IN THE UNITED STATES DISTRICT COURT
                   FOR THE WESTERN DISTRICT OF LOUISIANA
                             LAFAYETTE DIVISION

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

   BYRON RICHARD, D/B/A
   HYLITES LOUNGE,
         Defendant.

   _________________________________

                                 COMPLAINT

   The United States of America alleges:

    1. This action is brought by the Attorney General on behalf of the
       United States to enforce Title II of the Civil Rights Act of 1964
       (Public Accommodations), 42 U.S.C. § 2000a-5(a).
    2. This Court has jurisdiction of this action pursuant to 42 U.S.C.
       2000a-6(a) and 28 U.S.C. § 1345.
    3. Defendant Byron Richard owns and operates the business
       establishment known as "Hylites Lounge" located on Highway 91 in
       Gueydan, Louisiana, in the Western District of Louisiana. This
       Defendant is a resident of the Western District of Louisiana.
    4. Hylites Lounge is a nightclub facility where persons are amused
       and entertained by, inter alia, dancing, listening to live music,
       playing pool and other games, and drinking alcoholic and
       non-alcoholic beverages. Hylites Lounge offers its goods,
       services, and facilities to the public for a fee.
    5. Hylites Lounge is a place of public accommodation within the
       meaning of 42 U.S.C. § 2000a(b)(3).
    6. The operations of the Defendant at Hylites Lounge affect commerce
       within the meaning of 42 U.S.C. § 2000a(c)(3).
    7. Defendant has himself, and acting through his employees and
       agents, implemented a policy and practice of denying to
       African-American persons, on account of race, the full and equal
       enjoyment of the goods, services, facilities, and privileges of
       Hylites Lounge on the same basis as they make such available to
       non-African-American persons. This policy and practice has been
       implemented, among other ways, by refusing to admit
       African-American customers into the club while admitting white
       customers, and by refusing to serve African-American customers.
    8. The conduct of Defendant described in Paragraph 7 constitutes a
       pattern or practice of resistance to the full and equal enjoyment

                    IN THE UNITED STATES DISTRICT COURT
                       WESTERN DISTRICT OF LOUISIANA
                        LAFAYETTE-OPELOUSAS DIVISION

   UNITED STATES OF AMERICA,
        Plaintiff

   v.

                                                 CIVIL ACTION NO. 99-1594
                                                           JUDGE MELANÇON
                                                 MAGISTRATE JUDGE METHVIN
   BYRON RICHARD, D/B/A
   HYLITES LOUNGE,
        Defendant

   ____________________________________

                               CONSENT DECREE

   On August 31, 1999, the United States filed its complaint in this
   action alleging that the Defendant violated Title II of the Civil
   Rights Act of 1964, 42 U.S. C. §§ 2000a et seq., by discriminating
   against African-Americans.

   Defendant Byron Richard presently owns and operates, along with
   co-owner Dewey Dupree, III, a bar and nightclub known as Hylites
   Lounge, located at 205 First Street, Louisiana Highway 91 South,
   Gueydan, Louisiana. Defendant Byron Richard also currently owns and
   operates a bar and nightclub known as Charlie's Lounge in Mermentau,
   Louisiana. In the Complaint, the United States alleges that the
   Defendant has engaged in a pattern and practice of denying to
   African-American persons, on the basis of race, the full use and
   enjoyment of the goods, services, facilities, privileges, advantages,
   and accommodations of Hylites Lounge on the same basis as such are
   provided to white members of the general public. More specifically,
   the United States alleges that the Defendant has excluded
   African-American persons from entering the nightclub by, among other
   means, refusing admittance and refusing to serve African-Americans.
   For the purposes of establishing jurisdiction, the parties stipulate
   that at all times relevant to the allegations of the United States,
   Hylites Lounge is a "place of public accommodation" within the meaning
   of 42 U.S. C. § 2000a (b) (3), and that its operations "affect
   commerce" within their meaning of 42 U.S. C. § 2000a (c).

   At this time, the United States and the Defendant have agreed that, in
   order to avoid protracted and costly litigation, their controversy
   should be resolved without further litigation, through the terms of