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California State Court Complaint

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California State Court Complaint 1 ANDY DOGALI Pro Hac Vice to be submitted 2 Florida Bar No. 0615862 3 Dogali Law Group, P.A. 101 E. Kennedy Blvd., Suite 1100 4 Tampa, Florida 33602 5 Email: [email protected]; [email protected] 6 Tel: (813) 289-0700 Fax: (813) 289-9435 7 Attorney for Plaintiffs 8 And 9 10 EUGENE FELDMAN California Bar No. 118497 11 [email protected] 12 Eugene Feldman, Attorney at Law, APC 555 Pier Avenue, Suite 4 13 Hermosa Beach, CA 90254 14 Tel: (310) 372-4636 Fax: (310) 372-4639 15 Email: [email protected] 16 Attorney for Plaintiffs DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 18 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 19 20 T.P., by and through S.P., as Next Friend, Case No. __________________ Parent and Natural Guardian; 21 S.P., Individually; 22 A.T.W., by and through T.W.R., COMPLAINT FOR 23 as Next Friend, Parent and Natural DECLARATORY AND Guardian; INJUNCTIVE RELIEF AND 24 T.L.R., by and through R.C.R., DAMAGES 25 as Next Friend, Parent and Natural 26 Page 1 _____________________________________________________________________ COMPLAINT T.P., by and through S.P., et al. v. Walt Disney Parks & Resorts US, Inc. Case No. __________________ 1 Guardian; T.W.R., Individually; and JURY TRIAL DEMANDED R.C.R., Individually; 2 A.M.W., by and through D.L.W., 3 as Next Friend, Parent and Natural Guardian; R.D.W., Individually; and 4 D.L.W., Individually; 5 L.T.T., by and through L.J.T., 6 as Next Friend, Parent and Natural Guardian; and L.J.T., Individually 7 L.D.J., by and through T.M.J., 8 as Next Friend, Parent and Natural Guardian; T.M.J., individually; and 9 D.A.J., Individually; E.G.R., Individually; 10 J.H., Individually; T.A.L., by and through G.L., 11 as Next Friend, Parent and Natural 12 Guardian; and G.L., Individually; D.F., by and through C.F., 13 as Next Friend, Parent and Natural 14 Guardian; and C.F., Individually; M.I.P., Individually; 15 A.M.N., by and through V.M.N., 16 as Next Friend, Parent and Natural DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI Guardian; and V.M.N., Individually; 17 D.L.B., by and through L.V.F., 18 as Next Friend, Parent and Natural Guardian; and L.V.F., Individually; 19 B.D.G., Individually; 20 V.J.B., by and through S.L.B., as Next Friend, Parent and Natural 21 Guardian; and S.L.B., Individually; 22 J.L.C., by and through K.A.C., 23 as Next Friend, Parent and Natural Guardian; and J.L.C., Individually; 24 E.L.M., by and through C.P., 25 as Next Friend, and Natural Guardian; 26 Page 2 _____________________________________________________________________ COMPLAINT T.P., by and through S.P., et al. v. Walt Disney Parks & Resorts US, Inc. Case No. __________________ 1 and C.P., Individually; J.A.S., by and through J.F.S., 2 as Next Friend, Parent and Natural 3 Guardian; and J.F.S., Individually; E.W.V., by and through A.M.P., 4 as Next Friend, Parent and Natural 5 Guardian; and E.W.V., Individually; 6 T.J.A., by and through L.A., as Next Friend, Parent and Natural 7 Guardian; and L.A., Individually; 8 V.T.V., by and through N.L.C., as Next Friend, Parent and Natural 9 Guardian; and N.L.C., Individually; 10 P.F.E., by and through B.P.E., as Next Friend, Parent and Natural 11 Guardian; and B.P.E., Individually; 12 Y.Z., by and through M.Y.R., as Next Friend, Parent and Natural 13 Guardian; and M.Y.R., Individually; 14 K.A.R., by and through D.R., as Next Friend, Parent and Court-appointed 15 Co-Guardian; and D.R., Individually; 16 C.M.H., by and through H.A.H., DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI as Next Friend, Parent and Natural 17 Guardian; and H.A.H., Individually; 18 A.S.T., by and through S.D.T., as Next Friend, Parent and Natural 19 Guardian; and 20 S.M.T., by and through S.D.T., as Next Friend, Parent and Natural 21 Guardian; and S.D.T., Individually; 22 E.A.P., by and through A.E.P., 23 as Next Friend, Parent and Natural Guardian; and A.E.P., Individually; 24 P.A.D., by and through A.C.E., 25 as Next Friend, Parent and Natural 26 Page 3 _____________________________________________________________________ COMPLAINT T.P., by and through S.P., et al. v. Walt Disney Parks & Resorts US, Inc. Case No. __________________ 1 Guardian; and A.C.E., Individually; 2 Plaintiffs, 3 v. 4 WALT DISNEY PARKS AND RESORTS 5 US, INC. 6 Defendant. 7 ______________________________________/ 8 9 COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF AND DAMAGES AND DEMAND FOR JURY TRIAL 10 11 Plaintiffs T.P., by and through S.P., as Next Friend, Parent and Natural 12 Guardian; S.P., Individually; A.T.W., by and through T.W.R., as Next Friend, 13 Parent and Natural Guardian; T.L.R., by and through R.C.R., as Next Friend, 14 Parent and Natural Guardian; T.W.R., Individually; and R.C.R., Individually; 15 A.M.W., by and through D.L.W., as Next Friend, Parent and Natural 16 Guardian; R.D.W., Individually; and D.L.W., Individually; L.T.T., by and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 through L.J.T., as Next Friend, Parent and Natural Guardian; and L.J.T., 18 Individually; L.D.J., by and through T.M.J., as Next Friend, Parent and 19 Natural Guardian; T.M.J., individually; and D.A.J., Individually; E.G.R., 20 Individually; J.H., Individually; T.A.L., by and through G.L., as Next Friend, 21 Parent and Natural Guardian; and G.L., Individually; D.F., by and through 22 C.F., as Next Friend, Parent and Natural Guardian; and C.F., Individually; 23 M.I.P., Individually; A.M.N., by and through V.M.N., as Next Friend, Parent 24 and Natural Guardian; and V.M.N., Individually; D.L.B., by and through 25 26 Page 4 _____________________________________________________________________ COMPLAINT T.P., by and through S.P., et al. v. Walt Disney Parks & Resorts US, Inc. Case No. __________________ 1 L.V.F., as Next Friend, Parent and Natural Guardian; and L.V.F., 2 Individually; B.D.G., Individually; V.J.B., by and through S.L.B., as Next 3 Friend, Parent and Natural Guardian; and S.L.B., Individually; J.L.C., by and 4 through K.A.C., as Next Friend, Parent and Natural Guardian; and J.L.C., 5 Individually; E.L.M., by and through C.P., as Next Friend, and Natural 6 Guardian; and C.P., Individually; J.A.S., by and through J.F.S., as Next Friend, 7 Parent and Natural Guardian; and J.F.S., Individually; E.M.V., by and 8 through A.M.P., as Next Friend, Parent and Natural Guardian; and E.M.V., 9 Individually; T.J.A., by and through L.A., as Next Friend, Parent and Natural 10 Guardian; and L.A., Individually; V.T.V., by and through N.L.C., as Next 11 Friend, Parent and Natural Guardian; and N.L.C., Individually; P.F.E., by and 12 through B.P.E., as Next Friend, Parent and Natural Guardian; and B.P.E., 13 Individually; Y.Z., by and through M.Y.R., as Next Friend, Parent and 14 Natural Guardian; and M.Y.R., Individually; K.A.R., by and through D.R., as 15 Next Friend, Parent and Court-appointed Co-Guardian; and D.R., 16 Individually; C.M.H., by and through H.A.H., as Next Friend, Parent and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Natural Guardian; and H.A.H., Individually; A.S.T., by and through S.D.T., as 18 Next Friend, Parent and Natural Guardian; and S.M.T., by and through 19 S.D.T., as Next Friend, Parent and Natural Guardian; and S.D.T., 20 Individually; E.A.P., by and through A.E.P., as Next Friend, Parent and 21 Natural Guardian; and A.E.P., Individually; P.A.D., by and through A.C.E., as 22 Next Friend, Parent and Natural Guardian; and A.C.E., Individually; sue 23 Defendant, WALT DISNEY PARKS AND RESORTS US, INC. upon the facts 24 and causes alleged below. 25 26 Page 5 _____________________________________________________________________ COMPLAINT T.P., by and through S.P., et al. v. Walt Disney Parks & Resorts US, Inc. Case No. __________________ 1 2 I. INTRODUCTION 3 1. This is an action seeking damages, injunctive relief, and 4 declaratory relief for violations of the Unruh Civil Rights Act (§51 of the 5 California Civil Code) and common law. 6 2. Defendant WALT DISNEY PARKS AND RESORTS US, INC. 7 (“Disney”) is a California corporation which at all material times: 8 a. Has maintained its principal place of business in Los 9 Angeles County, California, is authorized to conduct business in the states of 10 California and Florida, and is conducting business in Los Angeles County in the 11 City of Burbank, California and in Orange County in the City of Lake Buena 12 Vista, Florida; and 13 b.
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