Strojnik

I. BACKGROUND

26 A. Factual Allegations 27 impairment, renal cancer, severe right-sided neural foraminal stenosis with symptoms of femoral neuropathy, missing right knee ameliorated with a prosthesis, limitation on the use of both shoulders, elbows and wrists, pleurisy, hyper blood pressure” that “limit major life activities” including “walking, standing, sitting, bending, sleeping, working, performing manual tasks, reaching, grasping, lifting, climbing, kicking, pushing, opening doors, twisting the wrist, shoulder and elbows, working or performing any physical activity whatsoever.” FAC ¶¶ 8, 14-15, 17. According to Plaintiff, his disabilities require “the use of lodging facilities that are accessible to him and have the standard accessibility features of the construction related accessibility standards…” Id. ¶ 18. The “actual, physical or architectural barriers to accessibility” at Defendant’s Hotel caused Plaintiff “discomfort and pain when using, negotiating, overcoming or otherwise encountering such barriers.” Id. ¶ 24. Plaintiff contends that he lodged at the Hotel on or about September 26-27, 2019 and …