

Re: Days Inn Elberton, GeorgiaDear Ms. Bass:As per our conversation last week, the following items shall be noted;

1. Slope arrow shall be shown on all ramps.(revision # 28)


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Thank you for working with us on this project. If you shall have any furtherquestions or concernsplease call me. Look forward to your response.Sincerely,Ray E. Cox, Jr.REC:tccc: Mr Ricky Patel

Mr Robert LeverettEnclosure01-01173


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ADDENDUM NUMBER ONEDays InnElberton, Ga.Architect: Southern Design

Anderson, South CarolinaArchitects Project Number18 July 1996Addendum number one consists of modifications/changes to the specification anddrawings.SPECIFICATIONS/DRAWINGSIn section 8 DOORS AND WINDOWS for the clear meaning all lock/latchoperationsshall be leaver handles, no knobs are to be allowed. Leavers to be brushed,stainless steel finish to match existing on site.All other information contained on the drawings and in the specifications isto remain as is.END OF ADDENDUM NUMBER ONE.

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THE DAYS INN ELBERTON, GA.RENOVATION TO EXISTING DAYS INN ELBERTON, GA.FOR AMERICANS WITH DISABILITIES ACT COMPLIANCEAND U.S. DEPARTMENT OF JUSTICE SETTLEMENT PURPOSESDRAWING INDEXA COVER SHEET

A-1 SITE PLANA-2 FLOOR PLANS AND DETAILS01-01175


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(MAP) SITE PLAN01-01176


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(MAP) FLOOR PLAN ROOMS 102, 103, 113 & 11401-01177

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