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  • ORLANDO GARCIA VS MICKEY MONDRAGON Civil Rights/Discrimination (General Jurisdiction) document preview
  • ORLANDO GARCIA VS MICKEY MONDRAGON Civil Rights/Discrimination (General Jurisdiction) document preview
						
                                

Preview

1 Center for Disability Access, APC Mark Potter, Esq., SBN 166317 2 Sumedh Rishi, Esq, SBN 348167 Mail: 100 Pine St., Ste. 1250 3 San Francisco, CA 94111 (858) 375-7385; (888) 422-5191 fax 4 ADALIT@cda4access.com 5 Attorneys for Plaintiff 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF LOS ANGELES 9 10 Orlando Garcia, Case No. 11 Plaintiff, UNLIMITED CIVIL CASE 12 v. 13 Verified Complaint for Damages Mickey Mondragon; and DOES 1 and Injunctive Relief for Violations of: Unruh Civil Rights Act; California 14 through 50, inclusive Disabled Persons Act 15 Defendants. 16 ACTION SUBJECT TO THE 17 SUPPLEMENTAL FEE IN GOVERNMENT CODE SECTION 18 70616.5 19 20 Plaintiff Orlando Garcia complains of Mickey Mondragon; and DOES 1 21 through 50, inclusive (“Defendants”), and alleges as follows: 22 23 Parties: 24 1. Plaintiff is a California resident with physical disabilities and a member of a 25 protected class of persons under the Americans with Disabilities Act. Plaintiff 26 suffers from Cerebral Palsy. He has manual dexterity issues. He cannot walk. He 27 uses a wheelchair for mobility. 28 2. Defendant Mickey Mondragon owned the real property located at or about 1 Verified Complaint PH#82922-01