SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND AURORA HEALTH CARE UNDER THE AMERICANS WITH DISABILITIES ACT

BACKGROUND

1. The parties to this Settlement Agreement are the United States of America and Aurora Health Care, Inc. ("Aurora").

2. This matter is based upon two complaints filed with the United States Department of Justice, in which the Complainants allege that Aurora discriminated against them on the basis of disability in violation of title III of the Americans with Disabilities Act ("ADA"), 42 U.S.C. §§ 12181-12189. Specifically, the Complainants allege that Aurora refused to provide medical treatment to them because they have the human immunodeficiency virus ("HIV").

3. The parties have reached agreement, which the United States believes is in the public interest, to resolve this dispute. The parties therefore voluntarily enter into the following Agreement: