Complaint,Petition: ORLANDO GARCIA VS BLUE DEVILS LESSEE, LLC

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                                20SMCV01428
                                  Assigned for all purposes to: Santa Monica Courthouse, Judicial Officer: H. Ford III



Electronically FILED by Superior Court of California, County of Los Angeles on 10/02/2020 03:03 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Watson,Deputy Clerk


                  1
                               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
                  8
                                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA
                  9
                                                             COUNTY OF LOS ANGELES
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                11
                                   Orlando Garcia,                                                      Case No.
                12
                                             Plaintiff,                                                 UNLIMITED CASE
                13
                                      v.
                                                                                                        Complaint For Damages And
                14                                                                                      Injunctive Relief For
                                   Blue Devils Lessee, LLC, a
                                   Delaware Limited Liability                                           Violations Of: Americans With
                15                                                                                      Disabilities Act; Unruh Civil
                                   Company; and Does 1-10,
                                                                                                        Rights Act
                16
                                            Defendants,
                17                                                                                      Damages demanded exceed
                                                                                                        $25,000.
                18
                19
                20                    Plaintiff Orlando Garcia complains of Blue Devils LLC, and Does 1-10
                21         (“Defendants”), and alleges as follows:
                22
                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 Blue Devils LLC, owns and operates the Le Meridien Delfina
                28         Santa Monica Hotel located at 530 Pico Blvd., Santa Monica, California,


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                           Complaint