Lawyers' Language in ADA Non-Compliant Complaint

Some have come to me asking what the lawyers' language looks like in the ADA non-compliant complaint.  Note that the word "Plaintiff" is you, the "Watchdogs in Wheelchairs".

• The Plaintiffs have visited, used, or attempted to use the property which forms the basis of this lawsuit on, about and between the dates above referenced, and but for the discrimination they encountered on the visits, plan to and intend to return to the property to avail themselves of the goods and services offered to the public at the property.  The Plaintiffs have encountered architectural barriers and discriminatory policies and procedures at the subject property.  The barriers to access at the property have endangered their safety.  Plaintiffs are disabled individuals who are currently deterred from patronizing a public accommodation due to Defendants' failure to comply with the ADA and so they have suffered an actual injury.  Plaintiffs and each of them are threatened with harm in the future because of existing and imminently threatened non-compliance with the ADA, and so they suffered imminent injury.

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Hank