UNITED STATES DISTRICT COURT
                        SOUTHERN DISTRICT OF FLORIDA

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

   Ghanashyambhai M. Patel and
   Joyitshana G. Patel, d/b/a
   Econo-Lodge Motel
        Defendants.

   ______________________________

                                 COMPLAINT

   The United States of America, by and through the undersigned United
   States Attorney, files this complaint and alleges:

    1. This action is brought by the Attorney General on behalf of the
       United States of America to enforce Title II of the Civil Rights
       Act of 1964 ("Public Accommodations Act"), 42 U.S.C. §2000a,
       pursuant to the provisions of 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. The Defendants, Ghanashyambhai M. Patel and Joyitshana P. Patel,
       own and/or operate the Econo-Lodge Motel, located at 553 N.E. 1^st
       Avenue, Florida City, Florida, which is within the Southern
       District of Florida.
    4. The Defendants, Ghanashyambhai M. Patel and Joyitshana P. Patel
       reside within the Southern District of Florida.
    5. The Econo-Lodge is a business establishment that provides lodging
       facilities to transient guests for a fee.
    6. Econo-Lodge is a "place of public accommodation" within the
       meaning of 42 U.S.C. §2000a-(b)(1).
    7. The operations of the Econo-Lodge affect commerce within the
       meaning of 42 U.S.C. §2000a-(c)(1).
    8. The Defendants and their employees and/or agents, have implemented
       a policy and practice of denying African-American persons, on the
       basis of their race and color, the full and equal enjoyment of the
       facilities, services and accommodations of the Econo-Lodge Motel
       on the same basis as such facilities, services and accommodations
       are provided to white persons. This policy and practice has been
       implemented, among other ways, as follows:
         a. Assigning African-American persons to specifically designated
            rooms and/or areas of the motel because of their race and
            color;

                    IN THE UNITED STATES DISTRICT COURT
                    FOR THE SOUTHERN DISTRICT OF FLORIDA

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

                                                         Case No. 00-3832

   Ghanashyambhai M. Patel and
   Joyitshana G. Patel, d/b/a
   Econo-Lodge Motel
        Defendant.

   ___________________________________

                               CONSENT ORDER

   THIS MATTER came before the Court on the parties' Joint Motion to
   Enter Consent Order. The Court having reviewed the Motion and the file
   in this matter, and being otherwise duly advised in the premises
   thereof, finds as follows:

    I. INTRODUCTION

    1. On October 18, 2000, the Plaintiff, United States of America filed
       this action against the defendants, Ghanashyambhai M. Patel and
       Joyitshana G. Patel, the owners and/or operators of the Econo
       Lodge Motel, located at 553 N.E. 1^st Avenue, Florida City,
       Florida, pursuant to Title II of the Civil Rights Act of 1964
       ("Public Accommodations Act"), 42 U.S.C. §2000a, seeking a
       permanent injunction against the defendants from engaging in a
       pattern or practice of discrimination on the basis of race in the
       operation of their business.
    2. The complaint alleges that the defendants engaged in a pattern or
       practice of denying African-Americans the full and equal enjoyment
       of rights secured to them under 42 U.S.C. §§ 2000a et. seq., in
       the operation of the Econo Lodge Motel. Specifically, the United
       States alleges that the Defendants and their employees and/or
       agents, have implemented a policy and practice of denying
       African-American persons, on the basis of their race and color,
       the full and equal enjoyment of the facilities, services and
       accommodations of the Econo-Lodge Motel on the same basis as such
       facilities, services and accommodations are provided to white
       persons. This policy and practice has been implemented, among
       other ways, as follows:
         a. Assigning African-American persons to specifically designated