SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND BLOCKBUSTER INC.DEPARTMENT OF JUSTICE COMPLAINT NUMBER 202-35-231

Monetary Relief for Complainant

19. The ADA authorizes the Attorney General to seek a court award of compensatory damages on behalf of individuals aggrieved as the result of violations of Title III of the ADA. 42 U.S.C. § 12188(b)(2)(B); 28 C.F.R. § 36.504(a)(2).

20. Within ten (10) days after the effective date of this Agreement, Blockbuster will compensate the Complainant in this matter by issuing a certified check made payable to the order of the Complainant in the amount of twelve thousand dollars ($12,000.00). Blockbuster will deliver the check to counsel for the United States by common carrier United Parcel Service, delivery prepaid, to the following address: William Lynch, Trial Attorney, Disability Rights Section, Civil Rights Division, 1425 New York Avenue, N.W., Washington, D.C. 20005. The United States will obtain Complainant´s signature on a release in the form attached hereto as Attachment B and will notify Blockbuster that it has done so. Upon obtaining Complainant´s signed release, the United States will send the Complainant the certified check described in this paragraph. The United States will send Blockbuster an original of the release signed by the Complainant promptly after confirming receipt of the certified check by the Complainant.

21. Within ten (10) days after the effective date of this Agreement, Blockbuster will issue a check or money order in the amount of ten thousand dollars ($10,000.00) made payable to the order of the United States Treasury as a payment in furtherance of the public interest. 42 U.S.C. § 12188(b)(2)(C); 28 C.F.R. § 36.504(a)(3) Blockbuster will deliver the check or money order to counsel for the United States by common carrier United Parcel Service, delivery prepaid, to the following address: William Lynch, Trial Attorney, Disability Rights Section, Civil Rights Division, 1425 New York Avenue, N.W., Washington, D.C. 20005.