Mayer

I. BACKGROUND

A. Mayer Encounters Barriers at City Hall Mayer is disabled and uses a wheelchair for mobility. Responsive Separate Statement 3 (“Statement of Facts”),! Fact 1,2, ECF No. 76. Mayer is an amateur photographer who enjoys 4 capturing pictures of public protests and cultural events, which he refers to as “First Amendment 5 Events.” Jd. at Fact 8,9. Mayer has attended about a dozen First Amendment Events at City Hall 6 in the West Plaza on the evenings and weekends when City Hall is closed. /d. at Fact 8, 9, 10, 16, 4 Additional Fact E. The West Plaza is an outdoor space located adjacent to City Hall with various 8 elevated areas surrounding it. See id. at Additional Fact B. Portions of the West Plaza may be 9 reserved for events, but no permit or payment is required to conduct a simple assembly of persons 10 on an unreserved area of the West Plaza, including the First Amendment Events. Jd. at Fact 7. 11 Mayer illustrates the West Plaza as follows: 12 City Hall West Plaza ° > Fe Weite a description tor your map: y le a Pe Ack fe i LL) = …