Monthly Archives: June 2017
2motions1page
2motions 1page
2 MOTIONS:
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
I hereby request leave to proceed in forma pauperis and state under oath that I am unable to pay the costs for commencement of this action, or to give security therefor, and that I believe I am entitled to redress.I further state the following:I have no sources of income. I have $0 IN CASH. I have $0 in the bank. I own no property.
I declare under penalty of perjury that the foregoing is true and correct.
THE MOTION FOR FOR LEAVE TO PROCEED IN FORMA PAUPERIS IS: GRANTED_ DENIED_
FOR PERMISSION FOR ELECTRONIC CASE FILING
As the Plaintiff in the above-captioned matter, I respectfully ask the Court for permission to participate in electronic case filing (“e-filing”) in this case. I hereby affirm that:
1. I have reviewed the requirements for e-filing and WILL abide by them.
2. I understand that once I register for e-filing, I will receive notices and documents only by email.
3. I have regular access to the technical requirements necessary to e-file successfully: A computer with internet access; An email account on a daily basis to receive notifications from the Court and notices from the e-filing system. A scanner to convert documents that are only in paper format into electronic files; A printer or copier to create required paper copies such as chambers copies; A word-processing program to create documents; and A pdf reader and a pdf writer to convert word processing documents into pdf format, the only electronic format in which documents can be e-filed.
The Motion for Permission for Electronic Case Filing is: GRANTED_
DENIED_
kei
Republican Rep. Clay Higgins on ‘Islamic Horror’: ‘Kill Them All’ – The Daily Beast
ADAtemplate
IN THE UNITED STATES DISTRICT COURT CASE #
PLAINTIFF: Ray Hakit
Gen Del Tumon Guts 96911
DEFENDANT: KEI
674A South Marine Drive
Tamuning, GU 96913
COMPLAINT
1. This Court has subject matter jurisdiction under 28 U.S.C. sections 1331 and 1343.
2. This action is commenced pursuant to 2201 and 2202 and 42 U.S.C., section 1983.
GENERAL ALLEGATIONS
3. Plaintiffs are citizen of the United States of America.
4. Defendant owns a commercial business
5. Plaintiffs are individuals with disabilities. Defendant’s business blocks disabled persons.
6. On July 26, 1990, Congress enacted the ADA, 42 U.S.C. section 12101, et seq.
7. The Congressional findings include: “discrimination persists "42 U.S.C. section l2101(a).
8. Congress says ADA is to: mandate “standards” 42 U.S.C. section 12101(b).
9. Congress gave time to implement the Act. The effective date was January 26, 1992.
10. Defendant’s business has barriers that block disabled persons.
11. ADA Title III, covers "Public Accommodations and Services." 42 U.S.C. section 12181.
12. Congress included businesses as public accommodations. 42 U.S.C. section 12181.
13. Defendant’s business is a public accommodation discriminating by not removing barriers
14 The barrier removal is.“readily achievable” 42 U.S.C.. section 12182(b)(2)(A)(iv).
15. Readily achievable removing barriers 28 C.F.R.. section 36.304(a) – (c).
16. Similar businesses have made similar modifications, but defendant chose not to comply.
17. In Section 44 and 190 of the IRS Code, a small business gets a tax credit of 50% of the barrier removal cost up to $10,500 yearly. Big businesses get up to $15,000 yearly.
18. Plaintiff wants to use the defendant’s business.
CLAIM FOR RELIEF:
19. Pursuant to the ADA, 42 U.S.C. section 12101, et seq., and law pursuant to this Act, 28 C.F.R. §36.304, defendant was to remove barriers by January 26, 1992. Defendant has not.
20. By failing to remove barriers defendant violates the ADA.
WHEREFORE, the plaintiffs pray that the Court order the defendant to remove barriers and pay plaintiffs attorney fees and such relief as may be just, proper, and equitable.
NAME:
I HEREBY CERTIFY that a true copy of the foregoing was sent to the other party the same day it was sent to this court.
Call/w prosecutor supervisor
j3
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On Jun 1, 2017 10:46 AM, "Ray Hackett" <3659745> wrote:
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