SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND OLYMPIA ENTERTAINMENT, INC. REGARDING JOE LOUIS ARENA

V. RESERVATION OF RIGHTS

43. If, for any reason, any time after the execution of this Settlement Agreement, it is reasonably foreseeable that Olympia’s planned Events Center or relocation shall fail to meet the schedule set forth in paragraph 13: (i) Olympia shall immediately provide written notice to the United States of such expected failure and any plans to cure; and (ii) subject to Olympia’s reservation of rights, claims and defenses as provided in paragraph 18 of this Settlement Agreement, the United States shall be free to seek further relief against Olympia, provided that such further relief shall not be implemented until the October 1, 2017-September 30, 2018 Entertainment Season.  Such further relief may include, but shall not be limited to, the removal of additional architectural barriers to access identified by the United States, to the extent such is readily achievable as required by applicable law, including modifying suites, and the installation of additional wheelchair seating locations and companion seating locations with comparable lines of sight. 

44. Should the United States find it necessary to seek further relief against Olympia pursuant to paragraph 43, Olympia shall agree to expedited resolution of this action such that any relief granted may be implemented, in whole or in part, for the October 1, 2017-September 30, 2018 Entertainment Season.

45. Nothing in paragraphs 43 through 44, shall relieve Olympia of any other obligations set forth in this Settlement Agreement.  Moreover, this Settlement Agreement in no way affects or relieves Olympia of its responsibility to comply with any other applicable federal, state, or local laws or regulations.