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UNITED STATES v DAYS INN Click to find out why . . .



Keywords & Phrases
CaseNo: USVDI124603, CourtName: US DEPARTMENT OF JUSTICE, Plaintiff: UNITED STATES, State: DC Washington D.C., UniqueCaseRef: LCD>USVDI124603, Standards, Inn, Guest Rooms, Willows, Design, Hotel, Civil Rights Division, United States, Ada, Disabilities, Defendant Patel, Violations, Construction, California, Huffman, Consistent, Lobby, Defendant Iyer, Toilet, America, Lavatory, Facility, Operating, Accessible Route, Justice, Defendant Dia, Drawing, Compliance, Exhibit, Consent, Plan, Accessible Parking Spaces, Bathroom Doors, Commerce, Eastern District, Hfs, Disability, District, Floor, Contract, Regulation, Dilip Patel, Failures , ContentID: 120249298

Case Documents
1   CONSENT ORDER AND FINAL JUDGMENT - PATEL
[ see first page and extracted highlights below  ] ItemID: 121334
14 pages
TXT
2   CONSENT ORDER AND FINAL JUDGMENT - IYER
[ see first page and extracted highlights below  ] ItemID: 121333
7 pages
TXT
3   CONSENT ORDER AND FINAL JUDGMENT - HUFFMAN
[ see first page and extracted highlights below  ] ItemID: 121332
10 pages
TXT
4   COMPLAINT
[ see first page and extracted highlights below  ] ItemID: 121331
13 pages
TXT
Total Documents: 4 documents , 44 pages
Price: $ 34.95


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1 . CONSENT ORDER AND FINAL JUDGMENT - PATEL

EXTRACTED KEY WORDS
GUEST ROOMS
DESIGN
DEFENDANT PATEL
INN
CONSISTENT
WILLOWS
VIOLATIONS
LOBBY
DRAWING
HOTEL
TOILET
CIVIL RIGHTS DIVISION
DISABILITIES
PLAN
ACCESSIBLE PARKING SPACES
LAVATORY
BATHROOM DOORS
UNITED STATES
ADA
OPERATING
ACCESSIBLE ROUTE
FLOOR
DILIP PATEL
COMPLIANCE
EXHIBIT
CONSTRUCTION
FAILURES
EXTERIOR
CONTROLS
1  JANET RENO
   Attorney General
2
   DEVAL L. PATRICK
3  Assistant Attorney General
   Civil Rights Division
4
   JOHN L. WODATCH, Chief
5  Disability Rights Section
   Civil Rights Division
6
   ALYSE S. BASS
7  THOMAS M. CONTOIS
   Attorneys
8  Disability Rights Section
   Civil Rights Division
9  U.S. Department of Justice
   Post Office Box 66738
10 Washington, D.C. 20035-6738
   (202) 616-9511
11
   For United States of America
12
   KEN BAKER
13 Attorney for Dilip Patel
40 Constitution Drive, Suite D
14 Chico, California 95973
   (916) 898-1488
15
   For Defendant Dilip Patel
16
17                      UNITED STATES DISTRICT COURT
                       EASTERN DISTRICT OF CALIFORNIA
18
19 UNITED STATES OF AMERICA,     )
                                 )
20                   Plaintiff,  )
                                 )
21                               )       No.: CIV-S-96 260 WBS GGH
        v.                       )
22                               )
                                 )       CONSENT ORDER AND FINAL
23 DAYS INNS OF AMERICA, INC,    )       JUDGMENT DISMISSING
   HOSPITALITY FRANCHISE         )       CLAIMS OF THE UNITED
24 SYSTEMS, INC.,                )       STATES AGAINST DILIP
   DILIP PATEL,                  )       PATEL
25 IYER & ASSOCIATES, and        )
   R.E. HUFFMAN, INC.,           )
26                               )
SNIPPETS:
  • Assistant Attorney General Civil Rights Division
  • For Defendant Dilip Patel
  • hotel at 475 North Humboldt, Willows, California, ("the hotel" or 10 the "Willows Days Inn").
  • 12 United States Department of Justice, Civil Rights Division,
  • 21 failed to comply with the ADA's Standards for Accessible Design,
  • Appendix A ("the Standards").
  • defendant Patel has agreed to
  • remedy the violations of the Standards set out in Exhibit 1.
  • 16 facility within the meaning of section 303of the ADA.
  • usable by individuals with disabilities,
  • The failures of defendant Patel to design and construct
  • of their compliance with this order.
  • 25 any future involvement in the design and construction of a public
  • There are no accessible parking spaces.
  • hotel lobby does not have a demarcated access aisle.
  • There is no accessible route connecting the swimming pool
  • Violations at exterior and interior stairs and areas of rescue assistance
  • The toilet in the lobby restroom is too far from the side
  • The hot water and drain pipes under the lavatory are not
  • Violations with respect to guest rooms generally
  • The bathroom doors in the rooms not designated accessible
  • The operating controls for the bedside lamps and heating
  • floor space at the operating mechanism for the heating
  • Parking and passenger loading zone violations will be remedied consistent with the Standards
  • Exterior route violations will be remedied consistent with the Standards and as shown and

  • 2 . CONSENT ORDER AND FINAL JUDGMENT - IYER

    EXTRACTED KEY WORDS
    INN
    DEFENDANT IYER
    WILLOWS
    CIVIL RIGHTS DIVISION
    COURT
    DISTRICT
    ADA
    HOTEL
    ATTORNEYS
    DISABILITY RIGHTS
    JUSTICE
    CALIFORNIA
    AGREEMENT
    PAYMENT
    FACILITY
    COMMERCE
    CERTIFICATE
    THOMAS
    MARGARITA
    PRIETO
    WASHINGTON
    AMERICA
    COMPLIANCE
    CONSENT
    HERETO
    EXHIBIT
    VIOLATIONS
    LAW
    HEREBY
    
    1  ISABELLE KATZ PINZLER
       Acting Assistant Attorney General
    2  Civil Rights Division
    3  JOHN L. WODATCH
       ALYSE S. BASS
    4  THOMAS M. CONTOIS
       MARGARITA M. PRIETO
    5  Attorneys
       Disability Rights Section
    6  Civil Rights Division
       U.S. Department of Justice
    7  Post Office Box 66738
       Washington, D.C. 20035-6738
    8  (202) 514-0196
    9  Attorneys for the United States
    10
       JOHN BERGHOLT
    11 Severson and Werson
       One Embarcadero Center
    12 Suite 2500
       San Francisco, California 94111
    13 (415) 398-3344
    14 Attorney for Defendant Iyer & Associates
    15
                       UNITED STATES DISTRICT COURT
    16                EASTERN DISTRICT OF CALIFORNIA
    17
       UNITED STATES OF AMERICA,        )
    18                                  )
                         Plaintiff,     )
    19                                  )
                                        )            No.: CIV-S-96 260 WBS GGH
    20       v.                         )
                                        )
    21                                  )
       DAYS INNS OF AMERICA, INC,       )
    22 HFS INCORPORATED, DILIP PATEL,   )
       IYER & ASSOCIATES, and           )
    23 R.E. HUFFMAN, INC.,              )
                                        )
    24                   Defendants.    )
                                        )
    25
    26               CONSENT ORDER AND FINAL JUDGMENT AS TO
                         DEFENDANT IYER AND ASSOCIATES
    27
    28
    01-01127
    
    
    SNIPPETS:
  • THOMAS M. CONTOIS MARGARITA M. PRIETO
  • Attorneys Disability Rights Section
  • Civil Rights Division U.S. Department of Justice
  • Post Office Box 66738 Washington,
  • Attorneys for the United States
  • UNITED STATES DISTRICT COURT
  • others, Iyer and Associates, architect for the Days Inn
  • hotel at 475 North Humboldt Street, Willows, California, ("the
  • hotel" or the "Willows Days Inn").
  • 23 States and defendant Iyer have negotiated this agreement,
  • admission by Iyer that it has violated the ADA or any other law
  • by consent of plaintiff United States and
  • Venue is proper in this district.
  • 13 whose operations affect commerce.
  • 14 facility within the meaning of section 303of the ADA.
  • The first certificate of occupancy for the Willows Days
  • 27 after the date of this order; the second payment shall be due
  • and shall not be 10 construed to address any issues of ADA compliance at the Willows
  • 11 Days Inn not identified in Exhibit 1 hereto,
  • 12 compliance at any other commercial facility or public accommoda13 tion designed defendant
  • For Plaintiff United States of America:
  • I, the undersigned, hereby certify that I am an employee in the Office of the Clerk, U.S.

  • 3 . CONSENT ORDER AND FINAL JUDGMENT - HUFFMAN

    EXTRACTED KEY WORDS
    GUEST ROOMS
    HUFFMAN
    DESIGN
    INN
    WILLOWS
    DEFENDANT
    HOTEL
    CIVIL RIGHTS DIVISION
    VIOLATIONS
    UNITED STATES
    ADA
    ATTORNEY
    DISABILITY
    JUSTICE
    CONSTRUCTION
    LOBBY
    KAY
    HUFFMAN CORPORATION
    CALIFORNIA
    CONSENT
    COURT
    TOILET
    OPERATING
    COMMERCE
    PUBLIC ACCOMMODATION
    ACCESSIBLE ROUTE
    LAVATORY
    BATHROOM
    INADEQUATE
    
     1 JANET RENO
       Attorney General
     2
       DEVAL L. PATRICK
     3 Assistant Attorney General
       Civil Rights Division
     4
       JOHN L. WODATCH, Chief
     5 Disability Rights Section
       Civil Rights Division
     6
       ALYSE S. BASS
     7 THOMAS M. CONTOIS
       Attorneys
     8 Disability Rights Section
       Civil Rights Division
     9 U.S. Department of Justice
       Post Office Box 66738
    10 Washington, D.C. 20035-6738
       (202) 616-9511
    11
       For the United States
    12
       LAWRENCE H. KAY
    13 Attorney for R.E. Huffman Corporation
       Stanton, Kay & Watson
    14 7801 Folsom Boulevard, Suite 350
       Sacramento, California 95826
    15 (916) 381-7880
    16 For R.E. Huffman Corporation
    17 UNITED STATES DISTRICT COURT
       EASTERN DISTRICT OF CALIFORNIA
    18
    19 UNITED STATES OF AMERICA,            )
                                            )
    20                      Plaintiff,      )
                                            )
    21                                      )       No.: CIV-S-96 260 WBS GGH
            v.                              )
    22                                      )
                                            )       CONSENT ORDER AND FINAL
    23 DAYS INNS OF AMERICA, INC,           )       JUDGMENT DISMISSING
       HOSPITALITY FRANCHISE                )       CLAIMS OF THE UNITED
    24 SYSTEMS, INC.,                       )       STATES AGAINST DEFENDANT
       DILIP PATEL,                         )       R.E. HUFFMAN, INC.
    25 IYER & ASSOCIATES, and               )
       R.E. HUFFMAN, INC.,                  )
    26                                      )
                            Defendants.     )
    
    SNIPPETS:
  • Assistant Attorney General Civil Rights Division
  • Disability Rights Section Civil Rights Division
  • 12 LAWRENCE H. KAY
  • 13 Attorney for R.E. Huffman Corporation Stanton,
  • EASTERN DISTRICT OF CALIFORNIA 18
  • CONSENT ORDER AND FINAL JUDGMENT DISMISSING CLAIMS
  • On February 8, 1996, the United States filed an action
  • ("the hotel" or the "Willows Days Inn").
  • United States Department of Justice, Civil Rights Division,
  • failed to comply with the ADA's Standards for Accessible Design,
  • 28 C.F.R. Part 36, Appendix A ("the Standards").
  • Claims of the United States against Defendant R.E. Huffman Inc.
  • The Court may grant declaratory and other relief pursuant to 28 10 U.S.C. S S 2201 and 2202.
  • 13 whose operations affect commerce.
  • 14 facility within the meaning of section 303of the ADA.
  • 25 construction of the Willows Days Inn by constructing the hotel.
  • 16 construction of a public accommodation or commercial facility.
  • Parking and passenger loading zone violations
  • hotel lobby does not have a demarcated access aisle.
  • There is no accessible route connecting the swimming pool
  • The toilet in the lobby restroom is too far from the side
  • The hot water and drain pipes under the lavatory are not
  • Violations with respect to guest rooms generally
  • The bathroom doors in the rooms not designated accessible
  • The operating controls for the bedside lamps and heating
  • There is inadequate clear floor space at the toilets in

  • 4 . COMPLAINT

    EXTRACTED KEY WORDS
    DEFENDANT
    DISABILITIES
    WILLOWS
    HOTEL
    DESIGN
    STANDARDS
    CALIFORNIA
    CIVIL RIGHTS DIVISION
    CONSTRUCTION
    AMERICA
    DEFENDANT PATEL
    DEFENDANT DIA
    ADA
    GUEST ROOMS
    UNITED STATES
    FACILITY
    EASTERN DISTRICT
    HFS
    BUSINESS
    HUFFMAN
    CONTRACT
    REGULATION
    CHIEF
    SPECIFICATIONS
    DEFENDANT IYER
    MEANING
    LICENSE
    COURT
    PURSUANT
    
    1 JANET RENO
      Attorney General
    2
      DEVAL L. PATRICK
    3 Assistant Attorney General
      Civil Rights Division
    4
      JOHN L. WODATCH, Chief
    5 L. IRENE BOWEN, Deputy Chief
      Disability Rights Section
    6 Civil Rights Division
    7 ALYSE S. BASS
      THOMAS M. CONTOIS
    8 KEN S. NAKATA
      Attorneys
    9 Disability Rights Section
      Civil Rights Division
    10 U.S. Department of Justice
       Post Office Box 66738
    11 Washington, D.C. 20035-6738
       (202) 616-9511
    12
       United States of America
    13
    14                      UNITED STATES DISTRICT COURT
                           EASTERN DISTRICT OF CALIFORNIA
    15
    16 UNITED STATES OF AMERICA,    )
                                    )
    17                    Plaintiff,)
                                    )
    18              v.              )        No.:
                                    )
    19 DAYS INNS OF AMERICA, INC.,  )
       HOSPITALITY FRANCHISE        )            COMPLAINT
    20 SYSTEMS, INC., DILIP PATEL,  )
       IYER & ASSOCIATES,           )
    21 and R.E. HUFFMAN CORPORATION,)
                                    )
    22                              )
                        Defendants. )
    23 _____________________________)
    24
            The United States of America alleges:
    25
            1.      This action is brought by the United States to enforce
    26
       title III of the Americans with Disabilities Act of 1990 (the
    27
    
    SNIPPETS:
  • Assistant Attorney General Civil Rights Division
  • Deputy Chief Disability Rights Section
  • United States of America
  • EASTERN DISTRICT OF CALIFORNIA 15
  • 21 and R.E. HUFFMAN CORPORATION,)
  • The United States of America alleges:
  • title III of the Americans with Disabilities Act of 1990 (the
  • including the Days Inn hotel at 475 N. Humboldt,
  • Inn hotel in Willows,
  • This court has jurisdiction of this action under
  • Defendant HFS is a Delaware corporation with its
  • 19 principal place of business at 339 Jefferson Road, Parsippany,
  • Defendant DIA is a Delaware corporation with its
  • Defendant Patel is an individual who resides at 4705
  • Defendant Iyer and Associates is a California 2 corporation with its principal place of
  • 17 entered into and maintains license agreements (the "license
  • 19 facility that participates in the Days Inn system.
  • 01-01119 1 a place of lodging, it is also a public accommodation within the 2 meaning of
  • 11 in the business of providing architectural and design
  • 13 design and construction of the Willows Days Inn by designing the
  • 14 hotel pursuant to a contract with defendant Patel.
  • 18 Willows Days Inn by constructing the hotel pursuant to a contract
  • and specifications contained in the design
  • 27 ("the regulation"), including the Standards for Accessible
  • 13 has standard guest rooms with two beds,
  •    |