DISTRICT COURT CASE #

PLAINTIFF:

DEFENDANT:

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.

ALLEGATIONS

3. Plaintiffs are USA citizen .

4. Defendant owns a business

5. Defendant blocks disabled .

6. ADA enacted 1/26/90,

7. Congress said “discrimination persists" 42 U.S.C. l2101(a).

8. Congress said ADA is to "mandate standards” 42 U.S.C. 12101(b).

9. ADA implemented 1/ 26/92.

10. Defendant’s business has barriers

11. ADA Title III, covers "Public Accommodations and Services." 42 U.S.C. 12181.

12. Businesses are public accommodations. 42 USC 12181.

13. Defendant’s business has barriers

14 The barrier removal is “readily achievable” 42 USC12182(b)(2)(A)(iv).

15. Removing barriers IS MANDATORY 28 C.F.R 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, businesses get a tax credit of 50% of the cost

18. Plaintiff wants to use the defendant’s business.

CLAIM FOR RELIEF:

19. Pursuant to the ADA, 42 USC12101, et seq., and law pursuant to this Act, 28 CFR36.304, defendant was to remove barriers by 1/26/92. .

20. By failing to remove barriers defendant violates the ADA.

WHEREFORE, the plaintiff

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.

I HEREBY CERTIFY this was sent to the other party the same day it was sent to this court

Lawsuit will be dismissed for mediation at www.rayis.me/ada

Mahalo

SIGNATURE:
Clifford "RAY" Hackett www.rayis.me RESUME: www.rayis.me/resume

I founded www.adapt.org in 1980 it now has over 50 million members.
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