SUSAN FERREYRA and JOE MARSH, on
behalf of themselves and all others similarly situated, Plaintiffs,
v.
NATIONAL RAILROAD PASSENGER CORPORATION ("AMTRAK"),
Defendant.

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION)


Case No. C-96-2704 FMS


NOTICE OF PROPOSED SETTLEMENT

This Notice has been ordered by the United States District Court for the Northern District of
California.

NOTICE TO THE FOLLOWING PEOPLE

For purposes of this notice, a "person with a mobility impairment" is defined as a person with a
physical impairment that substantially limits one or more major life activities and results in a need for
one or more of the access features of the accessible bedrooms on Amtrak rail cars, which include,
among other features, more maneuvering room, grab bars and accessible rest room facilities.

This notice is provided to all persons with a mobility impairment who used or sought to travel and/or
use, or will use bedroom accommodations on Amtrak Superliner or Viewliner rail cars. If you are a
member of this group (hereinafter the "Plaintiff Class"), you are entitled to receive Amtrak services
and discounts as a result of this settlement, as specified in this notice.

THE LAWSUIT: On July 31, 1996, plaintiffs Susan Ferreyra and Joe Marsh ("Individual
Plaintiffs") filed a class action Complaint alleging that individuals with mobility impairments and those
associated with them, have been, are being or will be denied full and equal access to the services,
programs, and activities offered by defendant National Railroad Passenger Corporation ("Amtrak").

The Complaint alleged, among other things, that Amtrak discriminated against the Plaintiff Class by
(1) failure to ensure that information related to access is effectively received from and
communicated to passengers with disabilities; (2) failure to ensure that the limited number of
wheelchair- accessible sleeper rooms are reserved for persons who need access features; (3) failure
to provide a standard bedroom accommodation rate for passengers with access needs; and (4)
failure to ensure that certain train services and amenities are made available to passengers with
mobility impairments and those associated with them.

Amtrak denies all of the Complaint's individual and class claims. Amtrak asserts that it is in full
compliance with all applicable laws regulating Amtrak's responsibilities to persons with disabilities
and persons who are associated with them. However, the parties have agreed that, in order to
avoid protracted and costly litigation, and in order to provide additional transportation benefits to
persons with mobility impairments, this controversy should be settled as described in this Notice.

THE SETTLEMENT:Under the settlement, you need do nothing, and you will be bound by the
terms of the settlement and be eligible for the benefits provided by the settlement. Each person
described above is automatically a member of the class and is entitled to the discounts and services
offered by Amtrak under the terms of this settlement.

The terms of the settlement are described below. A complete copy of the settlement, including a
description of various defined terms, may be obtained from the Court as provided below. Subject
to Court approval, the following services and discounts will be provided by Amtrak in settlement of
this case:

A. Pricing Policies. (1) Discount for Passengers With A Mobility Impairment. For a period
of ten (10) years, Amtrak shall keep in place its currently existing fifteen (15) percent discount on
the Rail Fare charged to Passengers With A Mobility Impairment. For purposes of the settlement, a
"Passenger With a Mobility Impairment" means any Amtrak passenger who is a person with a
physical impairment that substantially limits one or more major life activities and results in a need for
one or more of the access features of the accessible bedrooms on Amtrak rail cars, and who at or
prior to the time of ticket collection, furnishes to an Amtrak conductor a written self-certification of
a Mobility Impairment on the form provided by Amtrak.

(2) Discount For An Adult Companion Of A Passenger With A Mobility Impairment. For a
period of three (3) years, one Adult Companion who accompanies a Passenger With A Mobility
Impairment and is traveling on the same Amtrak ticket as that Passenger With A Mobility
Impairment shall receive a fifteen (15) percent discount off his or her Amtrak Rail Fare.

(3) Accessible Bedroom Pricing. For a period of ten (10) years, a Passenger With A Mobility
Impairment who reserves an available Accessible Bedroom on an Amtrak intercity train shall be
charged the lowest regular non-discounted bedroom accommodation charge available on that train
for any Standard Bedroom at the time a passenger makes a reservation (the "Standard Fare").

(4) Accessible Bedroom Discount. For a period of three (3) years, Passengers With A Mobility
Impairment who reserve an available Accessible Bedroom shall receive an additional thirty (30)
percent discount off the Standard Fare.

B. Reservations Policies. (1) Reservations Hold For Accessible Bedrooms. For a period of
ten (10) years, Amtrak shall allow only Passengers With A Mobility Impairment to reserve
Accessible Bedrooms up until fourteen (14) days prior to the date of a train's departure from its city
of origin. Beginning after the fourteenth (14th) day prior to departure from the city of origin, Amtrak
shall permit persons other than Passengers With A Mobility Impairment to reserve an Accessible
Bedroom only when all Deluxe and Family Bedrooms on the train previously have been reserved.

C. Information Policies.(1) Customer Services Desk. Currently, a prospective Amtrak
passenger who calls Amtrak's 800 number can be transferred to a Customer Services Desk by any
reservation agent. Customer Services Desk personnel, who are available 24 hours a day, are
trained to handle questions posed by a person with a Mobility Impairment about Amtrak fares or
equipment. Amtrak shall provide supplemental training to its reservations and Customer Services
Desk agents to improve access to pertinent information for persons with Mobility Impairments.
Additionally, Amtrak shall reprogram its ARROW computer reservation system to implement the
above-described pricing policies and to include rail car diagrams which identify structural and
access features.

(2) Publications for Passengers With Disabilities. Amtrak shall develop publications directed
toward Passengers With A Mobility Impairment which describe Amtrak's services for passengers
with disabilities. These publications shall also include rail car diagrams which identify the rail cars'
structural and access features. These publications shall be distributed to Amtrak staff, travel agents
and anyone to whom Amtrak routinely distributes information and made widely available to
passengers.

(3) Complaint Resolution Personnel. Amtrak shall continue to make available complaint
resolution personnel who are available and fully empowered to resolve most customer service
issues. Such personnel are available on Amtrak trains, at staffed Amtrak stations, and through an
additional 800 number for handling customer inquiries and complaints by or for persons with
disabilities.

D. No Changes to ADA-Specified Structural and Architectural Access Requirements. The
ADA and federal transportation regulations specify requirements for Amtrak train cars and
bedroom accommodations. The settlement does not change any of these requirements.

E. Program Access. Amtrak will provide menus for meals and snacks to Passengers With A
Mobility Impairment. In those rail cars that are not required to have accessible path of travel or
access features, Amtrak will, when feasible, assist passengers with mobility impairments in moving
to locations where any onboard movie may be viewed.

F. Attorney's Fees and Payments To Class Representatives. Class Counsel will receive a
total amount of $80,000 in attorney's fees and costs. Amtrak shall pay to the Individual Plaintiffs the
total sum of $15,000.00 in settlement of their individual claims against Amtrak.

FAIRNESS HEARING AND OBJECTIONS

A Fairness Hearing will be held on May 1, 1998, at 10:00 a.m. in Courtroom 6 of the United States
District Court, 450 Golden Gate Avenue, San Francisco, California, where the Court will consider
entry of the proposed Consent Decree and hear objections, if any, to the proposed settlement.

Any class member who objects to the proposed settlement or wishes to appear and present such
objections at the Fairness Hearing must submit a written Statement of Objection containing his or
her name and address, the basis of his or her objections, a brief or memorandum in support of the
objections, and, if appropriate, a notice of intention to appear at the hearing to: Clerk of the Court,
United States District Court, 450 Golden Gate Avenue, San Francisco, CA 94192. A copy must
also be mailed to the following counsel for the parties:

Counsel for Plaintiffs:
Linda D. Kilb
Disability Rights Education and Defense Fund, Inc.
2212 Sixth Street
Berkeley, CA 94710

William F. Alderman
Orrick, Herrington & Sutcliffe LLP
400 Sansome Street
San Francisco, CA 94111
Counsel for Defendant:
Paula A. Barran
Constance E. Norton
Lane Powell Spears Lubersky LLP
333 South Hope Street, Suite 3125
Los Angeles, CA 90071-3033


Statements of Objection must be Postmarked no later than March 20, 1998. No person shall be
heard at the Fairness Hearing unless he or she has timely filed and served a Statement of Objection.

FOR MORE INFORMATION

For additional information regarding the proposed Consent Decree, or a copy of the Consent
Decree, class members or their counsel may contact Linda D. Kilb of the Disability Rights
Education and Defense Fund, Inc. at the address listed above or call her at (510) 644-2555. Each
class member or his or her counsel may also obtain detailed information about the case by
examining the case file located in the office of the Clerk of the United States District Court for the
Northern District of California, 450 Golden Gate Avenue, San Francisco, CA.

DATED: January 12, 1998.
By ORDER of the Court
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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