Case 1:15-cv RBJ Document 1 Filed 02/09/15 USDC Colorado Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Similar documents
Case 2:17-cv Document 1 Filed 10/30/17 Page 1 of 10

Case 1:11-cv JLK Document 6 Filed 01/26/12 USDC Colorado Page 1 of 29 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 2:17-cv Document 1 Filed 10/30/17 Page 1 of 10

Case 1:18-cv Document 1 Filed 01/31/18 Page 1 of 23

Case 1:17-cv Document 1 Filed 05/04/17 Page 1 of 24

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

ALL DEAF.COM. Lawyer Settles Interpreter Case. April 9, 2004

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA ASHEVILLE DIVISION ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN

Plaintiff, Comfort Dental Group, Inc. ( Comfort Dental ), by its attorneys, MOYE WHITE LLP, states: INTRODUCTION

Case 1:15-cv ARR-VVP Document 1 Filed 09/23/15 Page 1 of 13 PageID #: 1. Plaintiff, Defendant. COMPLAINT

Case 2:12-cv KJM-GGH Document 1 Filed 07/02/12 Page 1 of 9 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA. (Sacramento Division)

Case 1:18-cv MSK Document 1 Filed 05/18/18 USDC Colorado Page 1 of 44 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

48th Judicial District LANGUAGE ACCESS PLAN

GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 2013 H 1 HOUSE BILL 933. Short Title: Informed Consent for HIV/AIDS Testing. (Public)

v. No. COMPLAINT FOR CIVIL RIGHTS VIOLATIONS, PERSONAL INJURIES, AND VIOLATIONS OF THE NEW MEXICO TORT CLAIMS ACT

b. Entities that lease or rent space for their events but have no permanent public office or facility must also follow Title III of the ADA.

Associates, llc, for its Complaint against the defendants, Gary K. DeJohn, Sr. and DeJohn

ANSCHUTZ CORPORATION : d/b/a REGAL ENTERTAINMENT GROUP and/or REGAL CINEMAS, INC., : Plaintiffs, Peter C. Harvey, Attorney General of New Jersey,

HOUSING AUTHORITY OF THE CITY AND COUNTY OF DENVER REASONABLE ACCOMMODATION GRIEVANCE PROCEDURE

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case 1:09-cv RMB-AMD Document 1 Filed 08/12/09 Page 1 of 6 PageID: 1

Parent/Student Rights in Identification, Evaluation, and Placement

29 th Judicial District Language Access Plan

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN. Case No.: COMPLAINT

KING COUNTY SUPERIOR COURT, WASHINGTON STATE CAUSE NO SEA

Case 3:16-cv PK Document 1 Filed 06/14/16 Page 1 of 11

Accessibility. Reporting Interpretation and Accommodation Requests

Case 3:18-cv ARC-MCC Document 1 Filed 04/11/18 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLANIA

Case 2:15-cv NVW Document 1 Filed 10/15/15 Page 1 of 30

SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY NO. COME NOW Plaintiffs by and through their attorneys of record J.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA. Plaintiff, COMPLAINT FOR DEFAMATION

Case 1:17-cv ECF No. 1 filed 10/26/17 PageID.1 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO UNITED CANNABIS CORPORATION. Plaintiff, PURE HEMP COLLECTIVE INC.

Appendix 11 GUIDELINES FOR TRIALS INVOLVING DEAF JURORS WHO SERVE WITH THE ASSISTANCE OF AMERICAN SIGN LANGUAGE INTERPRETERS

Case 1:19-cv UNA Document 1 Filed 03/26/19 Page 1 of 11 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES DISTRICT COURT

Case 2:14-cv Document 1 Filed 12/17/14 Page 1 of 12 UNITED STATES DISTRICT COURT FOR THE EASTEN DISTRICT OF LOUISIANA

Case 1:17-cv RDM Document 1 Filed 05/11/17 Page 1 of 14 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Policy / Drug and Alcohol-Free Workshops

The Americans with Disabilities Act (ADA): Movie Captioning and Video Description

State of Connecticut Department of Education Division of Teaching and Learning Programs and Services Bureau of Special Education

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

Important ADA Policy Guidance on Effective Communication

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC ) ) ) ) SECOND REPORT AND ORDER AND THIRD FURTHER NOTICE OF PROPOSED RULEMAKING

Case 2:15-cv SRC-CLW Document 9 Filed 02/04/16 Page 1 of 19 PageID: 246

A qualified interpreter is one who, via an onsite appearance or a video remote interpreting service (VRI), can:

Case 1:14-cv JEB Document 1 Filed 05/28/14 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:13-cr SCJ-JFK Document 1 Filed 01/22/13 Page 1 of 17 SEALED ATLANTA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO ) ) ) ) ) ) ) ) ) INFORMATION. General Allegations. A. Introduction and Background

NOTICE OF RIGHTS OF STUDENTS AND PARENTS UNDER SECTION 504

Grievance Procedure Last Revision: April 2018

OBLIGATIONS OF AIRPORTS TO PROVIDE COMMUNICATION ACCESSIBILITY TO DEAF AND HARD OF HEARING PERSONS

lm DEC 1 7 Z014 lqj rbj~ ~flw[g fri JUDGE ABR1AMS CLASS ACTION COMPLAINT PRELThflNARYSTATEMENT U.S.D.C. S.D. N.Y. CASHIERS Civil Actioii No.

4. Together, defendants CCA and CCC represent the vast majority of chiropractors practicing in Connecticut.

Registration. Is your registration form accessible? Series: Designing accessible events for people with disabilities and Deaf people

Position Statement on VRI Services in Hospitals

Effective this date, said Administrative Policy supersedes all previous directives on this subject.

Illinois Supreme Court. Language Access Policy

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:16-cv UNA Document 1 Filed 04/22/16 Page 1 of 10 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

Civil Rights Compliance for Patients

B. To protect, in particular, the health of vulnerable populations including children and those with chronic health conditions; and

Americans with Disabilities Act And the Hearing Impaired

SUPERIOR COURT OF WASHINGTON IN AND FOR KING COUNTY. Case No.: Plaintiffs Tammie Aust, Alison Grennan, Jennifer Schill, and Lang You Mau, by and

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON PORTLAND DIVISION

SECTION 504 NOTICE OF PARENT/STUDENT RIGHTS IN IDENTIFICATION/EVALUATION, AND PLACEMENT

Case: 3:17-cv wmc Document #: 1 Filed: 11/01/17 Page 1 of 12 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN

MOTION FOR PRELIMINARY INJUNCTION

Case 2:16-cv JCC Document 1 Filed 02/16/16 Page 1 of 16

South Carolina General Assembly 122nd Session,

Volume of Colorado Commission for the Deaf and Hard of Hearing (12 CCR )

Effective Communication

Return Date: February 27, 2002

19 TH JUDICIAL DUI COURT REFERRAL INFORMATION

Limited English Proficiency: Accommodating Persons with Limited English Proficiency

HEALTH REGULATION # 13 TOBACCO HANDLERS PERMITS

Case 5:04-cv gwc Document 195 Filed 04/16/07 Page 1 of 8

Case 1:17-cv Document 1 Filed 11/20/17 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS EASTERN DIVISION

In re: ) ) NOTICE OF CHARGES John E. Marshall, M.D., ) AND ALLEGATIONS; ) NOTICE OF HEARING Respondent. )

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

Case 1:17-cv UNA Document 1 Filed 02/14/17 Page 1 of 10 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA. Newport News Division

2:12-cv VAR-LJM Doc # 1 Filed 08/02/12 Pg 1 of 12 Pg ID 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN

Educating Courts, Other Government Agencies and Employers About Methadone May 2009

CITY OF PALMER, ALASKA. Ordinance No

Policy \ \ Medical (Palliative) Use of Marijuana

LEGAL IMPLICATIONS OF LANGUAGE SERVICES. Liz Swan, RN, BSN, MBA, CPHRM Marisa Hernandez, BA

How to Ask for a Reasonable Accommodation of Your Disability from the Office of Administrative Hearings (OAH)

1) Title III of the ADA applies to all private health care providers. See 42 U.S.C (7)(F).

Hearing Impaired/Disabled Communications

Report on Tomoka Correctional Institution in Daytona Beach, Florida 2013

Case 2:11-cv LDD Document 1 Filed 06/20/11 Page 1 of 23 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

(City, State, Zip Code)

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH ) ) ) ) ) ) ) ) ) ) ) ) ) GENERAL JURISDICTION AND COMMON FACTUAL ALLEGATIONS

Act 443 of 2009 House Bill 1379

In this chapter, you will learn about the requirements of Title II of the ADA for effective communication. Questions answered include:

Transcription:

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 1:15-cv-00270 GEORGE BACA, v. Plaintiff, PARKVIEW MEDICAL CENTER, INC., and PARKVIEW HEALTH SYSTEMS, INC., Defendants. COMPLAINT Plaintiff George Baca, by and through his attorneys, the Civil Rights Education and Enforcement Center, hereby brings this Complaint against Parkview Medical Center, Inc. and Parkview Health Systems, Inc. (collectively, Parkview ). INTRODUCTION 1. Twenty-four years after the Americans with Disabilities Act ( ADA ) was passed and more than 40 years after Section 504 of the Rehabilitation Act ( Section 504 ), Parkview failed to provide sign language interpreters and other accommodations for the deaf father of a critically injured minor, denying him effective communication and deeply exacerbating an already stressful situation.

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 2 of 10 JURISDICTION AND VENUE 2. This action arises under the laws of the United States. Jurisdiction is conferred upon this court pursuant to 28 U.S.C. 1331 and 1343 for the federal law claims, and 28 U.S.C. 1367 for the state law claim. 3. Venue is proper in this Court pursuant to 28 U.S.C. 1391(b)(2), as all of the events giving rise to the claims occurred in the District of Colorado. PARTIES 4. Plaintiff George Baca is currently and at all times relevant to this suit has been a resident of the State of Colorado in Pueblo County. Mr. Baca is an individual with a disability because he is substantially limited in major life activities, including hearing. 5. Defendants Parkview Medical Center, Inc. and Parkview Health Systems, Inc. are private, nonprofit corporations one or both of which own, operate, lease and/or lease to a private hospital, the Parkview Medical Center, which is a place of public accommodation as that term is used in title III of the Americans with Disabilities Act, 42 U.S.C. 12181(7) and the Colorado Anti-Discrimination Act, COLO. REV. STAT. 24-34-601. On information and belief, both Parkview Defendants are recipients of federal financial assistance as that term is used in Section 504. On information and belief, Parkview Medical Center employs more than 15 people. FACTUAL ALLEGATIONS 6. Plaintiff Baca is deaf, and does not understand speech. His first language and primary mode of communication is American Sign Language. 7. Like many individuals who have been deaf since childhood, Mr. Baca does not read or write with fluency. American Sign Language, not English, is his native language. 2

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 3 of 10 8. In order to communicate effectively with strangers and/or in situations that call for more than routine language, Mr. Baca requires the services of a qualified sign language interpreter. Specifically, he requires a sign language interpreter in communications relating to medical topics and in conversations involving multiple individuals. 9. At all times relevant to this lawsuit, Parkview has known that Mr. Baca is Deaf. 10. On the evening of July 6, 2013, Mr. Baca was notified that his minor daughter was struck by a car and taken by ambulance to Parkview. He arrived at the hospital not long after. 11. In the emergency room lobby, Mr. Baca immediately requested to see his daughter and to be provided a sign language interpreter. No interpreter was provided. 12. On the evening of July 6, for most of July 7, and for the morning of July 8, Mr. Baca repeatedly requested an interpreter to speak with doctors, nurses, and other hospital staff. He was receiving no effective communication concerning what staff were doing and desperately wanted to understand. 13. Mr. Baca requested a sign language interpreter on July 6, 2013. 14. Defendants did not provide an interpreter for Mr. Baca on July 6, 2013. 15. Mr. Baca requested a sign language interpreter on the morning of July 7, 2013. 16. Defendants did not provide an interpreter for Mr. Baca until approximately noon on July 7, 2013. 17. The interpreter Defendants provided to Mr. Baca on July 7, 2013 interpreted for him for approximately two hours. 3

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 4 of 10 18. After the interpreter provided to Mr. Baca on July 7, 2013 left, Defendants did not provide an interpreter for Mr. Baca for the remainder of that day. 19. On the morning of July 8, 2013, medical staff met in Mr. Baca s daughter s hospital room to discuss her condition. 20. Mr. Baca again requested an interpreter for this meeting. 21. Parkview did not provide an interpreter for the meeting with medical personnel on the morning of July 8, 2013. 22. Although a sign language interpreter was provided later in the day on July 8, medical personnel did not return to Mr. Baca s daughter s room to discuss her condition in the presence of the interpreter. 23. When Mr. Baca arrived at the Emergency Room on the evening of July 6, he was unable to understand what Parkview staff were telling him about his daughter s condition. The only way the doctor could convey the extent of Mr. Baca s daughter s injuries was to pull back the curtain on her room and show Mr. Baca her critical injuries. Without effective communication to convey the context of his daughter s injuries, this was terrifying for him. 24. Mr. Baca was asked to sign documents pertaining to his daughter s care. 25. Mr. Baca did not fully understand the documents he was requested to sign because Defendants did not provide a sign language interpreter to assist him. 26. Parkview was on notice that Mr. Baca needed an interpreter both because the need was obvious, and because on a number of occasions during his daughter s stay, Mr. Baca requested an interpreter. 4

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 5 of 10 27. On two occasions, a nurse attempted to communicate with Mr. Baca in writing about his daughter s care, the result of which were notes saying, She doesn t need surgery, and The doctor said he can come back. He is saying he [sic] injury is something that will heel [sic] on its own. We will do a CAT scan in the morning to Double Check. In response to the former, Mr. Baca wrote to underscore his need for an interpreter don t matter I must I know everything Because I will take care her when out hospital. In response to the latter, he wrote, OK for now Interpreter 24/7!!!! 28. Parkview either lacks policies and procedures sufficient to ensure timely provision of effective communication or has policies and procedures that are inadequate to ensure this. 29. Parkview denied Mr. Baca access to communication as effective as that available to hearing parents of patients in its health care facilities. 30. The actions above discriminated against Mr. Baca on the basis of his disability. 31. Mr. Baca was harmed by Parkview s discrimination and failure to make its aids, benefits, and services available to him on nondiscriminatory terms. The discrimination and absence of effective communication, themselves, harmed Mr. Baca. In addition, he suffered emotional harm from the experience of coping with his daughter s critical injuries without the communication and information essential to any parent in that situation. Throughout the first three days of his daughter s hospitalization for life-threatening injuries, he felt intensely emotional, helpless, and frustrated. 32. Mr. Baca and his family members have received services at Parkview on multiple occasions and Mr. Baca intends to continue to use Parkview as the principal hospital for himself 5

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 6 of 10 and his family for emergency or inpatient care. Parkview is the only Level II Medical Center in the region where he resides. For these reasons, it is likely that Mr. Baca will in the future be a patient or the companion of a patient receiving medical care at Parkview and, in the absence of the relief requested in this Complaint, likely encounter further illegal discrimination. FIRST CLAIM FOR RELIEF (Violations of Section 504 of the Rehabilitation Act) 33. Plaintiff incorporates the allegations set forth in the remainder of this Complaint and in each of the above paragraphs as if fully set forth herein. 34. Section 504 prohibits discrimination on the basis of disability by recipients of federal financial assistance such as Parkview. 28 U.S.C. 794. 35. Mr. Baca is an individual with a disability within the meaning of the Section 504. 36. Parkview discriminated against Mr. Baca on the basis of disability in violation of Section 504 and its implementing regulations as more fully described above. Such discrimination includes but is not limited to the failure to provide auxiliary aids and services necessary to ensure effective communication and failure to provide aids, benefits and services as effective as those provided to others. 37. Mr. Baca was qualified to participate in Defendants aids, benefits, and services within the meaning of Section 504. 38. Defendants denied Mr. Baca access to their aids, benefits, and services solely on the basis of his disability, thereby violating Section 504. 39. Despite the clear provisions of Section 504, Defendants knowledge of Mr. Baca s requests for an interpreter, and its knowledge of Mr. Baca s deafness and need for 6

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 7 of 10 accommodation, Defendants continued to impose conditions and practices that discriminated against Mr. Baca. 40. Defendants actions described in this Complaint were intentional and/or were taken with deliberate indifference to the strong likelihood that pursuit of its questioned policies would likely result in a violation of Mr. Baca s rights under the ADA and Section 504. 41. As a direct and proximate result of the acts, omissions, and violations alleged above, Mr. Baca has suffered damages, including but not limited to pain and suffering, inconvenience, and emotional distress. 42. Mr. Baca has been injured and aggrieved by and will continue to be injured and aggrieved by Defendants discrimination. SECOND CLAIM FOR RELIEF (Violations of title III of the Americans with Disabilities Act.) 43. Plaintiff incorporates the allegations set forth in each of the above paragraphs and remainder of this Complaint as if fully set forth herein. 44. Title III of the ADA prohibits discrimination on the basis of disability by entities such as Defendants who own, operate, lease or lease to places of public accommodation. 42 U.S.C. 12182 et seq. 45. Parkview Medical Center is a place of public accommodation as that term is used in title III of the ADA. 42 U.S.C. 12181(7)(F). 46. Mr. Baca is an individual with a disability within the meaning of the ADA. 47. Defendants discriminated against Mr. Baca on the basis of disability in violation of title III of the ADA and its implementing regulations as more fully described above. Such 7

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 8 of 10 discrimination includes but is not limited to the failure to provide auxiliary aids and services and the failure to provide communication equally effective to that provided to others. 48. Mr. Baca was qualified to participate in Defendants goods, services, facilities, privileges, advantages, and accommodations within the meaning of title III of the ADA. 49. Defendants denied Mr. Baca services, and otherwise treated him differently on the basis of his disability, thereby violating title III of the ADA. 50. Despite the clear provisions of title III, Defendants knowledge of Mr. Baca s requests for an interpreter, and its knowledge of Mr. Baca s deafness and need for accommodation, Defendants continued to impose conditions and practices that discriminated against Mr. Baca. 51. As a direct and proximate result of the acts, omissions, and violations alleged above, Mr. Baca has suffered damages including but not limited to pain and suffering, inconvenience, emotional distress, and impairment of quality of life. 52. Mr. Baca has been injured and aggrieved by and will continue to be injured and aggrieved by Defendants discrimination. THIRD CLAIM FOR RELIEF (Violations of the Colorado Anti-Discrimination Act.) 53. Plaintiff incorporates the allegations set forth in each of the above paragraphs of this Complaint as if fully set forth herein. 601(1). 54. Parkview is a place of public accommodation as defined in C.R.S. 24-34- 55. C.R.S. 24-34-601(2) provides in relevant part that [i]t is a discriminatory practice and unlawful for a person, directly or indirectly, to refuse, withhold from, or deny to an 8

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 9 of 10 individual or a group, because of disability... the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of a place of public accommodation... 56. By, among other things, failing to provide effective communication services to Mr. Baca on July 6, 7, 8 and at other times while his daughter was receiving services at Parkview, despite their knowledge that he was Deaf, and despite his repeated requests for interpreter services, Defendants discriminated against Mr. Baca by denying him the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of the Center in violation of C.R.S. 24-34-601. WHEREFORE, Plaintiff respectfully requests: 1. That this Court assume jurisdiction; 2. That this Court declare the actions of Defendants described in this Complaint to be in violation of title III of the Americans with Disabilities Act, Section 504, and the Colorado Anti-Discrimination Act; 3. That this Court enter an injunction ordering Defendants to cease discrimination on the basis of disability against deaf patients and companions of patients, including but not limited to Mr. Baca, by (among other things) establishing a procedure to ensure effective communication with persons who are deaf or hard of hearing; 4. That this Court award Mr. Baca compensatory damages pursuant to Section 504 and the Colorado Anti-Discrimination Act; 5. That this Court award Mr. Baca and/or his attorneys his reasonable attorneys fees and costs; and 9

Case 1:15-cv-00270-RBJ Document 1 Filed 02/09/15 USDC Colorado Page 10 of 10 and equitable. 6. That this Court award such additional or alternative relief as may be just, proper, Dated this 9 th day of February, 2015. Respectfully submitted, s/ Amy F. Robertson Amy F. Robertson Civil Rights Education and Enforcement Center 104 Broadway, Suite 400 Denver, CO 80203 Phone: (303) 757-7901 arobertson@creeclaw.org Attorney for Plaintiff 10