Perez

BACKGROUND

Plaintiff’s August 16, 2023 complaint alleged as follows. Defendants owned Rene’s Bakery in Los Angeles. The Department of Motor Vehicles provided plaintiff with a disability placard due to her “physical impairments.” Within one year prior to filing the complaint, plaintiff, “on at least three different occasions,” attempted to patronize the bakery but encountered a barrier to accessing the establishment in that it did not provide parking designated for customers with disability placards. Plaintiff sought $4,000 in statutory damages “per violation” on each cause of action, attorney fees, and costs of the lawsuit. Defendants did not file an answer. On November 27, 2023, plaintiff filed a request for entry of default and default was entered that same day. On October 29, 2024, the following documents were filed in support of a request for entry of a default judgment. Plaintiff’s counsel filed a declaration and requested $750 in attorney fees. Perez filed a declaration in support of the allegations in the complaint and the

2 entry of default judgment. In her declaration, Perez stated she attempted to patronize the bakery in June, July, and August of 2023 but was prevented…