[blindlaw] nfb v. lsac complaint
Michael Fry
mikefry79 at gmail.com
Sat Mar 14 17:01:42 UTC 2009
I did not know that a new policy regarding evalution of multiple LSAT scores
had been implemented. I agree with Angie and Craig that its better.
On Fri, Mar 13, 2009 at 10:15 PM, Craig Borne <cdborne at gmail.com> wrote:
> Angie,
> I wonder how many ABA accredited schools will follow the ABA's advice. I
> really believe this is a better way to go, though neither the ABA or law
> schools in general have solicited my advice. Shame on them.
> Craig
>
>
> Craig Borne
> Baltimore, Maryland
> "A long habit of not thinking a thing wrong, gives it a superficial
> appearance of being right, and raises at first a formidable outcry in
> defense of custom." --Thomas Paine, Common Sense
>
> -----Original Message-----
> From: blindlaw-bounces at nfbnet.org [mailto:blindlaw-bounces at nfbnet.org] On
> Behalf Of Angie Matney
> Sent: Saturday, March 14, 2009 12:55 AM
> To: NFBnet Blind Law Mailing List
> Subject: Re: [blindlaw] nfb v. lsac complaint
>
> Now that the ABA advises schools to only consider the highest score, it
> would seem to be less likely that a low first score would be considered
> irreparable harm.
>
> Angie
>
> On Fri, 13 Mar 2009 02:31:57 -0400, Rod Alcidonis wrote:
>
> >Well, academically speaking, the law suit could have prayed for a
> Temporary
>
> >Restraining Order, or a preliminary Injunction against the LSAC for folks
> >like you. Basically enjoined the LSAC from administering the exam until
> they
> >make the changes. The only difficulty with that I think justifies the
> reason
> >they probably did not pray for such a relief is that such a measure would
> >cause too much harm to the public, I.E, the thousands of law students and
> >schools who rely on the exam to make admissions decisions. Such an order
> >while it would have forced the LSAC to make the changes much faster, it
> >would have unreasonably halted the system for some times. If it were a
> class
> >action with thousands of members, it probably would have been easier to
> >argue, I think. Whether not passing an exam for the first time is
> considered
> >irreparable harm is another question -- you can still make the argument
> >under these circumstances.
>
> >Rod Alcidonis
> >Juris Doctor Candidate, 2009.
> >Roger Williams University School of Law
> >10 Metacom Ave., Box: 9003
> >Bristol, RI 02809
> >Cell: 718-704-4651
> >Home: 401-824-8685
>
> >----- Original Message -----
> >From: "Bill Spiry" <bspiry at comcast.net>
> >To: "'NFBnet Blind Law Mailing List'" <blindlaw at nfbnet.org>
> >Sent: Wednesday, March 11, 2009 9:52 PM
> >Subject: Re: [blindlaw] nfb v. lsac complaint
>
>
> >I understand. What might be done to getLSAC to authorize use of this
> >material as an accessible alternative to what they have to offer? I know
> NFB
> >is sueing them, but in the mean time that leaves folks like me who don't
> >have the Adobe skills you have, and facing the LSAT soon without
> accessible
> >matter. Any ideas or suggestions?
>
> >Thanks.
> >-----Original Message-----
> >From: blindlaw-bounces at nfbnet.org [mailto:blindlaw-bounces at nfbnet.org] On
> >Behalf Of James Pepper
> >Sent: Tuesday, March 10, 2009 10:43 AM
> >To: NFBnet Blind Law Mailing List
> >Subject: Re: [blindlaw] nfb v. lsac complaint
>
> >Well Bill the content is copyrighted by LSAC so I am not sure I can send
> >this to you. Perhaps some on this list can give that advice. I laid it out
> >properly.
>
> >James
>
> >On Tue, Mar 10, 2009 at 9:05 AM, Bill Spiry <bspiry at comcast.net> wrote:
>
> >> I would appreciate receiving this as well. Thanks.
> >> bspiry at comcast.net
> >>
> >>
> >> -----Original Message-----
> >> From: blindlaw-bounces at nfbnet.org [mailto:blindlaw-bounces at nfbnet.org]
> On
> >> Behalf Of James Pepper
> >> Sent: Tuesday, March 10, 2009 1:46 AM
> >> To: NFBnet Blind Law Mailing List
> >> Subject: Re: [blindlaw] nfb v. lsac complaint
> >>
> >> Scott: I laid out the first section of the LSAT to be accessible and I
> >> can
> >> send you the files if you would like to see it. Also I made the form
> that
> >> they use accessible so the blind can fill out the test without
> assistance.
> >> This works with JAWS and Window Eyes and a combination of Adobe's Read
> out
> >> Loud and Microsoft Narrator. My process works and if you need
> references
> >> at
> >> NFB, AFB and the AAPD I can send them to you.
> >>
> >> It took a while to figure out how they made thier pdfs and I know where
> >> they
> >> are making their mistakes. I can correct this problem. These PDFs are
> >made
> >> to work natively with JAWS and Adobe Reader and the other screen readers
> >> without making any adjustments. They work with the default settings in
> >> Adobe Reader.
> >>
> >> Also the forms can be digitally signed and saved and all that fancy
> stuff
> >> that you expect with Adobe Acrobat Professional can be done with
> >> Adobe Reader, versions 8 or 9 which is the free download from Adobe.com.
> >> So
> >> we can make the LSAT accessible to anyone with a PC running Windows XP
> Or
> >> VIsta without any change of settings. This means the PC can be there
> for
> >> the sighted and the blind, with equal access for all.
> >>
> >> Also since I labeled everything, it will be a lot quicker for you to
> fill
> >> out this test!
> >>
> >> Sincerely,
> >>
> >> James G. Pepper
> >>
> >>
> >>
> >> On Thu, Feb 19, 2009 at 4:32 PM, Scott C. LaBarre
> >> <slabarre at labarrelaw.com>wrote:
> >>
> >> > Below I am sharing the complaint that we filed today in California
> >Court.
> >> > **************
> >> > LaurEnce W. paradis (California Bar No. 122336)
> >> >
> >> > Anna levine (California Bar No. 227881)
> >> >
> >> > Disability Rights Advocates
> >> >
> >> > 2001 Center Street, Third Floor
> >> >
> >> > Berkeley, California 94704
> >> >
> >> > Telephone: (510) 665-8644
> >> >
> >> > Facsimile: (510) 665-8511
> >> >
> >> > TTY: (510) 665-8716
> >> >
> >> >
> >> >
> >> > SCOTT LABARRE (to seek pro hac vice admission)
> >> >
> >> > LABARRE LAW OFFICES, P.C.
> >> >
> >> > 1660 S. Albion Street, Ste 918
> >> >
> >> > Denver, Colo 80222
> >> >
> >> > Telephone: (303) 504-5979
> >> >
> >> > Fax: (303) 757-3640
> >> >
> >> >
> >> >
> >> > DANIEL F. GOLDSTEIN (to seek pro hac vice admission)
> >> >
> >> > MEHGAN Sidhu (to seek pro hac vice admission)
> >> >
> >> > Brown, Goldstein & Levy, LLP
> >> >
> >> > 120 E. Baltimore St., Suite 1700
> >> >
> >> > Baltimore, MD 21202
> >> >
> >> > Telephone: (410) 962-1030
> >> >
> >> > Fax: (410) 385-0869
> >> >
> >> >
> >> >
> >> > SUPERIOR COURT OF THE STATE OF CALIFORNIA
> >> > COUNTY OF ALAMEDA
> >> >
> >> >
> >> >
> >> > National Federation of the Blind, the National Federation of the
> >> Blind
> >> > of CALIFORNIA, and DEEPA GORAYA,
> >> >
> >> >
> >> >
> >> > Plaintiffs,
> >> >
> >> > v.
> >> >
> >> > LAW SCHOOL ADMISSION COUNCIL, INC.,
> >> >
> >> > Defendant.
> >> >
> >> >
> >> >
> >> > Case No.:
> >> >
> >> >
> >> >
> >> >
> >> >
> >> > COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF FOR VIOLATIONS OF
> >> THE
> >> > CALIFORNIA DISABLED PERSONS ACT AND UNRUH CIVIL RIGHTS ACT
> >> >
> >> >
> >> >
> >> >
> >> > INTRODUCTION
> >> >
> >> > Plaintiffs complain of Defendant and allege herein as follows:
> >> >
> >> > 1. This action, brought by the National Federation of the
> Blind,
> >> > the National Federation of the Blind of California, and Deepa Goraya,
> >> seeks
> >> > to put an end to civil rights violations committed by defendant Law
> >> School
> >> > Admissions Council (hereafter "LSAC") against blind persons seeking to
> >> take
> >> > the LSAT exam and apply to law schools. Plaintiff Deepa Goraya, a
> blind
> >> law
> >> > school applicant in California, has been and is being denied equal
> >access
> >> to
> >> > the accommodations, advantages, and facilities LSAC provides its
> >> > non-disabled customers through http://www.lsac.org (hereafter
> "lsac.org"
> >> > and "the website"). Plaintiffs National Federation of the Blind and
> the
> >> > National Federation of the Blind of California have members who are
> >> > similarly denied full and equal access to such accommodations,
> >advantages
> >> > and facilities. Lsac.org is currently the only place online where
> >> > prospective law students can register for the Law School Admissions
> Test
> >> > ("LSAT"), apply to law schools, and obtain official LSAT test
> >preparation
> >> > materials and information. Lsac.org contains multiple access barriers
> >> that
> >> > make it difficult if not impossible for blind law school applicants
> and
> >> LSAT
> >> > test takers to use the website and to obtain practice materials
> without
> >> > sighted assistance. LSAC thus excludes the blind, including Ms.
> Goraya,
> >> > from full and equal access to the accommodations, advantages,
> >facilities,
> >> > and privileges of lsac.org.
> >> >
> >> > JURISDICTION
> >> >
> >> > 2. This is a civil action under California's Disabled Persons
> >Act
> >> > (Cal. Civ. Code '' 54, et seq.) and the Unruh Civil Rights Act (Cal.
> >Civ.
> >> > Code '' 51, et seq.) and for declaratory relief. This Court has
> >> > jurisdiction over the claims alleged herein pursuant to California
> Civil
> >> > Code '' 54, et seq. and California Civil Code '' 51, et seq. and
> >> California
> >> > Code of Civil Procedure section 1060.
> >> >
> >> > 3. This Court has jurisdiction over LSAC because LSAC is a
> >> > corporation authorized to do business in California and LSAC conducts
> >> > substantial business in California. LSAC owns, maintains and operates
> >its
> >> > website, lsac.org, throughout California and in Alameda County.
> >> >
> >> >
> >> >
> >> > VENUE
> >> >
> >> > 4. Venue is proper in Alameda County because liability arises
> in
> >> > part in Alameda County, where the National Federation of the Blind of
> >> > California has its headquarters. LSAC has been and is committing the
> >> acts
> >> > alleged herein in Alameda County, has been and is violating the rights
> >of
> >> > patrons in Alameda County, and has been and is causing injury to
> patrons
> >> in
> >> > Alameda County.
> >> >
> >> > 5. Plaintiff Goraya is a California citizen and has
> experienced
> >> > injury in California as a result of LSAC's inaccessible website and
> >> practice
> >> > materials.
> >> >
> >> > PARTIES
> >> >
> >> > 6. Plaintiff the National Federation of the Blind (hereafter
> >> "NFB")
> >> > is a national advocacy organization. The NFB, the oldest and largest
> >> > national organization of blind persons, is a non-profit corporation
> duly
> >> > organized under the laws of the District of Columbia with its
> principal
> >> > place of business in Baltimore, Maryland. It has affiliates in all 50
> >> > states (including California) as well as Washington, D.C. and Puerto
> >> Rico.
> >> > The vast majority of the approximately 50,000 members are blind
> >persons.
> >> > The NFB is widely recognized by the public, Congress, executive
> >agencies
> >> of
> >> > government and the courts as a collective and representative voice on
> >> behalf
> >> > of blind Americans and their families. The purpose of the NFB is to
> >> promote
> >> > the general welfare of the blind by (1) assisting the blind in their
> >> efforts
> >> > to integrate themselves into society on terms of equality and (2)
> >> removing
> >> > barriers and changing social attitudes, stereotypes and mistaken
> beliefs
> >> > that sighted and blind persons hold concerning the limitations created
> >by
> >> > blindness resulting in the denial of opportunity to blind persons in
> >> > virtually every sphere of life. The NFB and many of its members have
> >> long
> >> > been actively involved in promoting adaptive technology for the blind,
> >so
> >> > that blind persons can live and work independently in today's
> >> > technology-dependent world. NFB members reside throughout the United
> >> > States, including the state of California, and many of its members
> would
> >> use
> >> > the services of lsac.org if this website is made independently usable
> by
> >> > the blind.
> >> >
> >> > 7. Plaintiff the National Federation of the Blind of
> California
> >> > (hereafter "NFB of California") is a state affiliate of the National
> >> > Federation of the Blind. NFB of California is a California
> corporation
> >> and
> >> > carries out NFB's objectives at the state level. It has local
> chapters
> >> > throughout California, including Alameda County, and has its
> >headquarters
> >> in
> >> > Fremont, California, in Alameda County.
> >> >
> >> > 8. Plaintiff Goraya is a member of the NFB and the NFB of
> >> > California. She is blind and has been denied full and equal access to
> >> the
> >> > accommodations, advantages, facilities and privileges of lsac.org.
> >> >
> >> > 9. Defendant LSAC, is a non-profit corporation
> >> > established to coordinate, facilitate, and enhance the law school
> >> admissions
> >> > process. LSAC owns, operates and/or maintains the website lsac.com, a
> >> > public accommodation. Plaintiffs seek access to the services provided
> >by
> >> > LSAC in California through lsac.org.
> >> >
> >> > FACTS
> >> >
> >> > 10. Lsac.org is owned, controlled and/or operated by LSAC.
> >> Lsac.org
> >> > is a public accommodation that offers its visitors comprehensive
> >services
> >> > for applying to law school. The website functions as the official
> >> > destination for guiding prospective law school applicants through the
> >> > fundamental steps of applying to law school. Among its services,
> >> lsac.orgoffers information about the LSAT and law school application
> >> process, and
> >> > extensive LSAT preparation materials and resources. Lsac.org also
> >serves
> >> as
> >> > the exclusive online means for registering for the LSAT and applying
> to
> >> > ABA-accredited law schools.
> >> >
> >> > 11. According to the website, lsac.org's online services enable
> >> > prospective law students to do the following, among other things:
> >> >
> >> > a.. Register for the LSAT
> >> > b.. Register for the LSDAS (Law School Data Assembly Service)
> >> > c.. Purchase publications and test preparation materials
> >> > d.. Have access to electronic applications for all ABA-approved law
> >> > schools
> >> > e.. Apply online to law schools
> >> > f.. Register for law school forums
> >> > g.. Have 24-hour file access
> >> > 12. In addition to facilitating the LSAT and law school application
> >> > processes, a significant portion of the lsac.org website is devoted
> to
> >> > preparing students to take the LSAT. Among the services offered in
> that
> >> > regard are online information guides that explain how to prepare for
> the
> >> > LSAT and free, downloadable sample practice tests and test questions.
> >> > Lsac.org also offers for a fee an online LSAT practice test tool and
> >the
> >> > opportunity to purchase more than 40 official LSAT practice tests.
> >> >
> >> > 13. While sighted visitors to lsac.org can easily obtain the
> benefits
> >> and
> >> > advantages offered by the website, blind individuals, including Ms.
> >> Goraya,
> >> > have been and are being denied access to lsac.org due to LSAC's
> failure
> >> > and refusal to remove access barriers to lsac.org. Specifically,
> blind
> >> > visitors to the website, including Ms. Goraya, cannot independently
> >apply
> >> to
> >> > law school, register for the LSAT, or obtain in an accessible format
> the
> >> > LSAT preparation materials and practice tests available through
> lsac.org
> >> .
> >> >
> >> > 14. The blind access websites by using keyboards in conjunction
> >> with
> >> > screen-reading software. This software vocalizes or conveys to a
> >> refreshable
> >> > Braille display information that appears visually on a computer
> screen.
> >> > Unless websites are designed to allow for use in this manner, blind
> >> persons
> >> > are unable to fully access the internet websites and the information,
> >> > products and services contained therein.
> >> >
> >> > 15. There are well-established guidelines for making websites
> >> > accessible to the blind. These guidelines have been in place for at
> >> least
> >> > several years and have been followed successfully by other public
> >> > accommodations in making their online services accessible. The Web
> >> > Accessibility Initiative (WAI), a project of the World Wide Web
> >> Consortium,
> >> > which is the leading standards organization for the Web, has developed
> >> > guidelines for making information that is reached via the internet
> >> > accessible. The federal government has also promulgated accessibility
> >> > standards under Section 508 of the Rehabilitation Act. These
> guidelines
> >> > have long been readily available via the internet so that any public
> >> > accommodation could easily secure the necessary information.
> >> >
> >> > 16. Lsac.org contains a variety of access barriers that prevent
> >> free
> >> > and full use by blind persons using keyboards and screen reading
> >> software.
> >> > These barriers include but are not limited to: lack of or improperly
> >> > labeled form controls; faulty keyboard navigation; and use of tables
> and
> >> > charts that are not formatted for accessibility. Form controls allow
> >> users
> >> > to input data on online forms and applications. These controls must
> be
> >> > coded and labeled to allow screen-access software to detect and
> vocalize
> >> the
> >> > requested information. Keyboard navigation refers to the ability to
> >> > successfully navigate a website using keyboard commands, as opposed to
> >> > requiring a mouse as the exclusive means for navigation of the site.
> >> > Further, charts and tables must be formatted to work with
> screen-access
> >> > software. Much of the lsac.org website, and in particular the online
> >> law
> >> > school application and LSAT registration sections of the website, lack
> >> these
> >> > fundamental accessibility components. As a result, blind visitors to
> >the
> >> > website cannot independently use those and other critical features.
> >> >
> >> > 17. Lsac.org's test preparation materials that are available on
> >the
> >> > website in Adobe Portable Document (PDF) format, are not properly
> >> "tagged."
> >> > This means that the headings, paragraphs, tables, image descriptions
> >and
> >> > form controls are not easily discernable to screen-reading software.
> As
> >> a
> >> > result, these materials are cumbersome, if not impossible, for a blind
> >> > visitor to navigate.
> >> >
> >> > 18. Finally, lsac.org fails to offer LSAT practice tests,
> >> available
> >> > as part of its test preparation services, in formats accessible to the
> >> > blind. While the sighted can easily use the website to obtain more
> than
> >> 40
> >> > formerly administered LSAT practice tests, the website fails to offer
> >the
> >> > opportunity to purchase these practice materials in formats accessible
> >to
> >> > the blind, such as Braille or an accessible electronic format.
> >> >
> >> > 19. As a result of lsac.org's accessibility barriers, blind law
> >> > school applicants, including Ms. Goraya, must go over extraordinary
> >> hurdles
> >> > to register and prepare for the LSAT and to apply to law school
> compared
> >> to
> >> > their sighted counterparts. After unsuccessfully attempting to use
> >> > lsac.org independently to register for the LSAT and fill out her law
> >> > school applications, for example, Plaintiff Goraya was forced to
> select
> >> and
> >> > rely upon a reader for over 50 hours simply to read aloud the content
> of
> >> the
> >> > website and complete her law school applications. Moreover, none of
> the
> >> > LSAT practice materials, which include previously administered
> versions
> >> of
> >> > the test, were available to her in accessible electronic formats.
> >> Lsac.org
> >> > thus contains numerous access barriers which deny full and equal
> access
> >> to
> >> > Plaintiff, who would otherwise use the accommodations, advantages, and
> >> > facilities of lsac.org.
> >> >
> >> > 20. On December 10, 2008, Plaintiff National Federation of the
> >> Blind
> >> > notified LSAC of the unlawful accessibility barriers on its website.
> >> LSAC
> >> > responded by setting up and then canceling a meeting with the NFB. On
> >> > January 22, 2009, the NFB notified LSAC that it intended to pursue
> legal
> >> > action against LSAC for the unlawful barriers on its website.
> >> >
> >> > FIRST CAUSE OF ACTION
> >> >
> >> > (Violation of Cal. Civ. Code '' 54, et seq. - the Disabled Persons
> Act)
> >> >
> >> > 21. The allegations contained in the previous paragraphs are
> >> > incorporated by reference.
> >> >
> >> > 22. The Disabled Persons Act ("DPA") requires that individuals
> >with
> >> > disabilities have "full and equal access, as other members of the
> >general
> >> > public, to accommodations, advantages, facilities, . . . and other
> >places
> >> to
> >> > which the general public is invited, subject only to the conditions
> and
> >> > limitations established by law, or state or federal regulation, and
> >> > applicable alike to all persons." Cal. Civ. Code 54.1(a)(1).
> >> >
> >> > 23. Lsac.org, which is owned, operated and/or maintained by
> LSAC,
> >> is
> >> > an
> >> >
> >> > accommodation, advantage, facility and/or place to which the general
> >> public
> >> > is invited, as those terms are used in Cal. Civ. Code ' 54.1(a)(1).
> >> >
> >> > 24. Defendant's conduct alleged herein violates the DPA,
> including
> >> > Cal. Civ. Code ' 54.1(a)(1), by denying the Plaintiffs full and equal
> >> access
> >> > to the accommodations, advantages and facilities of lsac.org.
> >> >
> >> > 25. As a result of Defendant's conduct, the NFB, the NFB of
> >> > California, and Ms. Goraya are entitled to injunctive relief requiring
> >> > Defendant to make lsac.org accessible to blind individuals, and to
> make
> >> > the LSAT test practice materials offered to lsac.org patrons
> available
> >> to
> >> > blind people in an accessible format.
> >> >
> >> > SECOND CAUSE OF ACTION
> >> >
> >> > (Violation of Cal.Civ. Code '' 51, et seq. - The Unruh Act)
> >> >
> >> > 26. The allegations contained in the previous paragraphs are
> >> > incorporated by reference.
> >> >
> >> > 27. California's Unruh Act requires that individuals with
> >> > disabilities have "full and equal accommodations, advantages,
> >facilities,
> >> > privileges or services in all business establishments of every kind
> >> > whatsoever." Cal. Civ. Code ' 51(b).
> >> >
> >> > 28. LSAC and Lsac.org are business establishments as that term
> is
> >> > used in Cal. Civ. Code ' 51(b) and lsac.org is an accommodation,
> >> > advantage, facility, privilege and service of LSAC.
> >> >
> >> > 29. Defendant's conduct alleged herein violates the Unruh Act,
> >> > including Cal. Civ. Code ' 51(b), by denying Plaintiffs the full and
> >> equal
> >> > accommodations, advantages, facilities, privileges or services of LSAC
> >> and
> >> > lsac.org.
> >> >
> >> > 30. Defendant violated the Unruh Act intentionally and/or with
> >> > deliberate indifference to the likelihood that it was violating the
> >> rights
> >> > of blind people and/or Defendant's violations were so intuitive or
> >> obvious
> >> > that noncompliance could not be other than intentional.
> >> >
> >> > 31. As a result of Defendant's conduct, the NFB, the NFB of
> >> > California, and Ms. Goraya are entitled to injunctive relief requiring
> >> > Defendant to make lsac.org accessible to blind individuals, and to
> make
> >> > the LSAT test practice materials offered to lsac.org patrons
> available
> >> to
> >> > blind people in an accessible format.
> >> >
> >> >
> >> >
> >> > THIRD CAUSE OF ACTION
> >> >
> >> > (Declaratory Relief, Cal. Civ. Proc. ' 1060 )
> >> >
> >> > 32. The allegations contained in the previous paragraphs are
> >> > incorporated by reference.
> >> >
> >> > 33. On information and belief, Defendants contend that they may
> >> > lawfully deny Plaintiffs access to their website and its contents.
> >> > Plaintiffs contend that lsac.org, which LSAC owns, operates, and/or
> >> > controls, must provide blind patrons access to its website and website
> >> > contents under California Civil Code '' 54, et seq. and California
> Civil
> >> > Code '' 51, et seq., which prohibit discrimination against the blind.
> >> >
> >> > 34. A judicial declaration is necessary and appropriate at this
> >> time
> >> > in order that each of the parties may know their respective rights and
> >> > duties and act accordingly.
> >> >
> >> > WHEREFORE, Plaintiffs request relief as set forth below.
> >> >
> >> > RELIEF REQUESTED
> >> >
> >> > WHEREFORE, Plaintiffs pray for judgment as follows:
> >> >
> >> > 1. An order enjoining LSAC from violating
> California
> >> > Civil Code '' 51, et seq. and '' 54, et seq.;
> >> >
> >> > 2. A declaration that LSAC is owning, maintaining
> >> and/or
> >> > operating lsac.org in a manner which discriminates against the blind
> and
> >> > which fails to provide access for persons with disabilities as
> required
> >> by
> >> > law;
> >> >
> >> > 3. Plaintiffs' reasonable attorneys' fees and costs
> >as
> >> > authorized by California California Civil Code '' 54, et seq.,
> >California
> >> > Civil Code '' 51, et seq., and pursuant to California Code of Civil
> >> > Procedure ' 1021.5.
> >> >
> >> > 4. Such other and further relief as the Court deems
> >> just
> >> > and proper.
> >> >
> >> >
> >> >
> >> > DATED:
> >> > DISABILITY RIGHTS ADVOCATES
> >> >
> >> >
> >> >
> >> >
> >> By:
> >> > ____________________________
> >> >
> >> >
> >> > Laurence W. Paradis
> >> >
> >> >
> >> >
> >> >
> >> >
> >> > Scott C. LaBarre, Esq.
> >> >
> >> > LaBarre Law Offices P.C.
> >> > 1660 South Albion Street, Ste. 918
> >> > Denver, Colorado 80222
> >> > 303 504-5979 (voice)
> >> > 303 757-3640 (fax)
> >> > slabarre at labarrelaw.com (e-mail)
> >> > www.labarrelaw.com (website)
> >> >
> >> > CONFIDENTIALITY NOTICE: This message may contain confidential and
> >> > privileged information. If you are not the designated recipient, you
> may
> >> not
> >> > read, copy, distribute or retain this message. If you received this
> >> message
> >> > in error, please notify the sender at 303) 504-5979 or
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