SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND THE CAVALIERS OPERATING COMPANY, LLC

I. BACKGROUND

1. The United States Attorney’s Office for the Northern District of Ohio (“USAO”) initiated a compliance review under Title III of the Americans with Disabilities Act, 42 U.S.C. §§ 12181 et seq. (“ADA”) regarding Quicken Loans Arena, located at One Center Court, Cleveland, Ohio (“Quicken Loans Arena”).  Under the authority granted by section 308(b) of the ADA, 42 U.S.C. § 12188, the USAO investigated Quicken Loans Arena’s policies and procedures, auxiliary aids and services, and seating in assembly areas, related to providing full and equal enjoyment to patrons with mobility impairments (e.g., use of a wheelchair), deaf patrons, and blind patrons (collectively, “Patrons with Disabilities”).