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IN THE UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF GEORGIA
VALDOSTA DIVISION


UNITED STATES OF AMERICA,
     Plaintiff,

v.

EARL WALKER,
d/b/a The Knights,
formerly Club 2000,
     Defendant.

______________________________


COMPLAINT

Plaintiff, the United States of America, alleges:

  1. This action is brought by the Attorney General on behalf of the United States to enforce Title II of the Civil Rights Act of 1964 (Public Accommodations), 42 U.S.C. § 2000a-5(a).

  2. This Court has jurisdiction of this action pursuant to 42 U.S.C. § 2000a-6(a) and 28 U.S.C. § 1345.

  3. Defendant Earl Walker, a resident of Valdosta, Georgia within the Middle District of Georgia, owns and operates a nightclub located at 4008 Bemiss Road, Valdosta, Georgia 31605. Mr. Walker's nightclub (hereinafter referred to as ("Club 2000") was known for a period of time as "Club 2000," and is currently known as "The Knights."

  4. Club 2000 is a facility which provides entertainment to persons by offering recorded music, dancing, and other forms of entertainment. Club 2000 offers its services, goods, and facilities to the public for a fee, including an admission price.

  5. Club 2000 is a place of public accommodation within the meaning of 42 U.S.C. § 2000a(b)(3).

  6. The operations of the defendants at Club 2000 affect commerce within the meaning of 42 U.S.C. § 2000a(c)(3).

  7. Club 2000's clientele includes, in part, servicemen and servicewomen of the United States Air Force stationed at nearby Moody Air Force Base in Georgia.

  8. Defendant, by himself, and acting through his employees and agents, has implemented a policy and practice of denying to African-American persons, including African-American members of the United States Air Force, on account of their race, the full and equal enjoyment of the goods, services, facilities, and privileges of Club 2000 on the same basis upon which he made such goods, services, facilities, and privileges available to non-African-American persons. This policy and practice has been implemented, among other ways, as follows:

    1. Refusing to admit African-American customers into the club while admitting white customers;

    2. Refusing to admit African-American customers on the same terms and conditions on which white customers are admitted;

    3. Charging African-American customers higher admission fees than white customers;

    4. Using advertising, including a billboard outside his nightclub, appealing to race discrimination; and

    5. Limiting the number of African-American customers at Club 2000.

  9. The conduct of defendants described in Paragraph 8 constitutes a pattern or practice of resistance to the full and equal enjoyment by African-American persons of rights secured by 42 U.S.C. § 2000a, et seq., and the pattern or practice are of such a nature and are intended to deny the full exercise of such rights.

  10. Unless restrained by Order of this Court, the defendants will continue to refuse to provide African-American persons with the full and equal enjoyment of rights secured to them by 42 U.S.C. § 2000a, et seq.

WHEREFORE, plaintiff, the United States, requests that the Court enter an Order:

  1. Declaring that the actions of the defendant as set forth above violate Title II of the Civil Rights Act of 1964, 42 U.S.C. § 2000a, et seq.

  2. Enjoining the defendant, his employees, agents, and successors, and all other persons in active concert or participation with any of them from engaging in any act or practice which, on the basis of race or color, denies or abridges any rights secured by Title II of the Civil Rights Act of 1964, 42 U.S.C. § 2000a, et seq.; and

  3. Enjoining the defendant, his agents, employees, and successors, and all other persons in active concert or participation with any of them from failing or refusing to take such affirmative steps as may be necessary to remedy the past unlawful conduct, including, but not limited to, informing the general public that the facilities of Club 2000 are available without regard to race or color, and restoring victims of defendants' past unlawful practices to the position they would have been in but for the discriminatory conduct.

The United States further prays for such additional relief as the interests of justice may require.


JANET RENO
Attorney General

G.F. Peterman, III
United States Attorney
M.D. Georgia

Bill Lann Lee
Assistant Attorney General
Civil Rights Division

Bill Gifford
Assistant United States Attorney
M.D. Georgia
P.O. Box 1702
Macon, GA 31202-1702

Joan A. Magagna
Chief, Housing & Civil Enforcement Section

Isabelle M. Thabault
Deputy Chief
Ming-Yuen Meyer-Fong
Attorney
Housing & Civil Enforcement Section
Civil Rights Division
Department of Justice
P.O. Box 65998
Washington, DC 20035-5998
Tel: (202) 514-4713


Document Filed: January 18, 2001

General Information Housing and Civil Enforcement Section
 
Leadership
Steven H. Rosenbaum
Chief
Contact
Housing & Civil
Enforcement Section
(202) 514-4713
TTY - 202-305-1882
FAX - (202) 514-1116
To Report an Incident of Housing Discrimination:
1-800-896-7743
Mailing Contact
U.S. Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, N.W.
Housing and Civil Enforcement Section, NWB
Washington, D.C. 20530

Email: fairhousing@usdoj.gov

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