Businesses concerned with ADA website compliance might want to check out []. Although the ADA defense bar has grown with the explosion of ADA Title III lawsuits, the number of truly knowledgeable ADA Title III attorneys remains quite small. Shaked Law Group had more plaintiffs including Pedro Martinez and Mary Conner. Providing quality ADA Defense, Business & Real Estate Services throughout the United States for over 40 years. Nov. 10, 2020) the Eleventh Circuit held that Congress validly abrogated 11th Amendment immunity with respect to the State of Floridas legislature, a holding that may eventually lead to a requirement that public legislative sessions be made accessible to those with hearing disabilities. They are a great team! From the first phone call I made to them, they have been extremely compassionate, very helpful, and 100% professional. Read the court order here: Court Order Dismissing District Attorney Lawsuit The law also requires employers to make reasonable accommodations for individuals with disabilities to help them do their job. Mail Fill out and send the paper ADA Complaint Form or a letter containing the same information, to: U.S. Department of Justice Civil Rights Division 950 Pennsylvania Avenue, NW Cal. On behalf of the nations largest car rental company, secured the dismissal of a lawsuit in which the plaintiff alleged that the company failed to provide wheelchair accessible rental cars. By Richard Hunt U.S. District Judge Paul Huck determined after a sanctions hearing that Attorney Scott Dinin had paid Johnson more than $84,500 over three years (2016-2018) for his participation in various ADA lawsuits. Seyfarth also prepared comments for leaders in the real estate, movie theater, and retail industries in connection with various rulemakings, including physical access standards, pool lifts, websites, furniture and equipment, and movie captioning and audio description. The ADA ensures that people with disabilities have equal access in many areas including employment, education, and public accommodations. Data is skewed because there are many law firms who are more focused on sending out demand letters (which do not become public record). Secured summary judgment for nations largest coffee retailer in two cases about its sales/service counters and is defending four summary judgment victories concerning these counters in the Ninth Circuit. This data is all based on 2020 Q4 data we gathered so it provides the best preview for 2021. Search for products and services by category, subcategory, or by company name. June 17, 2022 What Damages Are Available in Mass Torts. Each of these lawsuits made representations that Victim-1 and Victim-2 were represented by FINKELSTEIN or an associate. On March 1, 2023, Leslie Briggs, Evan Watson, and Henry A. Meyer III (collectively, "Plaintiffs"), represented by Frederic Dorwart, David Wayne Leimbach, and Paul DeMuro of Frederic Dorwart Lawyers PLLC; and Nick Southerland and Brian S. Wilkerson of Oklahoma Disability Law Center, Inc., filed a class action civil rights . PERIOD! An appeals court has ruled that the Florida federal judge who penalized a serial lawsuit-filer and his attorney for filing frivolous Americans with Disabilities Act (ADA) claims was right to do so, according to a report in Legal Newsline. In the meantime, we will be watching to see whether Dinin or Johnson appeal the Sanctions Order. Washington, D.C. 20530. Please, Americans With Disabilities Act Compliance Law. Drafted comprehensive ADA policies for almost every major hotel brand in the United States, in addition to a number of retailers and financial institutions. . All Rights Reserved. There has, in fact, been an increase in ADA lawsuits filed across the country over the past several years. California has a much higher standard for accessibility than most other states and countries; it has . I couldnt find a clue in the District Courts file. Sober living homes continue to create hostility and litigation as politicians try to balance doing the right thing against the demand of their constituents that they do the wrong thing. Seyfarth ADA Title III team members develop enterprise-wide ADA Title III compliance programs (e.g. August 26, 2021, Newsletter We want to hear your story. Why no request for fees? Rulemaking and Legislative Support. The Court based its findings on settlements from other ADA lawsuits, financial records, billing records, and even some email communications between Dinin and Johnson. Has your employer failed to make accommodations that would allow you to do your job? If an ADA plaintiff does not have a bona fide intent to do business with the defendant, then there is no standing because there is no harm to the plaintiff. 00:25. Tags: ADA default judgment, ADA defense, FHA Defense, hotel website, Informational injury, mootness, serial litigation, Strojnik, supplemental jurisdiction, tester standing. Since the ADA only provides for injunctive relief that was fatal to this claim as it had been to others in the past. What Is the ADA Employment Law Claims Process? The ADA's transformative and well-intentioned objective is to address "the discriminatory In the case of prolific plaintiff Alexander Johnson, it was a nice cash supplement to his disability income, apparently. Nonetheless, Im happy to act on a temporary basis as Virgil and see how far we can get. I needed them 3 TIMES! Where the change is physical courts generally have no problem finding that the situation isnt likely to recur, but when the change is to an ever-changing website the burden of showing the fix will last becomes much higher. Immediately, you can breathe. SUPERIOR COURT OF CALIFORNIA IN AND FOR THE COUNTY OF LOS ANGELES, ORANGE COUNTY, VENTURA, SAN BERNARDINO . This gives plaintiffs' attorneys an incentive to continue litigating even after the defendant has remediated everything in the original complaint. What is the ADA Act?The Americans with Disabilities Act (ADA) of 1990 is a civil rights law that prohibits discrimination against individuals with disabilities in all areas of public life and in all public and private places that are open to the general public. The ADA is divided into five Titles (or Sections) that relate to different areas of public life. Proof that the two were driven by the pursuit of money not access came in an email when they discussed taking out language in one case that noted the defendant had refused to turn off the videos entirely, Huck ruled. Moreover, it includes people who may not be practically disabled but technically have a limiting disability. Seyfarths ADA Title III team has extensive experience handling DOJ investigations, state and local agency investigations, lawsuits brought under the FHA and other disability access laws concerning assistance/service animals, reasonable accommodations for individuals with disabilities, and the failure to design and construct multifamily housing in accordance with accessibility requirements. We exceed the expectation of our clients. 2021). No promise about whether well find a Beatrice to take you to Paradise. By Richard Hunt The law allows for remedies of the violations through court orders, and for plaintiffs to recover legal fees that result from the lawsuit. Plaintiffs' entitlement to attorneys' fees under the ADA has created a cottage industry of plaintiffs' attorneys seeking to cash in on the ease by which they can identify a violation and extract a cost-of-defense settlement requiring remediation. U.S. Chamber of Commerce Institute for Legal Reform 2023, You copied the event url to the clipboard, Mass Arbitration Shakedown: Coercing Unjustified Settlements, Selling Out: The Dangers of Allowing Nonattorney Investment in Law Firms, ILR Briefly: Taming the Litigation Monster: The Continued Threat of Public Nuisance Litigation, Unlocking the Code: The Value of Bankruptcy to Resolve Mass Torts, What You Need to Know About Third Party Litigation Funding, Safeguarding Our Small Businesses Against ADA Lawsuits, Serial ADA Plaintiff and Lawyer Penalized for Frivolous Lawsuits. Seyfarth ADA Title III team attorneys also know all of the attorneys in the plaintiffs bar and their approaches to litigation and settlement. Quick Hits If youre going through hell edition. Seyfarth has participated in every rulemaking under Title III of the ADA for more than a decade on behalf of the lodging, movie theater, retail, and real estate industries. Janus, the two headed god that looked to the future and past and gave us the name for January, wouldnt find much new in the world of disability law if he were contemplating 2023. Similarly, investigations into ADA violations can be initiated through a complaint with the Department of Justice. January 6, 2023 Settlements of ADA lawsuits can benefit the plaintiff and their attorney, but such settlements are typically confidential. District attorneys in California recognize patterns of fraudulent filing by plaintiffs' lawyers, believing serial filers . Dinin was counsel for the plaintiff in the first website accessibility lawsuit to ever to go trial (Gil v. Winn Dixie). As previously mentioned, defendants who lose ADA cases are required to pay the plaintiff's legal fees. Dec. 9, 2022) Judge Jane Boyle joined Judge Sam Lindsay in finding that the standard form complaint used by a group of lawyers and their clients was inadequate. Reasonable accommodation may include, but is not limited to: Employers are not required under the ADA to provide employees with the exact accommodations they request or with the most expensive or best available accommodation. Seyfarths ADA Title III team has extensive experience litigating single plaintiff and class-action lawsuits in New York, California, and Florida, and is very familiar with each jurisdictions peculiarities. For those keeping score motions to dismiss almost identical complaints filed in the Northern and Western Districts of Texas have reached very different results. Shaked Law Group had more plaintiffs including Pedro Martinez and Mary Conner. Christian Sanchez Cohen & Mizrahi LLP Lawsuits, Cost Website Accessibility WCAG 2.1 AA Audit ADA Compliance, Southern District of Florida Miami Division. . Seyfarth attorneys know the unique challenges of litigating in the most plaintiff-friendly jurisdictions in the country, and routinely use that knowledge to their clients advantage. Has Your Business Been Accused? 9th Cir. Online File a complaint by submitting a report on the Department of Justice's Civil Rights Division website. 12205, is perfectly even handed. Serial ADA litigation is going strong because outcomes depend on the judge assigned rather than the law or the facts. They were caring and concerned about my case. U.S. District Judge Vince Chhabria on Tuesday found that serial ADA plaintiff Brian Whitaker and Potter Handy LLP, the San Diego-based law firm that represented Whitaker in the case, "feel so. in Accessibility Litigation Trends, ADA - serial litigation, ADA - Standing, ADA Attorney's Fees, ADA Internet Web, ADA Mootness, FHA Emotional Support Animals, FHA Policies The rise in claims was attributed in part to amendments to the Americans with Disabilities Act (ADA) that went into effect in 2009 as all as increased advocacy for strict enforcement of the act. Seyfarth deployed a strategy to ensure that the multi-year renovation would not be disrupted by the litigation and to secure the dismissal of the case. Although Rodney Atkins advice if youre going through hell, keep on going appears sound, winding through all the complexities of the ADA and FHA can seem like descending through all nine levels of hell. Accessibility.com now offers an impartial listing of digital accessibility vendors. With more than 800 attorneys nationwide, we have the resources and reach to provide you the best service possible. Tags: ADA defense, Deborah Laufer, FHA Defense, HOA, hotel websites, supplemental jurisdiction, website accessibility, Once again as in past Memorial Day editions Im firing up the grill with hundred dollar bills in honor of the money wasted on lawyers, who are the only ones who really benefit from most ADA and FHA litigation. Defend ADA lawsuits with experienced ADA legal representation. Previously, these lawsuits were primarily focused in South Florida. In providing advice to clientsparticularly on cutting edge new technologiesteam members must consider other disability-related laws that may apply. Following its earlier decisions involving the same lawyers and plaintiff the Eighth Circuit had little trouble concluding that the plaintiff, who visited the defendant only as a tester driven by his attorney and whose return would be as directed by his attorney did not have sufficiently concrete plans to return for there to be a likely future injury that would support standing for injunctive relief. ADA claims based on inaccessible gift cards are meritless for other reasons but standing holdings have a broader impact because they can influence all serial ADA claims, making these dismissals significant for other victims of serial litigation, at least in the 2nd Circuit. To illustrate, Pacific Trial Attorneys is very active in this space with many demand letters sent out with claims of a California Unruh Act violation but we didnt see any federal court filings for Pacific Trial Attorneys in our Q4 research. Madeira was traditionally aged in barrels that crossed the equator twice, the heat and time fortifying and sweetening the wine. It is simple to file a claim. Do you own or work for a small business that has faced anAmericans with Disabilities Act (ADA) lawsuit? At the hearing on the default motion, the Court decided to probe deeper into Dinan and Johnsons Title III lawsuit filings which eventually led to the Sanctions Order. An employer is not required to provide a reasonable accommodation if doing so would create an undue hardship for the employer. Therefore, we encourage you to continue your search for counsel while you await our response. When businesses need practical and sound advice or litigation defense on matters involving Title III of the Americans with Disabilities Act (ADA), they call the Seyfarth ADA Title III team. Johnson, a quadriplegic who forced ADA improvements at businesses around Northern California, faces up to three years in prison and a $100,000 fine for each count. The California ADA laws and the Federal United States American with Disabilities Act are one-sided. Businesses across the country feel under siege, bombarded with multiple lawsuits each year by serial plaintiffs and disability rights advocates. As a result, they rarely need research to answer client questions. Wernz claims under ADA attorney fees are awarded to the plaintiff, and that it is proper for plaintiffs to share attorney's fees. Americans with Disabilities Act Employment Law, Victims of Childhood Sexual Abuse Legislation Stalled in PA House, Morgan and Morgan Join in on the Fun at Monster Jam Pit Party, Morgan and Morgans Response to the Jackson Water Crisis. Join our community and get updates on legal reform and other exclusive content. Our results speak clearly. The Eighth Circuit has seen dozens, rather than tens of thousands, of ADA lawsuits because the Court takes Article III standing seriously. According to PACER, Dinin was counsel of record in over 251 federal lawsuits in 2018 and 177 in 2019. Join us for our Community update on the impact of the Ohio train derailment this Saturday at 10AM EST. The ADA also protects employees from retaliation for requesting a reasonable accommodation for a disability or good faith opposition to perceived disability discrimination. Both the employer and employee must engage in an interactive process to explore potential accommodations necessary to accommodate an employees disability. Accessibility Defense, Helping Business Avoid and Defend ADA and FHA Lawsuits. That means we get paid only if we win for you we never charge by the hour. The prohibition against future filings by Dinin and Alexander should reduce the number of ADA Title III lawsuits filed in Florida in the future. By Richard Hunt A qualified worker with a disability is someone who is able to perform the essential duties of the job, with or without a reasonable accommodation by the employer. By Richard Hunt The law also does not prohibit plaintiffs attorneys from seeking fees. Title III of the ADA also requires employers to make public accommodations as well. When clients partner with the Seyfarth ADA Title III team, they receive the collective expertise of more than ten attorneys with 70+ years of collective ADA Title III experience. Experienced ADA Counsel will also minimize future ADA risk for businesses by providing legal guidance in order to follow the action plan provided under the new Florida statute to certify compliance with the ADAs provisions or adopt appropriate remediation plans. This web site offers general information about our practice and its content is not intended to be, and should not be construed as, legal advice. Now ADA public accommodation lawsuits are spreading throughout Florida. Feel free to contact me at kris@accessible.org if I can help out with any services or answer any questions. California has seen tens of thousands of ADA/accessibiliy lawsuits in just the past few years; in just one Federal case category, more than 41% of the ADA/accessibility lawsuits in the United States were filed in California. More, Hunt Huey PLLC Most Common Claims Texas, Dec. 6, 2022) based on an almost identical pleading. Daniel Malakauskas is a young attorney that appears to specialize in plaintiff-side ADA litigation. in Accessibility Litigation Trends, ADA - drive-by litigation, ADA - Hotels, ADA - serial litigation, ADA - Standing, ADA Attorney's Fees, ADA Internet Web, ADA Mootness, ADA Point of Sale, ADA Policies, ADA Web Access. N.H. November 8, 2017) (denying a motion to dismiss sought against ADA claims) ("[Plaintiffs] rely on Title III of the ADA as governing the defendant's potential liability and invoke . The Americans with Disabilities Act(ADA) is an important piece of civil rights legislation that became law in 1990. Although it is possible for a plaintiff and their attorney to recover legal fees and perhaps secure a settlement, it can be impossible to determine how much plaintiffs benefit monetarily from ADA lawsuits; but, the plaintiffs named in such lawsuits should benefit from injunctions forcing compliance with the ADA. The Americans with Disabilities Act does not apply to the federal courts. Defend Your Rights.Florida ranks #2 in the nation for ADA Lawsuits.If your business has been accused of violating the Americans with Disabilities Act, The Harr Law Firm can help. Because of the teams nationwide footprint, Seyfarth is able to offer its clients complete coverage for ADA Title III matters for a coordinated approach to compliance and litigation. Morgan and Morgan is truly the best law firm! And when you win, we win. Don't be bullied. Research shows that there has been a steady increase in ADA Title III lawsuits filed. 972-675-2236 phone It prohibits discrimination against people with disabilities in workplaces, schools, transportation, and essentially in all areas of public and private life. Finally, you should understand that some legal matters are time sensitive. The ADA Title III team defends businesses against many hundreds of lawsuits and claims filed across the country each year. Garland, Texas 75044 The lawyer in the case was reported for his behavior to the Florida Bar and was ultimately suspended for 18 months. So what are the key claims made by the most frequent filers? The law firm that represents them is San Diego-based Potter Handy. ADAlawsuits.com. That doesn't mean that such litigation should be common. As previously mentioned, defendants who lose ADA cases are required to pay the plaintiffs legal fees. Gottlieb & Associates had more plaintiffs including Sandy Graciano, Donna Hedges, Henry Tucker, and Braulio Thorne. It also guarantees thatpeople with disabilities will have equal opportunity in public accommodations, their place of employment, state and local government services,transportation, and telecommunications. Thus, when clients call about a new lawsuit or complaint, they will most likely be able to provide an accurate assessment of the clients monetary and other exposure. Led by a former Department of Justice official who was responsible for overseeing the enforcement of this law, the team has more than 10 attorneys across the country who work almost exclusively in this highly specialized practice area. The plaintiffs can also recover legal fees, but without examining each case individually, no one can determine if the plaintiffs are sharing in the recovery with their attorney. Dec. 15, 2022) andMurphy v. Regal Cinemas, Inc., 2022 WL 17821218 (S.D.N.Y. From voting to parking, the ADA is a law that protects people with disabilities in many areas of public life. Fax: (202) 307-1197. Hear all about it Richard discusses ADA website litigation on the ADA Book podcast. Common plaintiffs include: Cynthia Hopson and Meryl Pomponio. Delay may result in the waiver of claims or defenses, or otherwise harm you position. Attorneys Fees in ADA and FHA cases - It's time for fairness January 22, 2014 By richardhunt in Accessibility Litigation Trends, ADA Attorney's Fees, ADA FHA General Tags: ada litigation, private lawsuits The attorney's fee provision in the ADA, 42 U.S.C. ADA Law Firms | ADA Plaintiff Attorneys (Click on Law Firm to see samples of their lawsuits and demand letters) California Center for Disability Access / Potter Handy LLP | Amanda Seabock, Mark Potter, Chris Carson, Denise Price, Russell Handy The Manning Law Firm | Joseph Manning, Craig Cote, Phyl Grace So. In this case no fees were awarded; in fact, none were requested even though the plaintiff was represented by counsel. Winn Dixies appeal of the pro-plaintiff judgment in that case is awaiting a decision from the Eleventh Circuit, and it is unclear what impact, if any, the Sanctions Order will have on the award of fees and costs in that closely watched case. Anxiety goes from a 10 to 0! Contact us today foradditional information about our Colorado A attorneys. Gottlieb & Associates had more plaintiffs including Sandy Graciano, Donna Hedges, Henry Tucker, and Braulio Thorne. The suits alleged that videos playing at gas pumps violated the ADA because they did not include closed captioning. Civil Rights Division. Our Personal Injury LawyersHave Over 28,0005-Star Reviews. Wilshire Law Firm had more plaintiffs including Darren Gresham and Brett DeSalvo. Judge Boyle granted leave to amend, so the case isnt over, but in past cases Segovia and his lawyers have not been able to substantively improve their complaint. Insurance companies truly know that they will take it to court! It would allow awarding of attorney fees and punitive . The ADA Title III team provides ADA Title III litigation defense and counseling services to businesses in every industry, including hospitality, retail, restaurant, financial services, media, health care, higher education, entertainment, sports, car rental, amusement parks, and more. InSegovia v. Shahrukh & Shahzeb Inc., 2022 WL 17566267 (N.D. Tex. The lawsuits can be filed in federal court. Mail: To file a complaint using by mail, send your complaint form to the following address: U.S. Department of Justice. The employers duty to provide a reasonable accommodation is triggered once the employee makes a request for one. Making existing facilities used by employees readily accessible to, and usable by, persons with disabilities, Acquiring or modifying equipment or devices, Adjusting or modifying examinations, training materials, or policies, Providing qualified readers or interpreters. For his part, Michenfelder appears undaunted by the reprimand . Ive linked to my quick profile write-ups of Wilshire (California) and Gottlieb (New York) above. DOJ Investigations. InHull v. Little, 2022 WL 17818065 (9th Cir. Disability Matters under the Fair Housing Act. The teams deep expertise ranges from the negotiation of highly favorable, early resolutions, to the aggressive defense of these cases through all stages of litigation. SeeEEOC-Fact-Sheet-Disability-Discrimination-ADA. Businesses are also confused about their accessibility obligations with respect to their digital assets and how to manage and mitigate that risk. You could consider yourself blessed when they take your case. In recent years, some plaintiffs and their attorneys have come under scrutiny for seemingly lining their pockets by abusing the system that was designed to protect people with disabilities. Kept me informed every step of the way about my case. The Court ordered the following sanctions: The Sanctions Order is an unexpected end to two of twenty-six cases brought by Johnson against gas station owners for allegedly showing TV programming on gas pumps that did not have closed captioning for the deaf. The staff was amazing, they treated me with the utmost respect and professionalism. Under the federal ADA statutes, property owners who successfully defend a lawsuit based on a disability access claim are entitled to recover their attorneys' fees only where the plaintiff's claim was "frivolous, unreasonable or groundless." Dec. 16, 2022) Home Depot was able to meet that burden because it had a policy of close captioning all of its videos before it was sued and it quickly fixed the one video that slipped through after it was sued. The court wrote in its 21-page Sanctions Order: This case reveals an illicit joint enterprise between Plaintiff, Alexander Johnson, and his attorney, Scott R. Dinin of Scott R. Dinin P.A., to dishonestly line their pockets with attorneys fees from hapless defendants under the sanctimonious guise of serving the interests of the disabled community. In fact, we are ADA Title III counsel to the market leaders of these industries which seek our counsel when they have critical and cutting edge ADA Title III challenges to solve. This included overturning a previous U.S. Supreme Court ruling that said available mitigating measures must be considered prior to determining if an individual has a disability. 3010 Mountain Ash Court Disability Rights Section - 1425 NYAV. Regulated and enforced by the U.S. Department of Justice, this title prohibits discrimination against disabled individuals in public entities such as transportation services like Amtrak. 2. Seyfarths ADA Title III team consists of attorneys with extensive experience in ADA Title III litigation located in many offices across the United States, including California where plaintiffs are most active. I got settlements for all 3 lawsuits. Another restaurant, Lola's Chicken Shack, was sued for lack of accessible outdoor tables and a high front door threshold. These lawsuits are sometimes filed by lawyers who recruit clients to target businesses with demand letters posing an ultimatum to either pay a quick settlement or face the threat of an ADA lawsuit. If you have any issues relating to alleged disability discrimination in the workplace and seek legal advice, please contact one of our labor and employment lawyers to discuss the issue in a free consultation. Protect Your Business. A reasonable accommodation is an adjustment or modification to an employees job requirements, responsibilities or working conditions that allows the employee to do the job. It prohibits discrimination against people with disabilities in workplaces, schools, transportation, and essentially in all areas of public and private life. in Accessibility Litigation Trends, ADA - Hotels, ADA - serial litigation, ADA - Standing, ADA Attorney's Fees, ADA Internet, ADA Policies, ADA Public Accommodation, FHA, FHA Emotional Support Animals, FHA Regulation, Internet Accessibility, Public Facilities The essential duties of the job are those tasks that are fundamental to the position. Get more information about this event and register here. Weve helped over 300,000 families. This is a civil right that we. Contact The Harr Law FirmToday.The Harr Law Firm works with the highest caliber of attorney with a proven track record of successful litigation, Jason L. Harr. Despite the prohibition against awarding monetary damages to the plaintiff, ADA lawsuits can still be lucrative for plaintiffs and their attorneys. ADA Defense Lawyer - New York | Bell Law Group New York ADA Defense Lawyer Read Our Latest Blog Posts What Does the CROWN Act Do in New York State? But the court did not stop there. An appeals court has ruled that the Florida federal judge who penalized a serial lawsuit-filer and his attorney for filing frivolous Americans with Disabilities Act (ADA) claims was right to do so, according to a report in Legal Newsline. Please be aware that we do not provide legal advice over the internet or in emails, nor will we agree to represent a party through an email. A latte shop was hit with a similar boilerplate ADA lawsuit by the same plaintiffs' law firm. If the Ninth Circuit ever does the same my blogs will start getting much shorter. If the owner prevails, a Plaintiff does not usually have to pay the owner's attorney's fees, but if the Plaintiff prevails, the owner will likely have to pay the Plaintiff's attorney's fees. Through this illicit joint enterprise, Johnson and Dinin filed numerous frivolous claims, knowingly misrepresented the billable time expended to litigate these claims, made numerous other misrepresentations to the Court, and improperly shared attorneys fees in violation of the Rules Regulating the Florida Bar, all done without regard to the interests of those with disabilities. People often ask us why plaintiffs are filing hundreds of ADA Title III lawsuits when the law only allows for injunctive relief and attorneys fees and costs. 950 Pennsylvania Avenue, NW. Dec. 27, 2022) is another example of a judge who is fairly hostile to serial litigants and will not, in all likelihood, exercise supplemental jurisdiction over Unruh Act claims.
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