Khinda

I. INTRODUCTION

20 On February 11, 2022, Plaintiff Darren Gilbert (“Plaintiff”) filed this case against Defendants Karnail Singh Khinda, Trustee of the Karnail and Narinder Khinda-Kaur Family Trust (“Defendant Khinda”); and Narinder Kaur dba Super Liquor and as Trustee of the Karnail and Narinder Khinda-Kaur Family Trust (“Defendant Kaur”) (together, “Defendants”), alleging claims under the Americans with Disabilities Act (“ADA”), 42 U.S.C. §§ 12101–12213; the California Unruh Act (the “Unruh Act”), California Civil Code § 51 et seq.; and California Health & Safety Code §§ 19955, 19959. (Doc. No. 1 (the “Complaint”).) The Complaint seeks an award of statutory damages, prejudgment interest on the damages, costs of suit, attorney’s fees, and injunctive relief. Id. Plaintiff alleges that Defendants own, operate, and/or lease the property that is the subject of this suit, Super Liquor (the “Property”), located at 1600 Tully Road, Modesto, CA 95350. (Id. ¶¶ 1, 7.) Plaintiff further alleges that he requires the use of a wheelchair, knee scooter, or prosthetic for mobility (id. ¶ 8), and the Property presents numerous…