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ADA template
https://docs.google.com/document/d/1tAw1qMypInPgBP-NGXzYMAXghp5yXKCTcorzrfW-_D4/edit?usp=drivesdk
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.
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MLB coach hit by foul ball, needs surgery
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North Korea news
The New York Times
Times Insider
A Eureka Moment for Two Times Reporters: North Korea’s Missile Launches Were Failing Too Often
By DAVID E. SANGER
MARCH 6, 2017
Times Insider delivers behind-the-scenes insights into how news, features and opinion come together at The New York Times.
This still image released in January purportedly shows a missile launched off the coast of North Korea igniting in mid-air on Dec. 21, 2015. North Korea had previously dubbed this event a “successful” ballistic missile test.
KCTV / AGENCE FRANCE-PRESSE — GETTY IMAGES
WASHINGTON — The launches were failing too often.
That was the topic of the conversation I was having one day late last spring with Bill Broad, one of The Times’s premier science writers. Just about every time the North Koreans tried to launch an advanced missile, it seemed to end up in the ocean seconds later. Maybe it was bad luck, we said to each other, or bad parts, or bad welding. After all, the North Koreans are not known for quality-control. Or maybe something else was going on.
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EDITORIAL
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CONTRIBUTING OP-ED WRITER
7rules
1make peace with your past so it won’t disturb your future
What others think of you is none of your business
The only one in charge of your happiness is you
Don’t compare yourself to others as comparison is the thief of joy
Time Heals so give it time
Stop thinking too much it’s okay not to know all the answers
Smile at you do not own all the problems in the world
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36size
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.
$500 of material=World’s fastest hydrofoil sailboat. http://sunrun.biz
China has FSM Spies all over Guam taking pictures of submarines and aircraft carriers
FSMspies.jpg signature rate
On Mar 4, 2017 9:51 AM, "Ray Hackett" <3659745> wrote:
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On Mar 4, 2017 9:04 AM, "Ray Hackett" <3659745> wrote:
R..China has FSM Spies all over Guam taking pictures of submarines and aircraft carriers
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66BibleBooks49pages China has FSM Spies all over Guam taking pictures of submarines and aircraft carriers
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On Mar 4, 2017 9:04 AM, "Ray Hackett" <3659745> wrote:
R..China has FSM Spies all over Guam taking pictures of submarines and aircraft carriers
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China FSM spies
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.
$500 of material=World’s fastest hydrofoil sailboat. http://sunrun.biz
On Sat, Mar 4, 2017 at 9:43 AM, Ray Hackett <3659745> wrote:
Mahalo
SIGNATURE:
Clifford "RAY" Hackett www.rayis.me RESUME: www.rayis.me/resumeI founded www.adapt.org in 1980 it now has over 50 million members.
$500 of material=World’s fastest hydrofoil sailboat. http://sunrun.biz
China FSM spies
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.
$500 of material=World’s fastest hydrofoil sailboat. http://sunrun.biz
Solar 