Within forty-five (45) days of the date of this Agreement, Walt Disney World Co. (WDW) shall offer to each of the complainants and each of their travel companions identified by the United States Department of Justice ("Department") compensatory damages for WDW's alleged failure to provide effective communication in violation of title III of the Americans with Disabilities Act ("ADA"). 42 ï½§ U.S.C. 12182(b)(2).
WDW agrees to provide compensatory damages to each complainant and those persons identified as travel companions by the Department during their earlier trips to Walt Disney World Resort that were the subject of complaints filed with the Department. As compensatory damages, WDW agrees to offer complainants, on their own behalf and on behalf of their travel companions, the choice of either:
- A repeat visit to Walt Disney World, Orlando, Florida, for the complainant and his or her travel companions, including:
- Four days and a three night stay at the Walt Disney Resort Hotel on WDW property, comparable to accommodations complainant had in the prior visit to Walt Disney World, unless the complainant stayed for more than four days on the prior visit, in which case WDW will agree to provide a stay of the same number of days at Walt Disney World during complainant's prior trip;
- Round-trip coach airfare to Orlando International Airport from the complainant's home city airport;
- "Be Our Guest Passes" for all members of each complainant's party, valid for four days in the Magic Kingdom, Epcot Center, Disney-MGM Studios, Typhoon Lagoon, Pleasure Island, Discovery Island, and River Country, which also includes unlimited use of the WDW transportation system;
- 500 Disney Dollars, for purchase only and not redeemable for United States currency, for each complainant and each travel companion; and,
- All travel and hotel accommodations under the terms of this Agreement are subject to availability, and must be completed by September 1, 1998.
In exchange for offers of payment of compensatory damages to complainants and their travel companions identified pursuant to this Agreement, the United States agrees to forego any further investigatory or legal action involving WDW on the basis of complainants' allegations.
The names and addresses of each complainant and their travel companions shall be provided by the Department to WDW within ten (10) days of the date of this Agreement.
Walt Disney World Co.
By: Corporate Officer
DEVAL L. PATRICK
Assistant Attorney General
Civil Rights Division
United States Department of Justice