DISTRICT COURT Case
PLAINTIFF: Clifford Hackett, General Delivery, Barrigada, GU, 96913

DEFENDANT: GRTA grta.guam.gov

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.

3. Defendant blocks disabled .

4. ADA enacted 1/26/90,

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

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

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

8. Businesses are public accommodations. 42 USC 12181.

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

10. Removing barriers IS MANDATORY 28 C.F.R 36.304(a) – (c). By failing to remove barriers defendant violates the ADA.

CLAIM FOR RELIEF

The plaintiff pray that the Court order the defendant to remove barriers and pay plaintiffs attorney fees and such relief as the court sees fit.

I HEREBY CERTIFY this was sent to the other party when it was sent to this court and I will settle for mediation at www.rayis.me/ada

3PART MOTION

FOR FREE PROCESS

I request waiver of fees as my only income is $600social security and I pay $500rent

_GRANTED DENIED_

TO ALLOW FILING BY FAX

I request the reasonable accommodation of filing by fax as I am deaf/blind

_GRANTED DENIED_

FOR ELECTRONIC PROCESS SERVICE

I request as a reasonable accommodation leave to serve parties via Fax and/or Email

_GRANTED DENIED_