ACCESS NOW, INC. v. AMBULATORY SURGERY CENTER GROUP, LTD.

IV. CONCLUSION

Because the Agreements proposed by the Parties are procedurally defective, the United States Objects to their approval and urges the Court to deny entry of these Agreements.

DATED: March ___, 2002

Respectfully submitted,
Ralph F. Boyd, Jr.
Assistant Attorney General
Civil Rights Division
John L. Wodatch, Chief
L. Irene Bowen, Deputy Chief
Philip L. Breen, Special Legal Counsel
Disability Rights Section

______________________________
Alyse S. Bass
Margaret L. Baskette
Trial Attorneys
Disability Rights Section
Civil Rights Division
United States Department of Justice
P.O. Box 66738
Washington, D.C. 20035-66738
(202) 616-9511
(202) 616-0330
(202) 307-1198 (fax)
[alyse.bass@usdoj.gov]
[peggy.baskette@usdoj.gov]

Guy A. Lewis
United States Attorney
Veronica Harrell-James
Assistant United States Attorney
Southern District of Florida
99 Northeast Fourth Street -6th Floor
Miami, Florida 33132
(305) 961-9327
Counsel for United States of America

CERTIFICATE OF SERVICE

I hereby certify that on this __ day of March, 2002, true and correct copies of “UNITED STATE’S MOTION FOR LEAVE TO PARTICIPATE AS AMICUS CURIAE” and “OBJECTIONS OF AMICUS CURIAE UNITED STATES TO PROPOSED CLASS ACTION PARTIAL SETTLEMENT AGREEMENTS OF NORTHWEST MEDICAL CENTER INC. AND LARGO MEDICAL CENTER, INC.,” and “PROPOSED ORDER” were served by Federal Express, postage pre-paid, on the following parties:

Miguel M. de la O
de la O and Marko, P.A.
3001 S.W. 3rd Avenue
Miami, Florida 33129
Attorney for Plaintiffs and the Class

Youndy C. Cook
Ford & Harrison
101 E. Kennedy Blvd.,
Suite 900
Tampa, Florida 33602
Attorneys for Settling Defendant

________________________
Alyse Bass