UNITED STATES DISTRICT COURT
                     FOR THE MIDDLE DISTRICT OF GEORGIA
                             VALDOSTA DIVISION

   UNITED STATES OF AMERICA,
        Plaintiff,

   vs.

                                               Civil Action No. 7:01-0008

   EARL WALKER, d/b/a The Knights,
   formerly Club 2000
        Defendant.

   ___________________________________

                               CONSENT DECREE

                                INTRODUCTION

    1. The United States has filed a complaint in this action alleging
       that defendant Earl Walker has violated Title II of the Civil
       Rights Act of 1964, 42 U.S.C. §§ 2000a et seq., by discriminating
       against African-Americans. The defendant presently owns and
       operates a bar and nightclub known at various times as "The
       Knights" or "Club 2000" (hereinafter "Club 2000"). In its
       Complaint, the United States alleges that the defendant has
       engaged in a pattern or practice of denying to African-American
       persons, on the basis of their race, the full and equal use and
       enjoyment of the goods, services, facilities, privileges,
       advantages, and accommodations of Club 2000. More specifically,
       the United States alleges that the defendant refused to serve
       African-American persons entering the nightclub.
    2. For the purpose of establishing jurisdiction, the parties
       stipulate that at all times relevant to the allegations of the
       United States, Club 2000 is a "place of public accommodation"
       within the meaning of 42 U.S.C. § 2000a(b)(3), and that its
       operations "affect commerce" within the meaning of 42 U.S.C.
       2000a(c).
    3. The United States and the defendant agree that in order to avoid
       protracted and costly litigation, their controversy should be
       resolved through the terms of this Consent Decree. Therefore,
       without a trial or adjudication on the merits, the United States
       and the defendant have consented to the entry of this Decree. Had
       this matter gone to trial, the United States would have presented
       evidence to establish that defendant has engaged in a pattern or
       practice of intentional race discrimination. Although a complete

                    IN THE UNITED STATES DISTRICT COURT
                         MIDDLE DISTRICT OF GEORGIA
                             VALDOSTA DIVISION

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

   EARL WALKER,
   d/b/a The Knights,
   formerly Club 2000,
        Defendant.

   ______________________________

                                 COMPLAINT

   Plaintiff, 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 Earl Walker, a resident of Valdosta, Georgia within the
       Middle District of Georgia, owns and operates a nightclub located
       at 4008 Bemiss Road, Valdosta, Georgia 31605. Mr. Walker's
       nightclub (hereinafter referred to as ("Club 2000") was known for
       a period of time as "Club 2000," and is currently known as "The
       Knights."
    4. Club 2000 is a facility which provides entertainment to persons by
       offering recorded music, dancing, and other forms of
       entertainment. Club 2000 offers its services, goods, and
       facilities to the public for a fee, including an admission price.
    5. Club 2000 is a place of public accommodation within the meaning of
       42 U.S.C. § 2000a(b)(3).
    6. The operations of the defendants at Club 2000 affect commerce
       within the meaning of 42 U.S.C. § 2000a(c)(3).
    7. Club 2000's clientele includes, in part, servicemen and
       servicewomen of the United States Air Force stationed at nearby
       Moody Air Force Base in Georgia.
    8. Defendant, by himself, and acting through his employees and
       agents, has implemented a policy and practice of denying to
       African-American persons, including African-American members of
       the United States Air Force, on account of their race, the full
       and equal enjoyment of the goods, services, facilities, and
       privileges of Club 2000 on the same basis upon which he made such