Gross

I. Background

27 The Complaint includes six claims: (1) a civil rights claim under the Americans With 28 Disabilities Act (“ADA”); (2) a civil rights claim under California Civil Code sections 51 (the “Unruh Act”), 52, and/or 54, “at her election”; (3) a claim for declaratory relief under various provisions of State “and/or” federal law; (4) a claim for injunctive relief under various provisions of State “and/or” federal law; (5) a claim based on dangerous condition of public property, under California Government Code section 835; and (6) a claim for negligence under California Government Code section 815.2. ECF No. 1-3. The Complaint alleges that Plaintiff is visually impaired, and that she was injured when she fell on property “located at or near 11th Street, between B Street and C Street” in San Diego. Id. at ¶¶ 3, 6, 11. The Complaint alleges that the property at issue poses barriers to access by disabled persons, such barriers “including, but not limited to abraded or elevated sections of concrete . . . illegally excessive changes in elevation, improper transition areas, [and] inaccessible paths of travel.” Id. ¶ 9. The…