JUAN CARLOS GIL vs. BILLY CASPER GOLF, LLC, d/b/a DubsDread Golf Course

• Defendant‟s Website is not accessible to users who are visually impaired such that visually impaired are unable to go to the Website and obtain the most perfunctory information such as the cost of golfing, the cost of golf lessons, and information on the food available at the onsite restaurant.
• The Website does not offer include the universal symbol for the disabled and the symbol for website accessibilitywhich would permit disabled individuals to access the Website‟s accessibility information and accessibility protocols.
• There are readily available, well established guidelines on the Internet for making websites accessible to the blind and visually impaired. Incorporating the basic components to make its Website accessible would neither fundamentally alter the nature of Defendant‟s business nor would it result in an undue burden to the Defendants.

VIOLATIONS OF THE AMERICANS WITH DISABILITIES ACT

• The Court issue a declaratory judgment that Defendant has violated Plaintiff‟s rights as guaranteed by the ADA;
• The Court enter an Order requiring Defendant to update its www.historicaldubsdread.com website to remove barriers in order thatindividuals with visual disabilities can access the Website and effectively communicate with the Website to the full extent required by Title III of the ADA;
• The Court enter an Order requiring Defendant to clearly display the universal disabled logo and sign of website accessibility (standard WCAG 2.0) within its Website. Such a clear display is to insure that individuals who are disabled are aware of the availability of the accessible features of the www.historicaldubsdread.com website;
• The Court enter an Order compelling Defendant to contract with an independent ADA expert/consultant for the purposes of that ADA expert/consultant review Defendant‟s policies, practices and procedures for five years commencing from the date of the Court‟s Order to insure that Defendant is in compliance with the ADA;
• The Court enter an order requiring Defendant to retain an accessibility coordinator and a third party consultant to review and guide Defendant through their accessibility creation and procedures to insure compliance thereto;
• The Court enter an Order directing Defendant to evaluate its policies, practices and procedures toward persons with disabilities for suchreasonable time so as to allow Defendant to undertake and complete corrective procedures to the Website;
• The Court award damages in an amount to be determined at trial;
• The Court to award Plaintiff reasonable litigation expenses and attorneys‟ fees; and
• That the Court award such other and further relief as it deems necessary, just and proper.