Brooke

I. BACKGROUND

22 a. Plaintiff’s Complaint 23 Plaintiff filed her complaint on August 10, 2020. (ECF No. 1). Plaintiff claims that she is 24 a serial “tester” of the Americans With Disabilities Act (“ADA”). She has filed approximately 25 1,000 ADA lawsuits against hotels across the western United States. Plaintiff has been insulted 26 and threatened for her litigation positions. Although many ADA defendants have attempted to 27 have Plaintiff declared a vexatious litigation, these attempts have been unsuccessful. Plaintiff 28 states that she “is bringing this lawsuit as a stand against the lawyers and ADA defendants who are empowered to threaten and intimidate Plaintiff. She is fed up.” (ECF No. 1, at p. 4). Previously, Plaintiff filed an ADA lawsuit against Defendants in Brooke v. Jav. Patel, E.D. Cal. Case no. 1:20-cv-00101-NONE-SKO (the “Underlying Litigation”). Plaintiff alleges that Defendant Hatmaker Law Group threatened Plaintiff’s counsel with a State Bar complaint on three different occasions during a settlement discussion. Defendant Hatmaker Law Group also threatened a counterclaim without any basis, also during the course and…