SETTLEMENT AGREEMENT BETWEEN
   THE UNITED STATES OF AMERICA
   AND
   THE MARYLAND STADIUM AUTHORITY
   UNDER THE AMERICANS WITH DISABILITIES ACT OF 1990
   CONCERNING ACCESSIBLE PARKING AT THE PSINET STADIUM
   LOCATED IN BALTIMORE, MARYLAND

       INTRODUCTION

   1. This Settlement Agreement (Agreement) is made and entered into by
   the United States of America (United States) and the Maryland
   Stadium Authority (MSA) referred to hereinafter as the "Parties".

   2. This Agreement resolves an investigation of the MSA and the
   Baltimore Ravens Limited Partnership (Ravens), conducted by the
   United States Department of Justice under titles II and III of the
   Americans with Disabilities Act of 1990, 42 U.S.C. §§12131-12189
   (ADA), concerning accessible parking spaces that serve spectators
   attending Baltimore Ravens football games at PSINet Stadium
   (Stadium) located in Baltimore, Maryland.

   3. The Parties agree as follows:

       THE TERM OF THE AGREEMENT

   4. This Agreement shall remain in effect for a period of three years
   from the date it becomes effective.

       THE PARTIES

   5. The term "Respondent" refers to the MSA.

   6. The term "Department" refers to the U.S. Department of Justice
   and, because the Department is the designated enforcement authority
   for the ADA under titles II and III of the ADA, "Department" is used
   interchangeably with "United States."

   7. The term "parking" or "parking area" refers to the area that is
   owned and operated by the MSA adjoining the Stadium and used for
   automobile parking during Ravens football games.
   8. The MSA is the current owner of the Stadium. MSA was created on
   July 1, 1986, by the Maryland General Assembly, as a section of the
   executive branch of the Maryland State government. MSA is a
   department, agency, special purpose district, or other
   instrumentality of a State or local government and is, therefore, a
   public entity within the meaning of 42 U.S.C. § 12131(1)(B) and 28
   C.F.R. § 35.104, and is subject to title II of the ADA.

       THE STADIUM

   9. PSINet Stadium includes the Stadium and the parking area owned by
   MSA and serving the Stadium.

   10. The Stadium is a building, structure, site, or complex, owned
   and operated by the MSA, and is, therefore, a "facility" within the
   meaning of 28 C.F.R. § 35.104, and is covered by title II.

   11. Construction of the Stadium began after January 26, 1992, and
   the Stadium is, therefore, a newly constructed facility within the
   meaning of title II of the ADA. 28 C.F.R. § 35.151(a).

       THE DEPARTMENT OF JUSTICE INVESTIGATION

   12. This matter was initiated by a complaint filed with the
   Department by a person with a disability who attends Ravens football
   games. The complaint alleges that the Ravens discriminate against
   people with disabilities in violation of the ADA because they fail
   to provide persons who need accessible parking with an equal
   opportunity to reserve parking spaces in advance. The Disability
   Rights Section undertook an investigation under the authority
   granted by Sections 203 and 308(b) of the ADA, 42 U.S.C. 12133 and
   12188(b).

   13. The United States asserts that, from June 2000 through the
   present, the Department conducted an in-depth investigation (the
   Department's File No. DJ 204-35-207 and 202-35-135) of the parking
   area, as well as the policies, practices and procedures used in
   operating the parking area for Ravens football games. The Department
   enters into this Agreement on the basis of the results of that
   investigation.

   14. The United States asserts that Respondent has violated the new
   construction provisions of title II of the ADA by designing and
   constructing, or by contracting with others to design and construct,
   the Stadium parking area so that it is not readily accessible to and
   usable by individuals with disabilities. Specifically, the United
   States asserts that Respondent failed to comply with the
   Department's regulation implementing title II of the ADA, including
   the Standards for Accessible Design (Standards) incorporated into
   the regulations and found at Appendix A to 28 C.F.R. Part 36.

   15. The United States asserts that the Ravens' reserved parking
   areas deny persons with disabilities an equal opportunity to
   participate in or benefit from the advantage of reserved parking
   provided to Club Seat members who do not require accessible parking
   in violation of title II of the ADA. 28 C.F.R. § 35.149.

   16. Respondent does not admit the truth of any of the alleged facts,
   characterizations of its alleged conduct, or conclusions asserted by
   the Department, as set out in this Agreement. Respondent denies that
   it has violated the ADA and nothing in this Agreement should be
   taken as an admission, explicit or implicit, that such violation has
   taken place. Respondent enters into this Agreement without prejudice
   to their rights to assert in any subsequent action or proceeding
   that any conditions identical or similar to those alleged by the
   Department do not violate the ADA or otherwise impose liability upon
   Respondent.

       REMEDIAL ACTION

         Policies

   17. Within 30 days of the effective date of this Agreement,
   Respondent will:

       a. Ensure that accessible entrances that are closest to
       accessible parking remain open and usable by individuals with
       disabilities during events held at the Stadium in accordance
       with § 4.14.1 of the Standards; and

       b. Train all employees who operate the parking area in the
       requirements of this Agreement.

         Parking Area

   18. Respondent has modified the spectator parking area to provide
   accessible parking spaces in accordance with § 4.1.2(5) of the
   Standards. The parking spaces are located as set forth in Exhibit A.

   19. In order to comply with the requirements of § 4.1.2(5) of the
   Standards, Respondent has:

       a. Re-striped accessible parking spaces so that each accessible
       space is at least 96 inches wide in accordance with § 4.6.3 of
       the Standards;

       b. Re-striped accessible parking spaces, excluding van
       accessible spaces, so that each has an obvious and contiguous
       access aisle at least 60 inches wide in accordance with §§ 4.3
       and 4.6.3 of the Standards;

       c. Re-striped the accessible parking spaces so that one out of
       every eight is a van-accessible space, meaning that it is 96
       inches wide and has an obvious and contiguous access aisle that
       is 96 inches wide in accordance with §§ 4.1.2(5) and A4.6.3 of
       the Standards;

       d. Installed signage so that each accessible parking space is
       identified by a sign that displays the international symbol of
       accessibility mounted so that it cannot be obscured by a vehicle
       parked in that identified space. Signage indicating the location
       of van-accessible parking spaces shall contain the words "van
       accessible" below the symbol of accessibility in accordance with
       §§ 4.6.4 and 4.30.7(a) of the Standards;

       e. Where necessary, modified the access aisles so that
       accessible parking spaces are joined to an accessible route in
       accordance with § 4.6.2 of the Standards; and

       f. Trained its employees so that they are aware of the location
       of the accessible or van-accessible parking spaces.

         Maintenance

   20. Respondent agrees to maintain the accessible routes connecting
   accessible parking spaces to accessible entrances. In order to
   maintain the accessible routes, Respondent will:

       a. Perform a weekly inspection of all access aisles and
       accessible routes between each accessible parking space and the
       accessible entrances for potholes, debris, or other obstacles
       that may be a potential barrier to accessibility during the
       football season. The first weekly inspection will take place no
       later than two weeks before the first preseason game to be held
       in the Stadium each season. These weekly inspections shall be
       held until the football season ends, meaning that either the
       Ravens have been eliminated from the playoffs or the playoffs
       have been completed, and either the Super Bowl will not be held
       in the Stadium or the Super Bowl has been completed;

       b. In addition to the weekly football season inspections,
       perform an inspection one week before each non-football event
       held in the Stadium;

       c. Maintain a log of every inspection it performs;

       d. Remove or repair any potential barrier to accessibility
       expeditiously upon discovery, whether discovered during an
       inspection or in any manner or time;

       e. Maintain the accessible parking spaces and access aisles and
       the accessible routes from the access aisles to the accessible
       entrances so that they are reasonably free of snow, ice, excess
       water, or any other obstacle made by natural occurrences, and
       the ground surface along the accessible route so that it is
       firm, stable and slip resistant when the parking area is in use
       for Ravens games and other events held in the Stadium.

   21. Respondent agrees not to reduce the total number of accessible
   and van-accessible parking spaces provided under the terms of this
   Agreement.

       IMPLEMENTATION AND ENFORCEMENT OF THIS AGREEMENT

   22. In consideration for the actions undertaken by Respondent under
   the terms of this Agreement, the United States agrees to refrain
   from filing suit or conducting further investigation of this matter
   except as provided in this Agreement or to enforce the terms of this
   Agreement.

   23. The Department may monitor and review compliance with this
   Agreement at reasonable times and upon reasonable notice.

   24. If the Department believes this Agreement or any provision of it
   has been violated, the Department shall promptly notify Respondent
   in writing of the nature of the alleged violation(s), and, within
   ten days of receipt by Respondent of said written notice from the
   Department, Respondent shall either satisfy the Department that no
   violation has taken place, or initiate and diligently pursue a cure
   of any such violation, to the Department's reasonable satisfaction.
   In each instance where the Department makes a reasonable
   determination that a violation of the Agreement has taken place and
   that a cure has not been initiated and diligently pursued within the
   ten-day period specified, or where the Respondent fails to
   adequately respond to the Department's written notice, the
   Department may exercise its rights under the Agreement or the ADA to
   enforce the provisions of the Agreement or of title II of the ADA.

   25. In the event that Respondent plans to modify the Stadium parking
   area so that it materially reduces or interferes with the
   accessibility of accessible parking spaces or access aisles, or the
   accessible routes from the access aisles to accessible entrances,
   Respondent shall notify the Department of the planned modifications.
   Such notice shall include a description of the planned or completed
   modifications, the estimated impact of those modifications, and a
   brief description of the reason(s) for each modification. Respondent
   shall make every reasonable effort to notify the Department of the
   planned changes in their earliest stages of development. Changes
   covered by this paragraph are those that have occurred since the
   Department's site investigation of September 3, 2000, or that have
   been made pursuant to this Agreement. If the Department determines
   that such a change would amount to a breach of this Agreement, said
   change will be subject to paragraph 24 of this Agreement.

   26. The Department recognizes that Respondent has previously allowed
   flexibility in its parking policies, locations and procedures, to
   provide additional, temporary parking zones for patrons requiring
   accessible parking. In the event Respondent makes such temporary
   modifications, those modifications will not be deemed by the
   Department to violate this Agreement, so long as all other
   provisions of this Agreement have been met, and also, provided the
   temporary modification: a) continues to comply with all relevant
   provisions of the ADA and its implementing regulations, consistent
   with the interpretations thereof underlying the terms of this
   Agreement, and its exhibit; and b) results in the provision of equal
   or greater accessibility to people with disabilities.

   27. Failure by the United States to enforce this entire Agreement or
   any provision of it with regard to any deadline or any other
   provision contained herein shall not be construed as a waiver by the
   United States of any right to do so.

   28. This Agreement is a public document. A copy of this document or
   any information contained herein may be made available to any
   person. Respondent, at its option, shall either provide a copy of
   this Agreement upon request or refer any person who inquires about
   obtaining a copy of this Agreement to the Department at the address
   and telephone number indicated following the Department's signature
   lines within this document.

   29. This Agreement shall be binding on Respondent and its successors
   in interest. Respondent has a duty to notify all such successors in
   interest of these obligations, and include notice of this Agreement
   and its terms in all future Agreements pertaining to the transfer of
   any right or interest in the Stadium's parking area or in the
   operation thereof.

   30. This Agreement shall be binding on all persons or entities with
   whom Respondent contracts to provide parking or parking services for
   football games at the Stadium. Respondent has a duty to notify such
   contractors of these obligations and include notice of this
   Agreement and its terms in all future contracts pertaining to
   providing parking or parking services for football games at the Stadium.

   31. If any provision of this Agreement is affected by any future
   proceeding in bankruptcy, the Parties shall jointly apply to the
   Bankruptcy Court for withdrawal to the United States District Court
   for the District of Maryland for resolution of the matter.

   32. This Agreement, including the exhibit attached hereto,
   constitutes the entire agreement between the Parties on the matters
   raised herein, and no other statement, promise, or agreement, either
   written or oral, made by either party or agents of either party,
   that is not contained in this written Agreement, shall be
   enforceable. In the event a court of competent jurisdiction
   concludes that any part of this Agreement is unenforceable, such
   portion shall be severed from this Agreement and all other portions
   shall remain enforceable.

   33. This Agreement applies to operation of the parking area when
   used for events held at the Stadium, with the exception of the
   maintenance provisions set forth in paragraph 20, which are
   effective as stated herein. It does not apply to any other use of
   the parking area owned, leased or operated by Respondent. This
   Agreement does not affect any continuing responsibility of
   Respondent to comply with the ADA, where applicable, concerning: (a)
   any duties of Respondents with regard to any other venues being
   designed, planned, modified or operated for use by the Ravens; (b)
   any responsibilities Respondent may incur toward employees under
   titles I and II of the ADA; (c) any other elements within the
   Stadium; and (d) sale or provision of tickets for events held in the
   Stadium.

   34. The Parties hereby represent and acknowledge that this Agreement
   is given and executed voluntarily and is not based upon any
   representation by either Party to the other Party as to the merits,
   legal liability, or value of any claims of the Parties or any
   matters related thereto.

   35. The Parties acknowledge that they have been afforded an
   opportunity to consider this Agreement and the terms and conditions
   set forth herein, and that they have read and understood the terms
   of this Agreement and have been given an opportunity to consult with
   their respective counsel prior to executing this Agreement.

   36. A signer of this document, in a representative capacity for the
   MSA or the Department, represents that he or she is authorized to
   bind such entity to this Agreement.

   37. In any instance where notice is required to be given to either
   of the Parties to this Agreement, such notice shall be provided in
   writing, sent via certified or registered U.S. Mail, return receipt
   requested, to the following individuals in their capacity as
   representatives of the Parties to this Agreement:

   The Maryland Stadium Authority:

       Edward E. Cline
       Deputy Director Maryland Stadium Authority
       The Warehouse at Camden Yards
       333 West Camden Street, Suite 500
       Baltimore, Maryland 21201
       410-333-1560

   The Department:

       John L. Wodatch, Section Chief
       Disability Rights Section
       Civil Rights Division
       U.S. Department of Justice
       P.O. Box 66738
       Washington, D.C. 20035-6738

   38. This Agreement may be executed in several counterparts, each of
   which shall be an original and shall constitute one and the same
   instrument. The exhibit hereto is hereby incorporated by specific
   reference into this Agreement, and its terms are made a part of this
   Agreement as though fully recited herein.

   39. The date this Agreement becomes effective is the date of the
   last signature below.

   *UNITED STATES OF AMERICA

   *  

       *THE MARYLAND STADIUM
       AUTHORITY*

   _______________________________
   RALPH F. BOYD, JR.
   Assistant Attorney General for Civil Rights

   JOHN L. WODATCH
   Chief

   SUSAN BUCKINGHAM REILLY
   Deputy Chief
   NAOMI MILTON
   Supervisory Attorney

   SUSAN G. QUINN
   Investigator
   Disability Rights Section
   Civil Rights Division
   U.S. Department of Justice
   P.O. Box 66738
   Washington, DC 20035-6738
   (202) 307-0982

   Date: __12-14-01________________________

   _______________________________
   RICHARD W. SLOSSEN
   Executive Director

   Date:  ___11/28/01______________________________

... Catatonic (n):  An aging cat in desperate need of Geritol.
___ Blue Wave/QWK v2.12