SETTLEMENT AGREEMENT UNDER THE AMERICANS WITH DISABILITIES
          ACT OF 1990 BETWEEN THE UNITED STATES OF AMERICA AND
        LAVERNE UNREIN AND JULIANA UNREIN, FORMER OWNERS OF THE
          PREFERRED MOTOR INN, LIMON, COLORADO, DJ 202-13-101


                                I. Background

        1. This matter was initiated by a complaint, dated July 1,
1994, filed with the United States Department of Justice ("the
Department"), against the Preferred Motor Inn ("Preferred"), in
Limon, Colorado. The complaint was investigated by the
Department under the authority granted by section 308(b) of the
Americans with Disabilities Act of 1990 ("ADA"), 42 U.S.C.
12188. The complainants are Carl W. Coates, who has a hearing
disability and uses a service animal, and Eleanor S. Coates, his
wife. They allege that they attempted to obtain overnight
lodging at the Preferred Motor Inn on June 16, 1994, but were
denied lodging due to the presence of Mr. Coates' service dog.

        2. At the time of this incident, Preferred was owned and
operated by Laverne and Juliana Unrein, and it was Preferred's
policy to deny lodging to anyone accompanied by an animal. There
were signs posted at the motel stating the motel's policy that no
animals were allowed. No exception was made for service animals
accompanying persons with disabilities.

        3. The parties to this Settlement Agreement ("Agreement")
are the United States of America and Laverne and Juliana Unrein
("the Unreins"), the former owners and operators of the Preferred
Motor Inn. The Unreins sold the Preferred Motor Inn on April 3,
1995, and now have no interest or control in the operation of
that facility.

        4. The parties enter into this settlement agreement in
order to avoid litigation and hereby agree as follows:

                        II. Title III Coverage

        5. Preferred is an inn, hotel, motel, or other place of
lodging, and is therefore a place of public accommodation as
defined in section 301(7)(A) of the ADA, 42 U.S.C. 12181, and
its implementing regulation, 28 C.F.R. 36.104.

        6. The ADA requires that public accommodations make
reasonable modifications in policies, practices, or procedures,
to permit the use of a service animal by people with a
disabilities. 28 C.F.R. 36.302(c).

        7. The complainant, Carl W. Coates, is an individual with a
disability, as defined by section 3(2)(A) of the Act and section
36.104 of the title III regulation. 42 U.S.C. 12102, 28 C.F.R.
 36.104. The complainant, Eleanor S. Coates, is an individual
known to have a relationship or association with an individual
with a disability. 42 U.S.C. 12182(b)(1)(E), 28 C.F.R. 
36.205.

                III. Actions to be taken by the Unreins

        8. The Unreins agree to pay to Carl W. and Eleanor S.
Coates each the sum of $250 by certified check within 45 days of
the date of this Agreement. The checks shall be made payable to
Carl W. Coates and Eleanor S. Coates and shall be mailed to them.
Copies of the checks and the transmittal letter(s) shall be sent
to counsel for the government.

        9. The Unreins agree that, should they own or operate an
inn, hotel, motel, or other place of public accommodation at any
time after the effective date of this agreement, they will take
the following actions within 45 days of their start of business
operations:
                a. The Unreins shall develop and post in a prominent
        location of the public areas a written policy statement
        indicating that persons with disabilities accompanied by
        service animals are welcome in the place of public
        accommodation, and that no proof of an animal's
        certification as a service animal is required. However,
        the Unreins may inquire of any person bringing an animal
        into the place of public accommodation whether such animals
        are service animals required because of a disability.

                b. The Unreins shall train any staff to ensure that
        all people with service animals are treated in a
        nondiscriminatory manner and are afforded the same service
        and courtesy as that afforded any customer of the place of
        public accommodation.

                        IV. Implementation

        10. Under section 308(b)(1)(B) of the ADA, 42 U.S.C.
12188(b)(1)(B), the Attorney General is authorized to bring a
civil action under title III in any situation where a pattern or
practice of discrimination is believed to exist or where a matter
of general public importance is raised. In consideration of the
Agreement as set forth above, the Attorney General agrees to
refrain from undertaking further investigation or from filing a
civil suit under title III in this matter.

        11. If the Department believes that this Agreement or
provisions thereof have been violated, it may institute a civil
action in the federal district court for Colorado, or any other
appropriate federal district court, following written notice to
the Unreins of the possible violation and a period of ten (10)
days in which the Unreins have the opportunity to cure the





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alleged violation. The Attorney General is authorized to seek
civil penalties pursuant to 42 U.S.C.  12188(b)(2)(C).

        12. A violation of this Agreement shall be deemed a
subsequent violation of the ADA. 42 U.S.C.  12188(b)(3) and 28
C.F.R.  36.504(b)

        13. This Agreement is a public document. A copy of this
Agreement or any information contained herein may be made
available to any person. The Unreins or the Department shall
provide a copy of this Agreement to any person upon request.

        14. This Agreement shall become effective as of the date of
the last signature below.

        15. This Agreement constitutes the entire agreement between
the parties on the matters raised herein, and no other statement,
promise, or agreement, either written or oral, made by either
party or agents of either party, that is not contained in this
written Agreement shall be enforceable. This Agreement is
limited to the facts as set forth in paragraphs 1 through 3, and
it does not purport to remedy any other potential violations of
the ADA or any other federal law.

For the United States:

Deval L. Patrick
Assistant Attorney General for Civil Rights


By:     (Signature)                     Date: 10/30/95
        John L. Wodatch
        Joan A. Magagna
        Phyllis M. Cohen
        Attorneys
        Disability Rights Section
        Civil Rights Division
        U.S. Department of Justice
        P.O. Box 66738
        Washington, D.C. 20035-6738
        (202) 514-3882

For the Unreins:
By:     (Signature)                     Date: 10/19/95
        Laverne Unrein
        P.O. Box 1557
        Hays, Kansas 67601
By:                                     Date: 10/19/95
Juliana Unrein
P.O. Box 1557
Hays, Kansas 67601