Complaint,Petition: ORLANDO GARCIA VS PALMETTO HOSPITALITY OF SANTA MONICA II, LLC

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                                20SMCV01700
                         Assigned for all purposes to: Santa Monica Courthouse, Judicial Officer: Mark Young




Electronically FILED by Superior Court of California, County of Los Angeles on 11/06/2020 01:49 AM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Watson,Deputy Clerk
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                       CENTER FOR DISABILITY ACCESS
          2            Raymond Ballister Jr., Esq., SBN 111282
                       Russell Handy, Esq., SBN 195058
          3            Amanda Seabock, Esq., SBN 289900
                       Zachary Best, Esq., SBN 166035
          4            Mail: 8033 Linda Vista Road, Suite 200
                       San Diego, CA 92111
          5            (858) 375-7385; (888) 422-5191 fax
          6            amandas@potterhandy.com

          7            Attorneys for Plaintiff
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                                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                                     COUNTY OF LOS ANGELES
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                           Orlando Garcia,                                                      Case No.
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                                    Plaintiff,
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                              v.                                                                Complaint For Damages And
                                                                                                Injunctive Relief For
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                           Palmetto Hospitality of Santa                                        Violations Of: Americans With
                           Monica II, LLC, a California                                         Disabilities Act; Unruh Civil
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                           Limited Liability Company;                                           Rights Act
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                            and Does 1-10,
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                                    Defendants,
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        20                    Plaintiff Orlando Garcia complains of Palmetto Hospitality of Santa
        21        Monica II, LLC, a California Limited Liability Company; and Does 1-10
        22        (“Defendants”), and alleges as follows:
        23             PARTIES:
        24             1. Plaintiff is a California resident with physical disabilities. He is
        25        substantially limited in his ability to walk. He suffers from cerebral palsy. He
        26        has the use of only one arm. He uses a wheelchair, walker, or cane for mobility.
        27             2. Defendant Palmetto Hospitality of Santa Monica II, LLC owns and
        28        operates the Hampton Inn & Suites Santa Monica, located at 501 Colorado


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                  Complaint