SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND PALACE SPORTS AND ENTERTAINMENT, LLC, REGARDING THE PALACE OF AUBURN HILLS

A. Arena Assembly Seating:

14. PSE shall provide at least 99 wheelchair accessible seats in The Palace in compliance with the wheelchair space requirements set forth in §802.1 of the 2010 Standards, in accordance with the drawings attached to this Agreement as Exh A, no later than October 1, 2013.

15. At least one companion seat shall be provided for each wheelchair space. Companion seats shall be located to provide shoulder alignment with adjacent wheelchair spaces. The shoulder alignment point of the wheelchair space shall be measured 36 inches from the front of the wheelchair space. The floor surface of the companion seat shall be at the same elevation as the floor surface of the wheelchair space. Companion seats shall be equivalent in size, quality, comfort, and amenities to the seating in the immediate area. Companion seats shall be permitted to be movable. See the 2010 Standards §§ 221.3, 802.3.1 and 802.3.2. If an individual using a wheelchair purchases more than one companion seat, PSE shall offer the individual a location for the additional companion(s) in the same row if such location is available at the time of purchase.

16. PSE will ensure that all accessible and companion seating will be integrated with the rest of the seating on that level. See the 2010 Standards §221.2.2.

17. For basketball configurations, PSE shall provide three (3) first-row wheelchair spaces with three (3) companion seats, with adequate horizontal dispersal to be determined by PSE. If these wheelchair spaces and companion seats are not purchased as part of a season ticket package, they will be filled and sold on an individual game basis in the same manner as other accessible seating. See the 2010 Standards §§ 221.1, 221.2.3.1, 221.3, 802.1 and 802.3.

18. For basketball game seating configurations, PSE shall allow a space which could accommodate a wheelchair adjacent to the players' bench. The space need not be marked, and a removable seat may be placed in the wheelchair space when it is not required to accommodate a person eligible for the wheelchair space. See the 2010 Standards §§ 221.2.1.4 and 802.1.

19. For concert configurations, PSE shall provide twelve (12) wheelchair spaces with twelve (12) companion seats on the arena floor, with ADA-compliant lines of sight. The spaces will typically be located in the first two rows on the arena floor, but may be adjusted based on artist requirements and varying stage configurations. See the 2010 Standards §§ 221.1, 221.2.3, 221.3, 802.1 and 802.3.

20. As all new arena assembly accessible seating shall be accessed from the rear, PSE shall ensure all spectators using wheelchairs are situated as far forward in each space as possible, and that all circulation paths in front of wheelchair spaces are not improperly encroached. See the 2010 Standards §§ 221.1 and 802.1.5.

21. Each wheelchair and companion seating location shall provide lines of sight over both seated and standing spectators comparable to those enjoyed by persons without disabilities in the same area. See the 2010 Standards §§ 221.2.3 and 802.2.

22. PSE shall alter 5% of aisle seats (for a total of 99 seats) to provide for removable armrests. The designated aisle seats shall be the aisle seats located closest to the accessible routes and shall be identified with a sign or marker. See the 2010 Standards, §§221.4, 802.4.1, and 802.4.2.