1 ANDY DOGALI Pro Hac Vice to be submitted 2 Florida Bar No. 0615862 3 Dogali Law Group, P.A.

4 5 6

7 Attorney for Plaintiffs 8 And 9 10 EUGENE FELDMAN California Bar No. 118497 11 [email protected] 12 Eugene Feldman, Attorney at Law, APC

13 14

15 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 Deadline.com 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

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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;Deadline.com 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;

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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 Deadline.com 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

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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;Deadline.com 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

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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 NextDeadline.com 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

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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. Owns and operates six themed amusement parks 14 (collectively, the “Disney Parks”), including Disneyland and Disney’s California 15 Adventure (collectively, “Disneyland”) in the Disneyland Resort, located in 16 Orange County, California, and Magic Kingdom, Hollywood Studios, Epcot, and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Animal Kingdom (collectively, “Walt Disney World”) in the Walt Disney World 18 Resort, located in Orange County, Florida and Osceola County, Florida. 19 Deadline.comII. JURISDICTION AND VENUE 20 3. Venue is proper in this judicial district, pursuant to California 21 Code of Civil Procedure §395(a). Defendants reside and/or transact business 22 in the County of Los Angeles, and are within the jurisdiction of this Court for 23 purpose of service of process. 24

25

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1 2 III. ALLEGATIONS COMMON TO ALL ACTIONS 3 A. The Unruh Civil Rights Act 4 4. §51(b) of the California Civil Code, known as the “Unruh Civil 5 Rights Act" provides protection from discrimination by all business 6 establishments in California, including housing and public accommodations, 7 because of age, ancestry, color, disability, national origin, race, religion, sex 8 and sexual orientation. 9 5. Specifically, §51(b) provides that: 10 All persons within the jurisdiction of this State are free and

11 equal, and no matter what their sex, race, color, religion, ancestry, national origin, disability, medical condition, marital 12 status, or sexual orientation are entitled to the full and equal 13 accommodations, advantages, facilities, privileges, or services in all business establishments of every kind whatsoever. 14 15 (Emphasis added.) 16 DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 6. While §52(a) provides that: 18 Whoever denies, aids or incites a denial, or makes any discrimination or distinction contrary to Section 51… is liable for 19 each and everyDeadline.com offense for the actual damages, and any amount 20 that may be determined by a jury, or a court sitting without a jury, up to a maximum of three times the amount of actual 21 damage but in no case less than four thousand dollars ($4,000), 22 and any attorney's fees that may be determined by the court in addition thereto, suffered by any person denied the rights 23 provided in Section 51... 24 7. §51.5(a) provides in pertinent part that: 25

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1 No business establishment of any kind whatsoever shall discriminate against, boycott or blacklist. . . any person in this 2 state on account of any characteristic listed or defined in 3 subdivision (b) or (c) of §51. . . because the person is perceived to 4 have one or more of those characteristics, or because the person is associated with a person who has, or is perceived to have, any 5 of those characteristics. 6 (Emphasis added.) 7

8 8. §51(f) provides that: 9 A violation of the right of any individual under the Americans 10 with Disabilities Act shall also constitute a violation of this section. 11

12 (Emphasis added.) By virtue of §51(f), portions of the Americans with 13 Disabilities Act are pertinent to Plaintiffs’ claims under the Unruh Act. 14 a. In 1990, the United States Congress made findings that 15 laws were needed to more fully protect “some 43 million Americans [with] 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI one or more physical or mental disabilities;” that “historically society has 17 tended to isolate and segregate individuals with disabilities;” and that 18 “such forms of discrimination against individuals with disabilities continue 19 to be a serious Deadline.comand pervasive social problem;” that “the Nation’s proper 20 goals regarding individuals with disabilities are to assure equality of 21 opportunity, full participation, independent living and economic self 22 sufficiency for such individuals;” and that “the continuing existence of 23 unfair and unnecessary discrimination and prejudice denies people with 24 disabilities the opportunity to compete on an equal basis and to pursue 25

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1 those opportunities for which our free society is justifiably famous....” 42 2 U.S.C. § 12101. 3 b. 42 U.S.C. §12182(a) provides as follows: 4 No individual shall be discriminated against on the basis of 5 disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place 6 of public accommodation by any person who owns, leases (or 7 leases to), or operates a place of public accommodation.

8 c. 42 U.S.C. §12181(7)(B), regarding “public 9 accommodations”, provides in pertinent part: 10 The following private entities are considered public

11 accommodations for purposes of this subchapter, if the operations of such entities affect commerce— 12 13 * * *

14 (I) a park, zoo, amusement park, or other place of recreation; 15 16 (Emphasis added.) DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 d. 42 U.S.C. §12102(1) defines “disability” in pertinent part 18 as follows: 19 (1) DisabilityDeadline.com 20 The term “disability” means, with respect to an individual— 21 22 (A) a physical or mental impairment that substantially limits one or more major life activities of such individual; 23

24 e. For purposes of the “disability” definition, 42 U.S.C. 25 §12102(2) defines “major life activities” thus:

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1 (A) In general 2 For purposes of paragraph (1), major life activities include, but 3 are not limited to, caring for oneself, performing manual 4 tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, 5 concentrating, thinking, communicating, and working. 6 (Emphasis added.) 7 8 f. Title III includes a “General prohibition” against 9 discrimination. 42 U.S.C. §12182(b)(1)(A) provides in pertinent part: 10 (i) Denial of participation

11 It shall be discriminatory to subject an individual or class of 12 individuals on the basis of a disability or disabilities of such individual or class, directly, or through contractual, licensing, or 13 other arrangements, to a denial of the opportunity of the 14 individual or class to participate in or benefit from the goods, services, facilities, privileges, advantages, or accommodations of 15 an entity. 16 DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI (ii) Participation in unequal benefit 17

18 It shall be discriminatory to afford an individual or class of individuals, on the basis of a disability or disabilities of such 19 individual Deadline.comor class, directly, or through contractual, licensing, or 20 other arrangements with the opportunity to participate in or benefit from a good, service, facility, privilege, advantage, or 21 accommodation that is not equal to that afforded to other 22 individuals. 23 (iii) Separate benefit 24 25

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1 It shall be discriminatory to provide an individual or class of individuals, on the basis of a disability or disabilities of such 2 individual or class, directly, or through contractual, licensing, or 3 other arrangements with a good, service, facility, privilege, 4 advantage, or accommodation that is different or separate from that provided to other individuals, unless such action is necessary to 5 provide the individual or class of individuals with a good, service, 6 facility, privilege, advantage, or accommodation, or other opportunity that is as effective as that provided to others. 7 8 g. Title III further includes a “Specific prohibition” against 9 discrimination. 42 U.S.C. §12182(b)(2)(A)(ii) provides in pertinent part: 10 . . . discrimination includes—

11 (ii) a failure to make reasonable modifications in policies, 12 practices, or procedures, when such modifications are necessary to afford such goods, services, facilities, privileges, advantages, or 13 accommodations to individuals with disabilities, unless the entity 14 can demonstrate that making such modifications would fundamentally alter the nature of such goods, services, facilities, 15 privileges, advantages, or accommodations. 16 DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 B. Facts Common to All Claims 18 1) The Disney Parks, and Plaintiffs’ Cognitive Impairments 19 9. Disneyland,Deadline.com Disney’s California Adventure, Magic Kingdom, 20 Hollywood Studios, Epcot and Animal Kingdom are each “business 21 establishments” under the Unruh Civil Rights Act and “public 22 accommodations” under the Americans with Disabilities Act. 23 10. Each of the Disney Parks includes motions rides, simulation rides, 24 attractions, shows, parades, costumed character interactions, displays and 25 exhibits, restaurants and eating establishments, and more. 26 Page 11 ______COMPLAINT T.P., by and through S.P., et al. v. Walt Disney Parks & Resorts US, Inc. Case No. ______

1 11. Persons with developmental disorders or cognitive impairments 2 vary widely in the precise manifestations of their impairments. Generally, a 3 person with a cognitive disability has greater difficulty with one or more types 4 of mental tasks than a person with average cognitive skills, and most cognitive 5 disabilities are the result of a biological or physiological trait of the individual. 6 The connection between an individual’s biology or physiology on the one hand 7 and their mental processes on the other is most obvious in the case of 8 traumatic brain injury and genetic disorders, though less pronounced or more 9 severe cognitive disabilities are often borne in brain structure or chemistry as 10 well. A person with severe cognitive impairment typically needs assistance

11 with all aspects of daily life. A person with minor cognitive impairment 12 typically needs assistance with some aspects of daily life. 13 12. Cognitive disabilities are often classified as either clinical or 14 functional. Clinically diagnosed cognitive disabilities include autism, Down 15 Syndrome, traumatic brain injury, and dementia. Less severe cognitive 16 conditions include attention deficit disorder (ADD), dyslexia (difficulty DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 reading), dyscalculia (difficulty with math), and other learning disabilities. 18 13. Functional cognitive disabilities focus less on the diagnosis of the 19 disability and moreDeadline.com on the resulting or special needs, abilities and challenges. 20 Principal categories of functional cognitive disabilities include deficits or 21 difficulties with: memory, problem solving, attention, reading, language and 22 verbal comprehension, math comprehension, and visual comprehension. 23 14. Clinical cognitive disabilities typically exhibit one or more of the 24 functional cognitive disabilities. 25

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1 15. Plaintiffs T.P., A.T.W., T.L.R., A.M.W., L.T.T., L.D.J., T.A.L., D.F., 2 A.M.N., D.L.B., V.J.B., K.A.C., E.L.M., J.A.S., E.W.V., T.J.A., V.T.V., P.F.E., Y.Z., K.A.R., 3 C.M.H., A.S.T., S.M.T., E.A.P., and P.A.D. (collectively, the “Disabled Plaintiffs”) 4 each has a developmental disorder and a clinically diagnosed cognitive 5 impairment. Each is substantially limited in the ability to care for himself or 6 herself, perform manual tasks, speak, learn, read, concentrate, think, 7 communicate, and work. 8 16. Each Disabled Plaintiff whose actions are prosecuted in this 9 complaint by and through a next friend, parent or guardian is an individual 10 who is afforded the protections afforded under the Unruh Civil Rights Act and

11 the Americans with Disabilities Act. 12 17. Because persons with developmental disorders encompassing 13 cognitive disabilities display a wide variety and magnitude of functional 14 impairments, no single accommodation is available which will invariably 15 satisfy each of their special needs. Even so, certain traits are common 16 throughout the community of persons with cognitive impairments: DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 a. The Disabled Plaintiffs, like other persons with cognitive 18 impairments, are mentally and physically incapable of waiting for significant 19 periods of time, Deadline.comregardless of whether they are waiting in a line or queue, or 20 whether they are told to come back at a later time. The idle, unfocused state 21 which necessarily results from waiting causes persons on the autism 22 spectrum, and other near-spectrum exhibitors, to over-stimulate, resulting in 23 heightened anxiety and meltdown behaviors. A “meltdown” is an episode 24 familiar to those who care for autistic and other cognitively-impaired persons. 25

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1 Most commonly, the autistic person, when required to wait for more than a 2 few minutes or indefinitely, will begin displaying signs of an oncoming 3 meltdown; oftentimes by exhibiting their individual form of “stimming,” which 4 is a tic or tendency which can take the form of humming sounds, random 5 noises, striking out, swinging arms, hitting oneself, or flailing wildly. A 6 meltdown within a Disney queue is an awkward and uncomfortable 7 experience for those in the immediate vicinity, can be hazardous to the 8 disabled person and bystanders, and can be humiliating and embarrassing for 9 the disabled person and his or her companions. Requiring the person to stand 10 and wait for extended periods of time will induce meltdowns in the large

11 majority of persons with cognitive impairments, including the Disabled 12 Plaintiffs. 13 b. The Disabled Plaintiffs, like other persons with cognitive 14 impairments, are mentally and physically incapable of traveling across a park 15 to the site of an attraction only to be told to come back later. Explaining the 16 disruption would be as impracticable as telling a person with no sense of time DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 or sequence to keep a weekly calendar, or re-programming a computer in the 18 middle of its computation, or placing food in front of someone with no sense 19 of present versusDeadline.com future tense and telling them not to eat it now but to wait 20 until later. Invariably, this experience will induce meltdowns in the large 21 majority of persons with cognitive impairments, including the Disabled 22 Plaintiffs. 23 18. Autistic persons typically lack “Theory of Mind,” the characteristic 24 which enables a person to attribute thoughts, beliefs, and emotions to self and 25

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1 to others. Autistic persons are thus unable to interpret social cues, such as 2 waiting for their turn, to take into account other persons’ expectations of 3 them, and to distinguish between appropriate and objectionable social 4 behaviors. 5 19. Except for the highest-functioning autistic persons, persons with 6 autism also lack “Executive Functioning,” which is generally the ability to 7 process information, so they are unable to appreciate the significance of 8 details within a larger construct, or to grasp the concept of sequencing 9 individual parts within a whole. Consequently, expecting an autistic person to 10 comprehend the concept of waiting – any kind of waiting – is an exercise in

11 futility. 12 20. Perhaps ironically, Disney’s “Magic” often plays a role in the 13 development of young persons with autism. Parents, special education 14 teachers, speech pathologists and other professionals who interact with 15 autistic children on a regular basis, often use Disney’s adorable and highly- 16 recognizable characters, cartoons, stories, toys, and movies to assist in DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 opening autistic children to the world around them. Disney becomes a driving 18 force in the lives of these children, and can become the only part of their lives 19 that generates visibleDeadline.com signs of fun and exuberance. 20 2) The Guest Assistance Card: Disney’s Commendable 21 Accommodation of Plaintiffs, Pre-October 2013 22 21. The Disabled Plaintiffs visited one or more of the Disney theme 23 parks on multiple occasions prior to October of 2013. Generally, on those 24 25

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1 occasions, Disney adopted and followed systems, policies and procedures 2 which wonderfully accommodated the Disabled Plaintiffs’ special needs. 3 22. Visits to the Disney Parks became among the most, if not the most, 4 joyous and eagerly anticipated experiences in Plaintiffs’ lives. The Plaintiffs’ 5 parent acknowledges that, prior to about October 9, 2013, taking her children 6 to the Disney Parks was one of the few experiences, if not the only experience, 7 which would bring obvious joy to the Disabled Plaintiffs for many hours in a 8 row, a notion very uncommon outside Disney’s magical worlds. 9 23. The experience of visiting the Disney Parks may have been more 10 uniquely entertaining for the Disabled Plaintiffs because of their limited

11 ability to participate in other ordinary experiences. For the most part, the 12 Disabled Plaintiffs and other persons with cognitive impairments cannot go to 13 birthday parties, they cannot play on baseball teams, they cannot go fishing or 14 bowling, they cannot go to church. Absent other joyful experiences, the 15 terrific product Disney developed and admirably delivered gave great hope 16 and anticipation to Plaintiffs and their family. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 24. Prior to October of 2013, Disney’s system for accommodating 18 disabled persons’ special needs was universally enjoyed and appreciated by 19 the community ofDeadline.com persons touched by cognitive impairments. The system was 20 known as the “Guest Assistance Card” (“GAC”). A redacted example of a Guest 21 Assistance Card which was used at the Walt Disney World Resort is attached 22 as Exhibit 1, and a redacted example of a Guest Assistance Card which was 23 used at the Disneyland Resort is attached as Exhibit 2. With the Guest 24 Assistance Card, Plaintiffs knew they could expect minimal, manageable waits 25

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1 at the various attractions of interest, and this was precisely what Disney, 2 through its employees, routinely delivered. Disney did not make the Disabled 3 Plaintiffs travel all the way to an attraction only to be told to leave and come 4 back later. Nor did Disney make him wait more than a few minutes to board 5 rides or enter attractions. Very little risk of over-stimulation or meltdown 6 ever arose. 7 25. In addition, the Disney Parks’ employees always appeared to have 8 been trained to care about Plaintiffs’ special needs. Actually, the employees 9 were so talented in this role that it did not appear they had to be trained to 10 care; it appeared they simply did care, naturally. They never did anything

11 which was designed or prone to inflict embarrassment or shame or 12 humiliation upon the disabled guest and their companions. 13 3) The Disability Access Service: Disney’s Failed 14 Accommodation of Plaintiffs Commencing October 9, 2013 15 26. On or about October 9, 2013, Disney revoked the Guest Assistance 16 Card program and its related systems, policies and procedures for DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 accommodating Plaintiffs’ special needs. Disney replaced the Guest Assistance 18 Card program with a set of company-wide systems, policies and procedures 19 which were connectedDeadline.com to the new “Disability Access Service” (“DAS”) card. A 20 redacted example of a Disability Access Service card is attached as Exhibit 3. 21 27. Disney conducted such an extensive research and development 22 program in advance of the DAS, only to create a system which is so obviously 23 and outrageously discriminatory toward persons with cognitive impairments, 24 25

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1 that it is inconceivable that the Disability Access Service’s discriminatory 2 impact upon Plaintiffs is an accident. 3 28. The systems, policies and procedures associated with the 4 Disability Access Service which Disney rolled out in October of 2013 were 5 certain to create discrimination against Plaintiffs, and it was obvious that the 6 community of persons with cognitive impairments would be harmed by the 7 DAS. 8 29. Disney came to disfavor its GAC system because it undermined 9 Disney’s highly profitable tour guide services. Disney often issued GACs to 10 persons who, according to Disney, “abused” the GAC system. Such persons

11 were frequently independent theme park tour guides who charged fees to 12 others for the privilege of being the GAC holder’s companions. An 13 independent tour guide with a GAC offered his or her companions a tour of the 14 Disney Parks which was superior to the experience offered by Disney’s own 15 tour guides, or offered a substantially similar experience for far less than the 16 $350-$500 per hour, with six-hour minimum, which Disney charged and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 continues to charge to guests who hire Disney’s own tour guides. The DAS 18 was deliberately designed to provide no meaningful advantage to a person 19 holding a DAS card,Deadline.com to prevent independent tour guides from advertising or 20 providing a service which competed with Disney’s own tour guide services. 21 Disney eliminated any incentive to obtain a DAS, regardless of how stripping 22 the DAS of any substance might impact persons with cognitive impairments. 23 30. Disney further came to disfavor its GAC system because persons 24 with developmental disorders such as autism occasionally behave loudly and 25

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1 erratically in public. Disney disfavored such episodes because they upset the 2 Disney “magic” being otherwise experienced by Disney’s nearby non-disabled 3 guests. Either by design or as a collateral benefit from Disney’s perspective, 4 Disney’s new system takes steps to end this Disney-perceived problem. 5 Overtly discriminating against Plaintiffs and others like them until persons 6 with autism and other developmental disorders simply no longer visit 7 Disney’s theme parks will likely end any potential disruption of the “magical” 8 Disney experience enjoyed by Disney’s non-disabled guests. 9 31. Disney further came to disfavor its GAC system because persons 10 with developmental disorders such as autism often do not exhibit some other

11 physical disorder – i.e., those who present the “invisible disability” of autism. 12 For persons presenting obvious, visible disabilities, such as persons in 13 wheelchairs, the nearby guests could see that the guest’s special need was 14 being accommodated. For autistic guests, the disability is often not apparent, 15 leading nearby Disney guests to conclude that the guest is being allowed to 16 promptly enter the ride for reasons relating to preferential favoritism and not DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 to disability accommodation. Disney has always desired to curb the 18 resentment harbored by nearby non-disabled guests who wait in Disney’s 19 infamously longDeadline.com queues. Either by design or as a collateral benefit from 20 Disney’s perspective, Disney’s new system takes steps to end this Disney- 21 perceived problem. Overtly discriminating against Plaintiffs and others like 22 them until persons with autism and other developmental disorders simply no 23 longer visit Disney’s theme parks will likely end any potential disruption of 24 the “magical” Disney experience enjoyed by Disney’s non-disabled guests. 25

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1 32. Either Disney designed the DAS with a goal or “benefit” in mind of 2 substantially reducing the number of autistic and cognitively impaired 3 persons who visit the Disney Parks, or Disney recognized such “benefit” 4 promptly upon release of the DAS and has accepted its adverse impact upon 5 Plaintiffs. One manifestation of this motivation or acceptance is clear from the 6 changes in service provided by Disney’s employees. Disney’s employees, who 7 previously exhibited only the highest care and attention for Plaintiffs during 8 their visits to the parks, turned overnight into a terrible new version of 9 themselves. Disney’s employees uniformly reversed all of their prior 10 characteristics; courtesy was replaced with rudeness, acceptance with

11 suspicion, understanding with impatience, and consideration with 12 discourtesy. The switch from respect for Plaintiff’s needs to disdain for 13 Plaintiffs’ presence was so broad, and so consistent, and so abrupt, that Disney 14 clearly trained its personnel to engage in behavior that is calculated to deter 15 Plaintiffs from ever returning to the Parks in the future. Typically egregious 16 remarks by Disney employees include: “I do not care what your child’s issues DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 are,” and “These are the new policies, and you’re going to have to deal with it.” 18 33. The DAS card itself reveals Disney’s motivations: 19 a. Deadline.comDisney replaced its generically-titled “Guest Assistance 20 Card” with the stigma-emphasizing title of “Disability Access Service” card. 21 There can be no plausible good faith reason for deliberately re-naming the 22 card in this manner. 23 b. Disney now insists upon taking a photograph of the disabled 24 guest at the commencement of each two-week period the guest visits the 25

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1 Disney Parks. Non-disabled persons are not required to submit to the taking 2 of their photograph. There can be no plausible good faith reason for adding 3 this pre-condition to disabled persons’ entry to the Disney Parks. 4 c. The card expressly cites its purpose as follows: 5 The Disability Access Service is designed for Guests who are unable 6 to tolerate extended waits due to disability. This service allows Guests to schedule a return time that is comparable to the current 7 queue wait for the given attraction. 8 This service does not provide immediate or priority attraction 9 access. 10 Disney cannot possibly miss the facial incongruity in this language. The first

11 sentence purports to help the Plaintiffs avoid waits, while the second sentence 12 institutionally mandates waits. A “return time” equal to other patrons’ 13 “current queue wait” is a wait. And, for the Disney Parks, it is definitively a 14 long wait. Disney’s biggest obstacle to providing a perfect outing for all its 15 guests is its notoriously long wait times. One-hour wait times are the norm. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI Non-disabled patrons is that they can tolerate and withstand the dreaded wait 17 times, while Plaintiffs cannot. In the third sentence, Disney notes a difference 18 between immediate access and priority access; that is, immediate access is not 19 necessarily preferentialDeadline.com or superior treatment in comparison to the access 20 afforded other guests. The importance of this distinction is unclear, as 21 Plaintiffs have never sought either immediate access or “priority” access. 22 23 d. The first and last of the “Terms and Conditions” which are 24 shown on the DAS are: 25 Your scheduled return time does not provide immediate access upon

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1 your return.

2 When utilizing this service, it is possible to experience waits greater 3 than the posted wait time.

4 Disney cannot in good faith miss the incongruity of these provisions. To 5 suggest that the disabled guest must schedule an appointment for a ride, for 6 whatever time in the future would be the start or boarding time if the guest 7 were to stand in line, while not promising to allow the guest onto the ride at 8 the appointment time, is outlandish. Disney mandates the making of an 9 appointment time but refuses to commit to honoring the appointment time. 10 By doing so, Disney refuses to commit to providing an accommodation.

11 Plaintiffs do not control and cannot predict whatever variables may exist to 12 influence Disney’s decision to accommodate a guest by honoring a promised 13 wait time. The second sentence establishes that even if the DAS is followed, 14 other, non-disabled guests may receive more favorable service. 15 e. The very cover of the DAS card gives the disabled guest this 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI instruction: 17 At each attraction, please show this card to an attraction Cast 18 Member to notify them of your assistance needs. They will assign a 19 return time based on the current wait. Deadline.com 20 When available, please use Disney FASTPASS service to reduce your 21 wait time. 22 This language constitutes an admission that Disney will not, under any 23 circumstances, eliminate or reduce a wait time. The first sentence invites a 24 discussion of a guest’s special needs. The second sentence establishes that 25

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1 no matter what special need the disabled guest may want to discuss, one 2 and only one accommodation will be offered, and it is to wait as long as a 3 non-disabled guest waits. (Or, given Disney’s lack of commitment to 4 honoring a promised return time, perhaps even longer.) The third 5 sentence confirms that, under any circumstances, the disabled person will 6 experience an extended wait, because he or she is encouraged to take other 7 measures to reduce the wait time. 8 34. When Disney unleashed the DAS system on its unsuspecting 9 disabled fans, Disney publicly announced that only the highest-functioning 10 persons would be accommodated by the DAS system and that others would be

11 accommodated based upon their individual special needs. In fact, when 12 concerned parents who had already purchased airfare, tickets, made hotel 13 reservations, and/or purchased annual or seasonal passes, called ahead to ask 14 about the DAS, they were invariably assured that upon arrival at the Parks, 15 Disney would make necessary arrangements to ensure that their children 16 were individually accommodated. Disney knew, as admitted by Mark Jones, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disney’s Manager of Domestic Services for Guests with Disabilities, that other 18 autistic persons and other persons with cognitive impairments would require 19 individualized attentionDeadline.com in order to accommodate their special needs. But 20 Disney expressly trained its Guest Relations employees not to acknowledge 21 any individual special needs and not to provide any individualized 22 accommodations. As the DAS card provides on its cover, no matter what the 23 special need, the “accommodation” is the same. 24 25

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1 35. On March 27, 2014, the United States Centers for Disease Control 2 and Prevention released a report concluding that in 2010, one of every 68 3 American children was identified as autistic, an increase of 30% in two years. 4 Disney, as one of the world’s premier providers of goods and services for 5 children, does not miss such demographics and trends. 6 36. Disney knew the DAS would be universally despised by guests 7 with cognitive disabilities, because the system would not accommodate their 8 special needs. 9 37. The entire DAS is predicated upon the concept that Disney will 10 accommodate Plaintiffs, not by relieving them of the burden of waiting, but by

11 relieving them of the burden of waiting in lines. However, when Plaintiffs 12 have visited the Parks since October 9, 2013, they reported as required by 13 Disney to City Hall or Guest Relations, and was immediately met with an 14 extended wait, in line, just to obtain the DAS card. Disney is too smart to 15 genuinely believe that it reasonably accommodates disabled persons by 16 making them wait in lines as a precondition of being relieved of the burden of DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 waiting in lines. 18 38. Disney knows the DAS makes the wait time of disabled persons 19 even longer thanDeadline.com the notorious wait times which non-disabled persons are 20 already required to endure in the Parks. When the wait time associated with 21 reporting to Guest Relations to complete the stigmatizing procedure of having 22 a photograph taken, a procedure not required of non-disabled persons, is 23 added to the assigned and designated wait time for any particular ride, the 24 disabled person’s wait is, by definition, longer than the non-disabled person’s 25

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1 wait time. If a disabled person waits one hour at Guest Relations to obtain the 2 DAS card, then complies with the DAS and rides one ride which has a one-hour 3 wait time, the disabled person’s wait time is two hours, while the non- 4 disabled person’s wait time is only one hour. If the disabled person rides five 5 rides, each with a one-hour wait time, the disabled person’s wait time is 12 6 minutes longer per ride than the non-disabled person’s wait time. 7 39. Disney’s Disability Access Service systematically builds in still 8 another mechanism for ensuring that disabled persons spend more time 9 waiting than non-disabled persons, and that they do so in lines. Under 10 Disney’s prior Guest Assistance Card program, the guest obtained a card

11 which was effective for the succeeding 14 days with no further administration 12 or hassle. But under the new DAS, anything resembling an accommodation 13 beyond the baseline DAS, such as a single Fastpass, is a “one-time only” 14 accommodation. And it is not an accommodation associated with a guest’s 15 disability; it is one provided only to quiet those who push back against Disney 16 in the inevitably futile effort to make Disney’s employees, who have been DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 trained not to listen, understand that the DAS does not accommodate persons 18 with cognitive impairments. For this reason, the disabled guest must report 19 to Guest RelationsDeadline.com every day upon entry into one of the Parks. The disabled 20 guest must then repeat the first day’s one-hour wait in the Guest Relations 21 line, all for the privilege of repeating the prior day’s complaints in vain, hoping 22 that someone will listen or that someone will provide something in addition to 23 the DAS which, standing alone, is nothing. There can be no good faith reason 24 25

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1 for Disney to require families in which someone has a developmental disorder 2 or cognitive impairment to begin their day in such an unpleasant fashion. 3 40. Disney’s insistence upon requiring persons with autism and other 4 developmental disorders to endure extended wait times, and wait times 5 which non-disabled patrons need not endure such as time waiting at Guest 6 Relations, creates still another adverse discriminatory impact. Typically, the 7 total time an autistic person stays at one of the Parks is shorter than other 8 guests, because the disabled guest lacks the capacity or stamina to stay an 9 entire day. It is common for the disabled guest to remain in one of the Parks 10 for only 3 hours or so. Disney is not insuring that the majority of that time be

11 spent doing nothing, except stimming and melting down. 12 41. Disney is now keeping a “Magic File” on its guests who obtain a 13 DAS and on those for whom Disney has arbitrarily provided its “one-time 14 only” accommodations. When any family has the audacity to mention again an 15 accommodation previously provided, such as a single Fastpass in addition to 16 the DAS, Disney’s Guest Services personnel disappear into a back room to DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 consult a manager, after which they re-appear to advise that the “file” 18 indicates the guest has been once provided an “accommodation”, and that 19 providing the sameDeadline.com accommodation again would be unthinkable. 20 42. Disney’s effort to use scattered “kiosks” to give out ride times 21 does not ameliorate this problem. Apparently Disney proposes, in lieu of 22 walking all the way to an attraction simply to get an appointment for later, the 23 guest can walk all the way to a central kiosk to get an appointment for later. 24 That is, Disney suggests that walking to a central kiosk to experience nothing 25

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1 is a solution to walking to an attraction to experience rejection. The kiosk 2 arrangement was apparently created to permit guests using Disney’s Fastpass 3 and Fastpass Plus systems to identify rides and attractions for which they can 4 make appointments, or to permit such guests to impulsively change plans and 5 visit different attractions based upon the then-current wait times or seating 6 availability. This arrangement is no accommodation for guests who are 7 incapable of making and changing spur-of-the-moment plans. This 8 arrangement achieves only: 9 a. More total walking, back-and-forth to kiosks to schedule 10 appointments.

11 b. More total wait time, because: 12 i. Lines exist at the kiosks; 13 ii. Even if Disney gives the guest an appointment time 14 which is 10 minutes less than a current ride wait time, this is simply Disney’s 15 effort to robotically ensure that disabled persons wait as long as everyone 16 else, including the time they spend going back-and-forth to the kiosks, which DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disney apparently believes takes about 10 minutes each time; and 18 iii. A line exists when the guest returns to the ride, 19 making the totalDeadline.com wait time longer for the disabled guest than the non-disabled 20 guest. 21 c. Less convenience than is necessary for a non-disabled guest, 22 because the disabled guest, who started their day in line at City Hall or Guest 23 Relations, now must travel repeatedly to designated kiosks to obtain ride 24 return times, wait in the line at each kiosk, wait for each return time, and then 25

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1 wait at each attraction at the assigned time. If Disney’s new DAS is intended 2 to eliminate line times for disabled persons while making certain their total 3 wait times are the same as everyone else’s, and if the DAS is intended to work 4 in tandem with the kiosks, the kiosks achieve the opposite. They simply 5 ensure disabled persons must wait in three lines instead of one, and that their 6 total wait time is longer than everyone else’s. 7 d. Less routine and predictability of experience, because: 8 i. A guest cannot know what to expect about the 9 availability of a ride until arriving at the kiosk, just as is the case when 10 arriving at a ride, and the cognitively-impaired guest has less flexibility to

11 simply change plans at the kiosk; 12 ii. A routine circuit through the Parks becomes 13 impossible, when one must go back-and-forth to the kiosks in between 14 attractions; 15 iii. Disney moves the kiosks, and occasionally even 16 changes their number, as it did when Disney reduced the kiosks in Disney’s DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 California Adventure from four to three; and 18 iv. The employees at the kiosks are not willing or trained 19 to listen to guests’Deadline.com explanations of their individualized, special needs. 20 4) The Disability Access Card: A Contrived Solution to a Non- 21 Existent Problem 22 62. On May 14, 2013, public news and media outlets reported that 23 Disney was suffering from a problem of systemic “abuse” of its GAC-based 24 disability access system. Reportedly, Disney was issuing GACs to persons who 25

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1 routinely invited others to be their companions for a fee and who advertised 2 or provided independent theme park tour guide services. An independent 3 tour guide who held a GAC could provide a materially better tour than one of 4 Disney’s own internal tour guides, or a substantially similar tour for much less 5 than Disney’s customary price of $350-$500 per hour with a six-hour 6 minimum. 7 63. When the news reports surfaced, Disney was already engaged in a 8 an extensive effort to design a replacement system for the GAC, to address the 9 competition being provided by GAC-carrying independent tour guides. 10 64. The news reports provided Disney with great cover for the

11 unveiling of the discriminatory DAS, in that Disney benefited from the public 12 perception that “abuse” of its system existed, and that the problem was one of 13 epidemic proportion, with Disney as its victim. 14 65. One facet of the DAS is that guests with mobility challenges are 15 removed entirely from the DAS system. Disney now refuses to even 16 acknowledge that persons in wheelchairs have a disability. Guests with DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 wheelchairs are now told that the queues are fully accessible for them so they 18 may wait in lines with the non-disabled persons. Even if the so-called “abuse” 19 problem ever reallyDeadline.com existed, once Disney removed mobility-challenged guests 20 from the DAS, the problem was solved. The systemic abuse about which 21 Disney purportedly became suddenly frantic in 2013 could never be carried 22 out by or with persons with developmental disorders or cognitive 23 impairments. If there was a problem with non-disabled guests “renting” 24 persons in wheelchairs for a day, the problem could not occur with persons 25

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1 like Plaintiffs. No fake companion would “rent” an autistic guest for a day in 2 the Parks, because the eccentricities of the disabled person’s visit to the Parks 3 would render the day completely unpleasant for a paying companion. Autistic 4 persons are mentally and physically incapable of browsing or wandering 5 randomly in search of an attraction that might be inviting. Many must follow 6 the same pattern through the Parks, every time, riding the same rides, in the 7 same order, every time. Others – “repeat riders” - must ride the same ride, 8 over and over, for several hours at a time. They do not stop for casual dining, 9 or to rest, or for shopping or picture-taking. They cannot honor the schedule 10 or priorities of their companions. Their day does not resemble a day anyone

11 who would “rent” them might want. By completely eliminating persons with 12 mobility challenges from the DAS and making those disabled persons wait in 13 queues, Disney eliminated the epidemic it wants the public to believe existed. 14 There was no longer a reason to roll out the DAS at all. 15 66. Disney’s cited justification for abandoning Plaintiff’s right of equal 16 access to Disney’s facilities: “[The GAC] had been abused and exploited to DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 such an extent that we were no longer able to sustain the program” is simply 18 meritless. The so-called problem of widespread abuse of Disney’s 19 accommodationsDeadline.com never existed, and never could have existed, in connection 20 with Plaintiffs. 21 67. The DAS provides no meaningful advantage to anyone, disabled or 22 otherwise. As a result, there exists no incentive to lie to obtain it, or to 23 advertise that a superior tour of the Disney Parks is available through a 24 disabled tour guide who can obtain a DAS. Disney sought to eradicate the 25

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1 competition presented by disabled independent tour guides, and sacrificed its 2 autistic guests to achieve this end. 3 5) The Electronic DAS 4 68. Disney unveiled an electronic version of the DAS at its Disneyland 5 Parks in late 2014, and at its Walt Disney World Parks in early 2015. Instead 6 of a paper DAS card filled in by hand by Disney employees at kiosks scattered 7 around the Parks, the electronic DAS is paperless and linked to each guest’s 8 park ticket or annual pass. Disney employees at the kiosks assign entry times 9 to the park tickets which are linked to the ticket or to the annual pass of the 10 disabled guest to whom a DAS is issued.

11 69. Disney employees at each ride scan the guest’s park ticket and 12 confirm on their “tablet” that those guests are allowed to enter at that time. In 13 the process of doing so, Disney employees are given access to that guests 14 “Magic File,” which possesses all information about that guest that Disney 15 chooses to include in that guest’s file. Until the guest scans his or her ticket or 16 annual pass at the assigned ride, the guest cannot return to a kiosk to receive DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 another DAS return time. 18 70. This electronic DAS now requires each disabled guest issued a 19 DAS to declare inDeadline.com advance every guest in their party; each guest will then have 20 their ticket or annual pass electronically linked by Guest Relations to the 21 disabled guest’s ticket. Each park ticket or annual pass will only be allowed to 22 be linked to one DAS ticket holder at a time. 23 71. The electronic DAS singles out disabled guests even further than 24 non-disabled guests, and places additional requirements and burdens on their 25

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1 visit to the Parks which exist only by nature of their status as a disabled guest. 2 The electronic DAS also raises significant privacy concerns, especially 3 surrounding sensitive and protected health information. 4 6) DAS Disinformation: Disney Sponsors Outrageous and 5 Insulting Videos on the Web for Its own Spin Control Benefit 6 72. Public blogs and social networking websites are a very common 7 form of communication within the autistic community. Since October of 2013, 8 those sites have consistently shown how widely and acutely despised Disney’s 9 new form of “accommodation” is. 10 73. Fearing for its own reputation within the highly profitable non-

11 disabled community, Disney caused well-scripted messages to be posted on 12 such websites, without acknowledging Disney’s sponsorship. 13 74. Disney has sponsored, without attribution or acknowledgement, 14 videos on the internet which are inexplicably contrary to all known science 15 and evidence about cognitive impairments. There can be no good faith reason 16 for sponsoring false messages. These videos are designed to induce the non- DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 disabled community to believe that Disney is really trying to accommodate 18 persons with cognitive impairments. For viewers within the disabled 19 community, the Deadline.comvideos are even worse because they blame the autistic person 20 for their own failures to appreciate Disney’s Parks. They go so far as to 21 propose that the reason an autistic person cannot tolerate a ridiculous wait or 22 queue time is their own lack of effort or control; Disney asserts that persons 23 with developmental disorders they can self-teach the calm and deliberative 24 handling of such environments, and proposes that if such persons were to 25

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1 simply try harder, they would see that one-hour waits are quite easy to bear. 2 In October 2013 a video appeared advising parents of children with 3 developmental disorders to have their child practice waiting before visiting 4 the park. Disney knew disabled Plaintiffs are incapable of idly waiting for long 5 periods without melting down yet treated the harm caused by waiting as if it 6 were a skill which could be acquired with repetition. 7 75. Disney knows that viewers of these messages who are part of the 8 disabled community or who have any true understanding of cognitive 9 impairments will be insulted and disgusted, because Disney is too smart to be 10 delivering such inane messages in good faith, just as Disney is too smart to

11 genuinely believe autistic persons can go all the way to a ride and calmly and 12 peaceably accept an instruction to come back later. Disney also knows that it 13 is very common for disabled persons to visit the Parks with only one parent 14 companion – this is particularly common for autistic children who live in the 15 vicinity of the Parks and visit more frequently using annual or extended 16 passes. A single parent accompanying an autistic child cannot leave the child DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 alone or with another person; there is no choice but to take the child all the 18 way to the ride only to have the child learn that he or she is prohibited from 19 riding it. More aptly,Deadline.com the child will be told he or she is prohibited from riding 20 the ride “at this time,” but the temporal portion of the prohibition is too 21 complicated for the child to understand. 22 76. Illicitly-supported videos are not designed to actually aid persons 23 with cognitive impairments or their caretakers. Disney is too knowledgeable 24 to propose that an instructional video could ever meaningfully teach or 25

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1 encourage persons with cognitive impairments to “practice waiting in line,” or 2 to “browse in the stores” during the wait time, or to similarly kill time by using 3 the restroom or having a snack. 4 77. These messages, posts and videos are not designed for their 5 stated audience, which Disney knows will know better. They are designed 6 only to cover Disney’s reputation in the non-disabled community, in case any 7 of the disabled community’s widespread despair about the DAS system should 8 spill over to the non-disabled community. 9 7) Feigned Accommodation: Inconsistently Doling Out 10 Occasional Ride Passes to Quiet Complaining Guests

11 78. Upon creating and implementing a system that was destined to 12 create horrible experiences for persons with cognitive impairments, with the 13 result of deterring persons with cognitive impairments from visiting the 14 Parks, Disney further trained its Guest Relations employees that these guests 15 were likely to complain about their experiences and about the new system’s 16 total failure to accommodate their special needs. The employees were DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 instructed to tolerate whatever resistance they could, and when absolutely 18 unavoidable, the employees could consult with a supervisor, and upon 19 receiving approval,Deadline.com give up to three no-appointment ride entry passes to the 20 guest. Even during the first few months of the system, the Guest Relations 21 employees arbitrarily and capriciously extended these passes to Plaintiffs. 22 Occasionally the employees granted three passes; sometimes two. Other 23 times the employees advised that they could provide no passes at all and 24 could only provide the DAS card and nothing more, because Disney policy 25

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1 firmly prohibits any accommodation beyond that afforded by the DAS card. 2 Even when two or three passes were extended, some families of disabled 3 guests were advised that Disney policy firmly provides that no further passes 4 could or would be made available that day. Others were advised that more 5 passes might be made available that day, but only if the guest were to return 6 to Guest Relations to obtain them, which the employees know is unworkable 7 because returning to Guest Relations would be contrary to the disabled 8 guests’ special needs. Some disabled guests were even told at one Disney Park 9 that additional passes were available in addition to the DAS card, while being 10 told on the next day, at a different park during the same visit to the Walt

11 Disney World resort, that Disney’s new DAS policy strictly prohibits the 12 granting of such passes. 13 79. Disney’s new policy of inconsistently, arbitrarily and capriciously 14 granting additional passes only when a guest loudly complains, creates 15 complete unpredictability for families in which someone has a developmental 16 disorder or cognitive impairment. Disney knows this arbitrariness will DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 further deter families in which someone has a developmental disability or 18 cognitive impairment from visiting the Parks. If the families cannot rely upon 19 Disney and itsDeadline.com employees to graciously, caringly and empathetically 20 accommodate disabled persons’ special needs as Disney always previously 21 did, the families will not risk the disabled person’s calmness and stability by 22 visiting the Parks. Guests living more than a day-trip away will not risk the 23 investment of an extended vacation. 24 25

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1 80. Disney’s arbitrariness is also destined to deter further visits to the 2 Parks because Plaintiffs and similarly-situated guests simply do not welcome 3 the notion of having to start each day in the Parks by reporting to Guest 4 Relations and becoming a complainer, with the hope of obtaining a marginally 5 meaningful gesture such as random Fastpasses. Starting the day so 6 unpleasantly is the antithesis of any person’s anticipated day in one of the 7 Parks. 8 81. Families in which someone has a cognitive impairment are well- 9 connected in web groups and social networking communities. Some of those 10 discussion outlets are Disney-specific and are monitored by Disney, either

11 openly or secretly. Disney expected the word to quickly get out within those 12 virtual communities that Disney no longer meaningfully accommodates 13 persons with cognitive impairments. 14 82. Disney can of course readily modify the DAS or roll out alternate 15 procedures which would accommodate Plaintiffs’ needs, with no alteration in 16 Disney’s way of doing business. The best indicators of this simple feasibility DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 include: 18 a. Even before the Americans with Disabilities Act existed – 19 even before DisneyDeadline.com had an express statutory obligation to accommodate 20 disabled persons – Disney accommodated disabled persons, admirably. 21 b. When the Americans with Disabilities Act was passed and 22 for more than 20 years thereafter, Disney admirably accommodated the needs 23 of guests with developmental disorders and cognitive impairments. 24 25

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1 c. Even after conjuring up the DAS, Disney created a Magic File 2 concept. Disney refuses to publicize its Magic File, lest it actually become 3 widely known within the disability community. 4 d. At about the same time that Disney rolled out the DAS, or 5 shortly thereafter, Disney started a test release of its Magic Band product, 6 which enables rides to be scheduled by appointment. The band could easily 7 be programmed to allow the disabled wearer reasonably prompt access to all 8 rides, or to specific rides. Disney refuses to make Magic Bands available for 9 such purpose. 10 8) A Secret Accommodation, Unknown to Disabled Guests, is No

11 Accommodation at All 12 83. After an initial period of systemically-designed unpredictability, 13 followed by the total predictability of no accommodation at all beyond 14 Disney’s impossible one-accommodation-fits-all DAS, Disney began 15 inconsistently, arbitrarily and capriciously doling out still another occasional 16 accommodation, internally known as the “Magic File.” The Magic File is a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 secret list of persons to whom Disney will automatically extend, without the 18 stigma of a “Disability” card, and without a mandatory photograph, and 19 without the newlyDeadline.com-ingrained disrespect shown by Disney employees, 20 numerous no-appointment ride entry passes. 21 84. The Magic File does not perfectly accommodate the special needs 22 of all persons with cognitive impairments, but it is considerably better than 23 the recklessly inadequate DAS card. 24 25

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1 85. Disney is withholding the existence of the “Magic File” from the 2 broader community of families in which someone has a cognitive impairment. 3 By doing so, Disney continues to deter families from visiting the Parks or 4 making plans to do so. Families of persons with developmental disabilities or 5 cognitive impairments remain unwilling to return to the Parks, in fear that the 6 disabled person will experience otherwise avoidable meltdowns and 7 otherwise be subjected to discrimination, apathy, and humiliation in the 8 Parks. If the accommodation to be provided to persons in the Magic File were 9 refined, and if the Magic File were made known to disabled persons and their 10 families to allow them to predict their likely experience prior to incurring the

11 risk and investment of traveling to the Parks, this deterrence would be 12 substantially reduced or eliminated. 13 9) Disney has Demonstrated Callous Disregard for the Rights of 14 Plaintiffs, Each of Whom has a Developmental Disorder 15 86. Disney possesses sophisticated knowledge of the special needs of 16 persons with cognitive impairments. Disney did not accidentally roll out a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 system which is so distinctly inconsistent with the special needs of such 18 persons. Disney did so intentionally or recklessly, to cleanse its Parks of what 19 Disney views asDeadline.com the anti-Magic of such persons’ stimming, tics, and 20 meltdowns, or to rid Disney of the pesky threat of competition from disabled 21 persons offering tour guide services and subsequently intentionally or 22 recklessly accepted the damage to Plaintiffs as a collateral benefit to Disney. 23 87. In connection with the planning and implementation of the DAS, 24 Disney: 25

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1 • Spent years designing a system which is wholly inconsistent 2 with Disney’s own sophisticated knowledge base about persons with cognitive 3 impairments; 4 • Fostered the dissemination of false information about a 5 problem which never existed to any meaningful extent, and which never 6 existed to any extent for persons with cognitive impairments, to gain cover for 7 its planned unveiling of a harshly discriminatory program; 8 • Implemented a new accommodations system which wholly 9 eliminated accommodations for guests with mobility impairments, thus 10 erasing the problem which Disney had contrived as cover; there remained no

11 epidemic for Disney to “cure” by creating a new accommodations program for 12 persons with cognitive impairments, who were never part of the now- 13 eliminated problem; 14 • Unleashed the DAS system, to the entirely predictable 15 dismay of the community of families which include persons with cognitive 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI impairments; 17 • Caused or allowed families in which a person has a 18 cognitive impairment to suffer horribly unpleasant visits to Disney’s Parks for 19 several months, Deadline.comwith knowledge that such experiences would become widely 20 known and would deter other such families from bringing their visible “non- 21 Magic” into the Parks in the future; 22 • Trained its employees to adopt positions toward guests 23 with cognitive impairments which involve offering feigned accommodations 24 which were destined to be soundly rejected, predictably creating a newly 25

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1 disrespectful and unkind attitude not previously exhibited by Disney’s 2 employees; 3 • Inconsistently, arbitrarily and capriciously provided “one- 4 time only” additional gestures only to families who complained loud enough, 5 and even then only to an extent which was not genuinely designed to 6 accommodate the guests’ special needs. The principal purpose for these 7 arbitrary “one-time only” gestures was simply to give Disney’s employees 8 something to ameliorate their own unkind treatment of disabled persons, and 9 to allow the employees to quiet the loudest complainers; 10 • Kept a secret “Magic File” of persons Disney is willing to

11 accommodate, without disseminating information about the existence of the 12 file, and without advising the public as to the criteria which are being used by 13 Disney to exclude many disabled persons from the Magic File while making it 14 available to others; 15 • Made plans to officially roll out a new technology which 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI could be used to accommodate Plaintiff’s special needs only after Plaintiff and 17 others like him have been deterred from visiting the Parks; 18 • Systemically refuses to communicate with guests about 19 their accessibilityDeadline.com needs, to avoid addressing any possible modifications to 20 Disney’s plans and procedures which might accommodate such needs. 21 88. Disney maliciously caused injury to Plaintiffs, discriminating 22 against them in the short term with the expectation or known consequence of 23 deterring them and other similarly-situated persons from visiting the Disney 24 Parks in the long term. 25

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1 89. Disney cruelly and oppressively subjected Plaintiffs to 2 discrimination for no defensible, honorable purpose. 3 90. Disney fraudulently disseminated or encouraged the 4 dissemination of false information, for the purpose of creating cover to 5 prevent discovery or public discussion of its scheme. 6 IV. ATTORNEYS FEES AND LITIGATION EXPENSES 7 91. As a result of Disney’s callous discrimination and violations of the 8 Unruh Civil Rights Act, Plaintiffs have been required to retain the services of 9 undersigned counsel. Plaintiffs have agreed to pay undersigned counsel a 10 reasonable attorneys’ fee and have agreed to reimburse the attorneys’

11 reasonably-incurred litigation expenses. Plaintiffs are entitled to recover 12 their reasonable attorneys’ fees and costs in filing and prosecuting this action, 13 pursuant to §52(a) of the California Civil Code. 14 V. CAUSES OF ACTION 15 COUNT 1 16 Negligent Infliction of Emotional Distress DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 T.P. v. Disney 18 92. Plaintiff T.P. incorporates and re-alleges paragraphs 1 through 90 19 above. Deadline.com 20 93. T.P. has been diagnosed with autism, severe obsessive compulsive 21 disorder (OCD), attention deficit hyperactivity disorder (ADHD), and is subject 22 to anxiety attacks. He becomes particularly anxious when forced to idly wait 23 for more than a few minutes. Additionally, T.P.’s verbal skills are not well- 24 25

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1 developed. Behavioral meltdowns for T.P. consist generally of aggressive 2 behavior directed towards his mother, which may include pulling at her hair. 3 94. T.P. is a person with a disability, as that term is defined in 42 4 U.S.C. §12102(1). 5 95. T.P. is 13 years old and is generally in the care of his mother, S.P. 6 who brings this action as T.P.'s next friend, parent and natural guardian. 7 96. T.P. and S.P. are residents of the City of Norwalk in Los Angeles 8 County, California. 9 97. T.P. loves Disney unconditionally. It is his only true social skill, 10 and the only thing T.P. wants to discuss with others. T.P. will talk at length

11 about anything Disney, including his favorite attractions, the Parks, the 12 movies, the characters, and most importantly, his next visit and what he is 13 going to do while he is there. 14 98. Indeed, for much of his childhood T.P. has visited Disneyland with 15 his brother and S.P. T.P. carried the Guest Assistance Card, and he was 16 admirably accommodated. During those visits, T.P. exhibited a nature and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 extent of joy that he rarely showed in any other setting. S.P. was always proud 18 and joyful of the opportunity to bring to her beloved child a level of happiness 19 which he rarely showedDeadline.com elsewhere. 20 99. In July 2013 T.P. and S.P. obtained season passes for Disneyland. 21 T.P. and S.P. visited the Disney parks six to eight times between July 2013 and 22 October 2013. T.P. only experienced one behavioral meltdown during his 23 visits to Disneyland prior to October 2013. 24 25

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1 100. Since T.P. was a toddler, his cognitive impairments have 2 manifested themselves in a certain way during the family’s visits to the Parks. 3 T.P. must experience the park in a specific order, so that disruptions in his 4 planned routine will tend to escalate his stimming behaviors toward 5 meltdowns. T.P. has a strict schedule in his head of the Disneyland rides he 6 must ride, and the order in which he must ride them. Deviation from that 7 order will likely lead to a meltdown. For example, T.P.'s favorite Disneyland 8 attraction is It’s a Small World. If T.P. were to visit Disneyland and visit It’s a 9 Small World immediately upon arriving, and not be afforded the opportunity 10 to ride that ride at that time, he would likely experience a meltdown.

11 101. Similarly, if T.P. were required to idly wait for entry into a ride or 12 attraction for more than a few minutes he also would likely melt down. 13 During the wait, his behaviors – anxiety, aggression toward his mother, 14 echolalia (the repetition of certain phrases over and over again) would 15 escalate in frequency or severity. If he is not removed from the condition, a 16 meltdown will occur. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 102. Because T.P. is incapable of understanding the concept of visiting 18 a ride or attraction only to be prohibited from riding it until a future time, the 19 new DAS createsDeadline.com avoidable stressors for T.P., escalating his stimming patterns 20 toward meltdowns, in high traffic areas of the park. Since Disney’s 21 implementation of the new DAS, T.P. has experienced several meltdowns at 22 Disneyland. Two of these meltdowns were so bad S.P. had to remove T.P. 23 from the park due to the potential of T.P. hurting himself, S.P., and others. 24 25

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1 103. Due to its failure to accommodate which leads to an increased 2 propensity for T.P. experiencing a meltdown, Defendant has prevented T.P. 3 from experiencing the full enjoyment of its Parks, equal to the experiences of 4 persons without a disability. 5 104. Shortly after S.P.’s and T.P.’s October 20, 2013 visit to Disneyland, 6 S.P. wrote an email to Disney explaining the hardship the newly implemented 7 DAS causes her and T.P. Disney refused or failed to reasonably modify the 8 policy for the needs of T.P. and others like him. S.P. has contacted Disney 9 Guest Relations and certain Disney employees, including Mark Jones, 10 expressing her frustration and need for an individual accommodation. Their

11 only response was to reiterate the need to “try it out,” without mention that 12 accommodation would actually be made, and the suggestion that she begin the 13 process to cancel their annual passes. 14 105. After October 9, 2013, T.P. no longer received the type of 15 accommodation and attention T.P. and S.P. had received when they visited the 16 Parks in the past. Specifically, since October 9, 2013, T.P. and S.P. have been to DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 the Disneyland Parks, including Disneyland in Anaheim, six times, most 18 recently on February 17, 2014. The DAS has specifically adversely impacted 19 T.P. because additionalDeadline.com time must be expended in line at the start of each visit 20 to obtain the DAS. 21 106. As a result of Disney’s failure to modify its procedures to 22 reasonably accommodate T.P.’s needs, T.P. and S.P. have been discouraged and 23 deterred from the full use and enjoyment of the park's rides and attractions. 24 S.P. would visit the Parks with T.P. more often had Disney not abandoned its 25

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1 past policy of accommodating the special needs of persons with cognitive 2 impairments. Their interest in attending the Parks is substantially reduced. 3 S.P. knows they should avoid attending the parks in the future due to the 4 expectation that the experience will again be an un-magical and un- 5 accommodating one, and especially due to the risk that the experience will be 6 destructive for T.P. 7 107. Notwithstanding Disney’s highly sophisticated knowledge of the 8 needs of persons with cognitive impairments, and notwithstanding Disney’s 9 historic ability to accommodate T.P.’s special needs, Disney personnel have 10 failed to conduct an individualized assessment of T.P.'s capacity to utilize the

11 DAS, and to modify the DAS to allow T.P. to enjoy the same benefits and 12 privileges as non-disabled patrons. 13 108. Disney personnel have shown no willingness or desire to improve 14 the experience for guests like T.P. 15 109. S.P. incurred monetary costs in purchasing annual pass tickets to 16 the Parks, in addition to annual parking passes and other expenses which DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 were wasted during the family’s wasted trips to the Parks. 18 110. T.P. and S.P. have already visited the Parks considerably less 19 frequently than Deadline.comthey intended when they purchased the annual passes, a 20 situation which continues to this day. Their interest in attending Disney Parks 21 is substantially diminished. 22 111. During one or more visits to the Parks, T.P. suffered an actual 23 meltdown. 24 25

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1 112. The symptoms and conditions associated with T.P.’s meltdown 2 constitute a physical injury under California law. 3 113. T.P.’s meltdown in the Parks was proximately caused by Disney’s 4 negligent, unlawful, reckless and arbitrary treatment of T.P. during his 5 patronage of Disney’s facilities. At all material times, Disney knew T.P. to be 6 vulnerable to emotional injury if treated in such a manner by anyone. 7 114. T.P.’s meltdown and the treatment which proximately caused T.P. 8 to experience the meltdown caused him grave and extreme mental anguish 9 and emotional trauma, for which Disney should be held accountable. 10 WHEREFORE, Plaintiff T.P. by and through S.P., as T.P.'s next friend,

11 parent and natural guardian, prays that this Court adjudicate this dispute 12 and enter an Order: 13 • Enjoining Defendant to cease the practices which are causing 14 discrimination against Plaintiff on account of T.P.’s disability; and 15 • Enjoining Defendant to reasonably modify its policies, practices, 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI and procedures to afford Plaintiff with an opportunity to 17 experience Disney’s goods, services, facilities, privileges, 18 advantages, and accommodations; and 19 • EstablishingDeadline.com Court-approved remedial measures that Disney must 20 implement, to prevent Disney from further discriminating against 21 Plaintiff when they visit the Disney Parks; and 22 • Establishing Court-approved requirements for information 23 dissemination about Disney’s remedial measures and modified 24 25

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1 policies, to prevent Disney from further deterring Plaintiff from 2 visiting Disney Parks as a result of anticipated discrimination; and 3 • Establishing a monitoring program to ensure Disney’s compliance 4 with the Court’s Orders; and 5 • Finding that Disney negligently inflicted emotional distress upon 6 T.P.; and 7 • Finding such infliction to have caused damages to T.P.; and 8 • Entering judgment for Plaintiff T.P. in the amount of such 9 damages; and 10 • Awarding reasonable attorney’s fees as may be determined by the

11 Court in favor of Plaintiff and against Disney; and 12 • Awarding reasonable litigation costs as may be determined by the 13 Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 2 17 18 Intentional Infliction of Emotional Distress 19 Deadline.comT.P. v. Disney 20 115. Plaintiff T.P. incorporates and re-alleges the allegations of 21 paragraphs 1 through 90, and 93 through 114 above. 22 116. During one or more visits to the Parks, T.P. suffered an actual 23 meltdown. 24 117. The symptoms and conditions associated with T.P.’s meltdown 25 constitute a physical injury under California law.

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1 118. T.P.’s meltdown in the Parks was proximately caused by Disney’s 2 outrageous, unlawful and reckless treatment of T.P. during his patronage of 3 Disney’s facilities. At all material times, Disney knew T.P. to be vulnerable to 4 emotional injury if treated in such a manner by anyone. 5 119. T.P.’s meltdown and the treatment which proximately caused T.P. 6 to experience the meltdown caused him grave and extreme mental anguish 7 and emotional trauma, for which Disney should be held accountable. 8 WHEREFORE, Plaintiff T.P., by and through S.P. as T.P.’s next friend, 9 parent and natural guardian, prays that this Court adjudicate this dispute 10 and enter an Order:

11 • Finding that Disney intentionally inflicted emotional distress 12 upon T.P.; and 13 • Finding such infliction to have caused damages to T.P.; and 14 • Entering judgment for Plaintiff T.P. in the amount of such 15 damages; 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment in favor of Plaintiffs and against Disney for 17 exemplary or punitive damages; and 18 • Awarding reasonable litigation costs as may be determined by 19 the CourtDeadline.com in favor of Plaintiff and against Disney; and 20 • Awarding prejudgment interest; and 21 • Such other relief as this Court may find just and equitable. 22 COUNT 3 23 Negligent Infliction of Emotional Distress 24 S.P. v. Disney 25

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1 120. Plaintiff S.P. incorporates and re-alleges the allegations of 2 paragraphs 1 through 90, and 93 through 114 above. 3 121. During one or more visits to the Parks, S.P.’s beloved son T.P. 4 suffered an actual meltdown while in S.P.’s presence. 5 122. The symptoms and conditions associated with T.P.’s meltdown 6 constitute a physical injury to T.P. under California law. 7 123. T.P.’s meltdown in the Parks was proximately caused by Disney’s 8 negligent, unlawful, reckless and arbitrary treatment of T.P. during his 9 patronage of Disney’s facilities. At all material times, Disney knew T.P. to be 10 vulnerable to emotional injury if treated in such a manner by anyone.

11 124. S.P. directly observed the stressors leading up to the meltdown, 12 T.P.’s resulting escalation and his meltdown. Particularly in light of her trust 13 and confidence that Disney would comply with applicable law and act in a 14 gracious and caring manner toward her son, S.P. could do nothing reasonable 15 to prevent the meltdown. 16 125. S.P.’s observation of T.P.’s meltdown and of the outrageous

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 conduct and treatment which proximately caused T.P. to experience the 18 meltdown caused S.P. grave and extreme mental anguish and emotional 19 trauma, for whichDeadline.com Disney should be held accountable. 20 WHEREFORE, Plaintiff S.P. prays that this Court adjudicate this 21 dispute and enter an Order: 22 • Finding that Disney negligently inflicted emotional distress 23 upon S.P.; and 24 • Finding such infliction to have caused damages to S.P.; and 25

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1 • Entering judgment for Plaintiff S.P. in the amount of such 2 damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 4 8 Intentional Infliction of Emotional Distress 9 S.P. v. Disney 10 126. Plaintiff S.P. incorporates and re-alleges the allegations of

11 paragraphs 1 through 90, and 93 through 114 above. 12 127. During one or more visits to the Parks, S.P.’s beloved son T.P. 13 suffered an actual meltdown. 14 128. The symptoms and conditions associated with T.P.’s meltdown 15 constitute a physical injury under California law. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 129. T.P.’s meltdown in the Parks was proximately caused by Disney’s 17 outrageous, unlawful and reckless treatment of T.P. during his patronage of 18 Disney’s facilities. At all material times, Disney knew T.P. to be vulnerable to 19 emotional injuryDeadline.com if treated in such a manner by anyone. 20 130. S.P. directly observed the stressors leading up to the meltdown, 21 T.P.’s resulting escalation and his meltdown. Particularly in light of her trust 22 and confidence that Disney would comply with applicable law and act in a 23 gracious and caring manner toward her son, S.P. could do nothing reasonable 24 to prevent the meltdown. 25

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1 131. S.P.’s observation of T.P.’s meltdown and of the outrageous 2 conduct and treatment which proximately caused T.P. to experience the 3 meltdown caused S.P. grave and extreme mental anguish and emotional 4 trauma, for which Disney should be held accountable. 5 WHEREFORE, Plaintiff S.P. prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney intentionally inflicted emotional distress 8 upon S.P.; and 9 • Finding such infliction to have caused damages to S.P.; and 10 • Entering judgment for Plaintiff S.P. in the amount of such 11 damages; 12 • Entering judgment in favor of Plaintiffs and against Disney for 13 exemplary or punitive damages; and 14 • Awarding reasonable litigation costs as may be determined by 15 the Court in favor of Plaintiff and against Disney; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Awarding prejudgment interest; and 17 • Such other relief as this Court may find just and equitable. 18 COUNT 5 19 Deadline.comBreach of Contract 20 S.P. v. Disney 21 132. Plaintiff S.P. incorporates and re-alleges the allegations of 22 paragraphs 1 through 90, and 93 through 114 above. 23 133. S.P., through S.P.’s acquisition of Disney annual passes for T.P. and 24 her family, entered into a contract through which Disney promised to provide 25

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1 a reasonable and enjoyable amusement park experience, and one which 2 complies with applicable law. 3 134. Disney failed or refused to provide the promised experience, and 4 is in breach of contract. 5 135. S.P. incurred monetary costs in purchasing annual passes to the 6 Parks for trips that were entirely wasted, and incurred other expenses during 7 the wasted trips to the Parks. Plaintiff is damaged by Disney’s breach of 8 contract. 9 WHEREFORE, Plaintiff S.P. prays that this Court adjudicate this 10 dispute and enter an Order:

11 • Finding that Disney breached its contract with S.P..; and 12 • Entering judgment for Plaintiff S.P.in the amount of her economic 13 monetary damages; and 14 • Awarding reasonable litigation costs as may be determined by the 15 Court in favor of Plaintiff and against Disney; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Awarding prejudgment interest; and 17 • Such other relief as this Court may find just and equitable. 18 COUNT 6 19 NegligentDeadline.com Infliction of Emotional Distress 20 A.T.W. v. Disney 21 136. Plaintiff A.T.W. incorporates and re-alleges the allegations of 22 paragraphs 1 through 90 above. 23 137. A.T.W. has been diagnosed with severe mental and medical 24 conditions that have placed him on home hospital services, including autism 25

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1 and is subject to anxiety attacks. He becomes particularly anxious when 2 forced to idly wait for more than five minutes. Additionally, A.T.W.’s verbal 3 skills are not well-developed; he is uncommunicative and non-verbal. 4 Behavioral meltdowns for A.T.W. consist generally of aggressive behavior 5 directed toward his father, mother, and sister which may include scratching 6 and biting. 7 138. Autism substantially limits a person’s ability to care for himself, 8 perform manual tasks, speak, learn, read, concentrate, think, communicate, 9 perceive the concept of time, pair sights and sounds that happen 10 simultaneously, and work.

11 139. A.T.W. is a person with a disability, as that term is defined in 42 12 U.S.C. §12102(1). 13 140. A.T.W. is 17 years old and is generally in the care of his mother, 14 T.W.R., who brings this action as A.T.W.'s next friend, parent and natural 15 guardian, and his step-father, R.C.R. 16 141. A.T.W. and T.W.R. are residents of Los Angeles County, California.

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 142. A.T.W. first attended Disneyland in 2005 when he was seven years 18 old. From that time forward, T.W.R., R.C.R., and A.T.W. regularly attended the 19 Disney Parks withDeadline.com his sister, T.L.R., going 2-3 times per week. 20 143. Indeed, for much of his childhood A.T.W. has visited Disneyland 21 with T.W.R., R.C.R., and his sister, T.L.R. A.T.W. carried the Guest Assistance 22 Card, and he was admirably accommodated. During those visits, A.T.W. 23 exhibited a nature and extent of joy that he rarely showed in any other setting. 24 Disneyland was a place where R.C.R., T.W.R., T.L.R., and A.T.W. could unwind 25

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1 after school and bond together, as a family with two children diagnosed with 2 cognitive disabilities. T.W.R. was always proud and joyful of the opportunity 3 to bring to her beloved child a level of happiness which he rarely showed 4 elsewhere. A.T.W. could stay for the entire day at the Disney Parks with his 5 family, usually culminating in watching the fireworks before leaving the park 6 for dinner at ESPN Sports Zone or Pizza Port. 7 144. In 2012, A.T.W. was offered and granted a “Green Light Pass” from 8 Disney based on Disney’s reviewing his medical documentation provided by 9 Home Hospital Services. Disneyland claimed that the Green Light Pass was 10 only provided to “Make-A-Wish Foundation” children.

11 145. On October 9, 2013 when the DAS went into effect, Disney then 12 revoked A.T.W.’s Green Light Pass, later stating that it had been replaced by a 13 “Genie Button,” offered through Make-A-Wish. However, Disney advised that 14 his Genie Button is subject to being revoked, because the DAS would be the 15 only accepted “accommodation” for disabled guests such as A.T.W. 16 146. In 2004 A.T.W. and T.W.R. obtained annual passes for Disneyland.

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 A.T.W. and T.W.R. visited Disney Parks 2-3 times per week between 2004 and 18 2014 and A.T.W. rarely experienced any meltdown problems. In early 2014 19 Disney, with noDeadline.com explanation, stopped accepting A.T.W.’s Green Light Pass, 20 advising that the DAS is the only acceptable or permitted policy. 21 147. Since A.T.W. was a toddler, his cognitive impairments have 22 manifested themselves in a certain way during the family’s visits to the Parks. 23 A.T.W. and his sister T.L.R. require repeat experience, which leads them to 24 experience the Parks’ attractions in a specific order, and disruptions in their 25

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1 planned routine will tend to escalate their stimming behaviors toward 2 meltdowns. A.T.W. and T.L.R. begin their experience with a pre-programmed 3 strict schedule in their heads of the Disneyland rides they must ride, and the 4 order in which the rides must be ridden. Deviation from this pre-defined 5 order will likely lead to a meltdown. For example, A.T.W. and T.L.R. have 6 experienced Disneyland in the following order: (1) Matterhorn Bobsleds or 7 Big Thunder Mountain Railroad; (2) Space Mountain; (3) Finding Nemo 8 Submarine Voyage (now closed) or Star Tours – The Adventure Continues; (4) 9 Autopia; and (5) Alice in Wonderland or Mad Tea Party. If A.T.W. were to visit 10 Disneyland, he would first travel to Matterhorn Bobsleds or Big Thunder

11 Mountain Railroad, and, if he were not afforded the opportunity to first 12 experience that particular ride before others, he would likely experience a 13 meltdown. 14 148. A.T.W.’s disorders also cause him to have to experience certain 15 Disney attractions repetitively. A.T.W. is a “repeat rider.” This is a propensity 16 common among autistic persons – a variety of the need for consistency, order DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 and routine. A.T.W. will experience a particular ride or attraction, such as Big 18 Thunder Mountain Railroad or Tower of Terror, over and over, for several 19 hours at a time. Deadline.comDisney personnel are very familiar with the repeat rider type 20 of guest. 21 149. Similarly, if A.T.W. were required to idly wait for entry into a ride 22 or attraction for more than a few minutes he also would likely melt down. 23 150. Because A.T.W. is incapable of understanding the concept of 24 visiting a ride or attraction only to be prohibited from riding it until a future 25

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1 time, the new DAS creates avoidable stressors for A.T.W., escalating his 2 stimming patterns toward meltdowns almost instantaneously. Since Disney’s 3 implementation of the new DAS, A.T.W. has experienced several meltdowns at 4 Disneyland. 5 151. The first day A.T.W. attended the Parks after the DAS came into 6 effect, he attended with R.C.R., T.W.R., and his sister T.L.R., on October 12, 7 2013. Upon arriving, T.W.R. and R.C.R. waited two hours before speaking to an 8 employee at Guest Relations. During this ludicrously long wait, A.T.W. began 9 to have his first meltdown. R.C.R. and T.W.R explained A.T.W.’s Green Light 10 Pass to the Disney employee, only to have the employee refuse to recognize its

11 validity. After waiting an additional 45 minutes in a back office of Guest 12 Relations at Disneyland, A.T.W. was given three FastPasses expressly as a 13 compromise for no longer recognizing his Green Light Pass, but was told they 14 would still have to wait in lines. In the process of doing so, the employee also 15 reviewed A.T.W.’s medical documentation evidencing his cognitive 16 impairments. They also realized A.T.W. was in their system for Green Light DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 access, and was given a Genie Button. 18 152. For the remainder of A.T.W.’s day at Disneyland, prevailing 19 conditions wereDeadline.com misery and chaos. Disney employees and ride operators 20 exhibited a lack of training, did not know how to implement the DAS, 21 appeared consistently perplexed by the DAS cards as they were presented to 22 them, and generally displayed a poor attitude toward disabled guests. The 23 uniform response by Disney employees and ride operators that day was: “this 24 is what the policy is and this is how we were trained.” 25

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1 153. After various chaotic and stress-inducing events throughout the 2 day, A.T.W. was forced to leave the park with R.C.R., T.W.R., and T.L.R. by mid- 3 afternoon. The frustration was too much to bear. 4 154. During a later visit in March of 2014, A.T.W., who attended 5 Disneyland with his caretaker, was denied access to a ride because the Disney 6 ride operator refused to allow his caretaker to go on the ride with A.T.W. This 7 incident was reported to Mark Jones immediately thereafter; to this day, Mr. 8 Jones has not responded. 9 155. During another subsequent visit, A.T.W. attended Disneyland with 10 R.C.R., T.W.R., and T.L.R. to see the Aladdin Show. Upon arrival, R.C.R. and

11 T.W.R. presented A.T.W.’s Genie Button, Make-A-Wish Foundation Lanyard, 12 and his DAS. They requested a “blue card,” which in the past, had allowed 13 A.T.W. and his party to sit in a special area until the show opened to sit its 14 guests. Initially, the card was granted. However, shortly before the show 15 started and everyone had been seated, a Disney employee went over to A.T.W., 16 removed the blue card, and gave him a green card instead. Soon thereafter, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 that same employee allowed the non-disabled guests waiting in line to enter 18 first before the disabled guests. By the time A.T.W. and the rest of the disabled 19 guests were allowedDeadline.com to enter the theatre, most of the disability seating had 20 been taken. R.C.R. asked an employee why this had happened. The employee 21 then replied: “You know the rules of the park when you come in. If you have a 22 complaint, take it up with Guest Relations.” The employee then turned his 23 back and walked away. 24 25

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1 156. Due to Disney’s failure to accommodate A.T.W.’s special needs, 2 and due to Disney’s arbitrary policies toward disabled guests such as A.T.W. 3 which leads to an increased propensity for A.T.W. experiencing a meltdown, 4 Disney has turned its back on disabled persons and prevented A.T.W. from 5 experiencing the full enjoyment of its Parks, equal to the experiences of 6 persons without a disability. 7 157. After October 9, 2013, A.T.W. no longer received the type of 8 accommodation and attention A.T.W. and T.W.R. received when they visited 9 the Parks in the past. 10 158. As a result of Disney’s refusal to modify its procedures to

11 reasonably accommodate A.T.W.’s needs, A.T.W. and T.W.R. have been 12 discouraged and deterred from the full use and enjoyment of the park's rides 13 and attractions. T.W.R. would visit the Parks with A.T.W. more often if Disney 14 had not abandoned its past policy of accommodating the special needs of 15 persons with cognitive impairments. Their interest in attending the Parks is 16 substantially reduced. T.W.R. knows they should avoid attending the parks as DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 much in the future due to the reasonable expectation that the experience will 18 include further discrimination against A.T.W., and will continue to be 19 thoroughly un-magicalDeadline.com and un-accommodating. 20 159. Notwithstanding Disney’s highly sophisticated knowledge of the 21 needs of persons with cognitive impairments, and notwithstanding Disney’s 22 historic ability to accommodate A.T.W.’s special needs, Disney personnel have 23 refused to conduct an individualized assessment of A.T.W.'s capacity to utilize 24 25

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1 the DAS, and have refused to modify the DAS to allow A.T.W. to enjoy the same 2 benefits and privileges as non-disabled patrons. 3 160. Disney personnel have shown no openness, willingness or desire 4 to improve the experience for guests like A.T.W. 5 161. T.W.R. incurred expenses associated with the family’s wasted 6 trips to the Parks. 7 162. During one or more visits to the Parks, A.T.W. suffered an actual 8 meltdown. 9 163. The symptoms and conditions associated with A.T.W.’s meltdown 10 constitute a physical injury under California law.

11 164. A.T.W.’s meltdown in the Parks was proximately caused by 12 Disney’s negligent, unlawful, reckless and arbitrary treatment of A.T.W. during 13 his patronage of Disney’s facilities. At all material times, Disney knew A.T.W. 14 to be vulnerable to emotional injury if treated in such a manner by anyone. 15 165. A.T.W.’s meltdown and the treatment which proximately caused 16 A.T.W. to experience the meltdown caused him grave and extreme mental DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 anguish and emotional trauma, for which Disney should be held accountable. 18 WHEREFORE, Plaintiff A.T.W. by and through T.W.R., as A.T.W.'s next 19 friend, parent andDeadline.com natural guardian, prays that this Court adjudicate this 20 dispute and enter an Order: 21 • Enjoining Defendant to cease the practices which are causing 22 discrimination against Plaintiff on account of A.T.W.’s 23 disability; and 24 25

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1 • Enjoining Defendant to reasonably modify its policies, 2 practices, and procedures to afford Plaintiff with an 3 opportunity to experience Disney’s goods, services, facilities, 4 privileges, advantages, and accommodations; and 5 • Establishing Court-approved remedial measures that Disney 6 must implement, to prevent Disney from further discriminating 7 against Plaintiff when they visit the Disney Parks; and 8 • Establishing Court-approved requirements for information 9 dissemination about Disney’s remedial measures and modified 10 policies, to prevent Disney from further deterring Plaintiff from

11 visiting Disney Parks as a result of anticipated discrimination; 12 and 13 • Establishing a monitoring program to ensure Disney’s 14 compliance with the Court’s Orders; and 15 • Finding that Disney negligently inflicted emotional distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI upon A.T.W.; and 17 • Finding such infliction to have caused damages to A.T.W.; and 18 • Entering judgment for Plaintiff A.T.W. in the amount of such 19 damages;Deadline.com and 20 • Awarding reasonable attorney’s fees as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 • Awarding reasonable litigation costs as may be determined by 23 the Court in favor of Plaintiff and against Disney; and 24 25 • Such other relief as this Court may find just and equitable.

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1 COUNT 7 2 Intentional Infliction of Emotional Distress 3 A.T.W. v. Disney 4 166. Plaintiff A.T.W. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, and 137 through 165 above. 6 167. During one or more visits to the Parks, A.T.W. suffered an actual 7 meltdown. 8 168. The symptoms and conditions associated with A.T.W.’s meltdown 9 constitute a physical injury under California law. 10 169. A.T.W.’s meltdown in the Parks was proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of A.T.W. during his 12 patronage of Disney’s facilities. At all material times, Disney knew A.T.W. to 13 be vulnerable to emotional injury if treated in such a manner by anyone. 14 170. A.T.W.’s meltdown and the treatment which proximately caused 15 A.T.W. to experience the meltdown caused him grave and extreme mental 16 anguish and emotional trauma, for which Disney should be held accountable. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 WHEREFORE, Plaintiff A.T.W., by and through T.W.R. as A.T.W.’s next 18 friend, parent and natural guardian, prays that this Court adjudicate this 19 dispute and enterDeadline.com an Order: 20 • Finding that Disney intentionally inflicted emotional distress 21 upon A.T.W.; and 22 • Finding such infliction to have caused damages to A.T.W.; and 23 • Entering judgment for Plaintiff A.T.W. in the amount of such 24 damages; 25

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1 • Entering judgment in favor of Plaintiffs and against Disney for 2 exemplary or punitive damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 8 COUNT 8 9 Negligent Infliction of Emotional Distress 10 T.L.R. v. Disney

11 171. Plaintiff T.L.R. incorporates and re-alleges the allegations of 12 paragraphs 1 through 90. 13 172. T.L.R. has autism, severe separation anxiety, sleeping disorder, 14 and is severely asthmatic. She becomes anxious when forced to idly wait for 15 more than a few minutes. Additionally, T.L.R.’s verbal skills are under- 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI developed. Behavioral meltdowns for T.L.R. consist generally of crying, 17 throwing herself on the ground, and possible eloping without warning. 18 173. Autism substantially limits a person’s ability to care for herself, 19 perform manualDeadline.com tasks, speak, learn, read, concentrate, think, communicate, 20 perceive the concept of time, pair sights and sounds that happen 21 simultaneously, and work. 22 174. T.L.R. is a person with a disability, as that term is defined in 42 23 U.S.C. §12102(1). 24 25

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1 175. T.L.R. is nine years old and is generally in the care of her father, 2 R.C.R. who brings this action as T.L.R.'s next friend, parent and natural 3 guardian and her mother, T.W.R. 4 176. T.L.R. and R.C.R. are residents of Los Angeles County, California. 5 177. T.L.R. first attended Disneyland in 2006 when she was five 6 months old. T.L.R. would then regularly attend Disney Parks with R.C.R., 7 T.W.R., and her brother, A.T.W., going 2-3 times per week. 8 178. In fact, for much of her childhood T.L.R. has visited Disneyland 9 with R.C.R., T.W.R., and her brother, A.T.W. T.L.R. carried the Guest Assistance 10 Card, and she was admirably accommodated. During those visits, T.L.R.

11 exhibited a nature and extent of joy that she rarely showed in any other 12 setting. R.C.R. was always proud and joyful of the opportunity to bring to his 13 beloved child a level of happiness which she rarely showed elsewhere. 14 Disneyland was a place where R.C.R., T.W.R., A.T.W. and T.L.R. could unwind 15 after school and bond together, as a family with two children diagnosed with 16 cognitive impairments. T.L.R. could stay for the entire day at the Disney Parks DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 with her family, usually culminating in watching the fireworks before leaving 18 the park for dinner at ESPN Sports Zone or Pizza Port. 19 179. In 2006,Deadline.com T.L.R. and R.C.R. obtained annual passes for Disneyland. 20 T.L.R. and R.C.R. visited the Disney Parks 2-3 times per week between 2006 21 and 2014. T.L.R. also rarely experienced behavioral meltdowns during her 22 visits to Disneyland prior to October of 2013 when Disney began enforcing the 23 DAS. 24 25

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1 180. Since T.L.R. was a toddler, her cognitive impairments have 2 manifested themselves in a certain way during the family’s visits to the Parks. 3 T.L.R. and her brother, A.T.W. are programmed to and must experience the 4 park in a specific order, so that disruptions in their planned routine will tend 5 to escalate their stimming behaviors toward meltdowns. A.T.W. and T.L.R. 6 have a strict schedule in their head of the Disneyland rides they must ride, and 7 the order in which they must ride them. Deviation from that order will likely 8 lead to a meltdown. For example, T.L.R. and A.T.W. must experience 9 Disneyland in the following order: (1) Matterhorn Bobsleds or Big Thunder 10 Mountain Railroad; (2) Space Mountain; (3) Finding Nemo Submarine Voyage

11 (now closed) or Star Tours – The Adventure Continues; (4) Autopia; and (5) 12 Alice in Wonderland or Mad Tea Party. If T.L.R. were to visit Disneyland and 13 first visit Matterhorn Bobsleds or Big Thunder Mountain Railroad, and if she 14 were not afforded the opportunity to first experience that ride, she would 15 likely experience a meltdown. 16 181. T.L.R.’s disorders also cause her to have to experience certain

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disney attractions repetitively. T.L.R. is a “repeat rider.” This is a propensity 18 common among autistic persons – a variety of the need for consistency, order 19 and routine. T.L.R.Deadline.com will experience a particular ride or attraction, such as 20 Goofy’s Sky School or Grizzly River Run, over and over, for several hours at a 21 time. Disney personnel are very familiar with the repeat rider type of guest. 22 182. Similarly, if T.L.R. were required to idly wait for entry into a ride 23 or attraction for more than a few minutes, she also would likely melt down. 24 25

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1 183. Much like her brother, T.L.R. is incapable of understanding the 2 concept of visiting a ride or attraction only to be prohibited from riding it until 3 a future time. Thus, the new DAS creates avoidable stressors for T.L.R., 4 escalating her stimming patterns toward meltdowns almost instantaneously. 5 Since Disney’s implementation of the new DAS, T.L.R. has experienced several 6 meltdowns at Disneyland. 7 184. The first day T.L.R. attended the parks after the DAS came into 8 effect, she attended with R.C.R., T.W.R., and her brother A.T.W., on October 12, 9 2013. Upon arriving, R.C.R. and T.W.R. waited two hours before speaking to an 10 employee at Guest Relations, and an additional 45 minutes in a back office of

11 Guest Relations at Disneyland. While the employee questioned R.C.R. and 12 T.W.R. about T.L.R.’s disability, T.L.R. experienced a meltdown to which the 13 employee said, “I see,” before issuing a DAS. 14 185. For the remainder of T.L.R.’s day at Disneyland, prevailing 15 conditions were misery and chaos. Disney employees and ride operators 16 exhibited a lack of training, did not know how to implement the DAS, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 appeared consistently perplexed by the DAS cards as they were presented to 18 them, and generally displayed a poor attitude toward disabled guests. The 19 uniform responseDeadline.com by Disney employees and ride operators that day was: “this 20 is what the policy is and this is how we were trained.” 21 186. After various chaotic and stress-inducing events throughout the 22 day, T.L.R. was forced to leave the park with R.C.R., T.W.R., and A.T.W. by mid- 23 afternoon. The frustration was too much to bear. 24 25

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1 187. T.L.R. has experienced embarrassment at the hands of Disney and 2 as a consequence of Disney’s newfound inability to accommodate her. 3 188. Due to Disney’s failure to accommodate which leads to an 4 increased propensity for T.L.R. experiencing a meltdown, Defendant has 5 prevented T.L.R. from experiencing the full enjoyment of its Parks, equal to 6 the experiences of persons without a disability. 7 189. After October 9, 2013, T.L.R. no longer received the type of 8 accommodation and attention T.L.R. and R.C.R. had received when they visited 9 the Parks in the past. The DAS has specifically adversely impacted T.L.R. 10 because additional time must be expended in line at the start of each visit to

11 obtain the DAS. 12 190. As a result of Disney’s refusal to modify its procedures to 13 reasonably accommodate T.L.R.’s needs, T.L.R. and R.C.R. have been 14 discouraged and deterred from the full use and enjoyment of the park's rides 15 and attractions. R.C.R. would visit the Parks with T.L.R. more often if Disney 16 had not abandoned its past policy of accommodating the special needs of DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 persons with cognitive impairments. Their interest in attending the Parks is 18 substantially reduced. R.C.R. knows they should avoid attending the parks as 19 much in the futureDeadline.com due to the expectation that the experience will result in 20 further discrimination against T.L.R., and will again be thoroughly un-magical 21 and un-accommodating. 22 191. Notwithstanding Disney’s highly sophisticated knowledge of the 23 needs of persons with cognitive impairments, and notwithstanding Disney’s 24 historic ability to accommodate T.L.R.’s special needs, Disney personnel have 25

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1 refused to conduct an individualized assessment of T.L.R.'s capacity to utilize 2 the DAS, and have refused to modify the DAS to allow T.L.R. to enjoy the same 3 benefits and privileges as non-disabled patrons. 4 192. Disney personnel have shown no openness, willingness or desire 5 to improve the experience for guests like T.L.R. 6 193. R.C.R. incurred expenses associated with the family’s wasted trips 7 to the Parks. 8 194. During one or more visits to the Parks, T.L.R. suffered an actual 9 meltdown. 10 195. The symptoms and conditions associated with T.L.R.’s meltdown

11 constitute a physical injury under California law. 12 196. T.L.R.’s meltdown in the Parks was proximately caused by 13 Disney’s negligent, unlawful, reckless and arbitrary treatment of T.L.R. during 14 his patronage of Disney’s facilities. At all material times, Disney knew T.L.R. to 15 be vulnerable to emotional injury if treated in such a manner by anyone. 16 197. T.L.R.’s meltdown and the treatment which proximately caused

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 T.L.R. to experience the meltdown caused him grave and extreme mental 18 anguish and emotional trauma, for which Disney should be held accountable. 19 WHEREFORE,Deadline.com Plaintiff T.L.R. by and through R.C.R., as T.L.R.'s next 20 friend, parent and natural guardian, prays that this Court adjudicate this 21 dispute and enter an Order: 22 • Enjoining Defendant to cease the practices which are causing 23 discrimination against Plaintiff on account of T.L.R.’s disability; 24 and 25

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1 • Enjoining Defendant to reasonably modify its policies, 2 practices, and procedures to afford Plaintiff with an 3 opportunity to experience Disney’s goods, services, facilities, 4 privileges, advantages, and accommodations; and 5 • Establishing Court-approved remedial measures that Disney 6 must implement, to prevent Disney from further discriminating 7 against Plaintiff when they visit the Disney Parks; and 8 • Establishing Court-approved requirements for information 9 dissemination about Disney’s remedial measures and modified 10 policies, to prevent Disney from further deterring Plaintiff from

11 visiting Disney Parks as a result of anticipated discrimination; 12 and 13 • Establishing a monitoring program to ensure Disney’s 14 compliance with the Court’s Orders; and 15 • Finding that Disney negligently inflicted emotional distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI upon T.L.R.; and 17 • Finding such infliction to have caused damages to T.L.R.; and 18 • Awarding reasonable attorney’s fees as may be determined by 19 the CourtDeadline.com in favor of Plaintiff and against Disney; and 20 • Awarding reasonable litigation costs as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 • Such other relief as this Court may find just and equitable. 23 24 COUNT 9 25 Intentional Infliction of Emotional Distress

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1 T.L.R. v. Disney 2 198. Plaintiff T.L.R. incorporates and re-alleges the allegations of 3 paragraphs 1 through 90, and 172 through 197 above. 4 199. During one or more visits to the Parks, T.L.R. suffered an actual 5 meltdown. 6 200. The symptoms and conditions associated with T.L.R.’s meltdown 7 constitute a physical injury under California law. 8 201. T.L.R.’s meltdown in the Parks was proximately caused by 9 Disney’s outrageous, unlawful and reckless treatment of T.L.R. during his 10 patronage of Disney’s facilities. At all material times, Disney knew T.L.R. to be

11 vulnerable to emotional injury if treated in such a manner by anyone. 12 202. T.L.R.’s meltdown and the treatment which proximately caused 13 T.L.R. to experience the meltdown caused her grave and extreme mental 14 anguish and emotional trauma, for which Disney should be held accountable. 15 WHEREFORE, Plaintiff T.L.R., by and through R.C.R. as T.L.R.’s next 16 friend, parent and natural guardian, prays that this Court adjudicate this DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 dispute and enter an Order: 18 • Finding that Disney intentionally inflicted emotional distress 19 uponDeadline.com T.L.R.; and 20 • Finding such infliction to have caused damages to T.L.R.; and 21 • Entering judgment for Plaintiff T.L.R. in the amount of such 22 damages; 23 • Entering judgment in favor of Plaintiffs and against Disney for 24 exemplary or punitive damages; and 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding prejudgment interest; and 4 • Such other relief as this Court may find just and equitable. 5 6 7 8 9 10

11 12 13 14 15 16 DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 18 19 Deadline.com 20 21 22 23 24 25

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1 COUNT 10 2 Negligent Infliction of Emotional Distress 3 T.W.R. v. Disney 4 203. Plaintiff T.W.R. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, 137 through 165, 167 through 170, 172 through 6 197, and 199 through 202 above. 7 204. During one or more visits to the Parks, T.W.R.’s beloved son 8 A.T.W. suffered an actual meltdown while in T.W.R.’s presence. 9 205. The symptoms and conditions associated with A.T.W.’s meltdown 10 constitute a physical injury to A.T.W. under California law.

11 206. A.T.W.’s meltdown in the Parks was proximately caused by 12 Disney’s negligent, unlawful, reckless and arbitrary treatment of A.T.W. during 13 his patronage of Disney’s facilities. At all material times, Disney knew A.T.W. 14 to be vulnerable to emotional injury if treated in such a manner by anyone. 15 207. T.W.R. directly observed the stressors leading up to the 16 meltdown, A.T.W.’s resulting escalation and his meltdown. Particularly in DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 light of her trust and confidence that Disney would comply with applicable 18 law and act in a gracious and caring manner toward her son, T.W.R. could do 19 nothing reasonableDeadline.com to prevent the meltdown. 20 208. T.W.R.’s observation of A.T.W.’s meltdown and of the outrageous 21 conduct and treatment which proximately caused A.T.W. to experience the 22 meltdown caused T.W.R. grave and extreme mental anguish and emotional 23 trauma, for which Disney should be held accountable. 24 25

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1 WHEREFORE, Plaintiff T.W.R. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney negligently inflicted emotional distress 4 upon T.W.R.; and 5 • Finding such infliction to have caused damages to T.W.R.; and 6 • Entering judgment for Plaintiff T.W.R. in the amount of such 7 damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 11 13 Intentional Infliction of Emotional Distress 14 T.W.R. v. Disney 15 209. Plaintiff T.W.R. incorporates and re-alleges the allegations of 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI paragraphs 1 through 90, 137 through 165, 167 through 170, 172 through 17 197, and 199 through 202 above. 18 210. During one or more visits to the Parks, T.W.R.’s beloved son 19 A.T.W. suffered anDeadline.com actual meltdown. 20 211. The symptoms and conditions associated with A.T.W.’s meltdown 21 constitute a physical injury under California law. 22 212. A.T.W.’s meltdown in the Parks was proximately caused by 23 Disney’s outrageous, unlawful and reckless treatment of A.T.W. during his 24 25

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1 patronage of Disney’s facilities. At all material times, Disney knew A.T.W. to 2 be vulnerable to emotional injury if treated in such a manner by anyone. 3 213. T.W.R. directly observed the stressors leading up to the 4 meltdown, A.T.W.’s resulting escalation and his meltdown. Particularly in 5 light of her trust and confidence that Disney would comply with applicable 6 law and act in a gracious and caring manner toward her son, T.W.R. could do 7 nothing reasonable to prevent the meltdown. 8 214. T.W.R.’s observation of A.T.W.’s meltdown and of the outrageous 9 conduct and treatment which proximately caused A.T.W. to experience the 10 meltdown caused T.W.R. grave and extreme mental anguish and emotional

11 trauma, for which Disney should be held accountable. 12 WHEREFORE, Plaintiff T.W.R. prays that this Court adjudicate this 13 dispute and enter an Order: 14 • Finding that Disney intentionally inflicted emotional distress 15 upon T.W.R.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Finding such infliction to have caused damages to T.W.R.; and 17 • Entering judgment for Plaintiff T.W.R. in the amount of such 18 damages; 19 • EnteringDeadline.com judgment in favor of Plaintiff and against Disney for 20 exemplary or punitive damages; and 21 • Awarding reasonable litigation costs as may be determined by 22 the Court in favor of Plaintiff and against Disney; and 23 • Awarding prejudgment interest; and 24 • Such other relief as this Court may find just and equitable. 25

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1 COUNT 12 2 Breach of Contract 3 T.W.R. v. Disney 4 215. Plaintiff T.W.R. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, 137 through 165, 167 through 170, 172 through 6 197, and 199 through 202 above. 7 216. T.W.R. entered into a contract through which Disney promised to 8 provide a reasonable and enjoyable amusement park experience, and one 9 which complies with applicable law. 10 217. Disney failed or refused to provide the promised experience, and

11 is in breach of contract. 12 218. T.W.R. incurred expenses associated with the family’s wasted 13 trips to the Parks. Plaintiff is damaged by Disney’s breach of contract. 14 WHEREFORE, Plaintiff T.W.R. prays that this Court adjudicate this 15 dispute and enter an Order: 16 • Finding that Disney breached its contract with T.W.R..; and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 • Entering judgment for Plaintiff T.W.R.in the amount of her 18 economic monetary damages; and 19 • AwardingDeadline.com reasonable litigation costs as may be determined by 20 the Court in favor of Plaintiff and against Disney; and 21 • Awarding prejudgment interest; and 22 • Such other relief as this Court may find just and equitable. 23

24 25

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1 COUNT 13 2 Negligent Infliction of Emotional Distress 3 R.C.R. v. Disney 4 219. Plaintiff R.C.R. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, 137 through 165, 167 through 170, 172 through 6 197, and 199 through 202 above. 7 220. During one or more visits to the Parks, R.C.R.’s beloved son A.T.W. 8 suffered an actual meltdown while in R.C.R.’s presence. 9 221. The symptoms and conditions associated with A.T.W.’s meltdown 10 constitute a physical injury to A.T.W. under California law.

11 222. A.T.W.’s meltdown in the Parks was proximately caused by 12 Disney’s negligent, unlawful, reckless and arbitrary treatment of A.T.W. during 13 his patronage of Disney’s facilities. At all material times, Disney knew A.T.W. 14 to be vulnerable to emotional injury if treated in such a manner by anyone. 15 223. R.C.R. directly observed the stressors leading up to the meltdown, 16 A.T.W.’s resulting escalation and his meltdown. Particularly in light of his DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 trust and confidence that Disney would comply with applicable law and act in 18 a gracious and caring manner toward his son, R.C.R. could do nothing 19 reasonable to preventDeadline.com the meltdown. 20 224. R.C.R.’s observation of A.T.W.’s meltdown and of the outrageous 21 conduct and treatment which proximately caused A.T.W. to experience the 22 meltdown caused R.C.R. grave and extreme mental anguish and emotional 23 trauma, for which Disney should be held accountable. 24 25

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1 WHEREFORE, Plaintiff R.C.R. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney negligently inflicted emotional distress 4 upon R.C.R.; and 5 • Finding such infliction to have caused damages to R.C.R.; and 6 • Entering judgment for Plaintiff R.C.R. in the amount of such 7 damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 14 13 Intentional Infliction of Emotional Distress 14 R.C.R. v. Disney 15 225. Plaintiff R.C.R. incorporates and re-alleges the allegations of 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI paragraphs 1 through 90, 137 through 165, 167 through 170, 172 through 17 197, and 199 through 202 above. 18 226. During one or more visits to the Parks, R.C.R.’s beloved son A.T.W. 19 suffered an actualDeadline.com meltdown. 20 227. The symptoms and conditions associated with A.T.W.’s meltdown 21 constitute a physical injury under California law. 22 228. A.T.W.’s meltdown in the Parks was proximately caused by 23 Disney’s outrageous, unlawful and reckless treatment of A.T.W. during his 24 25

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1 patronage of Disney’s facilities. At all material times, Disney knew A.T.W. to 2 be vulnerable to emotional injury if treated in such a manner by anyone. 3 229. R.C.R. directly observed the stressors leading up to the meltdown, 4 A.T.W.’s resulting escalation and his meltdown. Particularly in light of his 5 trust and confidence that Disney would comply with applicable law and act in 6 a gracious and caring manner toward his son, R.C.R. could do nothing 7 reasonable to prevent the meltdown. 8 230. R.C.R.’s observation of A.T.W.’s meltdown and of the outrageous 9 conduct and treatment which proximately caused A.T.W. to experience the 10 meltdown caused R.C.R. grave and extreme mental anguish and emotional

11 trauma, for which Disney should be held accountable. 12 WHEREFORE, Plaintiff R.C.R. prays that this Court adjudicate this 13 dispute and enter an Order: 14 • Finding that Disney intentionally inflicted emotional distress 15 upon R.C.R.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Finding such infliction to have caused damages to R.C.R.; and 17 • Entering judgment for Plaintiff R.C.R. in the amount of such 18 damages; 19 • EnteringDeadline.com judgment in favor of Plaintiff and against Disney for 20 exemplary or punitive damages; and 21 • Awarding reasonable litigation costs as may be determined by 22 the Court in favor of Plaintiff and against Disney; and 23 • Awarding prejudgment interest; and 24 • Such other relief as this Court may find just and equitable. 25

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1 COUNT 15 2 Negligent Infliction of Emotional Distress 3 A.M.W. v. Disney 4 231. Plaintiff A.M.W. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90 above. 6 232. A.M.W. has autism spectrum disorder. Her cognitive disabilities 7 are a result of permanent brain damage she suffered when she underwent 8 heart surgery when she was one month old and her surgeon inadvertently 9 severed a nerve that wraps around her heart. The event also led to paralysis of 10 her vocal folds and a resulting airway obstruction, which in turn, led to her

11 airway being obstructed. A.M.W. spent her first six years on and off of life- 12 support systems. She is deaf, non-verbal, and suffers from seizures. A.M.W.’s 13 conditions sometimes have the effect of causing A.M.W. to lose the ability to 14 breathe, thus requiring the use of an oxygen bag and mask. 15 233. A.M.W. also experiences behavioral meltdowns, which generally 16 consist of crying and severe self-abusive behavior. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 234. Autism substantially limits a person’s ability to care for herself 18 perform manual tasks, speak, learn, read, concentrate, think, communicate, 19 perceive the conceptDeadline.com of time, pair sights and sounds that happen 20 simultaneously, and work. 21 235. A.M.W. is a person with a disability, as that term is defined in 42 22 U.S.C. §12102(1). 23 24 25

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1 236. A.M.W. is 19 years old and is generally in the care of her mother, 2 D.L.W., who brings this action as A.M.W.'s next friend, parent and natural 3 guardian. 4 237. A.M.W. and D.L.W. are residents of Los Angeles County, California. 5 238. Due to A.M.W.’s impairments, she spent most of her childhood 6 years either at home or at hospitals, until age eleven. D.L.W. constantly 7 weighed the risks of respiratory issues and behavioral meltdowns against the 8 reward of engaging A.M.W. in new social activities. When A.M.W.’s medical 9 condition was sufficiently stable, D.L.W. started taking A.M.W. to the 10 Disneyland parks. Thereafter, all of A.M.W.’s birthdays were celebrated at the

11 Disney Parks. 12 239. Since their first visit to the Parks, A.M.W.’s favorite thing in the 13 world was Disneyland. A.M.W. exhibited a nature and extent of joy that she 14 just did not experience in any other setting. She would visibly light up and 15 glow during their visits. No place else on earth had ever made A.M.W. that 16 happy. During that time, A.M.W. received the GAC and was admirably DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 accommodated. 18 240. Due to A.M.W.’s impairments, she is unable to stay in the Parks for 19 long periods ofDeadline.com time, because doing so increases the risk that she will 20 experience a meltdown, or much worse, respiratory arrest. The GAC allowed 21 A.M.W. and D.L.W. to go to the Disney Parks, enjoy considerable experiences in 22 a short period of time, and return home without worry that her medical 23 conditions would interfere with her day. D.L.W. was proud and joyful of the 24 25

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1 opportunity to bring to her beloved daughter a level of happiness which she 2 rarely showed elsewhere. 3 241. Five years ago, D.L.W. purchased Disneyland annual passes for 4 A.M.W. and her family. D.L.W. and A.M.W. visited the parks between six to 5 eight times per year, depending on A.M.W.’s health. 6 242. Their visits to Disneyland with the GAC were brief, but enjoyable. 7 While D.L.W. would have to carry A.M.W.’s emergency bag with them the 8 throughout every visit, in case A.M.W. had a respiratory event, she rarely 9 needed to use it because the GAC allowed quicker access to the rides, less time 10 walking around the Parks being exposed to the elements, less time idly in

11 stimulating environments, and overall, the ability to enjoy the Disney Parks 12 the same as other, non-disabled guests were able to enjoy the Disney Parks. 13 243. Given A.M.W.’s fragile condition, disaster could not always be 14 avoided. During one of their Disneyland visits, when the GAC system was still 15 in place, while in the FastPass line at Space Mountain, A.M.W. went into 16 respiratory arrest. A.M.W. had visited Disneyland with her family for her DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 birthday, without knowing that Disney had changed its usual GAC policy, by 18 prohibiting a guest with a GAC to go through the FastPass lane, and requiring 19 guests to use theDeadline.com disabled line instead. A.M.W.’s family had not been informed 20 of this change until they arrived at Space Mountain and the employee directed 21 them to the disabled line. From said location, the ride was not visible. Because 22 of this, A.M.W. interpreted their walking away from the ride entrance to mean 23 that they were not going on the ride at all. This resulted in a major meltdown, 24 wherein A.M.W. started screaming, jumped up to throw herself onto her knees 25

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1 and onto the floor, and started banging her head on the concrete. Although the 2 employee saw the entire episode, including the fact that A.M.W.’s family was 3 struggling to calm her down, and that A.M.W. was bleeding by that point, the 4 Disney employee did not even use her walkie-talkie to ask if an exception 5 could be made to their new policy. 6 244. After the calamitous and heartbreaking episode at Space 7 Mountain, and Disney’s employee’s unbelievable lack of inclination to be 8 flexible, once A.M.W. calmed down, A.M.W.’s family went to City Hall and 9 explained what occurred. The employees at City Hall apologized profusely and 10 to prevent a similar effect from happening in the future, A.M.W. was given a

11 “Green Light Pass”, by which she could use whichever line was the most 12 convenient for their family. 13 245. After being provided with a Green Light Pass, A.M.W.’s 14 experiences at Disneyland were even more magical. More attractions became 15 accessible to A.M.W. for her short three-to-four-hour stays. Additionally, 16 because of this wonderful accommodation, A.M.W. suffered no additional DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 meltdowns or breathing issues while visiting the one place where she could 18 truly enjoy her childhood. 19 246. ThisDeadline.com changed drastically on October 10, 2014 when A.M.W. visited 20 Disneyland. The family had booked a Disney hotel for three nights for A.M.W’s 21 birthday trip the following week. They had heard about the DAS, and wanted 22 to see in advance if it would work for A.M.W, or if they would have to cancel 23 the birthday reservations. While at Guest Relations, employees informed 24 25

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1 D.L.W. that neither the Green Light nor the GAC accommodations were 2 available; the only available accommodation is the DAS. 3 247. D.L.W. was aware of changes to Disney’s policies beforehand 4 because she called Disney on multiple occasions before their trip. During 5 these calls, she was promised that A.M.W. would receive an individualized 6 accommodation once she arrived at Disneyland. During that October visit, 7 D.L.W. realized that Disney’s assurances could not have been further from the 8 truth. 9 248. While D.L.W. attempted to check in A.M.W. at Guest Relations, she 10 asked to speak in a private room, as opposed to having to discuss A.M.W.’s

11 impairments in front of other guests. By the time the taxing Guest Relations 12 check-in process was complete, and A.M.W. visited one attraction, the family 13 had been at Disneyland for about three hours, very close to A.M.W.’s physical 14 limit. 15 249. A.M.W.’s cognitive impairments have always manifested 16 themselves in a certain way during the family’s visits to the Parks. A.M.W. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 must experience the park in a specific order, and disruptions in her pre- 18 planned routine will trend A.M.W. toward self-harming meltdowns or 19 respiratory events.Deadline.com For A.M.W., every trip to Disneyland must begin with a 20 visit to the jewelry store to purchase a piece of jewelry or a watch for A.M.W. 21 to wear. Deviation from her routine causes her heightened anxiety and a 22 manifestation of her medical conditions. 23 250. When A.M.W. suffers a respiratory event, she stops breathing and 24 requires an oxygen mask and ambu bag until she is able to breathe on her 25

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1 own. These events generally last between three and 20 minutes, but can last 2 as long as 50 minutes. If she does not regain the ability to breathe on her own 3 within a certain window of time, she loses consciousness and experiences 4 seizures, which makes resuscitation far more difficult. Placing A.M.W. in 5 stressful or frustrating experiences increases A.M.W.’s risk of suffering such 6 episodes. 7 251. During the October 10, 2013 visit, the family arrived at their first 8 ride, Pirates of the Caribbean, at their designated time. D.L.W. and A.M.W. 9 were placed in a separate wait line for disabled guests, separate from the 10 ordinary standby line. There was no FastPass Line. The posted wait time

11 listed for the standby line was 30 minutes. Even though D.L.W. and A.M.W. 12 arrived on time for their appointment at the ride, they waited between 30 and 13 40 minutes to gain admission. 14 252. Next, D.L.W. and A.M.W. visited one of the Parks’ kiosks to pick a 15 return time for a new ride. Facing return times too late in the day, and 16 exceeding the time they could safely stay in the park, D.L.W. and A.M.W. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 decided to use their FastPasses at Haunted Mansion. Again, they were placed 18 in the disabled line and endured a wait time that exceeded the wait time of the 19 ordinary standbyDeadline.com line. 20 253. They returned to a kiosk for a third time. Their return time for the 21 Peter Pan ride would have been 50 minutes later. By this time, A.M.W.’s family 22 could see physical changes in A.M.W., who appeared tired and unstable. 23 D.L.W. decided they had to leave the park. 24 25

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1 254. As the family exited Disneyland, D.L.W. stopped at City Hall to 2 speak with a supervisor. An employee named Dave Atkins spoke with D.L.W. 3 at the City Hall steps. During the conversation, A.M.W. collapsed and went into 4 respiratory arrest, right in front of Mr. Atkins, during the height of the Main 5 Street Parade. 6 255. Disney employees rushed to the scene and cleared a restroom of 7 guests, and A.M.W.’s father, R.D.W., went into the restroom to help D.L.W. 8 resuscitate A.M.W. 9 256. Mr. Atkins called for a van to take A.M.W.’s family out of the park. 10 During this time, he promised to be an advocate for A.M.W. in the future,

11 taking it “all the way to the top if he have to,” and said they would be in touch. 12 257. Subsequently, during a phone conversation with Mr. Atkins and 13 R.D.W., Mr. Atkins told R.D.W. that there was nothing he could do for A.M.W. 14 He suggested they consider one of two options: (1) cancel their annual passes 15 and not be charged; or (2) put their passes on hold into 2014 and check back 16 to see if anything had changed. The second option would still require monthly DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 payments, though, because “an outside company handles the payments.” 18 258. Despite these disastrous events, A.M.W. and her family have 19 returned to DisneylandDeadline.com on two occasions, only for a couple of hours per visit; 20 and they have encountered the same unaccommodating experience. 21 259. Due to its failure to reasonably accommodate A.M.W., Defendant 22 has prevented A.M.W. from experiencing the full enjoyment of its Parks, equal 23 to the experiences afforded to persons without a disability. 24 25

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1 260. As a result of Disney’s refusal to modify its procedures, A.M.W. 2 and D.L.W. have been deterred from the full use and enjoyment of the Parks’ 3 rides and attractions. D.L.W. would visit Disneyland with A.M.W. more often if 4 Disney had not abandoned its past policy of accommodating the special needs 5 of persons with cognitive and other medical impairments. D.L.W. knows her 6 family should avoid traveling to the parks in the future due to the reasonable 7 expectation that Disney will take no steps to accommodate A.M.W. and that 8 the visit will once again be a disaster. 9 261. Notwithstanding Disney’s highly sophisticated knowledge of the 10 needs of persons with cognitive impairments, and notwithstanding Disney’s

11 historic ability to accommodate A.M.W.’s special needs, Disney personnel have 12 refused to conduct an individualized assessment of A.M.W.'s capacity to utilize 13 the DAS, and have refused to modify the DAS to allow A.M.W. to enjoy the 14 same benefits and privileges as non-disabled patrons. 15 262. D.L.W. now hides pictures of Disneyland from A.M.W. to keep her 16 from asking to return to the parks. D.L.W. knows she cannot expose her DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 daughter to the heinous risks associated with another trip to Disneyland 18 under the DAS. 19 263. DisneyDeadline.com personnel have shown no willingness or desire to improve 20 the experience for guests like A.M.W. 21 264. D.L.W. incurred expenses associated with the family’s wasted 22 trips to the Parks. 23 265. During one or more visits to the Parks, A.M.W. suffered an actual 24 episode. 25

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1 266. The symptoms and conditions associated with A.M.W.’s episodes 2 constitute a physical injury under California law. 3 267. A.M.W.’s episodes in the Parks were proximately caused by 4 Disney’s negligent, unlawful, reckless and arbitrary treatment of A.M.W. 5 during her patronage of Disney’s facilities. At all material times, Disney knew 6 A.M.W. to be vulnerable to emotional injury if treated in such a manner by 7 anyone. 8 268. A.M.W.’s episodes and the treatment which proximately caused 9 A.M.W. to experience the episodes caused her grave and extreme mental 10 anguish and emotional trauma, for which Disney should be held accountable.

11 WHEREFORE, Plaintiff A.M.W., by and through D.L.W. as A.M.W.’s 12 next friend, parent and natural guardian, prays that this Court adjudicate 13 this dispute and enter an Order: 14 • Finding that Disney negligently inflicted emotional distress 15 upon A.M.W.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Finding such infliction to have caused damages to A.M.W.; and 17 • Entering judgment for Plaintiff A.M.W. in the amount of such 18 damages; and 19 • AwardingDeadline.com reasonable litigation costs as may be determined by 20 the Court in favor of Plaintiff and against Disney; and 21 • Awarding prejudgment interest; and 22 • Such other relief as this Court may find just and equitable. 23

24 25

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1 COUNT 16 2 Intentional Infliction of Emotional Distress 3 A.M.W. v. Disney 4 269. Plaintiff A.M.W. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, and paragraphs 232 through 268 above. 6 270. During one or more visits to the Parks, A.M.W. suffered an actual 7 episode. 8 271. The symptoms and conditions associated with A.M.W.’s episodes 9 constitute a physical injury under California law. 10 272. A.M.W.’s episodes in the Parks were proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of A.M.W. during her 12 patronage of Disney’s facilities. At all material times, Disney knew A.M.W. to 13 be vulnerable to emotional injury if treated in such a manner by anyone. 14 273. A.M.W.’s episodes and the treatment which proximately caused 15 A.M.W. to experience the episodes caused her grave and extreme mental 16 anguish and emotional trauma, for which Disney should be held accountable. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 WHEREFORE, Plaintiff A.M.W., by and through D.L.W. as A.M.W.’s 18 next friend, parent and natural guardian, prays that this Court adjudicate 19 this dispute andDeadline.com enter an Order: 20 • Finding that Disney intentionally inflicted emotional distress 21 upon A.M.W.; and 22 • Finding such infliction to have caused damages to A.M.W.; and 23 • Entering judgment for Plaintiff A.M.W. in the amount of such 24 damages; 25

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1 • Entering judgment in favor of Plaintiff and against Disney for 2 exemplary or punitive damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 17 8 Negligent Infliction of Emotional Distress 9 D.L.W. v. Disney 10 274. Plaintiff D.L.W. incorporates and re-alleges the allegations of

11 paragraphs 1 through 90, 232 through 268, and 270 through 273 above. 12 275. During one or more visits to the Parks, D.L.W.’s beloved daughter 13 A.M.W. suffered an episode while in D.L.W.’s presence. 14 276. The symptoms and conditions associated with A.M.W.’s episodes 15 constitute a physical injury to A.M.W. under California law. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 277. A.M.W.’s episodes in the Parks were proximately caused by 17 Disney’s negligent, unlawful, reckless and arbitrary treatment of A.M.W. 18 during her patronage of Disney’s facilities. At all material times, Disney knew 19 A.M.W. to be vulnerableDeadline.com to emotional injury if treated in such a manner by 20 anyone. 21 278. D.L.W. directly observed the stressors leading up to A.M.W.’s 22 respiratory arrest. Particularly in light of her trust and confidence that Disney 23 would comply with applicable law and act in a gracious and caring manner 24 25

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1 toward her daughter, D.L.W. could do nothing reasonable to prevent the 2 episode. 3 279. D.L.W.’s observation of A.M.W.’s episodes and of the outrageous 4 conduct and treatment which proximately caused A.M.W. to experience the 5 episodes caused D.L.W. grave and extreme mental anguish and emotional 6 trauma, for which Disney should be held accountable. 7 WHEREFORE, Plaintiff D.L.W. prays that this Court adjudicate this 8 dispute and enter an Order: 9 • Finding that Disney negligently inflicted emotional distress 10 upon D.L.W.; and

11 • Finding such infliction to have caused damages to D.L.W.; and 12 • Entering judgment for Plaintiff D.L.W. in the amount of such 13 damages; and 14 • Awarding reasonable litigation costs as may be determined by 15 the Court in favor of Plaintiff and against Disney; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Awarding prejudgment interest; and 17 • Such other relief as this Court may find just and equitable. 18 COUNT 18 19 IntentionalDeadline.com Infliction of Emotional Distress 20 D.L.W. v. Disney 21 280. Plaintiff D.L.W. incorporates and re-alleges the allegations of 22 paragraphs 1 through 90, 232 through 268, and 269 through 273 above. 23 281. During one or more visits to the Parks, D.L.W.’s beloved daughter 24 A.M.W. suffered an actual episode. 25

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1 282. The symptoms and conditions associated with A.M.W.’s episodes 2 constitute a physical injury under California law. 3 283. A.M.W.’s episodes in the Parks were proximately caused by 4 Disney’s outrageous, unlawful and reckless treatment of A.M.W. during her 5 patronage of Disney’s facilities. At all material times, Disney knew A.M.W. to 6 be vulnerable to emotional injury if treated in such a manner by anyone. 7 284. D.L.W. directly observed the stressors leading up to the episodes, 8 A.M.W.’s resulting escalation and her episodes. Particularly in light of her 9 trust and confidence that Disney would comply with applicable law and act in 10 a gracious and caring manner toward her daughter, D.L.W. could do nothing

11 reasonable to prevent the episodes. 12 285. D.L.W.’s observation of A.M.W.’s episodes and of the outrageous 13 conduct and treatment which proximately caused A.M.W. to experience the 14 episodes caused D.L.W. grave and extreme mental anguish and emotional 15 trauma, for which Disney should be held accountable. 16 WHEREFORE, Plaintiff D.L.W. prays that this Court adjudicate this DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 dispute and enter an Order: 18 • Finding that Disney intentionally inflicted emotional distress 19 uponDeadline.com D.L.W.; and 20 • Finding such infliction to have caused damages to D.L.W.; and 21 • Entering judgment for Plaintiff D.L.W. in the amount of such 22 damages; 23 • Entering judgment in favor of Plaintiff and against Disney for 24 exemplary or punitive damages; and 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding prejudgment interest; and 4 • Such other relief as this Court may find just and equitable. 5 COUNT 19 6 Breach of Contract 7 D.L.W. v. Disney 8 286. Plaintiff D.L.W. incorporates and re-alleges the allegations of 9 paragraphs 1 through 90, 232 through 268, and 269 through 273 above. 10 287. D.L.W. entered into a contract through which Disney promised to 11 provide a reasonable and enjoyable amusement park experience, and one 12 which complies with applicable law. 13 288. Disney failed or refused to provide the promised experience, and 14 is in breach of contract. 15 289. D.L.W. incurred expenses associated with the family’s wasted 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI trips to the Parks. Plaintiff is damaged by Disney’s breach of contract. 17 WHEREFORE, Plaintiff D.L.W. prays that this Court adjudicate this 18 dispute and enter an Order: 19 • FindingDeadline.com that Disney breached its contract with D.L.W.; and 20 • Entering judgment for Plaintiff D.L.W. in the amount of her 21 economic monetary damages; and 22 • Awarding reasonable litigation costs as may be determined by 23 the Court in favor of Plaintiff and against Disney; and 24 • Awarding prejudgment interest; and 25

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1 • Such other relief as this Court may find just and equitable. 2 COUNT 20 3 Negligent Infliction of Emotional Distress 4 R.D.W. v. Disney 5 290. Plaintiff R.D.W. incorporates and re-alleges the allegations of 6 paragraphs 1 through 90, 232 through 268, and 269 through 273 above. 7 291. During one or more visits to the Parks, R.D.W.’s beloved daughter 8 A.M.W. suffered an episode while in R.D.W.’s presence. 9 292. The symptoms and conditions associated with A.M.W.’s episodes 10 constitute a physical injury to A.M.W. under California law.

11 293. A.M.W.’s episodes in the Parks were proximately caused by 12 Disney’s negligent, unlawful, reckless and arbitrary treatment of A.M.W. 13 during her patronage of Disney’s facilities. At all material times, Disney knew 14 A.M.W. to be vulnerable to emotional injury if treated in such a manner by 15 anyone. 16 294. R.D.W. directly observed the stressors leading up to the episodes, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 A.M.W.’s resulting escalation and her episode. Particularly in light of his trust 18 and confidence that Disney would comply with applicable law and act in a 19 gracious and caringDeadline.com manner toward his daughter, R.D.W. could do nothing 20 reasonable to prevent the episodes. 21 295. R.D.W.’s observation of A.M.W.’s episodes and of the outrageous 22 conduct and treatment which proximately caused A.M.W. to experience the 23 episodes caused R.D.W. grave and extreme mental anguish and emotional 24 trauma, for which Disney should be held accountable. 25

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1 WHEREFORE, Plaintiff R.D.W. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney negligently inflicted emotional distress 4 upon R.D.W.; and 5 • Finding such infliction to have caused damages to R.D.W.; and 6 • Entering judgment for Plaintiff R.D.W. in the amount of such 7 damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 21 13 Intentional Infliction of Emotional Distress 14 R.D.W. v. Disney 15 296. Plaintiff R.D.W. incorporates and re-alleges the allegations of 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI paragraphs 1 through 90, 232 through 268, and 269 through 273 above. 17 297. During one or more visits to the Parks, R.D.W.’s beloved daughter 18 A.M.W. suffered an actual episode. 19 298. The Deadline.comsymptoms and conditions associated with A.M.W.’s episodes 20 constitute a physical injury under California law. 21 299. A.M.W.’s episodes in the Parks were proximately caused by 22 Disney’s outrageous, unlawful and reckless treatment of A.M.W. during her 23 patronage of Disney’s facilities. At all material times, Disney knew A.M.W. to 24 be vulnerable to emotional injury if treated in such a manner by anyone. 25

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1 300. R.D.W. directly observed the stressors leading up to the episodes, 2 A.M.W.’s resulting escalation and her episodes. Particularly in light of his trust 3 and confidence that Disney would comply with applicable law and act in a 4 gracious and caring manner toward his daughter, R.D.W. could do nothing 5 reasonable to prevent the episode. 6 301. R.D.W.’s observation of A.M.W.’s episodes and of the outrageous 7 conduct and treatment which proximately caused A.M.W. to experience the 8 episode caused R.D.W. grave and extreme mental anguish and emotional 9 trauma, for which Disney should be held accountable. 10 WHEREFORE, Plaintiff R.D.W. prays that this Court adjudicate this

11 dispute and enter an Order: 12 • Finding that Disney intentionally inflicted emotional distress 13 upon R.D.W.; and 14 • Finding such infliction to have caused damages to R.D.W.; and 15 • Entering judgment for Plaintiff R.D.W. in the amount of such 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI damages; 17 • Entering judgment in favor of Plaintiffs and against Disney for 18 exemplary or punitive damages; and 19 • AwardingDeadline.com reasonable litigation costs as may be determined by 20 the Court in favor of Plaintiff and against Disney; and 21 • Awarding prejudgment interest; and 22 • Such other relief as this Court may find just and equitable. 23

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1 COUNT 22 2 Negligent Infliction of Emotional Distress 3 L.T.T. v. Disney 4 302. Plaintiff R.D.W. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90 above. 6 303. L.T.T. has autism, and does not have control of his body. 7 304. Autism substantially limits a person’s ability to care for himself, 8 perform manual tasks, speak, learn, read, concentrate, think, communicate, 9 perceive the concept of time, pair sights and sounds that happen 10 simultaneously, and work.

11 305. Because of his cognitive disabilities, L.T.T. is incapable of 12 understanding the concept of waiting; and becomes particularly upset when 13 forced to idly wait for extended periods of time. 14 306. Before the DAS was implemented, L.T.T. loved to ride the Alice in 15 Wonderland ride repeatedly, something he cannot do with the DAS. 16 Additionally, due to his autism, L.T.T. must follow a pre-planned schedule. He DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 must ride the Disneyland rides listed on his schedule; otherwise, he becomes 18 highly frustrated. 19 307. L.T.T.Deadline.com expresses his frustrations through behavioral meltdowns; 20 which consist of flailing his head around, spinning, bumping into things, and 21 pushing his family members. During a meltdown, he cannot respond to verbal 22 commands, including his own name. 23 308. L.T.T. is a person with a disability, pursuant to that term’s 24 definition in 42 U.S.C. §12102(1). 25

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1 309. L.T.T. is 10 years of age and in the care of his mother, L.J.T., who 2 brings this action as L.T.T.'s next friend, parent, and natural guardian, and his 3 father, K.K.T. 4 310. L.T.T., L.J.T., and K.K.T. are residents of Ventura County, California. 5 311. L.T.T. has been going to Disneyland regularly with his parents 6 since he was three years of age. At that early age, L.J.T. knew a woman who 7 had an autistic child, who told L.J.T. about Disney’s Guest Assistance Card 8 (GAC) program, which L.J.T. thought sounded wonderful. 9 312. When the GAC program was in place, L.T.T. was always beautifully 10 accommodated. During those visits, L.T.T. exhibited a nature and extent of joy

11 that he rarely manifests in any other setting. L.J.T. delighted in the opportunity 12 to bring to her beloved son a level of happiness which he does not express 13 anywhere else. 14 313. Once Disneyland implemented the new Disability Access Service, 15 everything changed for the worse for L.T.T. and his family. The DAS forces the 16 autistic guest to appreciate the distinction between present and future. L.T.T. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 simply cannot do so. He cannot understand that the present-tense rejection is 18 in exchange for future-tense acceptance. When faced with these realities, 19 L.T.T. is very likelyDeadline.com to experience a meltdown. 20 314. Before their arrival, L.J.T. called Disneyland and asked whether, 21 under the DAS, there can be any other accommodations provided for guests 22 who provide medical documentation. L.J.T. was told that medical records 23 would not be necessary, and to talk to Guest Relations about any 24 accommodations for her son. 25

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1 315. Despite Disney’s considerable knowledge that persons with 2 cognitive disabilities are commonly unable to withstand long and idle wait 3 times, Disney requires precisely those persons to endure a long and idle wait 4 just to start their day. The same was true for L.T.T. and his family, as they 5 were required to begin their day in line at Guest Relations in order to obtain 6 the DAS card. 7 316. After starting the day in such an unproductive and discriminatory 8 manner, L.J.T. asked the Disney employee if there were any alternatives or any 9 other type of accommodation available for her son. She was told no; this is the 10 way the DAS works, and that’s it.

11 317. After begging for additional ways to make their trip more 12 bearable, L.J.T. was provided with three “Attraction Readmission Passes,” and 13 told to get FastPasses in between kiosk and ride wait times. Showing even 14 more ignorance of, or refusal to acknowledge, the challenges which face 15 families like L.J.T.’s, the employee told L.J.T. the family should bide time during 16 waits, eating and shopping. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 318. When the family arrived at Splash Mountain and attempted to 18 acquire FastPasses as directed, they encountered a return time of five hours 19 later. This “accommodation”Deadline.com was no accommodation at all. The day did not 20 improve. 21 319. L.T.T. experienced a number of crying periods, and several 22 meltdowns during his most recent visit to Disneyland. As a result of the DAS, 23 Disneyland went from being L.T.T.’s favorite place to being an absolute 24 25

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1 nightmare. Watching her son break down as he did, at Disneyland, his one 2 happy place, was heartbreaking for L.J.T. 3 320. Due to Disney’s recent refusal to provide individually tailored 4 accommodations for the benefit of guests with cognitive disabilities such as 5 L.T.T., and Disney’s new arbitrary policies which are enforced regardless of 6 the guest’s specific needs, L.T.T. has been prevented from experiencing the full 7 enjoyment of the Parks to the same extent he has enjoyed them in the past, 8 and to the same extent afforded to persons without a disability. 9 321. After the DAS went into effect, L.T.T. no longer receives the type of 10 accommodation and attention he used to receive when they visited

11 Disneyland in the past. 12 322. Also due to Disney’s refusal to modify its procedures to 13 reasonably accommodate L.T.T.’s needs, L.J.T. has been deterred from the full 14 use and enjoyment of the Parks’ rides and attractions. As a consequence, the 15 family’s interest in continuing their visits to the Disney Parks has been 16 considerably diminished. In fact, they have not returned to Disneyland at all DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 since their disastrous visit under DAS. 18 323. If Disney had not abandoned its long standing practices of 19 welcoming and Deadline.comaccommodating the special needs of guests with cognitive 20 impairments, L.T.T. and his parents would continue to visit the Parks as often 21 as they have been doing for the past several years. 22 324. Notwithstanding Disney’s highly sophisticated knowledge and 23 awareness of the needs of persons with cognitive disabilities, and 24 notwithstanding Disney’s historic eagerness and ability to accommodate 25

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1 L.T.T.’s special needs, Disney personnel have refused to conduct an 2 individualized assessment of L.T.T.'s capacity to avail himself to the DAS 3 policies; and to modify DAS to allow L.T.T. to enjoy the same benefits and 4 privileges as non-disabled guests. 5 325. Disney employees have shown no willingness or desire to 6 improve the experience for guests like L.T.T. 7 326. L.J.T. incurred in monetary costs by purchasing tickets to the 8 parks for herself and L.T.T., in addition to other expenses associated to the 9 family’s recent regrettable trips to Disneyland, such as mileage and food. 10 327. During one or more visits to the Parks, L.T.T. suffered actual

11 meltdowns. 12 328. L.T.T.’s meltdowns at Disneyland were proximately caused by 13 Disney’s negligent, unlawful, reckless, and arbitrary treatment of L.T.T. during 14 his patronage of Disney’s facilities. At all material times, Disney knew L.T.T. to 15 be vulnerable to emotional injury if treated in such a manner. 16 329. L.T.T.’s meltdowns and the treatment which proximately caused

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 L.T.T. to experience them caused him grave and extreme mental anguish and 18 emotional trauma, for which Disney should be held accountable. 19 WHEREFORE,Deadline.com Plaintiff L.T.T., by and through L.J.T. as L.T.T.’s next 20 friend, parent, and natural guardian, prays that this Court adjudicate this 21 dispute and enter an Order: 22 • Enjoining Defendant to cease the practices which are causing 23 discrimination against Plaintiff on account of L.T.T.’s disability; 24 and 25

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1 • Enjoining Defendant to reasonably modify its policies, 2 practices, and procedures in order to afford Plaintiff with an 3 opportunity to experience Disney’s goods, services, facilities, 4 privileges, advantages, and accommodations; and 5 • Establishing Court-approved remedial measures that Disney 6 must implement, to prevent Disney from further discriminating 7 against Plaintiff when she visits the Disney Parks; and 8 • Establishing Court-approved requirements for information 9 dissemination regarding Disney’s remedial measures and 10 modified policies, to prevent Disney from further deterring

11 Plaintiff from visiting Disney Parks as a result of anticipated 12 discrimination; and 13 • Establishing a monitoring program to ensure Disney’s 14 compliance with the Court’s Orders; and 15 • Finding that Disney negligently inflicted emotional distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI upon L.T.T.; and 17 • Finding such infliction to have caused damages to L.T.T.; and 18 • Entering judgment for Plaintiff L.T.T. in the amount of such 19 damages;Deadline.com and 20 • Awarding reasonable litigation costs as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 • Awarding prejudgment interest; and 23 24 • Such other relief as this Court may find just and equitable. 25

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1 COUNT 23 2 Intentional Infliction of Emotional Distress 3 L.T.T. v. Disney 4 330. Plaintiff L.T.T. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, and 303 through 329 above. 6 331. During one or more visits to the Parks, L.T.T. suffered actual 7 meltdowns. 8 332. L.T.T.’s meltdowns in the Parks were proximately caused by 9 Disney’s outrageous, unlawful and reckless treatment of L.T.T. during his 10 patronage of Disney’s facilities. At all material times, Disney knew L.T.T. to be

11 vulnerable to emotional injury if treated in such a manner. 12 333. L.T.T.’s meltdown and the treatment which proximately caused 13 L.T.T. to experience them caused him grave and extreme mental anguish and 14 emotional trauma, for which Disney should be held accountable. 15 WHEREFORE, Plaintiff L.T.T., by and through L.J.T., as L.T.T.’s next 16 friend, parent, and natural guardian, prays that this Court adjudicate this DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 dispute and enter an Order: 18 • Finding that Disney intentionally inflicted emotional distress 19 uponDeadline.com L.T.T.; and 20 • Finding such infliction to have caused damages to L.T.T.; and 21 • Entering judgment for Plaintiff L.T.T. in the amount of such 22 damages; 23 • Entering judgment in favor of Plaintiffs and against Disney for 24 exemplary or punitive damages; and 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding prejudgment interest; and 4 • Such other relief as this Court may find just and equitable. 5 COUNT 24 6 Negligent Infliction of Emotional Distress 7 L.J.T. v. Disney 8 334. Plaintiff L.J.T. incorporates and re-alleges the allegations of 9 paragraphs 1 through 90, 303 through 329, and 331 through 333 above. 10 335. During one or more visits to the Parks, L.J.T.’s beloved son, L.T.T., 11 suffered actual meltdowns while in L.J.T.’s presence. 12 336. L.T.T.’s meltdowns in the Parks were proximately caused by 13 Disney’s negligent, unlawful, reckless and arbitrary treatment of L.T.T. during 14 his patronage of Disney’s facilities. At all material times, Disney knew L.T.T. to 15 be vulnerable to emotional injury if treated in such a manner by anyone. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 337. L.J.T. directly observed the stressors leading up to the meltdowns, 17 L.T.T.’s escalating frustration, and his resulting meltdowns. Particularly in 18 light of her trust and confidence that Disney would comply with applicable 19 law and act in aDeadline.com gracious and caring manner toward her son, L.J.T. could do 20 nothing reasonable to prevent the meltdowns. 21 338. L.J.T.’s observation of L.T.T.’s meltdowns and of the outrageous 22 conduct and treatment which proximately caused L.T.T. to experience the 23 meltdowns, caused L.J.T. grave and extreme mental anguish and emotional 24 trauma, for which Disney should be held accountable. 25

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1 WHEREFORE, Plaintiff L.J.T. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney negligently inflicted emotional distress 4 upon L.J.T.; and 5 • Finding such infliction to have caused damages to L.J.T.; and 6 • Entering judgment for Plaintiff L.J.T. in the amount of such 7 damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 25 13 Intentional Infliction of Emotional Distress 14 L.J.T. v. Disney 15 339. Plaintiff L.J.T. incorporates and re-alleges the allegations of 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI paragraphs 1 through 90, 303 through 329, and 331 through 333 above. 17 340. During one or more visits to the Parks, L.J.T.’s beloved son, L.T.T., 18 suffered actual meltdowns. 19 341. L.T.T.’sDeadline.com meltdowns in the Parks were proximately caused by 20 Disney’s outrageous, unlawful, and reckless treatment of L.T.T. during his 21 patronage of Disney’s facilities. At all material times, Disney knew L.T.T. to be 22 vulnerable to emotional injury if treated in such a manner by anyone. 23 342. L.J.T. directly observed the stressors leading up to the meltdowns, 24 L.T.T.’s increasing distress, and his resulting meltdowns. Particularly in light 25

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1 of her trust and confidence that Disney would comply with applicable law and 2 act in a gracious and caring manner toward her son, L.J.T. could do nothing 3 reasonable to prevent the meltdowns. 4 343. L.J.T.’s witnessing of L.T.T.’s meltdowns and of the outrageous 5 conduct and treatment which proximately caused L.T.T. to experience the 6 meltdowns, caused L.J.T. grave and extreme mental anguish and emotional 7 trauma, for which Disney should be held accountable. 8 WHEREFORE, Plaintiff L.J.T. prays that this Court adjudicate this 9 dispute and enter an Order: 10 • Finding that Disney intentionally inflicted emotional distress

11 upon L.J.T.; and 12 • Finding such infliction to have caused damages to L.J.T.; and 13 • Entering judgment for Plaintiff L.J.T. in the amount of such 14 damages; 15 • Entering judgment in favor of Plaintiffs and against Disney for 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI exemplary or punitive damages; and 17 • Awarding reasonable litigation costs as may be determined by 18 the Court in favor of Plaintiff and against Disney; and 19 • AwardingDeadline.com prejudgment interest; and 20 • Such other relief as this Court may find just and equitable. 21

22 23 24 25

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1 COUNT 26 2 Breach of Contract 3 L.J.T. v. Disney 4 344. Plaintiff L.J.T. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, 303 through 329, and 331 through 333 above. 6 345. L.J.T. entered into a contract through which Disney promised to 7 provide a reasonable and enjoyable amusement park experience, and one 8 which complies with applicable law. 9 346. Disney failed or refused to provide the promised experience, and 10 is in breach of contract.

11 347. L.J.T. incurred expenses associated with the family’s wasted trips 12 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 13 WHEREFORE, Plaintiff L.J.T. prays that this Court adjudicate this 14 dispute and enter an Order: 15 • Finding that Disney breached its contract with L.J.T.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment for Plaintiff L.J.T. in the amount of her 17 economic monetary damages; and 18 • Awarding reasonable litigation costs as may be determined by 19 the CourtDeadline.com in favor of Plaintiff and against Disney; and 20 • Awarding prejudgment interest; and 21 • Such other relief as this Court may find just and equitable. 22

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1 COUNT 27 2 Negligent Infliction of Emotional Distress 3 L.D.J. v. Disney 4 348. Plaintiff L.J.T. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90 above. 6 349. L.D.J. has autism. Her cognitive level is that of a third grader, 7 approximately nine years below her equivalent grade level. L.D.J.’s verbal 8 skills are extremely limited. 9 350. Autism substantially limits a person’s ability to care for herself, 10 perform manual tasks, speak, learn, read, concentrate, think, communicate,

11 perceive the concept of time, pair sights and sounds that happen 12 simultaneously, and work. 13 351. L.D.J. becomes particularly agitated when forced to idly wait for 14 extended periods of time, or when there is any type of modification to her 15 usual routines. 16 352. L.D.J. expresses her frustrations through behavioral meltdowns

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 which generally consist of intense, extremely loud, dramatic crying episodes 18 that adversely affect her breathing. 19 353. L.D.J.Deadline.com is a person with a disability, pursuant to that term’s 20 definition in 42 U.S.C. §12102(1). 21 354. L.D.J. is 18 years old and in the care of her mother, T.M.J., who 22 brings this action as L.D.J.'s next friend, parent, and natural guardian, and her 23 father, D.A.J. 24 355. L.D.J. and T.M.J. are residents of Los Angeles County, California. 25

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1 356. L.D.J. first attended Disneyland with her parents when she was 2 two or three years of age. Because Disneyland was close to their home, L.D.J., 3 T.M.J., and D.A.J visited frequently. During these visits, L.D.J. exhibited a level 4 of excitement and joy she rarely exhibited elsewhere. For L.D.J and her family, 5 trips to Disneyland before the DAS were magical experiences. 6 357. For most of her childhood and throughout her teens, L.D.J. visited 7 Disneyland with T.M.J. and D.A.J., was issued a Guest Assistance Card, and was 8 wonderfully accommodated. T.M.J. loved the experience so much she became 9 a “Disney kid”. Her bedroom is decorated in a Disney theme, and going to 10 Disneyland was the one thing in the world T.M.J. felt was special for her

11 daughter. It was the one place where L.D.J. actually enjoyed herself, and the 12 only place where people really seemed to care for her. T.M.J. delighted in the 13 opportunity to bring to her beloved daughter a level of happiness which she 14 simply is unable to express anywhere but Disneyland. 15 358. For the past fourteen years, T.M.J., D.A.J., and L.D.J. have been 16 premium pass holders for Disneyland; visiting whenever they wished. L.D.J. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 rarely experienced behavioral meltdowns because with the Guest Assistance 18 Card, they were provided efficient access with few restrictions. 19 359. SinceDeadline.com L.D.J. was a small child, her cognitive impairments have 20 manifested themselves in a specific way during the family’s visits to the Parks: 21 L.D.J. must experience her favorite Disneyland rides in a precise, exact order. 22 For example, L.D.J. must start any Disneyland visit at the Teacups ride, and 23 must then proceed to It’s a Small World. The family happily followed the same 24 25

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1 schedule, during every single visit. Any changes or disruptions in that routine 2 would have resulted in a meltdown. 3 360. Whenever L.D.J. suffers through a meltdown, her parents make 4 every attempt to calm her down. However, nothing they try will soothe her. 5 These experiences are heart wrenching for T.M.J.’s parents because they want 6 nothing more than to help their daughter, but all they can do is wait for the 7 meltdown to subside. 8 361. Similarly, if L.D.J. is required to idly wait for entry into a ride or 9 attraction for more than a few minutes, she will experience a meltdown. 10 362. Because L.D.J. is incapable of understanding the concept of visiting

11 a ride or attraction for the purpose of making an appointment to come back 12 later. Traveling to an attractive only to be refused admission, as required by 13 the DAS, creates avoidable stressors for L.D.J., which significantly increases 14 the probability of experiencing a meltdown. In fact, since the implementation 15 of the DAS, L.D.J. has actually experienced several meltdowns at Disneyland. 16 363. T.M.J. and D.A.J were first told about Disney’s new DAS at City Hall.

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 They attempted to explain to Disney employees the ways in which the system 18 would not accommodate L.D.J.’s special needs. However, the Disney 19 employees refusedDeadline.com to discuss any individualized assessment of whether the 20 DAS would accommodate L.D.J.’s disability. They refused to discuss additional 21 accommodations, instead repeating the new Disney employee refrain that the 22 DAS is the new Disney policy and nothing else can or will be done. 23 364. After implementation of the DAS, Disneyland ceased being the 24 most wonderful place in the world for T.M.J. Instead, it was horrible. When 25

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1 confronted with the DAS’s inability to provide fair accommodations for L.D.J., 2 Disney employees uniformly responded: “This is what the policy is; this is how 3 we were trained.” 4 365. This new policy and training requires L.D.J.’s family to spend 5 additional time walking around the park, getting L.D.J.’s DAS passport 6 stamped, and making appointments for future rides. The DAS compounds this 7 frustration prohibiting the family from obtaining simultaneous wait times; i.e., 8 they cannot go on one ride while waiting for their turn to go on another ride. 9 366. Due to Disney’s arbitrary and discriminatory accessibility policy, 10 and due to Disney’s refusal to conduct individualized assessments, and due to

11 its refusal to accommodate guests with cognitive disabilities such as L.D.J., 12 L.D.J. has been prevented from experiencing the full enjoyment of the Parks, to 13 the same extent afforded to persons without a disability. 14 367. After DAS went into effect, L.D.J. no longer received the type of 15 accommodation and attention L.D.J., T.M.J, and D.A.J. received when they 16 visited the Parks in the past. L.D.J and her family have not returned to DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disneyland since their last visit during late 2013. 18 368. Due to Disney’s refusal to modify its procedures to reasonably 19 accommodate L.D.J.’sDeadline.com needs, L.D.J. has been deterred from the full use and 20 enjoyment of the park’s rides and attractions. As a consequence, the family’s 21 interest in attending Disneyland while the DAS remains in place has been 22 considerably reduced, if not completely extinguished. 23 369. T.M.J. and D.A.J. would continue to visit the Parks with L.D.J. 24 frequently, as they did for fourteen years, had Disney not abandoned its past 25

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1 practices of accommodating the special needs of persons with cognitive 2 impairments. The family’s decision to not return to Disneyland since their late 3 2013 visit is directly attributable to the dreadful experiences they have been 4 subjected to under the DAS. 5 370. Notwithstanding Disney’s highly sophisticated knowledge and 6 awareness of the needs of persons with cognitive impairments, and 7 notwithstanding Disney’s historic eagerness and ability to accommodate 8 L.D.J.’s special needs, Disney personnel have refused to conduct an 9 individualized assessment of L.D.J.'s capacity to avail herself to the DAS 10 policies; and to modify the DAS to allow L.D.J. to enjoy the same benefits and

11 privileges as non-disabled guests. 12 371. Disney personnel have shown no openness, willingness or desire 13 to improve the experience for guests like L.D.J. 14 372. T.M.J. incurred monetary costs associated with the family’s 15 lamentable and wasted post-DAS trip to Disneyland. 16 373. During one or more visits to the Parks, L.D.J. suffered actual

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 meltdowns. 18 374. The symptoms and conditions associated with L.D.J.’s meltdowns 19 constitute a physicalDeadline.com injury under California and Florida law. 20 375. L.D.J.’s meltdowns in the Parks were proximately caused by 21 Disney’s negligent, unlawful, reckless, and arbitrary treatment of L.D.J. during 22 her patronage of Disney’s facilities. At all material times, Disney knew L.D.J. to 23 be vulnerable to emotional injury if treated in such a manner. 24 25

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1 376. L.D.J.’s meltdowns and the treatment which proximately caused 2 L.D.J. to experience them caused her grave and extreme mental anguish and 3 emotional trauma, for which Disney should be held accountable. 4 WHEREFORE, Plaintiff L.D.J., by and through T.M.J. as L.D.J.’s next 5 friend, parent, and natural guardian, prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Enjoining Defendant to cease the practices which are causing 8 discrimination against Plaintiff on account of L.D.J.’s disability; 9 and 10 • Enjoining Defendant to reasonably modify its policies,

11 practices, and procedures in order to afford Plaintiff with an 12 opportunity to experience Disney’s goods, services, facilities, 13 privileges, advantages, and accommodations; and 14 • Establishing Court-approved remedial measures that Disney 15 must implement, to prevent Disney from further discriminating 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI against Plaintiff when she visits the Disney Parks; and 17 • Establishing Court-approved requirements for information 18 dissemination regarding Disney’s remedial measures and 19 modifiedDeadline.com policies, to prevent Disney from further deterring 20 Plaintiff from visiting Disney Parks as a result of anticipated 21 discrimination; and 22 • Establishing a monitoring program to ensure Disney’s 23 compliance with the Court’s Orders; and 24 25

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1 • Finding that Disney negligently inflicted emotional distress 2 upon L.D.J.; and 3 • Finding such infliction to have caused damages to L.D.J.; and 4 • Entering judgment for Plaintiff L.D.J. in the amount of such 5 damages; and 6 • Awarding reasonable litigation costs as may be determined by 7 the Court in favor of Plaintiff and against Disney; and 8 • Awarding prejudgment interest; and 9 • Such other relief as this Court may find just and equitable. 10 COUNT 28

11 Intentional Infliction of Emotional Distress 12 L.D.J. v. Disney 13 377. Plaintiff L.D.J. incorporates and re-alleges the allegations of 14 paragraphs 1 through 90 and 349 through 376 above. 15 378. During one or more visits to the Parks, L.D.J. suffered actual 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI meltdowns. 17 379. The symptoms and conditions associated with L.D.J.’s meltdowns 18 constitute a physical injury under California and Florida law. 19 380. L.D.J.’sDeadline.com meltdowns in the Parks were proximately caused by 20 Disney’s outrageous, unlawful and reckless treatment of L.D.J. during her 21 patronage of Disney’s facilities. At all material times, Disney knew L.D.J. to be 22 vulnerable to emotional injury if treated in such a manner. 23 24 25

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1 381. L.D.J.’s meltdown and the treatment which proximately caused 2 L.D.J. to experience them caused her grave and extreme mental anguish and 3 emotional trauma, for which Disney should be held accountable. 4 WHEREFORE, Plaintiff L.D.J., by and through T.M.J., as L.D.J.’s next 5 friend, parent, and natural guardian, prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney intentionally inflicted emotional distress 8 upon L.D.J.; and 9 • Finding such infliction to have caused damages to L.D.J.; and 10 • Entering judgment for Plaintiff L.D.J. in the amount of such 11 damages; 12 • Entering judgment in favor of Plaintiffs and against Disney for 13 exemplary or punitive damages; and 14 • Awarding reasonable litigation costs as may be determined by 15 the Court in favor of Plaintiff and against Disney; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Awarding prejudgment interest; and 17 • Such other relief as this Court may find just and equitable. 18 COUNT 29 19 NegligentDeadline.com Infliction of Emotional Distress 20 T.M.J. v. Disney 21 382. Plaintiff T.M.J. incorporates and re-alleges the allegations of 22 paragraphs 1 through 90, 349 through 376, and 378 through 381 above. 23 383. During one or more visits to the Parks, T.M.J.’s beloved daughter, 24 L.D.J., suffered actual meltdowns while in T.M.J.’s presence. 25

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1 384. The symptoms and conditions associated with L.D.J.’s meltdowns 2 constituted a physical injury to T.M.J. under California and Florida law. 3 385. L.D.J.’s meltdowns in the Parks were proximately caused by 4 Disney’s negligent, unlawful, reckless and arbitrary treatment of L.D.J. during 5 her patronage of Disney’s facilities. At all material times, Disney knew L.D.J. to 6 be vulnerable to emotional injury if treated in such a manner by anyone. 7 386. T.M.J. directly observed the stressors leading up to the 8 meltdowns, L.D.J.’s escalating frustration, and her resulting meltdowns. 9 Particularly in light of her trust and confidence that Disney would comply 10 with applicable law and act in a gracious and caring manner toward her

11 daughter, T.M.J. could do nothing reasonable to prevent the meltdowns. 12 387. T.M.J.’s observation of L.D.J.’s meltdowns and of the outrageous 13 conduct and treatment which proximately caused L.D.J. to experience the 14 meltdowns, caused T.M.J. grave and extreme mental anguish and emotional 15 trauma, for which Disney should be held accountable. 16 WHEREFORE, Plaintiff T.M.J. prays that this Court adjudicate this DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 dispute and enter an Order: 18 • Finding that Disney negligently inflicted emotional distress 19 uponDeadline.com T.M.J.; and 20 • Finding such infliction to have caused damages to T.M.J.; and 21 • Entering judgment for Plaintiff T.M.J. in the amount of such 22 damages; and 23 • Awarding reasonable litigation costs as may be determined by 24 the Court in favor of Plaintiff and against Disney; and 25

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1 • Awarding prejudgment interest; and 2 • Such other relief as this Court may find just and equitable. 3 COUNT 30 4 Intentional Infliction of Emotional Distress 5 T.M.J. v. Disney 6 388. Plaintiff T.M.J. incorporates and re-alleges the allegations of 7 paragraphs 1 through 90, 349 through 376, and 378 through 381 above. 8 389. During one or more visits to the Parks, T.M.J.’s beloved daughter, 9 L.D.J., suffered actual meltdowns. 10 390. The symptoms and conditions associated with L.D.J.’s meltdowns

11 constitute a physical injury under California and Florida law. 12 391. L.D.J.’s meltdowns in the Parks were proximately caused by 13 Disney’s outrageous, unlawful, and reckless treatment of L.D.J. during her 14 patronage of Disney’s facilities. At all material times, Disney knew L.D.J. to be 15 vulnerable to emotional injury if treated in such a manner by anyone. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 392. T.M.J. directly observed the stressors leading up to the 17 meltdowns, L.D.J.’s escalating distress, and her resulting meltdowns. 18 Particularly in light of her trust and confidence that Disney would comply 19 with applicable Deadline.comlaw and act in a gracious and caring manner toward her 20 daughter, T.M.J. could do nothing reasonable to prevent the meltdowns. 21 393. T.M.J.’s witnessing of L.D.J.’s meltdowns and of the outrageous 22 conduct and treatment which proximately caused L.D.J. to experience the 23 meltdowns, caused T.M.J. grave and extreme mental anguish and emotional 24 trauma, for which Disney should be held accountable. 25

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1 WHEREFORE, Plaintiff T.M.J. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney intentionally inflicted emotional distress 4 upon T.M.J.; and 5 • Finding such infliction to have caused damages to T.M.J.; and 6 • Entering judgment for Plaintiff T.M.J. in the amount of such 7 damages; 8 • Entering judgment in favor of Plaintiffs and against Disney for 9 exemplary or punitive damages; and 10 • Awarding reasonable litigation costs as may be determined by

11 the Court in favor of Plaintiff and against Disney; and 12 • Awarding prejudgment interest; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 31 15 Breach of Contract 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI T.M.J. v. Disney 17 394. Plaintiff T.M.J. incorporates and re-alleges the allegations of 18 paragraphs 1 through 90, 349 through 376, and 378 through 381 above. 19 395. T.M.J.Deadline.com entered into a contract through which Disney promised to 20 provide a reasonable and enjoyable amusement park experience, and one 21 which complies with applicable law. 22 396. Disney failed or refused to provide the promised experience, and 23 is in breach of contract. 24 25

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1 397. T.M.J. incurred monetary costs associated with the family’s ruined 2 and wasted trips to the Parks. Plaintiff is damaged by Disney’s breach of 3 contract. 4 WHEREFORE, Plaintiff T.M.J. prays that this Court adjudicate this 5 dispute and enter an Order: 6 • Finding that Disney breached its contract with T.M.J.; and 7 • Entering judgment for Plaintiff T.M.J. in the amount of her 8 economic monetary damages; and 9 • Awarding reasonable litigation costs as may be determined by 10 the Court in favor of Plaintiff and against Disney; and

11 • Awarding prejudgment interest; and 12 • Such other relief as this Court may find just and equitable. 13 COUNT 32 14 Negligent Infliction of Emotional Distress 15 D.A.J v. Disney 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 398. Plaintiff D.A.J. incorporates and re-alleges the allegations of 17 paragraphs 1 through 90, 349 through 376, and 378 through 381 above. 18 399. During one or more visits to the Parks, D.A.J.’s beloved daughter, 19 L.D.J., suffered actualDeadline.com meltdowns while in D.A.J.’s presence. 20 400. The symptoms and conditions associated with L.D.J.’s meltdowns 21 constitute a physical injury to L.D.J. under California and Florida law. 22 401. L.D.J.’s meltdowns in the Parks were proximately caused by 23 Disney’s negligent, unlawful, reckless, and arbitrary treatment of L.D.J. during 24 25

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1 her patronage of Disney’s facilities. At all material times, Disney knew L.D.J. to 2 be vulnerable to emotional injury if treated in such a manner by anyone. 3 402. D.A.J. directly observed the stressors leading up to the meltdowns, 4 L.D.J.’s escalating distress, and her resulting meltdowns. Particularly in light 5 of his trust and confidence that Disney would comply with applicable law and 6 act in a gracious and caring manner toward his daughter, D.A.J. could do 7 nothing reasonable to prevent the meltdowns. 8 403. D.A.J.’s witnessing of L.D.J.’s meltdowns and of the outrageous 9 conduct and treatment which proximately caused L.D.J. to experience the 10 meltdowns, caused D.A.J. grave and extreme mental anguish and emotional

11 trauma, for which Disney should be held accountable. 12 WHEREFORE, Plaintiff D.A.J. prays that this Court adjudicate this 13 dispute and enter an Order: 14 • Finding that Disney negligently inflicted emotional distress 15 upon D.A.J.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Finding such infliction to have caused damages to D.A.J.; and 17 • Entering judgment for Plaintiff D.A.J. in the amount of such 18 damages; and 19 • AwardingDeadline.com reasonable litigation costs as may be determined by 20 the Court in favor of Plaintiff and against Disney; and 21 • Awarding prejudgment interest; and 22 • Such other relief as this Court may find just and equitable. 23

24 25

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1 COUNT 33 2 Intentional Infliction of Emotional Distress 3 D.A.J. v. Disney 4 404. Plaintiff D.A.J. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, 349 through 376, and 378 through 381 above. 6 405. During one or more visits to the Parks, D.A.J.’s beloved daughter, 7 L.D.J., suffered actual meltdowns. 8 406. The symptoms and conditions associated with L.D.J.’s meltdowns 9 constitute a physical injury under California and Florida law. 10 407. L.D.J.’s meltdowns in the Parks were proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of L.D.J. during her 12 patronage of Disney’s facilities. At all material times, Disney knew L.D.J. to be 13 vulnerable to emotional injury if treated in such a manner by anyone. 14 408. D.A.J. directly observed the stressors leading up to the meltdowns, 15 L.D.J.’s escalating distress, and her resulting meltdowns. Particularly in light 16 of his trust and confidence that Disney would comply with applicable law and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 act in a gracious and caring manner toward his daughter, D.A.J. could do 18 nothing reasonable to prevent the meltdown. 19 409. D.A.J.’sDeadline.com witnessing of L.D.J.’s meltdown and of the outrageous 20 conduct and treatment which proximately caused L.D.J. to experience the 21 meltdowns, caused D.A.J. grave and extreme mental anguish and emotional 22 trauma, for which Disney should be held accountable. 23 WHEREFORE, Plaintiff D.A.J. prays that this Court adjudicate this 24 dispute and enter an Order: 25

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1 • Finding that Disney intentionally inflicted emotional distress 2 upon D.A.J.; and 3 • Finding such infliction to have caused damages to D.A.J.; and 4 • Entering judgment for Plaintiff D.A.J. in the amount of such 5 damages; 6 • Entering judgment in favor of Plaintiffs and against Disney for 7 exemplary or punitive damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 34 13 Breach of Contract 14 E.G.R. v. Disney 15 410. Plaintiff E.G.R. incorporates and re-alleges the allegations of 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI paragraphs 1 through 90 above. 17 411. P.H.G. has cerebral palsy, seizure disorder and anxiety. He is 18 100% disabled, as a wheelchair-bound quadriplegic. P.H.G. doesn’t speak, 19 walk or move hisDeadline.com hands. 20 412. P.H.G. is 23 years of age and is generally in the care of his mother, 21 E.G.R., who brings this action as P.H.G.’s court appointed conservator, next 22 friend, parent and natural guardian. 23 413. P.H.G. and E.G.R. are residents of San Bernardino County, 24 California. 25

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1 414. E.G.R. was an annual passholder who, prior to October 9, 2013, 2 visited Disneyland every month along with P.H.G. and P.H.G.’s father and four 3 brothers. During those visits, P.H.G. exhibited a nature and extent of joy that 4 he rarely showed in any other setting. E.G.R. was always proud and joyful of 5 the opportunity to bring to her beloved child a level of happiness which he 6 rarely showed elsewhere. 7 415. P.H.G. is incapable of idly waiting or biding time without his 8 cognitive impairments causing him to experience stimming and meltdowns or 9 being at risk from heat imposed anxiety and seizures. 10 416. On December 31, 2014, P.H.G. and his six family members visited

11 Disneyland and waited on a line at City Hall for over an hour to get a DAS card. 12 All seven family members had to wait on line as the Disney employee claimed 13 he had to see every family member in order for the pass to include them. 14 417. As a result of the long wait at City Hall, P.H.G. and his family did 15 not get to their first ride until two hours after they entered Disneyland. 16 418. P.H.G. wears a disposable undergarment for incontinence that

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 must be changed every two hours. 18 419. Based on the medical need to change P.H.G.’s undergarment, 19 P.H.G. missed a Deadline.comreturn ride time under the DAS. Despite explaining that to 20 employee at the attraction, the party was refused access to the ride. 21 420. P.H.G. and his family were also turned away from rides, including 22 the Peter Pan ride, when the party arrived with the DAS card to get a return 23 time and were told “we are not doing the DAS right now, you can come back 24 when we start doing them.” 25

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1 421. Yet when E.G.R. inquired “when is that?” The Disney employee 2 responded, “we don’t know.” 3 422. Disney failed to provide an opportunity to return and enjoy the 4 ride, and in doing so, failed to provide to P.H.G. a full opportunity to enjoy the 5 park, equal to those without a disability. 6 423. In fact, Disney affirmatively frustrated P.H.G.’s opportunity to 7 enjoy the park when a Disney employee sent away the party from the Space 8 Mountain DAS kiosk and falsely told them that only City Hall could provide a 9 Space Mountain return time in their passbook. 10 424. After being unnecessarily run around the park for 30 minutes in

11 order to get a ride time in his passbook for Space Mountain, P.H.G. and his 12 party learned that the information the Disney employee gave them was false. 13 They received a ride time for Space Mountain at the kiosk for Buzz Lightyear 14 which provided a return time that was another two hours later. 15 425. This scavenger hunt for a ride time was so stressful to P.H.G. and 16 caused so much anxiety that his entire body began to shake and convulse. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 426. The problem of rides being less accessible to the disabled than to 18 the rest of the population is pervasive and continued during P.H.G.’s visit to 19 California AdventureDeadline.com Park in January 2014. 20 427. At California Adventure, P.H.G.’s party was given a time to come 21 back but upon returning, the ride was not open and a Disney employee told 22 the party they had to wait another prolonged period of time until a newly- 23 issued passbook return time. 24 25

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1 428. Since Disney’s implementation of the new DAS, Defendant has 2 prevented P.H.G. from experiencing the full enjoyment of the Disney Parks, 3 equal to those without a disability. 4 429. In order to experience the facilities and services of Disney Parks 5 since the implementation of the DAS, P.H.G. is now forced to idly stand in an 6 extended-duration line, enduring all potential anxiety and seizure triggers, at 7 City Hall to have his photograph taken and a Disability Access Service Card 8 made for him. 9 430. Similarly, each time P.H.G. wants to experience Disneyland, he is 10 forced to idly wait amongst anxiety and seizure triggers, just to obtain

11 passbook return times. 12 431. The DAS card is only valid for approximately two weeks, despite 13 the fact that P.H.G.’s diagnosis will not change and his annual pass is good for 14 twelve months. The expiration of the DAS card after approximately two 15 weeks assures that each visit to the Parks will begin with stressors, not 16 pleasures. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 432. Since Defendant’s implementation of the DAS, P.H.G. and E.G.R. 18 have visited multiple Disney Parks, including Disneyland and California 19 Adventure Park Deadline.comon multiple occasions, including but not limited to visits on 20 December 31, 2013 and January, 2014. 21 433. The new procedure triggers P.H.G.’s anxiety and seizure more 22 frequently at the Disney Parks. 23 24 25

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1 434. The accommodations Disney claims to provide through the DAS 2 will not allow P.H.G. to utilize his annual pass in such a way that it provides 3 the equal enjoyment of the Disney Parks as that of a non disabled person. 4 435. Notwithstanding Disney’s highly sophisticated knowledge of the 5 needs of persons with cognitive impairments and other disabilities, and 6 notwithstanding Disney’s historic ability to accommodate P.H.G.’s special 7 needs, Disney personnel now offered ineffective, apathetic, obtuse responses 8 to E.G.R.’s recitations regarding P.H.G.’s needs. The further refuse to conduct 9 any individualized assessment of P.H.G.’s accessibility needs, particularly 10 whether Disney’s inflexible application of the DAS can accommodate them.

11 Disney’s actions and statements are so contrary to Disney’s body of 12 knowledge and to Disney’s historic performance that Disney cannot have 13 accidentally proposed such absurdities. 14 436. Disney personnel showed no openness, willingness or desire to 15 improve the experience for guests like P.H.G. 16 437. E.G.R. incurred expenses associated with the family’s wasted trips

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 to the park. 18 438. The interest P.H.G. and E.G.R. have in attending Disney Parks is 19 substantially reduced.Deadline.com 20 439. P.H.G. is and at all material times has been a disabled person 21 within the meaning of California Government Code §1296(j). 22 440. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 23 provides protection from discrimination by all business establishments in 24 California, including housing and public accommodations, because of age, 25

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1 ancestry, color, disability, national origin, race, religion, sex and sexual 2 orientation. 3 441. Section 52 of the California Civil Code provides that whoever 4 denies, aids or incites a denial, or makes any discrimination or distinction 5 contrary to Section 51 is liable for each and every offense. 6 442. Pursuant to California Civil Code Section 51(f), a violation of the 7 ADA also constitutes a violation of California Civil Code Section 51, et seq. 8 443. The Parks are “business establishments” within the meaning of 9 the California Code Section 51, et seq. 10 444. E.G.R. entered into a contract through which Disney promised to

11 provide a reasonable and enjoyable amusement park experience, and one 12 which complies with applicable law. 13 445. Disney failed or refused to provide the promised experience, and 14 is in breach of contract. 15 446. E.G.R. incurred expenses associated with the family’s wasted trips 16 to the Parks. Plaintiff is damaged by Disney’s breach of contract. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 WHEREFORE, Plaintiff E.G.R. prays that this Court adjudicate this 18 dispute and enter an Order: 19 • FindingDeadline.com that Disney breached its contract with E.G.R.; and 20 • Entering judgment for Plaintiff E.G.R. in the amount of her 21 economic monetary damages; and 22 • Awarding reasonable litigation costs as may be determined by 23 the Court in favor of Plaintiff and against Disney; and 24 • Awarding prejudgment interest; and 25

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1 • Such other relief as this Court may find just and equitable. 2 COUNT 35 3 Breach of Contract 4 J.H. v. Disney 5 447. Plaintiff J.H. incorporates and re-alleges the allegations of 6 paragraphs 1 through 90 above. 7 448. G.H. has Asperger’s syndrome, sensory integration dysfunction, 8 bipolar disorder, fibromyalgia, asthma, scoliosis, depression, anxiety, 9 orthostatic hypotension (dizzy spells), irritable bowel syndrome, and Type II 10 diabetes.

11 449. G.H. is 20 years of age, 6’2”, 250 pounds, and is generally in the 12 care of his mother, J.H., who brings this action as G.H.’s next friend, parent and 13 natural guardian. 14 450. G.H. and J.H. are residents of Los Angeles County, California. 15 451. G.H. and J.H. were annual pass holders who, prior to October 9, 16 2013, regularly visited Disneyland and Disney’s California Adventure. During DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 those visits, G.H. exhibited a nature and extent of joy that he rarely showed in 18 any other setting. J.H. was always proud and joyful of the opportunity to bring 19 to her beloved childDeadline.com a level of happiness which he rarely showed elsewhere. 20 452. G.H. is incapable of idly biding time for any significant period of 21 time without his cognitive impairments causing him to experience stimming 22 and meltdowns. Triggers will cause G.H. to exhibit stimming behaviors 23 including flapping his arms and hitting himself. 24 25

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1 453. In addition, G.H.’s sensory integration dysfunction causes him to 2 dislike others touching or getting too close to him. This causes irritation and 3 aggressive behavior. 4 454. Before G.H. went to Disneyland on October 25, 2013, J.H. wrote to 5 Disney to inquire about the effect of the DAS on her son and his disability. She 6 communicated that G.H. cannot tolerate extended idle waits. In response, J.H. 7 was told that Disney has long recognized that people have different needs, and 8 that Disney would continue to work individually with their guests with 9 disabilities to provide assistance that is responsive to their unique 10 circumstances. She was also told to visit Guest Relations at any of the Parks to

11 discuss her individual situation. Disney further assured J.H. that Disney would 12 work with J.H. to accommodate G.H. and the family’s specific needs. 13 455. Disney also represented that in addition to the DAS, 14 supplementary FastPasses may be available to G.H. at Guest Relations. J.H. 15 was not told that with the DAS, J.H. would have to check in at the ride, be given 16 a time to come back, and then still have to wait around for admission. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 456. Based on Disney’s assurances, J.H. renewed the annual passes and 18 the family visited the Disneyland on October 11, 2013 and on October 25, 19 2013. Deadline.com 20 457. During the October 11 visit, J.H. and G.H. waited in line for over 30 21 minutes at Disney’s California Adventure, in order to speak with an employee 22 about the DAS program. G.H. was on the verge of a complete meltdown as a 23 result of the wait, the noise, and the number of people present at Guest 24 25

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1 Relations. J.H. and G.H. ended up leaving the park because G.H. was highly 2 agitated. 3 458. During the October 25 visit, J.H. took the day off work, hoping that 4 the DAS would work better on a less crowded day. However, once again, at 5 Guest Relations at Disney’s California Adventure, G.H. became agitated. 6 Because Disney refused to provide any type of accommodation for her son, J.H. 7 said she wanted to cancel her annual passes. 8 459. In order to experience the facilities and services of Disney Parks 9 since the implementation of the DAS, G.H. was forced to begin his day by idly 10 standing in an extended-duration line, enduring all potential meltdown

11 triggers, at City Hall to have his photograph taken and a DAS Card made for 12 him. 13 460. Similarly, each time G.H. wanted to experience Disneyland, he was 14 forced to idly wait amongst trigger after trigger for return times on each ride, 15 which limited the order in which he could experience the rides. 16 461. The DAS card is only valid for approximately two weeks, despite

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 the fact that G.H.’s diagnosis will not change and the annual pass is good for 18 twelve months. The expiration of the DAS card after approximately two 19 weeks assures thatDeadline.com each visit to the Parks will begin with stressors, not 20 pleasures. 21 462. Since Disney’s implementation of the new DAS, Defendant has 22 prevented G.H. from experiencing the full enjoyment, equal to those without a 23 disability, of the Disney Parks. 24 25

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1 463. The accommodations Disney claims to provide through the DAS 2 will not allow G.H. to experience equal enjoyment of the Disney Parks as that 3 of a nondisabled person. 4 464. Notwithstanding Disney’s highly sophisticated knowledge of the 5 needs of persons with cognitive impairments, and notwithstanding Disney’s 6 historic ability to accommodate G.H.’s special needs, Disney personnel now 7 offered ineffective, apathetic, obtuse responses to J.H.’s recitations regarding 8 G.H.’s needs. Disney refuses to conduct an individualized assessment of the 9 DAS’s inability to accommodate G.H.’s accessibility needs. Disney’s actions 10 and statements were so contrary to Disney’s body of knowledge and to

11 Disney’s historic performance that Disney cannot have accidentally proposed 12 such absurdities. 13 465. Disney personnel showed no openness, willingness or desire to 14 improve the experience for guests like G.H. despite the advanced notice they 15 received of G.H.’s needs for accommodations. 16 466. J.H. incurred expenses associated with the family’s wasted trips to

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disneyland. Some costs were reimbursed after she cancelled the family’s 18 annual passes at the time of the October 25 visit, but many costs remain 19 unreimbursed. Deadline.com 20 467. G.H. and J.H. have not returned to the Disney Parks since J.H 21 cancelled their annual passes on October 25. 22 468. G.H. is and at all material times has been a disabled person within 23 the meaning of California Government Code §1296(j). 24 25

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1 469. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 2 provides protection from discrimination by all business establishments in 3 California, including housing and public accommodations, because of age, 4 ancestry, color, disability, national origin, race, religion, sex and sexual 5 orientation. 6 470. Section 52 of the California Civil Code provides that whoever 7 denies aids or incites a denial, or makes any discrimination or distinction 8 contrary to Section 51 is liable for each and every offense. 9 471. Pursuant to California Civil Code Section 51(f), a violation of the 10 ADA also constitutes a violation of California Civil Code Section 51, et seq.

11 472. The Parks are “business establishments” within the meaning of 12 the California Code Section 51, et seq. 13 473. J.H. entered into a contract through which Disney promised to 14 provide a reasonable and enjoyable amusement park experience, and one 15 which complies with applicable law. 16 474. Disney failed or refused to provide the promised experience, and

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 is in breach of contract. 18 475. J.H. incurred expenses associated with the family’s wasted trips to 19 the Parks. PlaintiffDeadline.com is damaged by Disney’s breach of contract. 20 WHEREFORE, Plaintiff J.H. prays that this Court adjudicate this 21 dispute and enter an Order: 22 • Finding that Disney breached its contract with J.H.; and 23 • Entering judgment for Plaintiff J.H. in the amount of her 24 economic monetary damages; and 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding prejudgment interest; and 4 • Such other relief as this Court may find just and equitable. 5 COUNT 36 6 Negligent Infliction of Emotional Distress 7 T.A.L. v. Disney 8 476. Plaintiff T.A.L. incorporates and re-alleges paragraphs 1 through 9 90 above. 10 477. T.A.L. has autism. He is largely non-verbal and suffers from 11 apraxia of speech. T.A.L.’s symptoms and stimming patterns include talking 12 loudly to himself, the inability to sit or stand still, and bumping into family 13 members. Behavior meltdowns for T.A.L. consist generally of aggressive, self- 14 injurious reactions, including biting his hand and crying loudly. T.A.L. can 15 cause anxiety in others in the surrounding area, in that he even at 13 years of 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI age, T.A.L. was six feet tall and weighed over 175 pounds. 17 478. Autism substantially limits a person’s ability to care for himself, 18 perform manual tasks, speak, learn, read, concentrate, think, communicate, 19 perceive the conceptDeadline.com of time, pair sights and sounds that happen 20 simultaneously, and work. 21 479. T.A.L. is a person with a disability, as that term is defined in 42 22 U.S.C. §12102(1). 23 480. T.A.L. is 15 years old and is generally in the care of his mother, 24 G.L., who brings this action as T.A.L.'s next friend, parent and natural guardian. 25

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1 481. T.A.L. and G.L. are residents of Denver County, Colorado. 2 482. G.L. grew up a Disney lover, visiting the Disney Parks often with 3 her mother, father, and brother. For three years, G.L. worked at Disneyland, 4 becoming familiar with what was once the culture and philosophy of Disney 5 toward all its guests, including those with disabilities. 6 483. G.L. first took T.A.L. to Disneyland when T.A.L. was nine years old. 7 From that time forward, G.L. frequently took T.A.L. to the Disney Parks, and 8 often for two to three days at a time. During those visits, T.A.L. exhibited a 9 nature and extent of joy that he rarely showed in any other setting. G.L. was 10 always proud and joyful of the opportunity to bring to her beloved child a

11 level of happiness which he rarely showed elsewhere. T.A.L. specifically 12 requested to go to Disneyland as often as G.L. could take him. For five 13 consecutive years, G.L. purchased premium passes for her family. Their 14 Disneyland trips were always a seminal event in T.A.L.’s life. For G.L. and 15 T.A.L., Disney truly was the happiest place on earth. 16 484. G.L. and T.A.L. relocated from California to Denver, Colorado, in

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 July of 2013, and the frequency of their trips to the Disney Parks, 18 unfortunately, was reduced. 19 485. SinceDeadline.com T.A.L. was a toddler, his cognitive impairments have 20 manifested themselves in a certain way during the family’s visits to the Parks. 21 T.A.L. must experience the park in a specific order, and disruptions to this 22 routine will tend to escalate his stimming behaviors toward meltdowns. T.A.L. 23 has a strict schedule in his head of the Disneyland attractions he must visit, 24 25

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1 and the order in which he must ride them, including where he wants to have 2 lunch. For T.A.L., any trip to Disneyland must start at Space Mountain. 3 486. Similarly, if T.A.L. were required to idly wait for entry into a ride 4 or attraction for more than a few minutes, he also would likely melt down. 5 During the wait, he would begin bumping into family members around him, 6 biting himself, and screaming loudly before experiencing a meltdown. Upon 7 meltdown, his mother knows to do whatever she can to prevent the behavior 8 from escalating, perhaps to pushing or bumping into others, which can create 9 an uncomfortable situation for his mother and those around him. 10 487. Because T.A.L. is incapable of understanding the concept of

11 visiting a ride or attraction only to be prohibited from riding it until a future 12 time, the new DAS creates avoidable stressors for T.A.L., escalating his 13 stimming patterns toward meltdowns. Since Disney’s implementation of the 14 new DAS, T.A.L. has experienced several meltdowns at Disneyland. 15 488. Due to Disney’s failure to accommodate T.A.L.s individualized 16 needs, which prior to the DAS Disney had always been able to admirably DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 accomplish, T.A.L. is now prone to experiencing meltdowns at Disneyland. He 18 is thus prevented from experiencing the full enjoyment of the Parks, equal to 19 the experiences ofDeadline.com persons without a disability. 20 489. G.L. and T.A.L.’s first visit to Disneyland under the new Disney 21 policies was during December of 2013. They had relocated to Colorado and 22 returned for a Disneyland trip prior to expiration of their premium passes. 23 G.L. waited for 30 minutes in line at Guest Relations while T.A.L. sat on a 24 bench close by, as they had done every time in the past. Upon reaching the 25

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1 front of the line, however, their trip took a sudden turn for the worse as the 2 employee explained that the GAC was no longer available and had been 3 replaced by the DAS. The employee asked G.L.: “Are you aware of our new 4 policy?” 5 490. As the Disney employee then explained how the DAS worked, G.L. 6 listened intently but disbelievingly. She immediately said this new 7 arrangement will not work for T.A.L.; it simply will not accommodate him. 8 She was only told that there is nothing more that could be done: “This is our 9 new policy.” 10 491. That day, most of the Disney employees were unfamiliar with the

11 DAS and were un-accommodating. Many Disney employees gave G.L. the 12 general impression that Disney doubted whether T.A.L. is really disabled. 13 492. The next day, Disney was even less warm and less 14 accommodating. The day got progressively worse until, ultimately, T.A.L. 15 suffered a meltdown while trying to enter a ride. The ride operator told T.A.L. 16 he could not enter the ride at that time, and the situation caused a meltdown DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 for T.A.L. G.L. and T.A.L. left the Disney Parks, for the first time feeling that 18 Disneyland was no longer the happiest place on earth. 19 493. As aDeadline.com result of Disney’s refusal to modify its procedures to 20 reasonably accommodate T.A.L.’s needs, T.A.L. and G.L. have been discouraged 21 and deterred from the full use and enjoyment of the Disneyland rides and 22 attractions. G.L. would visit the Parks with T.A.L. again had Disney not 23 abandoned its past policy of accommodating the special needs of persons with 24 cognitive impairments. G.L. knows they will avoid attending the parks in the 25

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1 future because T.A.L. will suffer disparate and discriminatory treatment as a 2 result of his disability. Undoubtedly, the experience will be an un-magical and 3 un-accommodating one. 4 494. Notwithstanding Disney’s highly sophisticated knowledge of the 5 needs of persons with cognitive impairments, and notwithstanding Disney’s 6 historic ability to accommodate T.A.L.’s special needs, Disney personnel 7 refused to conduct an individualized assessment of T.A.L.'s capacity to utilize 8 the DAS, and did not modify the DAS to allow T.A.L. to enjoy the same benefits 9 and privileges as Disney’s non-disabled patrons. 10 495. Disney personnel have shown no willingness or desire to improve

11 the experience for guests like T.A.L. 12 496. G.L. incurred expenses associated with the family’s wasted trip to 13 the Parks. 14 497. During one or more visits to the Parks, T.A.L. suffered an actual 15 meltdown. 16 498. The symptoms and conditions associated with T.A.L.’s meltdown

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 constitute a physical injury under California law. 18 499. T.A.L.’s meltdown in the Parks was proximately caused by 19 Disney’s negligent,Deadline.com unlawful, reckless and arbitrary treatment of T.A.L. during 20 his patronage of Disney’s facilities. At all material times, Disney knew T.A.L. to 21 be vulnerable to emotional injury if treated in such a manner by anyone. 22 500. T.A.L.’s meltdown and the treatment which proximately caused 23 T.A.L. to experience the meltdown caused him grave and extreme mental 24 anguish and emotional trauma, for which Disney should be held accountable. 25

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1 WHEREFORE, Plaintiff T.A.L., by and through G.L. as T.A.L.’s next 2 friend, parent and natural guardian, prays that this Court adjudicate this 3 dispute and enter an Order: 4 • Finding that Disney negligently inflicted emotional distress 5 upon T.A.L.; and 6 • Finding such infliction to have caused damages to T.A.L.; and 7 • Entering judgment for Plaintiff T.A.L. in the amount of such 8 damages; and 9 • Awarding reasonable litigation costs as may be determined by 10 the Court in favor of Plaintiff and against Disney; and

11 • Awarding prejudgment interest; and 12 • Such other relief as this Court may find just and equitable. 13 COUNT 37 14 Intentional Infliction of Emotional Distress 15 T.A.L. v. Disney 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 501. Plaintiff T.A.L. incorporates and re-alleges the allegations of 17 paragraphs 1 through 90, and 477 through 500 above. 18 502. During one or more visits to the Parks, T.A.L. suffered an actual 19 meltdown. Deadline.com 20 503. The symptoms and conditions associated with T.A.L.’s meltdown 21 constitute a physical injury under California law. 22 504. T.A.L.’s meltdown in the Parks was proximately caused by 23 Disney’s outrageous, unlawful and reckless treatment of T.A.L. during his 24 25

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1 patronage of Disney’s facilities. At all material times, Disney knew T.A.L. to be 2 vulnerable to emotional injury if treated in such a manner by anyone. 3 505. T.A.L.’s meltdown and the treatment which proximately caused 4 T.A.L. to experience the meltdown caused him grave and extreme mental 5 anguish and emotional trauma, for which Disney should be held accountable. 6 WHEREFORE, Plaintiff T.A.L., by and through G.L. as T.A.L.’s next 7 friend, parent and natural guardian, prays that this Court adjudicate this 8 dispute and enter an Order: 9 • Finding that Disney intentionally inflicted emotional distress 10 upon T.A.L.; and

11 • Finding such infliction to have caused damages to T.A.L.; and 12 • Entering judgment for Plaintiff T.A.L. in the amount of such 13 damages; 14 • Entering judgment in favor of Plaintiffs and against Disney for 15 exemplary or punitive damages; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Awarding reasonable litigation costs as may be determined by 17 the Court in favor of Plaintiff and against Disney; and 18 • Awarding prejudgment interest; and 19 • SuchDeadline.com other relief as this Court may find just and equitable. 20 COUNT 38 21 Negligent Infliction of Emotional Distress 22 G.L. v. Disney 23 506. Plaintiff G.L. incorporates and re-alleges the allegations of 24 paragraphs 1 through 90, 476 through 500 and 501 through 505 above. 25

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1 507. During one or more visits to the Parks, G.L.’s beloved son T.A.L. 2 suffered an actual meltdown while in G.L.’s presence. 3 508. The symptoms and conditions associated with T.A.L.’s meltdown 4 constitute a physical injury to T.A.L. under California law. 5 509. T.A.L.’s meltdown in the Parks was proximately caused by 6 Disney’s negligent, unlawful, reckless and arbitrary treatment of T.A.L. during 7 his patronage of Disney’s facilities. At all material times, Disney knew T.A.L. to 8 be vulnerable to emotional injury if treated in such a manner by anyone. 9 510. G.L. directly observed the stressors leading up to the meltdown, 10 T.A.L.’s resulting escalation and his meltdown. Particularly in light of her trust

11 and confidence that Disney would comply with applicable law and act in a 12 gracious and caring manner toward her son, G.L. could do nothing reasonable 13 to prevent the meltdown. 14 511. G.L.’s observation of T.A.L.’s meltdown and of the outrageous 15 conduct and treatment which proximately caused T.A.L. to experience the 16 meltdown caused G.L. grave and extreme mental anguish and emotional DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 trauma, for which Disney should be held accountable. 18 WHEREFORE, Plaintiff G.L. prays that this Court adjudicate this 19 dispute and enterDeadline.com an Order: 20 • Finding that Disney negligently inflicted emotional distress 21 upon G.L.; and 22 • Finding such infliction to have caused damages to G.L.; and 23 • Entering judgment for Plaintiff G.L. in the amount of such 24 damages; and 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding prejudgment interest; and 4 • Such other relief as this Court may find just and equitable. 5 COUNT 39 6 Intentional Infliction of Emotional Distress 7 G.L. v. Disney 8 512. Plaintiff G.L. incorporates and re-alleges the allegations of 9 paragraphs 1 through 90, 476 through 500 and 501 through 505 above. 10 513. During one or more visits to the Parks, G.L.’s beloved son T.A.L. 11 suffered an actual meltdown. 12 514. The symptoms and conditions associated with T.A.L.’s meltdown 13 constitute a physical injury under California law. 14 515. T.A.L.’s meltdown in the Parks was proximately caused by 15 Disney’s outrageous, unlawful and reckless treatment of T.A.L. during his 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI patronage of Disney’s facilities. At all material times, Disney knew T.A.L. to be 17 vulnerable to emotional injury if treated in such a manner by anyone. 18 516. G.L. directly observed the stressors leading up to the meltdown, 19 T.A.L.’s resultingDeadline.com escalation and his meltdown. Particularly in light of her trust 20 and confidence that Disney would comply with applicable law and act in a 21 gracious and caring manner toward her son, G.L. could do nothing reasonable 22 to prevent the meltdown. 23 517. G.L.’s observation of T.A.L.’s meltdown and of the outrageous 24 conduct and treatment which proximately caused T.A.L. to experience the 25

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1 meltdown caused G.L. grave and extreme mental anguish and emotional 2 trauma, for which Disney should be held accountable. 3 WHEREFORE, Plaintiff G.L. prays that this Court adjudicate this 4 dispute and enter an Order: 5 • Finding that Disney intentionally inflicted emotional distress 6 upon G.L.; and 7 • Finding such infliction to have caused damages to G.L.; and 8 • Entering judgment for Plaintiff G.L. in the amount of such 9 damages; 10 • Entering judgment in favor of Plaintiff and against Disney for

11 exemplary or punitive damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 40 17 Breach of Contract 18 G.L. v. Disney 19 518. PlaintiffDeadline.com G.L. incorporates and re-alleges the allegations of 20 paragraphs 1 through 90, 476 through 500 and 501 through 505 above. 21 519. G.L. entered into a contract through which Disney promised to 22 provide a reasonable and enjoyable amusement park experience, and one 23 which complies with applicable law. 24 25

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1 520. Disney failed or refused to provide the promised experience, and 2 is in breach of contract. 3 521. G.L. incurred expenses associated with the family’s wasted trips to 4 the Parks. Plaintiff is damaged by Disney’s breach of contract. 5 WHEREFORE, Plaintiff G.L. prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney breached its contract with G.L..; and 8 • Entering judgment for Plaintiff G.L. in the amount of her 9 economic monetary damages; and 10 • Awarding reasonable litigation costs as may be determined by 11 the Court in favor of Plaintiff and against Disney; and 12 • Awarding prejudgment interest; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 41 15 Negligent Infliction of Emotional Distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI D.F. v. Disney 17 522. Plaintiff incorporates and re-alleges paragraphs 1 through 90 18 above. 19 523. D.F. Deadline.comhas autism. He also suffers from obsessive compulsive 20 disorder, separation anxiety, and bipolar disorder. D.F. becomes overtly 21 anxious when his routine or schedule is altered, or when he is forced to idly 22 wait for more than a few minutes. Behavior meltdowns for D.F. consist 23 generally of grabbing, grunting, groaning, twisting and pulling his hair out, 24 chewing on a rag, and yelling profanities. 25

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1 524. Autism substantially limits a person’s ability to care for himself, 2 perform manual tasks, speak, learn, read, concentrate, think, communicate, 3 perceive the concept of time, pair sights and sounds that happen 4 simultaneously, and work. 5 525. D.F. is a person with a disability, as that term is defined in 42 6 U.S.C. §12102(1). 7 526. D.F. is 28 years old and is generally in the care of his mother, C.F. 8 who brings this action as D.F.'s next friend, parent, and natural guardian. 9 527. D.F. and C.F. are residents of San Bernardino County, California. 10 528. C.F. grew up a Disney lover and instilled that same love of Disney

11 in her son. C.F. first took D.F. to Disneyland when he was three years old, and 12 has been back every year since then, at least three times per year, including an 13 annual birthday trip which D.F. requests every year. 14 529. Disneyland was a blessing for D.F. It was the only place where C.F. 15 and D.F. could experience release from the disability that otherwise followed 16 C.F. and D.F. on a daily basis. Under the GAC, Disneyland evened the playing DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 field. 18 530. For C.F. and D.F., a typical visit to Disneyland during the prior GAC 19 was an accommodatingDeadline.com experience. Upon arrival at the Disney Parks, C.F. 20 obtained a GAC from Guest Relations within five minutes. During this 21 interaction, Disney employees courteously greeted C.F. and D.F. with a smile 22 before examining D.F.’s old GAC card and then stamping a new GAC card. They 23 spent the rest of the day riding the rides D.F. wished to ride, in the order he 24 needed to ride them on that particular day. Typically, their visits started with 25

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1 Snow White’s Scary Adventures, followed by Space Mountain, and finally Buzz 2 Lightyear Astro Blasters, before D.F. was comfortable venturing off with C.F. to 3 explore other areas of the Park. 4 531. Since D.F. was a toddler, his cognitive impairments have 5 manifested themselves in a certain way during the family’s visits to the Parks. 6 D.F. must experience the park in a specific order, and disruptions in his 7 necessary routine will tend to escalate his stimming behaviors toward 8 meltdowns. 9 532. If D.F. were required to idly wait for entry into a ride or attraction 10 for more than about ten minutes, he would likely melt down. During the wait,

11 his passive behaviors – usually repeating days of the week or calendar, for 12 example “How many weeks until May” – will escalate into more aggressive 13 behavior, including grasping, grunting, and groaning. In between the passive 14 and aggressive stages, D.F.’s pupils become dilated, his lips will purse, and he 15 will begin chomping his jaws. If D.F. is not removed from the condition, a 16 meltdown will occur. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 533. Similarly, if D.F. were required to experience the park in an 18 unanticipated sequence he would likely melt down. At present he is 19 compelled to experienceDeadline.com Star Tours, Space Mountain, and Buzz Lightyear 20 before riding any other ride. D.F. does not need to experience these first three 21 rides in a particular order, so long as he experiences these three rides before 22 any other ride. 23 534. Because D.F. is incapable of understanding the concept of visiting 24 a ride or attraction only to be prohibited from riding it until a future time, the 25

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1 new DAS creates avoidable stressors for D.F., escalating his stimming patterns 2 toward meltdowns. Since Disney’s implementation of the new DAS, D.F. has 3 experienced several meltdowns at Disneyland due to the varied stressors 4 which are imposed upon him by the DAS, including extended idle wait times, 5 directives to enter the rides from different locations, and disruption of 6 patterns and routines. 7 535. Due to Disney’s failure to accommodate, which leads to an 8 increased propensity for D.F. to experience a meltdown, Defendant has 9 prevented D.F. from experiencing the full enjoyment of its Parks, equal to the 10 experiences of persons without a disability.

11 536. C.F. and D.F.’s first visit to Disneyland under the DAS occurred 12 October 25, 2013. After a 45-minute wait at Guest Relations, C.F. and D.F. 13 were instructed by a Disney employee that the DAS was Disney’s new 14 accessibility system. Following C.F.’s objections, the employee advised C.F. to 15 figure out how to get over her anger and learn the new DAS, because there 16 would be no exceptions, and no changes. That day, as a one-time-only DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 accommodation, the employee gave C.F. courtesy passes to the three rides D.F. 18 most enjoyed. Shocked by the employee’s “advice,” C.F. and D.F. began their 19 supremely unaccommodatingDeadline.com day with a visit to Star Tours with their 20 courtesy pass. 21 537. Next, C.F. and D.F. visited Space Mountain, where their luck 22 quickly ran out upon encountering a disability line stretching hundreds of 23 yards. 24 25

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1 538. They obtained prompt access to Buzz Lightyear after showing the 2 courtesy pass. 3 539. C.F. and D.F. left the Parks disappointed by their unfulfilling 4 Disney experience which lacked the accommodation and magic C.F. and D.F. 5 had always experienced before the DAS. To make matters worse, they 6 encountered a new Disney attitude of neutral indifference at Guest Relations, 7 along with complete arbitrariness in every other area of the Park. 8 540. After October 9, 2013, D.F. no longer received the type of 9 accommodation and attention D.F. and C.F. had received when they visited the 10 Parks in the past.

11 541. Unlike most persons diagnosed with autism, D.F. is capable of 12 feeling embarrassment. D.F. has grown physically angry many times as a 13 result of the treatment he received by Disney because of being singled out on 14 account of his disability. 15 542. As a result of Disney’s refusal to modify its procedures to 16 reasonably accommodate D.F.’s needs, D.F. and C.F. have been discouraged DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 and deterred from the full use and enjoyment of the park's rides and 18 attractions. C.F. would visit the Parks with D.F. more often if Disney had not 19 abandoned its pastDeadline.com policy of accommodating the special needs of persons with 20 cognitive impairments. C.F. would have been eager to renew her deluxe 21 annual passes; she has been an annual passholder since 1999. However, their 22 interest in attending the Parks is substantially reduced. Accordingly, when 23 she renewed her pass in 2014, she downgraded from deluxe annual passes to 24 the “SOCAL” annual passes. C.F. knows they should avoid attending the parks 25

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1 in the future due to the reasonable expectation that D.F. will be subjected to 2 discrimination, and that the experience will again be an un-magical and un- 3 accommodating one. 4 543. Notwithstanding Disney’s highly sophisticated knowledge of the 5 needs of persons with cognitive impairments, and notwithstanding Disney’s 6 historic ability to accommodate D.F.’s special needs, Disney personnel have 7 refused to conduct an individualized assessment of D.F.'s capacity to utilize 8 the DAS, and have refused to modify the DAS to allow D.F. to enjoy the same 9 benefits and privileges as non-disabled patrons. 10 544. Disney personnel have shown no openness, willingness or desire

11 to improve the experience for guests like D.F. 12 545. C.F. incurred expenses associated with wasted trips to the Parks. 13 546. During one or more visits to the Parks, D.F. suffered an actual 14 meltdown. 15 547. The symptoms and conditions associated with D.F.’s meltdown 16 constitute a physical injury under California law. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 548. D.F.’s meltdown in the Parks was proximately caused by Disney’s 18 negligent, unlawful, reckless and arbitrary treatment of D.F. during his 19 patronage of Disney’sDeadline.com facilities. At all material times, Disney knew D.F. to be 20 vulnerable to emotional injury if treated in such a manner by anyone. 21 549. D.F.’s meltdown and the treatment which proximately caused D.F. 22 to experience the meltdown caused her grave and extreme mental anguish 23 and emotional trauma, for which Disney should be held accountable. 24 25

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1 WHEREFORE, Plaintiff D.F., by and through C.F. as D.F.’s next friend, 2 parent and natural guardian, prays that this Court adjudicate this dispute 3 and enter an Order: 4 • Enjoining Defendant to cease the practices which are causing 5 discrimination against Plaintiff on account of D.F.’s disability; 6 and 7 • Enjoining Defendant to reasonably modify its policies, 8 practices, and procedures to afford Plaintiff with an 9 opportunity to experience Disney’s goods, services, facilities, 10 privileges, advantages, and accommodations; and

11 • Establishing Court-approved remedial measures that Disney 12 must implement, to prevent Disney from further discriminating 13 against Plaintiff when they visit the Disney Parks; and 14 • Establishing Court-approved requirements for information 15 dissemination about Disney’s remedial measures and modified 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI policies, to prevent Disney from further deterring Plaintiff from 17 visiting Disney Parks as a result of anticipated discrimination; 18 and 19 • EstablishingDeadline.com a monitoring program to ensure Disney’s 20 compliance with the Court’s Orders; and 21 • Finding that Disney negligently inflicted emotional distress 22 upon D.F.; and 23 • Finding such infliction to have caused damages to D.F.; and 24 25

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1 • Entering judgment for Plaintiff D.F. in the amount of such 2 damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 42 8 Intentional Infliction of Emotional Distress 9 D.F. v. Disney 10 550. Plaintiff D.F. incorporates and re-alleges the allegations of

11 paragraphs 1 through 90, 523 through 549, and 554above. 12 551. During one or more visits to the Parks, D.F. suffered an actual 13 meltdown. 14 552. The symptoms and conditions associated with D.F.’s meltdown 15 constitute a physical injury under California law. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 553. D.F.’s meltdown in the Parks was proximately caused by Disney’s 17 outrageous, unlawful and reckless treatment of D.F. during her patronage of 18 Disney’s facilities. At all material times, Disney knew D.F. to be vulnerable to 19 emotional injuryDeadline.com if treated in such a manner by anyone. 20 554. D.F.’s meltdown and the treatment which proximately caused D.F. 21 to experience the meltdown caused him grave and extreme mental anguish 22 and emotional trauma, for which Disney should be held accountable. 23 24 25

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1 WHEREFORE, Plaintiff D.F., by and through C.F. as D.F.’s next friend, 2 parent and natural guardian, prays that this Court adjudicate this dispute 3 and enter an Order: 4 • Finding that Disney intentionally inflicted emotional distress 5 upon D.F.; and 6 • Finding such infliction to have caused damages to D.F.; and 7 • Entering judgment for Plaintiff D.F. in the amount of such 8 damages; 9 • Entering judgment in favor of Plaintiff and against Disney for 10 exemplary or punitive damages; and

11 • Awarding reasonable litigation costs as may be determined by 12 the Court in favor of Plaintiff and against Disney; and 13 • Awarding prejudgment interest; and 14 • Such other relief as this Court may find just and equitable. 15 COUNT 43 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI Negligent Infliction of Emotional Distress 17 C.F. v. Disney 18 555. Plaintiff C.F. incorporates and re-alleges the allegations of 19 paragraphs 1 throughDeadline.com 90, 523 through 549, and 551 through 554 above. 20 556. During one or more visits to the Parks, C.F.’s beloved daughter 21 D.F. suffered an actual meltdown while in C.F.’s presence. 22 557. The symptoms and conditions associated with D.F.’s meltdown 23 constitute a physical injury to D.F. under California law. 24 25

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1 558. D.F.’s meltdown in the Parks was proximately caused by Disney’s 2 negligent, unlawful, reckless and arbitrary treatment of D.F. during his 3 patronage of Disney’s facilities. At all material times, Disney knew D.F. to be 4 vulnerable to emotional injury if treated in such a manner by anyone. 5 559. C.F. directly observed the stressors leading up to the meltdown, 6 D.F.’s resulting escalation and his meltdown. Particularly in light of her trust 7 and confidence that Disney would comply with applicable law and act in a 8 gracious and caring manner toward her daughter, C.F. could do nothing 9 reasonable to prevent the meltdown. 10 560. C.F.’s observation of D.F.’s meltdown and of the outrageous

11 conduct and treatment which proximately caused D.F. to experience the 12 meltdown caused C.F. grave and extreme mental anguish and emotional 13 trauma, for which Disney should be held accountable. 14 WHEREFORE, Plaintiff C.F. prays that this Court adjudicate this 15 dispute and enter an Order: 16 • Finding that Disney negligently inflicted emotional distress DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 upon C.F.; and 18 • Finding such infliction to have caused damages to C.F.; and 19 • EnteringDeadline.com judgment for Plaintiff C.F. in the amount of such 20 damages; and 21 • Awarding reasonable litigation costs as may be determined by 22 the Court in favor of Plaintiff and against Disney; and 23 • Awarding prejudgment interest; and 24 • Such other relief as this Court may find just and equitable. 25

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1 COUNT 44 2 Intentional Infliction of Emotional Distress 3 C.F. v. Disney 4 561. Plaintiff C.F. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, 523 through 549, and 551 through 554 above. 6 562. During one or more visits to the Parks, C.F.’s beloved son D.F. 7 suffered an actual meltdown. 8 563. The symptoms and conditions associated with D.F.’s meltdown 9 constitute a physical injury under California law. 10 564. D.F.’s meltdown in the Parks was proximately caused by Disney’s

11 outrageous, unlawful and reckless treatment of D.F. during her patronage of 12 Disney’s facilities. At all material times, Disney knew D.F. to be vulnerable to 13 emotional injury if treated in such a manner by anyone. 14 565. C.F. directly observed the stressors leading up to the meltdown, 15 D.F.’s resulting escalation and his meltdown. Particularly in light of her trust 16 and confidence that Disney would comply with applicable law and act in a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 gracious and caring manner toward her daughter, C.F. could do nothing 18 reasonable to prevent the meltdown. 19 566. C.F.’sDeadline.com observation of D.F.’s meltdown and of the outrageous 20 conduct and treatment which proximately caused D.F. to experience the 21 meltdown caused C.F. grave and extreme mental anguish and emotional 22 trauma, for which Disney should be held accountable. 23 WHEREFORE, Plaintiff C.F. prays that this Court adjudicate this 24 dispute and enter an Order: 25

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1 • Finding that Disney intentionally inflicted emotional distress 2 upon C.F.; and 3 • Finding such infliction to have caused damages to C.F.; and 4 • Entering judgment for Plaintiff C.F. in the amount of such 5 damages; 6 • Entering judgment in favor of Plaintiffs and against Disney for 7 exemplary or punitive damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 45 13 Breach of Contract 14 C.F. v. Disney 15 567. Plaintiff C.F. incorporates and re-alleges the allegations of 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI paragraphs 1 through 90, 523 through 549, and 551 through 554 above. 17 568. C.F. entered into a contract through which Disney promised to 18 provide a reasonable and enjoyable amusement park experience, and one 19 which complies withDeadline.com applicable law. 20 569. Disney failed or refused to provide the promised experience, and 21 is in breach of contract. 22 570. C.F. incurred expenses associated with the family’s wasted trips to 23 the Parks. Plaintiff is damaged by Disney’s breach of contract. 24 25

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1 WHEREFORE, Plaintiff C.F. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney breached its contract with C.F..; and 4 • Entering judgment for Plaintiff C.F. in the amount of her 5 economic monetary damages; and 6 • Awarding reasonable litigation costs as may be determined by 7 the Court in favor of Plaintiff and against Disney; and 8 • Awarding prejudgment interest; and 9 • Such other relief as this Court may find just and equitable. 10 COUNT 46

11 Breach of Contract 12 M.I.P. v. Disney 13 571. Plaintiff M.I.P. incorporates and re-alleges the allegations of 14 paragraphs 1 through 90 above. 15 572. G.C.P. has autism. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 573. Autism substantially limits a person’s ability to care for himself, 17 perform manual tasks, speak, learn, read, concentrate, think, communicate, 18 perceive the concept of time, pair sights and sounds that happen 19 simultaneously, Deadline.comand work. 20 574. G.C.P. is six years of age and is generally in the care of his mother, 21 M.I.P., who brings this action as G.C.P.’s next friend, parent and natural 22 guardian. 23 575. G.C.P. and M.I.P. are residents of Orange County, California. 24 25

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1 576. G.C.P. and M.I.P. were annual pass holders who, prior to October 9, 2 2013, visited Disneyland approximately five times per month. During those 3 visits, G.C.P. exhibited a nature and extent of joy that he rarely showed in any 4 other setting. M.I.P. was always proud and joyful of the opportunity to bring 5 to her beloved child a level of happiness which he rarely showed elsewhere. 6 577. G.C.P. is incapable of standing idly around for a significant period 7 of time without his cognitive impairments causing him to experience 8 stimming and meltdowns, and G.C.P. is incapable of comprehending the 9 concept of time. Triggers will cause G.C.P. to run away, start stimming with 10 high-pitched groaning, spin objects, tip-toe walk, line up objects, throw

11 himself to the ground, and spit. 12 578. G.C.P.’s disorder necessitates that he experience park attractions 13 in a certain order, beginning with Star Tours, and riding it twice, then riding 14 the Rocket Ship, then the Buzz Lightyear ride. He will then repeat the 15 sequence. 16 579. Since Disney’s implementation of the new DAS, Defendant has

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 prevented G.C.P. from experiencing the full enjoyment, equal to those without 18 a disability, of the Disney Parks. 19 580. In orderDeadline.com to experience the facilities and services of Disney Parks 20 since the implementation of the DAS, G.C.P. is now forced to idly stand around 21 for extended durations, enduring all stressors and potential meltdown 22 triggers, starting with City Hall at the beginning of the day, where he must 23 wait just to have his photograph taken and to have the DAS card made for him. 24 25

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1 581. Similarly, each time G.C.P. wants to experience Disneyland, he is 2 forced to idly wait amongst trigger after trigger for return times on each ride 3 which alter the order in which he can experience the rides. 4 582. The DAS card is only valid for approximately two weeks, despite 5 the fact that G.C.P.’s diagnosis will not change and his annual pass is good for 6 twelve months. The expiration of the DAS card after approximately two 7 weeks assures that each visit to the Parks will begin with stressors, not 8 pleasures. 9 583. Since Defendant’s implementation of the DAS, G.C.P. and M.I.P. 10 have visited multiple Disney Parks, including Disneyland and California

11 Adventure Park on multiple occasions, including at least visits on November 2, 12 2013 and February 1, 2014. 13 584. The new procedure triggers G.C.P’s meltdowns more frequently at 14 the Disney Parks. 15 585. The accommodations Disney claims to provide through the DAS 16 will not allow G.C.P. to utilize his annual pass in such a way that it provides the DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 equal enjoyment of the Disney Parks as that of a non-disabled person. 18 586. Notwithstanding Disney’s highly sophisticated knowledge of the 19 needs of personsDeadline.com with cognitive impairments, and notwithstanding Disney’s 20 historic ability to accommodate G.C.P.’s special needs, Disney personnel now 21 offered ineffective, apathetic, obtuse responses to M.I.P.’s recitations 22 regarding G.C.P.’s needs. Their actions and statements were so contrary to 23 Disney’s body of knowledge and to Disney’s historic performance that Disney 24 cannot have accidentally proposed such absurdities. 25

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1 587. Disney personnel showed no openness, willingness or desire to 2 improve the experience for guests like G.C.P. 3 588. G.C.P. is and at all material times has been a disabled person 4 within the meaning of California Government Code §1296(j). 5 589. J.C.P. has autism. 6 590. Autism substantially limits a person’s ability to care for himself, 7 perform manual tasks, speak, learn, read, concentrate, think, communicate, 8 perceive the concept of time, pair sights and sounds that happen 9 simultaneously, and work. 10 591. J.C.P. is three years of age and is generally in the care of his

11 mother, M.I.P., who brings this action as J.C.P.’s parent and natural guardian. 12 592. J.C.P. and M.I.P. are residents of Orange County, California. 13 593. Prior to October 9, 2013, M.I.P. took J.C.P. to the Disney Parks 14 approximately five times per month. During those visits, J.C.P. exhibited a 15 nature and extent of joy that J.C.P. rarely showed in any other setting. M.I.P. 16 was always proud and joyful of the opportunity to bring to her beloved child a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 level of happiness which he rarely showed elsewhere. 18 594. Because of these fond memories, J.C.P. and M.I.P. visited California 19 Adventure Park Deadline.comand Disneyland after October 9, 2013. 20 595. Incapable of comprehending the concept of time, it is impossible 21 for J.C.P. to stand around for more than a few minutes, idly biding time, 22 without his cognitive impairments causing him to suffer meltdowns. Idly 23 waiting around for a significant time will cause J.C.P. to run away, walk and 24 jump on his tip toes, yell and cry. 25

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1 596. Since Disney’s implementation of the new DAS, Defendant has 2 prevented J.C.P. from experiencing the full enjoyment, equal to those without a 3 disability, of the Disney Parks. 4 597. In order to experience the facilities and services of Disney Parks 5 since the implementation of the DAS, J.C.P. is now forced endure expended 6 periods of idly waiting around, enduring all potential meltdown triggers, 7 including just to start the day at City Hall to have his photograph taken and a 8 DAS card made for him. 9 598. Similarly, each time J.C.P. wants to experience Disneyland he is 10 forced to idly wait amongst trigger after trigger for return times on each ride

11 which limit the order in which he can experience the rides. 12 599. The DAS card is only valid for approximately two weeks, despite 13 the fact that J.C.P.’s diagnosis will not change and his annual pass is good for 14 twelve months. The expiration of the DAS card after approximately two 15 weeks assures that each visit to the Parks will begin with stressors, not 16 pleasures. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 600. Since Defendant’s implementation of the DAS, G.C.P. and M.I.P. 18 have visited multiple Disney Parks, including Disneyland and California 19 Adventure Park Deadline.comon multiple occasions, including but not limited to visits on 20 November 2, 2013 and February 1, 2014. 21 601. The new procedure triggers J.C.P. to experience meltdowns more 22 frequently at the Disney Parks. 23 24 25

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1 602. The accommodations Disney claims to provide through the DAS 2 do not allow J.C.P. to experience equal enjoyment of the Disney Parks to the 3 same extent as that of a non-disabled person. 4 603. Notwithstanding Disney’s highly sophisticated knowledge of the 5 needs of persons with cognitive impairments, and notwithstanding Disney’s 6 historic ability to accommodate J.C.P.’s special needs, Disney personnel now 7 offered obtuse and ineffective responses to M.I.P.’s recitations regarding 8 J.C.P.’s needs. Their actions and statements were so contrary to Disney’s body 9 of knowledge and to Disney’s historic performance that Disney cannot have 10 accidentally proposed such absurdities.

11 604. Disney personnel showed no openness, willingness or desire to 12 improve the experience for guests like J.C.P. 13 605. J.C.P. is and at all material times has been a disabled person within 14 the meaning of California Government Code §1296(j). 15 606. M.I.P. expenses associated with the family’s wasted trips to the 16 Parks. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 607. J.C.P. and M.I.P. have already visited the Parks considerably less 18 frequently than they intended when they purchased the annual passes for 19 their family, andDeadline.com did not renew their passes. Their interest in attending 20 Disney Parks is substantially reduced. While they would have an interest in 21 returning to the Disney Parks if Disney should return to its prior commitment 22 to accommodating disabled persons, their current interest in attending Disney 23 Parks is substantially reduced. M.I.P. knows that upon returning to the Parks 24 25

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1 J.C.P. would experience further unlawful discrimination, and further 2 humiliation. 3 608. G.C.P. and M.I.P. reduced the frequency of Disneyland visits to two 4 times a month after October 9, 2013 and did not renew their passes upon 5 expiration. While they would have an interest in returning to the Disney 6 Parks if Disney should return to its prior commitment to accommodating 7 disabled persons, their current interest in attending Disney Parks is 8 substantially reduced. M.I.P. knows that upon returning to the Parks G.C.P. 9 would experience further unlawful discrimination, and further humiliation. 10 609. Section 51 of the California Civil Code, the Unruh Civil Rights Act,

11 provides protection from discrimination by all business establishments in 12 California, including housing and public accommodations, because of age, 13 ancestry, color, disability, national origin, race, religion, sex and sexual 14 orientation. 15 610. Section 52 of the California Civil Code provides that whoever 16 denies, aids or incites a denial, or makes any discrimination or distinction DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 contrary to Section 51 is liable for each and every offense. 18 611. Pursuant to California Civil Code Section 51(f), a violation of the 19 ADA also constitutesDeadline.com a violation of California Civil Code Section 51, et seq. 20 612. The Parks are “business establishments” within the meaning of 21 the California Code Section 51, et seq. 22 613. M.I.P. entered into a contract through which Disney promised to 23 provide a reasonable and enjoyable amusement park experience, and one 24 which complies with applicable law. 25

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1 614. Disney failed or refused to provide the promised experience, and 2 is in breach of contract. 3 615. M.I.P. incurred expenses associated with the family’s wasted trips 4 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 5 WHEREFORE, Plaintiff M.I.P. prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney breached its contract with M.I.P.; and 8 • Entering judgment for Plaintiff M.I.P. in the amount of her 9 economic monetary damages; and 10 • Awarding reasonable litigation costs as may be determined by 11 the Court in favor of Plaintiff and against Disney; and 12 • Awarding prejudgment interest; and 13 • Such other relief as this Court may find just and equitable. 14 15 COUNT 47 16 Negligent Infliction of Emotional Distress DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 A.M.N. v. Disney 18 616. Plaintiff A.M.N. incorporates and re-alleges paragraphs 1 through 19 90 above. Deadline.com 20 617. A.M.N. has autism. She also suffers from extreme sensory issues, a 21 behavioral feeding disorder, and low muscular tone. A.M.N. becomes overtly 22 anxious when forced to idly wait for more than a few minutes. A.M.N. wears 23 headphones to avoid over-stimulation and requires the use of a mobility 24 stroller and a service animal. A.M.N.’s service animal is trained to lead A.M.N. 25 through crowds, track her when she elopes, interrupt repetitive behaviors,

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1 and to alleviate her meltdowns by lying on top of her. Behavior meltdowns for 2 A.M.N. consist generally of aggressive behavior directed toward herself, her 3 mother, and her father, S.R.N., as well as increasing A.M.N.’s propensity to 4 elope. 5 618. Autism substantially limits a person’s ability to care for herself 6 perform manual tasks, speak, learn, read, concentrate, think, communicate, 7 perceive the concept of time, pair sights and sounds that happen 8 simultaneously, and work. 9 619. A.M.N. is a person with a disability, as that term is defined in 42 10 U.S.C. §12102(1).

11 620. A.M.N. is nine years old and is generally in the care of her mother, 12 V.M.N. who brings this action as A.M.N.'s next friend, parent and natural 13 guardian. 14 621. A.M.N. and V.M.N. are residents of Maricopa County, Arizona. 15 622. V.M.N. grew up a Disney lover and instilled that same love of 16 Disney in her daughter. In fact, V.M.N. visited Disney several times while she DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 was growing up; along with her sister, who has been diagnosed with cerebral 18 palsy; yet was able to enjoy her trips to Disneyland in the 1980s, a time when 19 Disneyland accommodatedDeadline.com V.M.N.’s sister wonderfully. 20 623. V.M.N. first took A.M.N. to Disneyland in 2009 when A.M.N. was 21 three years old. It was the only place in the world where V.M.N., A.M.N. and 22 S.R.N. were thinking about the same thing at the same time, enjoying the same 23 experience, as a family. After the first visit, V.M.N. took her child to the Disney 24 Parks at least twice a year. During those visits, A.M.N. exhibited a nature and 25

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1 extent of joy that she rarely showed in any other setting, even greeting 2 strangers and interacting with the Disney characters, Tinkerbell being her 3 favorite. V.M.N. was always proud and joyful of the opportunity to bring to 4 her beloved child a level of happiness which she rarely showed elsewhere. 5 624. For V.M.N. and A.M.N., a typical visit to Disneyland during the 6 prior GAC was an accommodating experience. Upon arrival at the Disney 7 Parks, V.M.N. would obtain a GAC from Guest Relations within five minutes. 8 During this interaction, Disney employees courteously greeted V.M.N. and 9 A.M.N. with a smile before examining their old GAC card and then stamping a 10 new GAC card. V.M.N. spent the rest of the day riding the rides A.M.N. wished

11 to ride in the order she needed to ride them in on that particular day. 12 625. Since A.M.N. was a toddler, her cognitive impairments have 13 manifested themselves in a certain way during the family’s visits to the Parks. 14 A.M.N. must experience the park in a specific order, and disruptions in her 15 necessary routine will tend to escalate her stimming behaviors toward 16 meltdowns. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 626. If A.M.N. were required to idly wait for entry into a ride or 18 attraction for more than about ten minutes, she also would likely melt down. 19 During the wait,Deadline.com her behaviors – pacing back and forth, tightening of her 20 muscles, anxiety, aggression toward her mother, her father, and herself, 21 echolalia (the repetition of certain phrases over and over again, such as the 22 name of the ride, “I want to go now!” and “too many people!”) would escalate 23 in frequency or severity. If she is not removed from the condition, a meltdown 24 will occur. 25

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1 627. When A.M.N. reaches the peak of her meltdown, she will drop to 2 the ground. It is at this point A.M.N.’s service animal will lay on top of her to 3 help ease A.M.N. during her meltdown. 4 628. Because A.M.N. is incapable of understanding the concept of 5 visiting a ride or attraction only to be prohibited from riding it until a future 6 time, the new DAS creates avoidable stressors for A.M.N., escalating her 7 stimming patterns toward meltdowns, especially in high traffic areas of the 8 Disney Parks. Since Disney’s implementation of the new DAS, A.M.N. has 9 experienced several meltdowns at Disneyland due to the varied stressors 10 which are imposed upon A.M.N. by the DAS: extended wait times; the directive

11 to enter the rides from different locations, disruption of patterns/routines 12 A.M.N. had grown used to. 13 629. Due to its failure to accommodate, which leads to an increased 14 propensity for A.M.N. experiencing a meltdown, Defendant has prevented 15 A.M.N. from experiencing the full enjoyment of its Parks, equal to the 16 experiences of persons without a disability. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 630. Unlike most individuals diagnosed with autism, A.M.N. possesses 18 the ability to understand she has autism. She has experienced embarrassment 19 at the hands of DisneyDeadline.com and their inability to accommodate her under the DAS 20 regime, often asking V.M.N., “Don’t they know I have autism?” 21 631. V.M.N. and A.M.N.’s last visit to Disneyland before the DAS was 22 implemented was on October 4, 2013. During this visit, a Disney employee 23 told V.M.N. Disney was doing away with the GAC. Shocked, V.M.N. asked how 24 Disney expected to accommodate A.M.N. during their next visit. The Disney 25

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1 employee simply replied, “You will have to wait and see,” and refused to 2 elaborate further. 3 632. V.M.N. and A.M.N.’s first visit to Disneyland under the DAS was on 4 February 28, 2014. After a 30-minute wait at Guest Relations, V.M.N. and 5 A.M.N.’s supremely unaccommodating day began at Peter Pan, where they 6 were asked to wait in a “wheelchair line.” While they waited in line, a family of 7 six non-DAS customers walked up with FastPasses in hand and were granted 8 immediate access to the ride, while V.M.N., S.R.N., and A.M.N. watched and 9 waited, aghast. Unfortunately, this would not be the only time V.M.N. and 10 A.M.N. would experience this exact set of circumstances; being asked to wait

11 in line and watch as other families were given prompt access to Disney’s 12 attractions and rides. Guests with tour guides were also allowed fast access to 13 the ride, while A.M.N. was required to wait extended periods of time. 14 633. Next, V.M.N. and A.M.N. visited the Frozen Meet and Greet 15 Attraction where they were confronted with a 120-minute wait. V.M.N. 16 showed the employee A.M.N.’s DAS card to which she responded “We don’t do DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 DAS or FastPasses for character meet and greets,” before refusing to write 18 down a return time on A.M.N.’s DAS card, contrary to explicit instructions 19 given to V.M.N. atDeadline.com Guest Relations when they first entered the Disney Parks. 20 V.M.N. and A.M.N. faced no choice but to walk away after which A.M.N. 21 experienced her first meltdown. If Disney is using the DAS to feign a genuine 22 desire to accommodate rather than exclude guests with cognitive 23 impairments, it has not even gone to the trouble of erecting a such a false 24 25

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1 construct for character meet and greets. Those events are simply inaccessible, 2 period. 3 634. V.M.N. and A.M.N. were able to recover from her first meltdown, 4 after which they successfully visited a few Disney attractions. Then they 5 reached Star Tours, which A.M.N. had always entered through an alternate 6 entrance. The ride operator told V.M.N. and A.M.N. they could no longer enter 7 that way and must ride an elevator. V.M.N. experienced another dreaded 8 meltdown, not entirely as a result of the arbitrary disruption. An additional 9 contributor is the requirement of elevator usage. Elevators are highly 10 stimulating to autistic persons, positively or negatively.

11 635. A.M.N. suffered another meltdown at Autopia, where the 12 employee directed A.M.N. and her parents to wait at a queue located in a 13 tunnel, instead of allowing them to enter the ride through the exit, as had 14 always been permitted in the past. 15 636. V.M.N. and A.M.N. left the Parks by 5:00 p.m., disappointed by 16 their unfulfilling Disney experience; which lacked the accommodation and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 magic V.M.N. and A.M.N. had always experienced before the DAS. 18 637. Before they left the park, V.M.N. went to Guest Relations to discuss 19 all of the unfavorableDeadline.com issues they were confronted with at Disneyland. The 20 employee told V.M.N. that she would communicate with management, and 21 asked V.M.N. to return in the morning. V.M.N. did as requested, but the 22 employee offered no answers. V.M.N. visited Guest Relations on five separate 23 occasions, each time hoping for answers about what more could be done other 24 than rigidly following the letter of the DAS. On each occasion, Disney refused 25

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1 to provide any information. Disney refused to consider or discuss any 2 individual assessment of A.M.N.’s needs. 3 638. V.M.N. and A.M.N. returned to the Disney Parks the next day, 4 hoping for a better Disney experience. After a 25-minute wait at Mickey’s Fun 5 Wheel, which did not accept the DAS or return times, A.M.N. experienced yet 6 another meltdown. 7 639. V.M.N. and A.M.N. returned to the Disney Parks again on October 8 6, 2014 for yet another arbitrary and unaccommodating experience. 9 640. Similar to their last visit to the Disney Parks, this trip began with a 10 long and frustrating encounter at Guest Relations. V.M.N. explained to the

11 Disney employee, “Kim,” that they had received five readmission passes 12 during their last visit to the Disney Parks. Kim simply responded that Disney 13 did not do this. V.M.N. then requested to speak to a manager. 14 641. “Kelley,” a Disney manager appeared on scene, and offered V.M.N. 15 an explanation of how the D.A.S. worked. V.M.N. then told Kelly about the five 16 readmission passes they had received during their last visit to the Disney DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Parks. Kelley mentioned that the computer did not reflect that this 18 accommodation had been given last time, but they would provide the 19 readmission passesDeadline.com anyways. Kim made out the passes, but indicated V.M.N. 20 would have to return to Guest Relations daily to receive the readmit passes. 21 V.M.N. protested having to go through this process daily, to which Kim again 22 had to speak with Kelley, who again overrode Kim and agreed to provide five 23 additional fast passes, daily, in envelopes for V.M.N. and A.M.N. The entire 24 25

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1 encounter at Guest Relations lasted close to 60 minutes and involved two 2 manager overrides. 3 642. Over the course of the next four days, A.M.N. and V.M.N. would 4 experience multiple incongruities and inconsistencies at the Disney Parks as a 5 result of the DAS, in addition to myriad instances of discrimination by Disney 6 employees, including: 7 a. A DAS kiosk was placed in the middle of a Trick or Treat 8 Trail making the wait line for that DAS kiosk appear very long, deterring and 9 making it difficult to obtain a DAS ride return time; 10 b. At Monsters Inc., Mike & Sulley to the Rescue! A.M.N. and

11 V.M.N. encountered a five minute wait. In order to accommodate A.M.N.’s need 12 for order and consistency, V.M.N. asked the Disney employee if A.M.N. could 13 enter through the ride’s exit, as she had done in the past. Initially, the Disney 14 employee refused to grant V.M.N. and A.M.N. this accommodation, ordering 15 they enter only through the main entrance. A similar experience was 16 encountered at Autotopia and Star Tours; DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 c. After three days of A.M.N. being given access to Star Tours 18 through the exit, on the fourth day A.M.N. was suddenly denied access to Star 19 Tours after V.M.N.Deadline.com was told by one Disney employee A.M.N. could enter 20 through the exit, only for V.M.N. to be denied access by another Disney 21 employee upon actually reaching the exit. That same Disney employee, 22 “Vanessa,” explained that “City Hall did not run her attraction” and that every 23 day that A.M.N. was accommodated by being given access to the ride through 24 the exit was a day they were bending the rules before huffing “Oh my God!” 25

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1 upon V.M.N. requesting to speak to a manager. Meanwhile, A.M.N. painfully 2 stood by and watched a total of eight ride sequences elapse before becoming 3 agitated, kicking and banging her head against the wall as she experienced a 4 meltdown; 5 d. V.M.N. and A.M.N. arrived at Pirates of the Caribbean two 6 hours after the time assigned on their DAS because A.M.N. had experienced a 7 meltdown earlier and needed time to eat dinner and recover. Upon showing 8 the Disney employee their DAS, the Disney employee told V.M.N. “You are very 9 late.” V.M.N. explained to the Disney employee why they were late, to which 10 the Disney employee responded “Well next time, try to come closer to the time

11 on the card.” 12 643. V.M.N. and A.M.N. encountered a 45-minute stand-by line even 13 after receiving their DAS ride return time. Upon arriving to the line at the 14 allotted DAS ride return time, 45 minutes later, a Disney employee then 15 directed V.M.N. and A.M.N. to a crowded FastPass line where A.M.N. had to 16 wait on the side with her service animal while her father waited in the DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 FastPass line for A.M.N. 18 644. After October 9, 2013, A.M.N. no longer received the type of 19 accommodation Deadline.comand attention A.M.N. and V.M.N. had received when they 20 visited the Disney Parks in the past. 21 645. As a result of Disney’s refusal to modify its procedures to 22 reasonably accommodate A.M.N.’s needs, A.M.N. and V.M.N. have been 23 discouraged and deterred from the full use and enjoyment of the park's rides 24 and attractions. V.M.N. would visit the Parks with A.M.N. more often if Disney 25

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1 had not abandoned its past policy of accommodating the special needs of 2 persons with cognitive impairments. Their interest in attending the Parks is 3 substantially reduced. V.M.N. knows they should avoid attending the parks in 4 the future due to the reasonable expectation that A.M.N. will be subjected to 5 discrimination, and that the experience will again be an un-magical and un- 6 accommodating one. 7 646. Notwithstanding Disney’s highly sophisticated knowledge of the 8 needs of persons with cognitive impairments, and notwithstanding Disney’s 9 historic ability to accommodate A.M.N.’s special needs, Disney personnel have 10 refused to conduct an individualized assessment of A.M.N.'s capacity to utilize

11 the DAS, and have refused to modify the DAS to allow A.M.N. to enjoy the same 12 benefits and privileges as non-disabled patrons. 13 647. Disney personnel have shown no openness, willingness or desire 14 to improve the experience for guests like A.M.N. 15 648. V.M.N. incurred expenses associated with wasted trips to the 16 Disney Parks. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 649. During one or more visits to the Parks, A.M.N. suffered an actual 18 meltdown. 19 650. The Deadline.comsymptoms and conditions associated with A.M.N.’s meltdown 20 constitute a physical injury under California law. 21 651. A.M.N.’s meltdown in the Parks was proximately caused by 22 Disney’s negligent, unlawful, reckless and arbitrary treatment of A.M.N. during 23 her patronage of Disney’s facilities. At all material times, Disney knew A.M.N. 24 to be vulnerable to emotional injury if treated in such a manner by anyone. 25

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1 652. A.M.N.’s meltdown and the treatment which proximately caused 2 A.M.N. to experience the meltdown caused her grave and extreme mental 3 anguish and emotional trauma, for which Disney should be held accountable. 4 WHEREFORE, Plaintiff A.M.N., by and through V.M.N. as A.M.N.’s next 5 friend, parent and natural guardian, prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Enjoining Defendant to cease the practices which are causing 8 discrimination against Plaintiff on account of J.C.P.’s disability; 9 and 10 • Enjoining Defendant to reasonably modify its policies,

11 practices, and procedures to afford Plaintiff with an 12 opportunity to experience Disney’s goods, services, facilities, 13 privileges, advantages, and accommodations; and 14 • Establishing Court-approved remedial measures that Disney 15 must implement, to prevent Disney from further discriminating 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI against Plaintiffs when they visit the Disney Parks; and 17 • Establishing Court-approved requirements for information 18 dissemination about Disney’s remedial measures and modified 19 policies,Deadline.com to prevent Disney from further deterring Plaintiff from 20 visiting Disney Parks as a result of anticipated discrimination; 21 and 22 • Establishing a monitoring program to ensure Disney’s 23 compliance with the Court’s Orders; and 24 25

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1 • Finding that Disney negligently inflicted emotional distress 2 upon A.M.N.; and 3 • Finding such infliction to have caused damages to A.M.N.; and 4 • Entering judgment for Plaintiff A.M.N. in the amount of such 5 damages; and 6 • Awarding reasonable litigation costs as may be determined by 7 the Court in favor of Plaintiff and against Disney; and 8 • Awarding prejudgment interest; and 9 • Such other relief as this Court may find just and equitable. 10 COUNT 48

11 Intentional Infliction of Emotional Distress 12 A.M.N. v. Disney 13 653. Plaintiff A.M.N. incorporates and re-alleges the allegations of 14 paragraphs 1 through 90 and 616 through 652 above. 15 654. During one or more visits to the Parks, A.M.N. suffered an actual 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI meltdown. 17 655. The symptoms and conditions associated with A.M.N.’s meltdown 18 constitute a physical injury under California law. 19 656. A.M.N.’sDeadline.com meltdown in the Parks was proximately caused by 20 Disney’s outrageous, unlawful and reckless treatment of A.M.N. during her 21 patronage of Disney’s facilities. At all material times, Disney knew A.M.N. to 22 be vulnerable to emotional injury if treated in such a manner by anyone. 23 24 25

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1 657. A.M.N.’s meltdown and the treatment which proximately caused 2 A.M.N. to experience the meltdown caused her grave and extreme mental 3 anguish and emotional trauma, for which Disney should be held accountable. 4 WHEREFORE, Plaintiff A.M.N., by and through V.M.N. as A.M.N.’s next 5 friend, parent and natural guardian, prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney intentionally inflicted emotional distress 8 upon A.M.N.; and 9 • Finding such infliction to have caused damages to A.M.N.; and 10 • Entering judgment for Plaintiff A.M.N. in the amount of such 11 damages; 12 • Entering judgment in favor of Plaintiff and against Disney for 13 exemplary or punitive damages; and 14 • Awarding reasonable litigation costs as may be determined by 15 the Court in favor of Plaintiff and against Disney; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Awarding prejudgment interest; and 17 • Such other relief as this Court may find just and equitable. 18 COUNT 49 19 NegligentDeadline.com Infliction of Emotional Distress 20 V.M.N. v. Disney 21 658. Plaintiff V.M.N. incorporates and re-alleges the allegations of 22 paragraphs 1 through 90, 616 through 652, and 654 through 657above. 23 659. During one or more visits to the Parks, V.M.N.’s beloved daughter 24 A.M.N. suffered an actual meltdown while in V.M.N.’s presence. 25

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1 660. The symptoms and conditions associated with A.M.N.’s meltdown 2 constitute a physical injury to A.M.N. under California law. 3 661. A.M.N.’s meltdown in the Parks was proximately caused by 4 Disney’s negligent, unlawful, reckless and arbitrary treatment of A.M.N. during 5 her patronage of Disney’s facilities. At all material times, Disney knew A.M.N. 6 to be vulnerable to emotional injury if treated in such a manner by anyone. 7 662. V.M.N. directly observed the stressors leading up to the meltdown, 8 A.M.N.’s resulting escalation and her meltdown. Particularly in light of her 9 trust and confidence that Disney would comply with applicable law and act in 10 a gracious and caring manner toward her daughter, V.M.N. could do nothing

11 reasonable to prevent the meltdown. 12 663. V.M.N.’s observation of A.M.N.’s meltdown and of the outrageous 13 conduct and treatment which proximately caused A.M.N. to experience the 14 meltdown caused V.M.N. grave and extreme mental anguish and emotional 15 trauma, for which Disney should be held accountable. 16 WHEREFORE, Plaintiff V.M.N. prays that this Court adjudicate this DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 dispute and enter an Order: 18 • Finding that Disney negligently inflicted emotional distress 19 uponDeadline.com V.M.N.; and 20 • Finding such infliction to have caused damages to V.M.N.; and 21 • Entering judgment for Plaintiff V.M.N. in the amount of such 22 damages; and 23 • Awarding reasonable litigation costs as may be determined by 24 the Court in favor of Plaintiff and against Disney; and 25

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1 • Awarding prejudgment interest; and 2 • Such other relief as this Court may find just and equitable. 3 COUNT 50 4 Intentional Infliction of Emotional Distress 5 V.M.N. v. Disney 6 664. Plaintiff V.M.N. incorporates and re-alleges the allegations of 7 paragraphs 1 through 90, 616 through 652, and 654 through 657above. 8 665. During one or more visits to the Parks, V.M.N.’s beloved daughter 9 A.M.N. suffered an actual meltdown. 10 666. The symptoms and conditions associated with A.M.N.’s meltdown

11 constitute a physical injury under California law. 12 667. A.M.N.’s meltdown in the Parks was proximately caused by 13 Disney’s outrageous, unlawful and reckless treatment of A.M.N. during her 14 patronage of Disney’s facilities. At all material times, Disney knew A.M.N. to 15 be vulnerable to emotional injury if treated in such a manner by anyone. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 668. V.M.N. directly observed the stressors leading up to the meltdown, 17 A.M.N.’s resulting escalation and her meltdown. Particularly in light of her 18 trust and confidence that Disney would comply with applicable law and act in 19 a gracious and caringDeadline.com manner toward her daughter, V.M.N. could do nothing 20 reasonable to prevent the meltdown. 21 669. V.M.N.’s observation of A.M.N.’s meltdown and of the outrageous 22 conduct and treatment which proximately caused A.M.N. to experience the 23 meltdown caused V.M.N. grave and extreme mental anguish and emotional 24 trauma, for which Disney should be held accountable. 25

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1 WHEREFORE, Plaintiff V.M.N. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney intentionally inflicted emotional distress 4 upon V.M.N.; and 5 • Finding such infliction to have caused damages to V.M.N.; and 6 • Entering judgment for Plaintiff V.M.N. in the amount of such 7 damages; 8 • Entering judgment in favor of Plaintiff and against Disney for 9 exemplary or punitive damages; and 10 • Awarding reasonable litigation costs as may be determined by

11 the Court in favor of Plaintiff and against Disney; and 12 • Awarding prejudgment interest; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 51 15 Breach of Contract 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI V.M.N. v. Disney 17 670. Plaintiff V.M.N. incorporates and re-alleges the allegations of 18 paragraphs 1 through 90, 616 through 652, and 654 through 657above. 19 671. V.M.N.Deadline.com entered into a contract through which Disney promised to 20 provide a reasonable and enjoyable amusement park experience, and one 21 which complies with applicable law. 22 672. Disney failed or refused to provide the promised experience, and 23 is in breach of contract. 24 25

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1 673. V.M.N. incurred expenses associated with the family’s wasted 2 trips to the Parks. Plaintiff is damaged by Disney’s breach of contract. 3 WHEREFORE, Plaintiff V.M.N. prays that this Court adjudicate this 4 dispute and enter an Order: 5 • Finding that Disney breached its contract with V.M.N..; and 6 • Entering judgment for Plaintiff V.M.N.in the amount of her 7 economic monetary damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 52 13 Negligent Infliction of Emotional Distress 14 D.L.B. v. Disney 15 674. Plaintiff D.L.B. incorporates and re-alleges paragraphs 1 through 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 90 above. 17 675. D.L.B. has autism, attention deficit hyperactivity disorder, and 18 oppositional defiance disorder. He also suffers from a mood disorder and 19 anxiety. D.L.B.’sDeadline.com symptoms include aggression, impulsiveness, defiance, 20 attention problems, social problems, and oppositional behaviors including 21 running from caregivers, arguing, and tantrums. Behavior meltdowns for 22 D.L.B. consist generally of a heightened propensity to elope and aggressive 23 behavior directed toward his nearby family members, including biting, 24 scratching, hitting, kicking, and head-butting. 25

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1 676. Autism substantially limits a person’s ability to care for himself, 2 perform manual tasks, speak, learn, read, concentrate, think, communicate, 3 perceive the concept of time, pair sights and sounds that happen 4 simultaneously, and work. 5 677. D.L.B. is a person with a disability, as that term is defined in 42 6 U.S.C. §12102(1). 7 678. D.L.B. is nine years old and is generally in the care of his mother, 8 L.V.F. who brings this action as D.L.B.'s next friend, parent and natural 9 guardian. 10 679. D.L.B. and L.V.F. are residents of Del Norte County, California.

11 680. L.V.F. grew up a Disney lover; annual trips to Disneyland were a 12 familial tradition. 13 681. L.V.F. first took D.L.B. to Disneyland in 2010 when D.L.B. was four 14 years old. Unfortunately, L.V.F., who was also pregnant at the time, did not 15 know the GAC was available to D.L.B. during that trip, and they attempted to 16 enjoy the day visiting the attractions through the standby lines. Given D.L.B.’s DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 condition, doing so made the day a largely un-accommodating experience. 18 Even during the first pre-DAS visit, without the GAC, D.L.B. exhibited a nature 19 and extent of joyDeadline.com that he rarely showed in any other setting. L.V.F. was always 20 proud and joyful of the opportunity to bring to her beloved child a level of 21 happiness which she rarely showed elsewhere. Disneyland provided the 22 unique chance to take D.L.B. out of his box and allow him to experience the 23 world as other non-disabled children are able to. 24 25

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1 682. D.L.B.’s cognitive impairments have manifested themselves in a 2 certain way during the family’s visits to the Parks. D.L.B.’s disorder makes it 3 very difficult for him to stand idly around, killing time, for extended periods of 4 time. 5 683. D.L.B’s disorders also compel him to experience certain Disney 6 attractions repetitively. D.L.B. can be a “repeat rider.” This is a propensity 7 common among autistic persons – a variety of the need for consistency, order 8 and routine. D.L.B. will experience a particular ride or attraction, such as Buzz 9 Lightyear, over and over, for several hours at a time. Disney personnel are 10 very familiar with the repeat rider type of guest. If D.L.B. were denied the

11 ability to ride a ride such as Buzz Lightyear repetitively, he would experience 12 a meltdown. 13 684. If D.L.B. were required to idly wait for entry into a ride or 14 attraction for more than a few minutes he also would likely melt down. 15 During the wait, his stimming behaviors would escalate in frequency or 16 severity. If he is not removed from the condition, or the condition removed DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 from him, a meltdown will occur. Most likely, D.L.B. would eventually elope, 18 or run away without warning. 19 685. BecauseDeadline.com D.L.B. is incapable of understanding the concept of 20 visiting a ride or attraction only to be prohibited from riding it until a future 21 time, the new DAS creates avoidable stressors for D.L.B., escalating his 22 stimming patterns toward meltdowns, especially in high traffic areas of the 23 park. Since Disney’s implementation of the new DAS, D.L.B. has experienced 24 several meltdowns at Disneyland. 25

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1 686. Due to its failure to accommodate which leads to an increased 2 propensity for D.L.B. experiencing a meltdown, Defendant has prevented 3 D.L.B. from experiencing the full enjoyment of its Parks, equal to the 4 experiences of persons without a disability. 5 687. L.V.F. and D.L.B.’s first and only visit to Disneyland under the DAS 6 was March 28, 2014. After a 45-minute wait and a trip up a flight of stairs with 7 a special needs stroller for her other child, who has been diagnosed with 8 Down syndrome, L.V.F. was able to speak with an employee at Guest Relations. 9 The employee then required L.V.F. to explain D.L.B.’s disability to her and 10 explain why they needed a DAS card. L.V.F. was given a DAS card for D.L.B.,

11 and a sticker for her other child which effectively turned the special needs 12 stroller into a wheelchair, forcing her to wait in line. Disneyland no longer 13 recognizes mobility disabilities and Down syndrome was not, according to 14 Disney, a cognitive impairment requiring a DAS card. Thus, L.V.F.’s family 15 would effectively become split up; one cognitively impaired child would be 16 given the DAS card and destined to a trip of return times while the other child DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 would be forced to wait in the standby line because she had the audacity to 18 also require mobility assistance. 19 688. L.V.F.Deadline.com began their new Disney experience, much of which 20 consisted of running between kiosks to determine or obtain ride times. 21 Eventually, D.L.B. was able to ride a ride, with the first one being Pirates of the 22 Caribbean with a mere 45-minute return time. 23 689. The next stop on their Disney adventure was Buzz Lightyear. After 24 waiting the requisite 25 minutes, as given to them at the Kiosk before going to 25

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1 the actual ride, L.V.F. and D.L.B. entered the line. Mid-queue, there was an 2 earthquake, subsequently shutting down the ride. L.V.F. and D.L.B. were asked 3 to come back. But because D.L.B.’s DAS card had already been scratched off by 4 the Disney employee, D.L.B. was required to obtain a new return time and 5 repeat the wait. 6 690. After riding Buzz Lightyear, D.L.B. wanted and expected to repeat- 7 ride. L.V.F. returned to the ride operator and asked if whether they could ride 8 Buzz Lightyear again. The ride operator looked at D.L.B.’s card, said this would 9 not be possible because there was no return time written down, and advised 10 they return to the kiosk. But before L.V.F. could take D.B.L. back to the kiosk

11 to do just that, he experienced a meltdown and immediately ran off in the 12 opposite direction. As he did this, the Disney ride operator told L.V.F. what her 13 son needed was “a good ol’ fashioned spankin’.” 14 691. L.V.F. and D.L.B. left the Disney Parks that night, feeling dejected 15 and frustrated, but hopeful that the next day would be the magical Disney 16 experience they had hoped for; the one for which they spent months saving DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 and two days traveling. 18 692. L.V.F. and D.L.B. returned to the Disney Parks the next day, only to 19 be as disappointedDeadline.com and un-accommodated as the first. This, despite the fact 20 that they explained to employees at kiosks that the new system was not 21 working for them. They encountered a 60-minute wait at Star Tours. Unable 22 to wait around for such a time, L.V.F. attempted to take D.L.B. away and 23 consume the time awaiting the return to Star Tours. During that effort, D.L.B. 24 suffered multiple meltdowns. After riding only two rides, L.V.F. was forced to 25

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1 leave the Disney Parks early with L.V.F.; she could not continue to allow her 2 son to suffer. 3 693. The third day at Disneyland was as unfulfilling and disastrous as 4 the first. Upon arriving at Pinocchio for their return time, L.V.F. could not 5 readily locate an alternate entrance. L.V.F. asked a Disney employee to help 6 her locate the alternate entrance. He then explained that she had to go to the 7 “regular line and wait like everyone else.” This of course, after already waiting 8 the requisite time as indicated on their DAS card. 9 694. Over the course of three days at the Disney Parks, D.L.B. rode a 10 total of seven rides.

11 695. As a result of Disney’s refusal to modify its procedures to 12 reasonably accommodate D.L.B.’s needs, D.L.B. and L.V.F. have been 13 discouraged and deterred from the full use and enjoyment of the park's rides 14 and attractions. L.V.F. would visit the Parks with D.L.B. more often if Disney 15 had not abandoned its past policy of accommodating the special needs of 16 persons with cognitive impairments. Their interest in attending the Parks is DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 substantially reduced. L.V.F. knows they should avoid attending the parks in 18 the future due to the reasonable expectation that the experience would again 19 subject D.L.B. toDeadline.com unlawful discrimination, and that they would simply suffer 20 through another un-magical and un-accommodating day. 21 696. Notwithstanding Disney’s highly sophisticated knowledge of the 22 needs of persons with cognitive impairments, and notwithstanding Disney’s 23 historic ability to accommodate D.L.B.’s special needs, Disney personnel have 24 refused to conduct an individualized assessment of D.L.B.'s capacity to utilize 25

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1 the DAS, and have refused to modify the DAS to allow D.L.B. to enjoy the same 2 benefits and privileges as non-disabled patrons. 3 697. Disney personnel have shown no willingness or desire to improve 4 the experience for guests like D.L.B. 5 698. L.V.F. incurred expenses associated with the family’s wasted trips 6 to the Parks. 7 699. During one or more visits to the Parks, D.L.B. suffered an actual 8 meltdown. 9 700. The symptoms and conditions associated with D.L.B.’s meltdown 10 constitute a physical injury under California law.

11 701. D.L.B.’s meltdown in the Parks was proximately caused by 12 Disney’s negligent, unlawful, reckless and arbitrary treatment of D.L.B. during 13 his patronage of Disney’s facilities. At all material times, Disney knew D.L.B. to 14 be vulnerable to emotional injury if treated in such a manner by anyone. 15 702. D.L.B.’s meltdown and the treatment which proximately caused 16 D.L.B. to experience the meltdown caused him grave and extreme mental DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 anguish and emotional trauma, for which Disney should be held accountable. 18 WHEREFORE, Plaintiff D.L.B., by and through L.V.F. as D.L.B.’s next 19 friend, parent andDeadline.com natural guardian, prays that this Court adjudicate this 20 dispute and enter an Order: 21 • Enjoining Defendant to cease the practices which are causing 22 discrimination against Plaintiff on account of D.L.B.’s disability; 23 and 24 25

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1 • Enjoining Defendant to reasonably modify its policies, 2 practices, and procedures to afford Plaintiff with an 3 opportunity to experience Disney’s goods, services, facilities, 4 privileges, advantages, and accommodations; and 5 • Establishing Court-approved remedial measures that Disney 6 must implement, to prevent Disney from further discriminating 7 against Plaintiff when they visit the Disney Parks; and 8 • Establishing Court-approved requirements for information 9 dissemination about Disney’s remedial measures and modified 10 policies, to prevent Disney from further deterring Plaintiff from

11 visiting Disney Parks as a result of anticipated discrimination; 12 and 13 • Establishing a monitoring program to ensure Disney’s 14 compliance with the Court’s Orders; and 15 • Finding that Disney negligently inflicted emotional distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI upon D.L.B.; and 17 • Finding such infliction to have caused damages to D.L.B.; and 18 • Entering judgment for Plaintiff D.L.B. in the amount of such 19 damagDeadline.comes; and 20 • Awarding reasonable litigation costs as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 • Awarding prejudgment interest; and 23 24 • Such other relief as this Court may find just and equitable. 25

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1 COUNT 53 2 Intentional Infliction of Emotional Distress 3 D.L.B. v. Disney 4 703. Plaintiff D.L.B. incorporates and re-alleges the allegations of 5 paragraphs 1 through 90, and 703 through 707 above. 6 704. During one or more visits to the Parks, D.L.B. suffered an actual 7 meltdown. 8 705. The symptoms and conditions associated with D.L.B.’s meltdown 9 constitute a physical injury under California law. 10 706. D.L.B.’s meltdown in the Parks was proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of D.L.B. during his 12 patronage of Disney’s facilities. At all material times, Disney knew D.L.B. to be 13 vulnerable to emotional injury if treated in such a manner by anyone. 14 707. D.L.B.’s meltdown and the treatment which proximately caused 15 D.L.B. to experience the meltdown caused him grave and extreme mental 16 anguish and emotional trauma, for which Disney should be held accountable. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 WHEREFORE, Plaintiff D.L.B., by and through L.V.F. as D.L.B.’s next 18 friend, parent and natural guardian, prays that this Court adjudicate this 19 dispute and enterDeadline.com an Order: 20 • Finding that Disney intentionally inflicted emotional distress 21 upon D.L.B.; and 22 • Finding such infliction to have caused damages to D.L.B.; and 23 • Entering judgment for Plaintiff D.L.B. in the amount of such 24 damages; 25

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1 • Entering judgment in favor of Plaintiff and against Disney for 2 exemplary or punitive damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 54 8 Negligent Infliction of Emotional Distress 9 L.V.F. v. Disney 10 708. Plaintiff L.V.F. incorporates and re-alleges the allegations of

11 paragraphs 1 through 90,675 through 702, and 704 through 707 above. 12 709. During one or more visits to the Parks, L.V.F.’s beloved son D.L.B. 13 suffered an actual meltdown while in L.V.F.’s presence. 14 710. The symptoms and conditions associated with D.L.B.’s meltdown 15 constitute a physical injury to D.L.B. under California law. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 711. D.L.B.’s meltdown in the Parks was proximately caused by 17 Disney’s negligent, unlawful, reckless and arbitrary treatment of D.L.B. during 18 his patronage of Disney’s facilities. At all material times, Disney knew D.L.B. to 19 be vulnerable to Deadline.comemotional injury if treated in such a manner by anyone. 20 712. L.V.F. directly observed the stressors leading up to the meltdown, 21 D.L.B.’s resulting escalation and his meltdown. Particularly in light of her trust 22 and confidence that Disney would comply with applicable law and act in a 23 gracious and caring manner toward her son, L.V.F. could do nothing 24 reasonable to prevent the meltdown. 25

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1 713. L.V.F.’s observation of D.L.B.’s meltdown and of the outrageous 2 conduct and treatment which proximately caused D.L.B. to experience the 3 meltdown caused L.V.F. grave and extreme mental anguish and emotional 4 trauma, for which Disney should be held accountable. 5 WHEREFORE, Plaintiff L.V.F. prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney negligently inflicted emotional distress 8 upon L.V.F.; and 9 • Finding such infliction to have caused damages to L.V.F.; and 10 • Entering judgment for Plaintiff L.V.F. in the amount of such 11 damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 55 17 Intentional Infliction of Emotional Distress 18 L.V.F. v. Disney 19 714. PlaintiffDeadline.com L.V.F. incorporates and re-alleges the allegations of 20 paragraphs 1 through 90,675 through 702, and 704 through 707 above. 21 715. During one or more visits to the Parks, L.V.F.’s beloved son D.L.B. 22 suffered an actual meltdown. 23 716. The symptoms and conditions associated with D.L.B.’s meltdown 24 constitute a physical injury under California law. 25

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1 717. D.L.B.’s meltdown in the Parks was proximately caused by 2 Disney’s outrageous, unlawful and reckless treatment of D.L.B. during his 3 patronage of Disney’s facilities. At all material times, Disney knew D.L.B. to be 4 vulnerable to emotional injury if treated in such a manner by anyone. 5 718. L.V.F. directly observed the stressors leading up to the meltdown, 6 D.L.B.’s resulting escalation and his meltdown. Particularly in light of her trust 7 and confidence that Disney would comply with applicable law and act in a 8 gracious and caring manner toward her son, L.V.F. could do nothing 9 reasonable to prevent the meltdown. 10 719. L.V.F.’s observation of D.L.B.’s meltdown and of the outrageous

11 conduct and treatment which proximately caused D.L.B. to experience the 12 meltdown caused L.V.F. grave and extreme mental anguish and emotional 13 trauma, for which Disney should be held accountable. 14 WHEREFORE, Plaintiff L.V.F. prays that this Court adjudicate this 15 dispute and enter an Order: 16 • Finding that Disney intentionally inflicted emotional distress DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 upon L.V.F.; and 18 • Finding such infliction to have caused damages to L.V.F.; and 19 • EnteringDeadline.com judgment for Plaintiff L.V.F. in the amount of such 20 damages; 21 • Entering judgment in favor of Plaintiff and against Disney for 22 exemplary or punitive damages; and 23 • Awarding reasonable litigation costs as may be determined by 24 the Court in favor of Plaintiff and against Disney; and 25

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1 • Awarding prejudgment interest; and 2 • Such other relief as this Court may find just and equitable. 3 COUNT 56 4 Breach of Contract 5 B.D.G. v. Disney 6 720. Plaintiff B.D.G. incorporates and re-alleges the allegations of 7 paragraphs 1 through 90 above. 8 721. J.T.G. has autism. 9 722. Autism substantially limits a person’s ability to care for himself, 10 perform manual tasks, speak, learn, read, concentrate, think, communicate,

11 perceive the concept of time, pair sights and sounds that happen 12 simultaneously, and work. 13 723. J.T.G. is seven years of age, and is generally in the care of his 14 mother, B.D.G., who brings this action as J.T.G.’s next friend, parent and 15 natural guardian. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 724. J.T.G. and B.D.G. are residents of Clark County, Nevada. 17 725. J.T.G. and B.D.G. planned J.T.G’s first trip to Disneyland. B.D.G. was 18 hopeful that J.T.G. would find in his Disneyland experience an extent of joy 19 that he rarely showedDeadline.com in any other setting. 20 726. J.T.G. is incapable of standing around for significant periods of 21 time, idly biding time, without his cognitive impairments causing him to 22 experience stimming and meltdowns. Triggers and anxiety will cause J.T.G. to 23 exhibit stimming and maladaptive behaviors including screaming, head 24 25

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1 banging, high blood pressure nose bleeds, climbing rails, and throwing himself 2 to the ground. 3 727. Before J.T.G. went to the Disneyland on February 26, 2014, B.D.G. 4 consulted J.T.G.’s special education teacher who suggested they plan out the 5 sequence of rides in advance because J.T.G. is so rigid and into routine and he 6 will get stressed if they proceed through the Disney Park without a plan or if 7 they deviate from the plan. 8 728. So J.T.G. and B.D.G. talked about the plan for maneuvering through 9 the Disneyland well in advance in advance of the trip. 10 729. N.T.G. also phoned Disney in advance of the trip with concerns

11 about accommodations for her son in the Disney Parks. 12 730. A Disney representative told N.T.G. that the DAS was 13 “independently based” and she was advised to bring J.T.G.’s individualized 14 education plan and letter, supporting his needs, from his doctor to Guest 15 Relations when she entered Disneyland. 16 731. N.T.G. communicated to Disney that J.T.G. could not endure

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 significant wait times. In response, she was told J.T.G. would not have to wait 18 in line. 19 732. DisneyDeadline.com represented that in addition to the DAS, additional 20 FastPasses may be available to J.T.G. at Guest Relations. N.T.G. was not told 21 that with the DAS, N.T.G. would have to check in at the ride and be given an 22 appointment time for later return. 23 733. Based on Disney’s misrepresentation and failed disclosure, B.D.G. 24 purchased tickets for Disneyland and visited the park on February 26, 2014. 25

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1 734. B.D.G. and J.T.G. had an awful experience. Their plan could not 2 work with the new DAS. The prohibition against making multiple ride 3 appointment times forced B.D.G. and J.T.G. to go on different rides in an 4 unpredictable sequence, because they were required to continuously return to 5 Guest Relations. Each time they did so, J.T.G. saw another ride along the way, 6 but it was just one more ride they could not ride without an appointment, and 7 for which they could not make an appointment while possessing another 8 appointment. 9 735. The entire experience led to multiple meltdowns for J.T.G. During 10 J.T.G.’s meltdowns his blood pressure rose so high he suffered nosebleeds.

11 736. Feeling defeated, J.T.G.’s father broke down in tears from the 12 stress on his family and the waste of monetary, emotional, and time resources 13 Disney placed on his family by not better accommodating his son. Only then, 14 did Guest Relations respond by providing the family with three passes which 15 were said to be an additional accommodation. 16 737. Still having trouble during the day, an attendant at the Gadget

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Coaster ride noticed that J.T.G. had a problem and she gave one member of his 18 party a gold-colored pass with the words “one-time-pass” on it. She told him 19 that they shouldDeadline.com show that pass, and they would not have to use the DAS pass. 20 This card was collected by a ride attendant and was thus a one-time-only 21 accommodation that did not last the length of the visit. 22 738. During one of J.T.G.’s meltdowns, B.D.G. took J.T.G. by monorail 23 back to the resort hotel for a break and to calm down after a nosebleed. 24 25

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1 739. Upon returning to Disneyland, J.T.G. continued to struggle with 2 meltdowns due to the poor accommodations for J.T.G.’s disability. 3 740. Moreover, the DAS card is only valid for approximately two 4 weeks, despite the fact that J.T.G.’s diagnosis will not change. 5 741. The expiration of the DAS card after approximately two weeks 6 assures that each visit to the Parks will begin with stressors, not pleasures. 7 742. The new DAS procedure triggered J.T.G.’s meltdowns on February 8 26, 2014. 9 743. Since Disney’s implementation of the new DAS, Defendant has 10 prevented J.T.G. from experiencing the full enjoyment, equal to those without

11 a disability, of the Disney Parks. 12 744. The accommodations Disney claims to provide through the DAS 13 did not allow J.T.G. to utilize his ticket in such a way that it provided the equal 14 enjoyment of the Disney Parks as that of a nondisabled person. 15 745. Notwithstanding Disney’s highly sophisticated knowledge of the 16 needs of persons with cognitive impairments, and notwithstanding Disney’s DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 historic ability to accommodate the special needs of those suffering with 18 cognitive disabilities such as J.T.G., Disney personnel offered ineffective, 19 apathetic, obtuseDeadline.com responses to B.D.G.’s recitations regarding J.T.G.’s needs. 20 Their actions and statements were so contrary to Disney’s body of knowledge 21 and to Disney’s historic performance that Disney cannot have accidentally 22 proposed such absurdities. 23 24 25

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1 746. Disney personnel showed no openness, willingness or desire to 2 improve the experience for guests like J.T.G. despite the advanced notice they 3 received of J.T.G.’s needs for accommodations. 4 747. B.D.G. incurred expenses associated with the family’s wasted trips 5 to the Disney Parks. 6 748. Disney has refused to conduct an individualized assessment of 7 J.T.G.’s capacity and for the feasibility of the DAS as a tool or policy for 8 accommodating him. 9 749. J.T.G. and B.D.G.’s interest in attending Disney Parks is 10 substantially reduced. They would like to return in the future, but they are

11 deterred by B.D.G.’s knowledge that the DAS will only lead to further 12 discrimination and misery for J.T.G. 13 750. J.T.G. is and at all material times has been a disabled person 14 within the meaning of California Government Code 12926(j). 15 751. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 16 provides protection from discrimination by all business establishments in DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 California, including housing and public accommodations, because of age, 18 ancestry, color, disability, national origin, race, religion, sex and sexual 19 orientation. Deadline.com 20 752. Section 52 of the California Civil Code provides that whoever 21 denies aids or incites a denial, or makes any discrimination or distinction 22 contrary to Section 51 is liable for each and every offense. 23 753. Pursuant to California Civil Code Section 51(f), a violation of the 24 ADA also constitutes a violation of California Civil Code Section 51, et seq. 25

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1 754. The Parks are “business establishments” within the meaning of 2 the California Code Section 51, et seq. 3 755. B.D.G. entered into a contract through which Disney promised to 4 provide a reasonable and enjoyable amusement park experience, and one 5 which complies with applicable law. 6 756. Disney failed or refused to provide the promised experience, and 7 is in breach of contract. 8 757. B.D.G. incurred expenses associated with the family’s wasted trips 9 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 10 WHEREFORE, Plaintiff B.D.G. prays that this Court adjudicate this

11 dispute and enter an Order: 12 • Finding that Disney breached its contract with B.D.G.; and 13 • Entering judgment for Plaintiff B.D.G. in the amount of her 14 economic monetary damages; and 15 • Awarding reasonable litigation costs as may be determined by 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI the Court in favor of Plaintiff and against Disney; and 17 • Awarding prejudgment interest; and 18 • Such other relief as this Court may find just and equitable. 19 Deadline.comCOUNT 57 20 Violation of the Unruh Civil Rights Act 21 California Civil Code §§51, 52 22 V.J.B. v. Disney 23 758. Plaintiff V.J.B. incorporates and re-alleges paragraphs 1through 91 24 above. 25

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1 759. V.J.B. has autism and suffers from an anxiety disorder. V.J.B.’s 2 symptoms and stimming patterns include pacing and negative self-talk. V.J.B. 3 also cannot tolerate idly waiting for events to develop, as this will cause him 4 to pace and engage in negative self-talk or become frustrated and anxious. If 5 he is unable to leave the situation, V.J.B. will either: shutdown, causing him to 6 sit down on the floor and repeat “I want to leave!”; or meltdown and 7 experience an outburst of negative self-talk, shaking his fist, hitting his head, 8 and inappropriate behaviors including talking very loudly until V.J.B. is able 9 to leave the situation. 10 760. Autism substantially limits a person’s ability to care for himself or

11 herself, perform manual tasks, speak, learn, read, concentrate, think, 12 communicate, perceive the concept of time, pair sights and sounds that 13 happen simultaneously, and work. 14 761. V.J.B. is and at all material times has been a disabled person 15 within the meaning of California Government Code §1296(j). 16 762. V.J.B. is 23 years of age, and is generally in the care of his father,

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 B.W.B., and his mother, S.L.B., who brings this action as V.J.B.’s next friend, 18 parent and natural guardian. 19 763. S.L.B.Deadline.com and V.J.B. are residents of Will County, Illinois. 20 764. V.J.B.’s cognitive impairments manifest themselves in a certain 21 way during his visits to the parks; V.J.B. is a “repeat rider.” Disney personnel 22 are very familiar with the repeat rider type of guest. This is a propensity 23 common among autistic persons – a variety of the need for consistency, order 24 and routine. V.J.B. will experience a particular ride or attraction, such as Buzz 25

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1 Lightyear Astro Blasters, over and over, for several hours at a time. V.J.B. is 2 often worn out at that time and requests to leave the Disney Parks so he can 3 relax and calm himself down. 4 765. V.J.B. is incapable of waiting significant periods of time to enter a 5 ride or attraction. If instructed to do so, the stimming patterns described 6 above will intensify toward a shutdown or worse, a meltdown. 7 766. V.J.B. has difficulty understanding the concept of time. Similarly, 8 V.J.B. is incapable of understanding the concept of visiting an attraction in the 9 present only to be told it cannot be experienced until sometime in the future. 10 As such, the new DAS creates avoidable stressors for V.J.B., constantly

11 escalating his stimming patterns towards either shutdown or meltdown. 12 767. Due to V.J.B.’s disability, V.J.B. has low muscle tone and becomes 13 fatigued very easily. V.J.B. can only stay in the Parks for a limited period of 14 time. As such, the new DAS creates more fatigue for V.J.B. by forcing him to 15 find things to do while waiting the allotted return time, not allowing him to 16 spend as much time in the Parks as other, non-disabled guests. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 768. S.L.B. grew up a Disney fan and attended the Disney Parks many 18 times before she was a mother. She took V.J.B. to the Disney Parks for the first 19 time in 1998 whenDeadline.com he was seven-years-old. They would return to the Parks 20 again in January 2011, January 2013, and August 2014. Every visit to the 21 Parks before August 2014 was a magical experience. During those pre-August 22 2014 visits, V.J.B. carried the Guest Assistance Card, and was admirably 23 accommodated. During those pre-August 2014 visits, V.J.B. exhibited a nature 24 and extent of joy that he rarely shows in any other setting. Typically, B.W.B., 25

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1 S.J.B. and V.J.B. would remain in the Parks for three-to-four hours, and would 2 be able to ride six different rides including one ride five-to-six times. After 3 four hours in the Disney Parks, B.W.B., S.J.B. and V.J.B. would leave the Disney 4 Parks since V.J.B. would be exhausted. However, B.W.B., S.J.B. and V.J.B. left the 5 Disney Parks happy. B.W.B. and S.L.B. were always proud and joyful of the 6 opportunity to bring to their beloved son a level of happiness which he rarely 7 shows elsewhere. The GAC gave B.W.B. and S.L.B. the opportunity to fully 8 enjoy their experience, no matter how brief it was. Disney employees were 9 always friendly and outgoing. Everyone was smiling and having a good time. It 10 really was a magical experience. Sometimes, S.L.B. or B.W.B. would return

11 with their daughter to experience more of the Disney magic. 12 769. This drastically changed in October 2013 when Disney released 13 the DAS. 14 770. S.L.B., B.W.B., and V.J.B.’s first visit to the parks after Disney 15 released the DAS was August 7, 2014. Like visits in the past, this one began at 16 Guest Services at California Adventure where they purchased multi-day DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 passes as they had planned on doing before arriving. B.W.B. received a DAS, 18 not knowing at the time how drastically different it was than the GAC from 19 prior trips to theDeadline.com Parks. 20 771. When S.L.B. discovered what the DAS was, she immediately 21 requested to speak to a supervisor at Guest Services. In the process of doing 22 so, V.J.B. became frustrated by the extended wait, laid down on a nearby 23 bench, and shutdown. B.W.B., S.L.B., and V.J.B. were already off to an 24 unaccommodating start. 25

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1 772. Nevertheless, B.W.B. and S.L.B. decided to give the DAS a try and 2 took V.J.B. to his first ride: Autopia. Upon arriving at Autopia, the Disney 3 employee directed B.W.B., S.L.B. and V.J.B. to a kiosk, where they would then 4 receive a return time: 5 B.W.B.: “What’s with the time?” 6 Disney employee: “This is how long the wait is, come back.” 7 B.W.B.: “Can we ride or do something else such as see a show in 8 between?” 9 Disney employee: “No.” 10 773. B.W.B., S.L.B., and V.J.B. returned to Guest Services to explain the

11 situation, assuming the Disney employee simply gave them the wrong pass. 12 B.W.B. and S.L.B. waited in line at Guest Services again before reaching the 13 counter to speak with a Disney employee. Once reaching the counter, with 14 written documentation in hand, S.L.B. tried to explain V.J.B.’s disability to the 15 Cast Member, and described in vivid detail all the ways the one-size fits all 16 DAS would not work for her family and why it was not responsive to V.J.B.’s DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 individual and unique needs . It was to no avail. In response, the Disney 18 employee at Guest Services told S.L.B. that: 1) they could not review written 19 documentation; Deadline.comand 2) everyone gets the same pass. Meanwhile, V.J.B., lying 20 on a nearby bench close to his sister, started to experience a meltdown as his 21 sister tried to assuage him. S.L.B. requested to speak to a supervisor, who then 22 arrived on scene. The Disney employee’s supervisor referred S.L.B. to Disney’s 23 in-house counsel, complete with contact information. 24 25

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1 774. S.L.B. left the line, confused, disillusioned, but still willing to give 2 the DAS a try; anything to bring V.J.B. the joy she had seen on his face at the 3 Disney Parks. V.J.B. was able to ride three rides before he could take no more 4 that day, shutdown, and demanded to leave the Park. 5 775. B.W.B., S.L.B., and V.J.B. returned to Disneyland the next day. Upon 6 arriving to Disneyland, S.L.B. went to Guest Services and requested to speak to 7 a supervisor. S.L.B. explained what had happened to her family the day before 8 and how horrible of an experience it was. S.L.B. further explained why the 9 one-size fits all DAS would not work for her family. This time, V.J.B. received 10 three FastPasses in addition to his DAS, and was able to actually tolerate the

11 Park. Unfortunately, it was not enough to make B.W.B., S.L.B. and V.J.B.’s visit 12 enjoyable. Relishing in the memory of the GAC, B.W.B. and S.L.B. quickly 13 realized neither the DAS nor the three extra Fastpasses made up for the 14 horrible experience the day prior. The Disney magic was gone. 15 776. During her family’s visit to the Disney Parks, S.L.B. reached out to 16 Disney’s in-house counsel, as directed by the Disney employee’s supervisor. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 She did not make it past the secretary who grew angry with S.L.B. and 18 demanded to know why S.L.B. was given their information and suggested 19 S.L.B. return to GuestDeadline.com Services. 20 777. Due to its failure to Disney’s refusal to accommodate the special 21 needs of persons like V.J.B., which leads to an increased propensity for V.J.B to 22 experience shutdowns or meltdowns, Disney prevents V.J.B. from 23 experiencing the full enjoyment of its Parks, equal to the experiences of 24 persons without a disability. 25

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1 778. After October 9, 2013, S.L.B., no longer received the type of 2 accommodation and attention B.W.B., V.J.B. and S.L.B. had received when they 3 visited the Parks in the past. 4 779. As a result of Disney’s refusal to modify its procedures to 5 reasonably accommodate V.J.B.’s needs, B.W.B., S.L.B. and V.J.B. have been 6 discouraged and deterred from the full use and enjoyment of the Parks' rides 7 and attractions. If Disney had not abandoned its past policy of 8 accommodating the special needs of persons with cognitive impairments, 9 B.W.B. and S.L.B. would continue to frequently visit the Parks with V.J.B. as a 10 guest. But the family’s interest in attending the Parks is substantially reduced.

11 B.W.B. and S.L.B. knows they should avoid attending the Parks in the future 12 because doing so will only lead to the same un-magical experience and un- 13 accommodating discrimination 14 780. Notwithstanding Disney’s highly sophisticated knowledge of the 15 needs of persons with cognitive impairments, and notwithstanding Disney’s 16 historic ability to accommodate V.J.B.’s special needs, Disney personnel began DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 in October of 2013 to offer blanket accommodations, and implemented a 18 policy of systematically refusing to conduct individualized assessments of the 19 needs of V.J.B. andDeadline.com persons like him. Since October of 2013, Disney has 20 repeatedly and continuously refused to modify its policies for accommodating 21 disabled persons, choosing instead to robotically follow the DAS. Disney fails 22 and refuses to modify the DAS to allow V.J.B. to enjoy the same benefits and 23 privileges as non-disabled patrons. 24 25

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1 781. Disney personnel have shown no willingness or desire to improve 2 the experience for guests like V.J.B. 3 782. B.W.B. and S.L.B. incurred expenses associated with the family’s 4 wasted trips to the Parks. 5 783. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 6 provides protection from discrimination by all business establishments in 7 California, including housing and public accommodations, because of age, 8 ancestry, color, disability, national origin, race, religion, sex and sexual 9 orientation. 10 784. Section 52 of the California Civil Code provides that whoever

11 denies aids or incites a denial, or makes any discrimination or distinction 12 contrary to Section 51 is liable for each and every offense. 13 785. Pursuant to California Civil Code Section 51(f), a violation of the 14 ADA also constitutes a violation of California Civil Code Section 51, et seq. 15 786. The Parks are “business establishments” within the meaning of 16 the California Code Section 51, et seq. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 787. Through the acts and omissions described in this Complaint, 18 Disney has violated California Civil Code Section 51 by denying Plaintiff V.J.B.’s 19 access to Disney’sDeadline.com programs, services and activities. Disney has instituted and 20 continues to utilize policies which deny or which aid or incite the denial of 21 Plaintiff’s full and equal enjoyment of Disney’s public accommodations in the 22 same manner as non-disabled persons. Disney refuses to modify its policies 23 and procedures to permit fair enjoyment of its facilities by Plaintiff. As a 24 direct and proximate result of the afore-mentioned acts and omissions, 25

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1 Plaintiff has suffered, and continues to suffer, hardship, humiliation and 2 anxiety due to Disney’s failure to provide reasonable accommodations and 3 access as are required by Plaintiff’s cognitive impairments. 4 788. Due to the continuous nature of Disney’s ongoing discriminatory 5 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 6 result of Defendant’s action, Plaintiff is suffering irreparable harm, and thus 7 expeditious relief is appropriate. 8 WHEREFORE, Plaintiffs V.J.B. prays that this Court adjudicate this 9 dispute and enter an Order: 10 • Enjoining Defendant to cease the practices which are causing

11 discrimination against Plaintiffs on account of V.J.B.’s disability; 12 and 13 • Enjoining Defendant to reasonably modify its policies, 14 practices, and procedures to afford Plaintiffs with an 15 opportunity to experience Disney’s goods, services, facilities, 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI privileges, advantages, and accommodations; and 17 • Establishing Court-approved remedial measures that Disney 18 must implement, to prevent Disney from further discriminating 19 againstDeadline.com Plaintiffs when they visit the Disney Parks; and 20 • Establishing Court-approved requirements for information 21 dissemination about Disney’s remedial measures and modified 22 policies, to prevent Disney from further deterring Plaintiffs 23 from visiting Disney Parks as a result of anticipated 24 discrimination; and 25

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1 • Establishing a monitoring program to ensure Disney’s 2 compliance with the Court’s Orders; and 3 • Determining the amount of V.J.B.’s actual damages; and 4 • Entering judgment in favor of Plaintiff and against Disney for 5 an amount up to three times the amounts of Plaintiff’s actual 6 damages, but in no event less than $4,000; and 7 • Awarding reasonable attorney’s fees as may be determined by 8 the Court in favor of Plaintiffs and against Disney; and 9 • Awarding reasonable litigation costs as may be determined by 10 the Court in favor of Plaintiffs and against Disney; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 58 13 Breach of Contract 14 S.L.B. v. Disney 15 789. Plaintiff S.L.B. incorporates and re-alleges paragraphs 1 through 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 90, and 759 through 788 above. 17 790. S.L.B. entered into a contract through which Disney promised to 18 provide a reasonable and enjoyable amusement park experience, and one 19 which complies withDeadline.com applicable law. 20 791. Disney failed or refused to provide the promised experience, and 21 is in breach of contract. 22 792. S.L.B. incurred expenses associated with the family’s wasted trips 23 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 24 25

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1 WHEREFORE, Plaintiff S.L.B. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney breached its contract with S.L.B.; and 4 • Entering judgment for Plaintiff S.L.B. in the amount of her 5 economic monetary damages; and 6 • Awarding reasonable litigation costs as may be determined by 7 the Court in favor of Plaintiff and against Disney; and 8 • Awarding prejudgment interest; and 9 • Such other relief as this Court may find just and equitable. 10 COUNT 59

11 Negligent Infliction of Emotional Distress 12 K.A.C. v. Disney 13 793. Plaintiff K.A.C. incorporates and re-alleges paragraphs 1 through 14 90 above. 15 794. K.A.C. has autism, Attention Deficit Hyperactive Disorder 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI (“ADHD”), a seizure disorder, Unspecified Intellectual Disability, mood 17 disorder, gastro intestinal issues, asthma, and suffers from other sensory 18 issues. K.A.C.’s symptoms and stimming patterns include pacing back and 19 forth, making handDeadline.com gestures and voice signals, and the inability to sit still. 20 K.A.C. also cannot tolerate idly waiting for events to develop; K.A.C. needs to 21 be occupied. K.A.C. is also affected by gross motor conditions which require 22 him to wear specially made orthotics for his feet. K.A.C. gets tired and must 23 utilize a wheelchair at times because he lacks the endurance and stamina to 24 walk for long periods of time. 25

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1 795. Autism substantially limits a person’s ability to care for himself or 2 herself, perform manual tasks, speak, learn, read, concentrate, think, 3 communicate, perceive the concept of time, pair sights and sounds that 4 happen simultaneously, and work. 5 796. K.A.C. is and at all material times has been a disabled person 6 within the meaning of California Government Code §1296(j). 7 797. K.A.C. is 11 years of age, and is generally in the care of his father, 8 F.G.C., and his mother, J.L.C., who brings this action as K.A.C.’s next friend, 9 parent and natural guardian. 10 798. J.L.C. and K.A.C. are residents of Dallas County, Texas.

11 799. K.A.C.’s cognitive impairments manifest themselves in a certain 12 way during his visits to the parks; K.A.C. is a “repeat rider.” This is a 13 propensity common among autistic persons – a variety of the need for 14 consistency, order and routine. K.A.C. will experience a particular ride or 15 attraction, such as Mad Tea Party and Buzz Lightyear’s Space Ranger Spin, 16 over and over, for several hours at a time. Disney personnel are very familiar DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 with the repeat rider type of guest. 18 800. K.A.C. is incapable of waiting significant periods of time to enter a 19 ride or attraction.Deadline.com If instructed to do so, the stimming patterns described 20 above will intensify toward meltdown. 21 801. K.A.C. is incapable of understanding the concept of visiting an 22 attraction in the present only to be told it cannot be experienced until 23 sometime in the future. As such, the new DAS creates avoidable stressors for 24 K.A.C., constantly escalating his stimming patterns toward meltdowns. Since 25

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1 Disney’s implementation of the new DAS, K.A.C. has experienced several 2 meltdowns at the Disney Parks. 3 802. K.A.C. is incapable of understanding the concept of time, and thus 4 cannot stand around, idly biding time, without his cognitive impairments 5 causing him to experience stimming and meltdowns. Triggers and anxiety 6 will cause K.A.C. to exhibit stimming and maladaptive behaviors, including 7 screaming loudly. 8 803. J.L.C. has been taking K.A.C. to the Disney Parks since K.A.C. was 9 four-years-old. J.L.C. has regularly returned to the Disney Parks at least once 10 per year, including a trip to Disneyland. Before March 10, 2014, K.A.C. had

11 always carried the Guest Assistance Card, and was admirably accommodated. 12 During those visits, K.A.C. exhibited a nature and extent of joy that he rarely 13 shows in any other setting. Typically, J.L.C. and K.A.C. would spend three-four 14 hours in the Disney Parks, riding the rides K.A.C. wanted to ride and having 15 access to those rides through the disabled entrance. J.L.C. was always proud 16 and joyful of the opportunity to bring to her beloved son a level of happiness DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 which he rarely shows elsewhere. Disney employees were always friendly and 18 outgoing. Everyone was smiling and having a good time. It was a magical 19 experience. Deadline.com 20 804. This drastically changed on March 10, 2014 when J.L.C. and K.A.C. 21 attended the Disney Parks for the first time after the DAS replaced the GAC. 22 805. J.L.C. began planning her and K.A.C.’s trips to the Disney Parks in 23 October 2013. J.L.C. made extensive preparations for her son, including hiring 24 a respite provider to accompany J.L.C. and K.A.C. through the Disney Parks. 25

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1 While making these preparations, J.L.C. heard about the changes to Disney’s 2 disability policy. J.L.C. called Disney Guest Services before their trip on 3 numerous occasions seeking the assurance that Disney’s new policy would 4 accommodate K.A.C. And on numerous occasions, numerous Disney 5 employees offered numerous explanations of Disney’s new disability policy, 6 all with one unifying assurance: Disney would take into consideration K.A.C.’s 7 individual needs. 8 806. With this assurance from Disney, J.L.C. and K.A.C. embarked on 9 their much anticipated trip to the Disney Parks on March 10, 2014. J.L.C. and 10 K.A.C.’s first stop was Epcot where they encountered “Tammy,” a Disney

11 employee working in Guest Services. 12 807. Disney employee Tammy issued K.A.C. a DAS, two Fastpasses and 13 told J.L.C. if she and K.A.C. had any problems, to return to Guest Services and 14 see her. J.L.C. and K.A.C. did not use K.A.C.’s DAS while in Epcot because of the 15 two Fastpasses received beforehand. 16 808. On the second day of their visit, K.A.C. and J.L.C. returned to the

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disney Parks, this time to Animal Kingdom. J.L.C. attempted to use K.A.C.’s DAS 18 at the first ride K.A.C. wanted to ride, It’s Tough to be a Bug!. J.L.C. took K.A.C. 19 out of his wheelchair,Deadline.com and walked with him to the front of the ride, expecting 20 to be able to enter. However, the Disney employee turned away K.A.C. and 21 J.L.C. and refused to sign K.A.C.’s DAS card. J.L.C. tried to speak with another 22 Disney employee at the ride’s standby line, only to be directed to a nearby 23 Fastpass kiosk. J.L.C. helped K.A.C. back into his wheelchair, and walked to the 24 kiosk where J.L.C. requested to speak with a manager. Once a Disney Manager 25

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1 arrived, J.L.C. explained the situation and reiterated K.A.C.’s need for an 2 accommodation, such as a Fastpass. Meanwhile, K.A.C., who had now 3 abandoned his wheelchair out of frustration, suffered a meltdown. Like most 4 children with similar cognitive impairments, J.L.C. could not understand the 5 concept of arriving to It’s Tough to be a Bug!, fully expecting to ride It’s Tough 6 to be a Bug! at that time, only to be turned away and told to return at a later 7 time. Despite the apparent aggravation J.L.C. and K.A.C. were experiencing, the 8 Disney Manager refused to give J.L.C. Fastpasses and instead escorted J.L.C. 9 and K.A.C. back to the ride and directed the Disney employee - who first 10 turned away K.A.C. and J.L.C. - to allow them both on the ride.

11 809. On the third day of their visit, K.A.C. and J.L.C. visited Magic 12 Kingdom. K.A.C. and J.L.C. encountered extended wait times for Mad Tea Party, 13 Dumbo the Flying Elephant, and Tomorrowland Speedway. K.A.C. would have 14 a meltdown at Mad Tea Party due to being forced to enter the ride through the 15 Fastpass entrance. Adding to the frustration were Disney employee’s repeated 16 inabilities to sign K.A.C.’s DAS card; with only one exception, the Barnstormer, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 K.A.C. was instead required to wait in the standby line with other, non- 18 disabled children. 19 810. On theDeadline.com fourth day of their visit, K.A.C. and J.L.C. visited Hollywood 20 Studios. Their first stop was Buzz Lightyear’s Space Ranger Spin where K.A.C. 21 and J.L.C. received a 65-minute return time. The standby line had the same 22 wait time: 65 minutes. K.A.C. would later have a meltdown during American 23 Idol Experience, forcing K.A.C. and J.L.C. to leave the show early. J.L.C. heard 24 25

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1 from her sister that Epcot was also issuing DAS return times equal to regular 2 wait times that day. 3 811. J.L.C. left Hollywood Studios and returned to Epcot, hoping to 4 speak with Disney employee Tammy again. Since Disney employee Tammy 5 was unavailable, J.L.C. spoke with Disney employee, “Josh”, instead. J.L.C. told 6 Disney employee Josh about the difficulties her and K.A.C. were experiencing 7 in the Disney Parks as a result of the DAS. On the edge of tears, J.L.C. begged 8 Josh for two Fastpasses. Disney employee Josh agreed, but warned the 9 Fastpasses could only be used at Epcot because every Disney Park applied the 10 DAS differently.

11 812. By the fourth day of their visit, J.L.C., dejected by the arbitrary 12 application of the DAS, decided to not have K.A.C. enter any of the Disney 13 Parks. Instead, K.A.C. stayed in his hotel room for the remainder of J.L.C. and 14 K.A.C.’s trip. For J.L.C., it was not worth putting K.A.C. through the 15 inconvenience of the DAS only to experience further dissatisfaction. J.L.C. 16 stayed in his hotel room with his respite provider that day, disillusioned, and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 above all, disappointed. 18 813. On March 20, 2014, J.L.C. sent an email to 19 [email protected] entitled “Disappointment with 20 Recent Trip-Disability Program.” In that email, J.L.C. described her and K.A.C.’s 21 recent visits to the Disney Parks and the overall unaccommodating and 22 unsatisfying experience they had, the difficulties encountered as a result of the 23 DAS, and requested someone from Disney review her inquiry and make 24 25

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1 reimbursements and/or accommodations for their entirely wasted trips to the 2 Disney Parks. 3 814. In response to J.L.C.’s email, Disney employee “April Sullivan”, 4 contacted J.L.C. and offered two complimentary nights in addition to six Park 5 Hopper passes to the Disney Parks with still no promise of an accommodation 6 despite J.L.C.’s repeated requests for one. 7 815. J.L.C. returned to the Disney Parks with K.A.C. on November 24, 8 2014 after disembarking from a Disney Cruise. Again, J.L.C. paid for the 9 additional expense of hiring and providing accommodations for a respite 10 provider to accompany J.L.C. and K.A.C. through the Disney Parks. J.L.C. and

11 K.A.C.’s experiences started positive at Magic Kingdom because J.L.C. and 12 K.A.C. were given some Fastpasses. However, this positive start would turn 13 out to be nothing more than a tease. J.L.C. and K.A.C.’s experience at the Disney 14 Parks in November 2014 were just as unpleasant and unaccommodating as 15 those during their March 2014 visits. 16 816. Although the first day at Magic Kingdom was a relatively

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 satisfying experience, the second day at Animal Kingdom on November 25, 18 2014 reminded J.L.C. why she had not returned to the Disney Parks since 19 March 2014. At GuestDeadline.com Services, J.L.C. received pushback from Disney employee 20 “Susan” in response to J.L.C. presenting the complimentary Park Hopper 21 passes given to her and her family by Disney employee April Sullivan. Disney 22 employee Susan demanded to know where J.L.C. received the Park Hopper 23 passes, and refused to grant any Fastpasses to K.A.C. and J.L.C. Instead, Disney 24 employee Susan offered to arrange wait times in advance. 25

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1 817. J.L.C. asked for a manager and spoke to Disney employee “Elise”, 2 who also refused to offer any Fastpasses. Disney employee Elise told J.L.C. that 3 only the Magic Kingdom could afford to offer Fastpasses because they have 4 more attractions. Sadly, when J.L.C. and the Disney employee attempted 5 acquiesce and arrange ride times in advance, all of the rides at the Disney 6 Parks that day were unavailable because the ride times had been requested 7 well in advance of their visit. K.A.C. tried to make the most of their visit, and 8 arranged a ride time for two rides, including DINOSAUR. 9 818. While attempting to ride DINOSAUR, J.L.C. and K.A.C. encountered 10 Disney employee “Joe”, the most unaccommodating Disney employee of them

11 all. When J.L.C. and K.A.C. approached, Disney employee Joe told them their 12 time had expired. J.L.C. asked him if K.A.C. could still ride and Disney 13 employee Joe began to insolently question J.L.C. - in front of other guests - why 14 J.L.C. and K.A.C. could not make it on time for the ride. J.L.C. had to explain 15 that she had a son with special needs and it took longer to get to the ride. 16 K.A.C. was able to ride DINOSAUR, but it was a humiliating experience. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 819. Later that evening, J.L.C. and K.A.C. visited Epcot Guest services. 18 J.L.C explained to the Disney employee at Epcot Guest Services what happened 19 to J.L.C. and K.A.C.Deadline.com at Animal Kingdom. The Disney employee gave J.L.C. two 20 Fastpasses and assigned K.A.C. a Unique ID (M003579534). The Disney 21 employee told J.L.C. that she would put notes in the system so any other 22 Disney employee could pull up J.L.C.’s file, so long as J.L.C. presented an 23 appropriate ID. 24 25

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1 820. Despite the additional assurance from the Disney employee at 2 Epcot Guest Services, J.L.C. and K.A.C.’s last day at Epcot on November 26, 3 2014 would prove to be just as unsatisfying as the rest. Thanks to the two 4 Fastpasses received the day before, J.L.C. and K.A.C. were able to ride two 5 rides. However, the 110 minute wait time at Soarin’ after presenting K.A.C.’s 6 DAS was the straw that broke the camel’s back. 7 821. Due to Disney’s refusal to accommodate the special needs of 8 persons like K.A.C., which leads to an increased propensity for K.A.C. to 9 experience meltdowns, Disney prevents K.A.C. from experiencing the full 10 enjoyment of its Parks, equal to the experiences of persons without a

11 disability. 12 822. After October 9, 2013, K.A.C., no longer received the type of 13 accommodation and attention K.A.C. and J.L.C. had received when they visited 14 the Disney Parks in the past. 15 823. As a result of Disney’s refusal to modify its procedures to 16 reasonably accommodate K.A.C.’s needs, K.A.C. and J.L.C. have been DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 discouraged and deterred from the full use and enjoyment of the Parks' rides 18 and attractions. If Disney had not abandoned its past policy of 19 accommodating Deadline.comthe special needs of persons with cognitive impairments, 20 J.L.C. would continue to frequent the Disney Parks with K.A.C. as a guest. But 21 the family’s interest in attending the Disney Parks is substantially reduced. 22 J.L.C. knows they should avoid attending the Disney Parks in the future 23 because doing so will only lead to the same un-magical experience and un- 24 accommodating discrimination. 25

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1 824. Notwithstanding Disney’s highly sophisticated knowledge of the 2 needs of persons with cognitive impairments, and notwithstanding Disney’s 3 historic ability to accommodate K.A.C.’s special needs, Disney personnel began 4 in October of 2013 to offer blanket accommodations, and implemented a 5 policy of systematically refusing to conduct individualized assessments of the 6 needs of K.A.C. and persons like him. Since October of 2013, Disney has 7 repeatedly and continuously refused to modify its policies for accommodating 8 disabled persons, choosing instead to robotically follow the DAS. Disney fails 9 and refuses to modify the DAS to allow K.A.C. to enjoy the same benefits and 10 privileges as non-disabled patrons.

11 825. Disney personnel have shown no willingness or desire to improve 12 the experience for guests like K.A.C. by offering reasonable accommodations. 13 826. K.A.C. incurred expenses associated with the family’s wasted trips 14 to the Disney Parks. 15 827. During one or more visits to the Parks, K.A.C. suffered an actual 16 meltdown. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 828. The symptoms and conditions associated with K.A.C.’s meltdown 18 constitute a physical injury under California and Florida law. 19 829. K.A.C.’sDeadline.com meltdown in the Parks was proximately caused by 20 Disney’s negligent, unlawful, reckless and arbitrary treatment of K.A.C. during 21 his patronage of Disney’s facilities. At all material times, Disney knew K.A.C. to 22 be vulnerable to emotional injury if treated in such a manner by anyone. 23 24 25

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1 830. K.A.C.’s meltdown and the treatment which proximately caused 2 K.A.C. to experience the meltdown caused him grave and extreme mental 3 anguish and emotional trauma, for which Disney should be held accountable. 4 WHEREFORE, Plaintiff K.A.C., by and through J.L.C. as K.A.C.’s next 5 friend, parent and natural guardian, prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney negligently inflicted emotional distress 8 upon K.A.C.; and 9 • Finding such infliction to have caused damages to K.A.C.; and 10 • Entering judgment for Plaintiff K.A.C. in the amount of such 11 damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 60 17 Intentional Infliction of Emotional Distress 18 K.A.C. v. Disney 19 831. PlaintiffDeadline.com K.A.C. incorporates and re-alleges paragraphs 1 through 20 90, and 794 through 830 above. 21 832. During one or more visits to the Parks, K.A.C. suffered an actual 22 meltdown. 23 833. The symptoms and conditions associated with K.A.C.’s meltdown 24 constitute a physical injury under California and Florida law. 25

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1 834. K.A.C.’s meltdown in the Parks was proximately caused by 2 Disney’s outrageous, unlawful and reckless treatment of K.A.C. during his 3 patronage of Disney’s facilities. At all material times, Disney knew K.A.C. to be 4 vulnerable to emotional injury if treated in such a manner by anyone. 5 835. K.A.C.’s meltdown and the treatment which proximately caused 6 K.A.C. to experience the meltdown caused him grave and extreme mental 7 anguish and emotional trauma, for which Disney should be held accountable. 8 WHEREFORE, Plaintiff K.A.C., by and through J.L.C. as K.A.C.’s next 9 friend, parent and natural guardian, prays that this Court adjudicate this 10 dispute and enter an Order:

11 • Finding that Disney intentionally inflicted emotional distress 12 upon K.A.C.; and 13 • Finding such infliction to have caused damages to K.A.C.; and 14 • Entering judgment for Plaintiff K.A.C. in the amount of such 15 damages; 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment in favor of Plaintiffs and against Disney for 17 exemplary or punitive damages; and 18 • Awarding reasonable litigation costs as may be determined by 19 the CourtDeadline.com in favor of Plaintiff and against Disney; and 20 • Awarding prejudgment interest; and 21 • Such other relief as this Court may find just and equitable. 22

23 24 25

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1 COUNT 61 2 Violation of the Unruh Civil Rights Act 3 California Civil Code §§51, 52 4 K.A.C. v. Disney 5 836. Plaintiff K.A.C. incorporates and re-alleges paragraphs 1 through 6 91, and 794 through 830 above. 7 837. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 8 provides protection from discrimination by all business establishments in 9 California, including housing and public accommodations, because of age, 10 ancestry, color, disability, national origin, race, religion, sex and sexual

11 orientation. 12 838. Section 52 of the California Civil Code provides that whoever 13 denies aids or incites a denial, or makes any discrimination or distinction 14 contrary to Section 51 is liable for each and every offense. 15 839. Pursuant to California Civil Code Section 51(f), a violation of the 16 ADA also constitutes a violation of California Civil Code Section 51, et seq. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 840. The Parks are “business establishments” within the meaning of 18 the California Code Section 51, et seq. 19 841. ThroughDeadline.com the acts and omissions described in this Complaint, 20 Disney has violated California Civil Code Section 51 by denying Plaintiff 21 K.A.C.’s access to Disney’s programs, services and activities. Disney has 22 instituted and continues to utilize policies which deny or which aid or incite 23 the denial of Plaintiff’s full and equal enjoyment of Disney’s public 24 accommodations in the same manner as non-disabled persons. Disney refuses 25

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1 to modify its policies and procedures to permit fair enjoyment of its facilities 2 by Plaintiff. As a direct and proximate result of the afore-mentioned acts and 3 omissions, Plaintiff has suffered, and continues to suffer, hardship, humiliation 4 and anxiety due to Disney’s failure to provide reasonable accommodations 5 and access as are required by Plaintiff’s cognitive impairments. 6 842. Due to the continuous nature of Disney’s ongoing discriminatory 7 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 8 result of Defendant’s action, Plaintiff is suffering irreparable harm, and thus 9 expeditious relief is appropriate. 10 WHEREFORE, Plaintiffs K.A.C. prays that this Court adjudicate this

11 dispute and enter an Order: 12 • Enjoining Defendant to cease the practices which are causing 13 discrimination against Plaintiffs on account of K.A.C.’s 14 disability; and 15 • Enjoining Defendant to reasonably modify its policies, 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI practices, and procedures to afford Plaintiffs with an 17 opportunity to experience Disney’s goods, services, facilities, 18 privileges, advantages, and accommodations; and 19 • EstablishingDeadline.com Court-approved remedial measures that Disney 20 must implement, to prevent Disney from further discriminating 21 against Plaintiffs when they visit the Disney Parks; and 22 • Establishing Court-approved requirements for information 23 dissemination about Disney’s remedial measures and modified 24 policies, to prevent Disney from further deterring Plaintiffs 25

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1 from visiting Disney Parks as a result of anticipated 2 discrimination; and 3 • Establishing a monitoring program to ensure Disney’s 4 compliance with the Court’s Orders; and 5 • Determining the amount of K.A.C.’s actual damages; and 6 • Entering judgment in favor of Plaintiff and against Disney for 7 an amount up to three times the amounts of Plaintiff’s actual 8 damages, but in no event less than $4,000; and 9 • Awarding reasonable attorney’s fees as may be determined by 10 the Court in favor of Plaintiffs and against Disney; and

11 • Awarding reasonable litigation costs as may be determined by 12 the Court in favor of Plaintiffs and against Disney; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 62 15 Negligent Infliction of Emotional Distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI J.L.C. v. Disney 17 843. Plaintiff J.L.C. incorporates and re-alleges paragraphs 1 through 18 90, 794 through 830, 832 through 835, and 837 through 842, above. 19 844. DuringDeadline.com one or more visits to the Parks, J.L.C.’s beloved son K.A.C. 20 suffered an actual meltdown while in J.L.C.’s presence. 21 845. The symptoms and conditions associated with K.A.C.’s meltdown 22 constitute a physical injury to J.L.C. under California and Florida law. 23 846. K.A.C.’s meltdown in the Parks was proximately caused by 24 Disney’s negligent, unlawful, reckless and arbitrary treatment of K.A.C. during 25

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1 his patronage of Disney’s facilities. At all material times, Disney knew K.A.C. to 2 be vulnerable to emotional injury if treated in such a manner by anyone. 3 847. J.L.C. directly observed the stressors leading up to the meltdown, 4 K.A.C.’s resulting escalation and his meltdown. Particularly in light of her trust 5 and confidence that Disney would comply with applicable law and act in a 6 gracious and caring manner toward her son, J.L.C. could do nothing reasonable 7 to prevent the meltdown. 8 848. J.L.C.’s observation of K.A.C.’s meltdown and of the outrageous 9 conduct and treatment which proximately caused K.A.C. to experience the 10 meltdown caused K.A.C. grave and extreme mental anguish and emotional

11 trauma, for which Disney should be held accountable. 12 WHEREFORE, Plaintiff J.L.C. prays that this Court adjudicate this 13 dispute and enter an Order: 14 • Finding that Disney negligently inflicted emotional distress 15 upon J.L.C.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Finding such infliction to have caused damages to J.L.C.; and 17 • Entering judgment for Plaintiff J.L.C. in the amount of such 18 damages; and 19 • AwardingDeadline.com reasonable litigation costs as may be determined by 20 the Court in favor of Plaintiff and against Disney; and 21 • Awarding prejudgment interest; and 22 • Such other relief as this Court may find just and equitable. 23

24 25

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1 COUNT 63 2 Intentional Infliction of Emotional Distress 3 J.L.C. v. Disney 4 849. Plaintiff J.L.C. incorporates and re-alleges paragraphs 1 through 5 90, 794 through 830, 832 through 835, and 837 through 842, above. 6 850. During one or more visits to the Parks, J.L.C.’s beloved son K.A.C. 7 suffered an actual meltdown. 8 851. The symptoms and conditions associated with K.A.C.’s meltdown 9 constitute a physical injury under California and Florida law. 10 852. K.A.C.’s meltdown in the Parks was proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of K.A.C. during his 12 patronage of Disney’s facilities. At all material times, Disney knew K.A.C. to be 13 vulnerable to emotional injury if treated in such a manner by anyone. 14 853. J.L.C. directly observed the stressors leading up to the meltdown, 15 K.A.C.’s resulting escalation and his meltdown. Particularly in light of her trust 16 and confidence that Disney would comply with applicable law and act in a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 gracious and caring manner toward her son, J.L.C. could do nothing reasonable 18 to prevent the meltdown. 19 854. J.L.C.’sDeadline.com observation of K.A.C.’s meltdown and of the outrageous 20 conduct and treatment which proximately caused K.A.C. to experience the 21 meltdown caused J.L.C. grave and extreme mental anguish and emotional 22 trauma, for which Disney should be held accountable. 23 WHEREFORE, Plaintiff J.L.C. prays that this Court adjudicate this 24 dispute and enter an Order: 25

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1 • Finding that Disney intentionally inflicted emotional distress 2 upon J.L.C.; and 3 • Finding such infliction to have caused damages to J.L.C.; and 4 • Entering judgment for Plaintiff J.L.C. in the amount of such 5 damages; 6 • Entering judgment in favor of Plaintiffs and against Disney for 7 exemplary or punitive damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 64 13 Breach of Contract 14 J.L.C. v. Disney 15 855. Plaintiff J.L.C. incorporates and re-alleges paragraphs 1 through 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 90, 794 through 830, 832 through 835, and 837 through 842, above. 17 856. J.L.C. entered into a contract through which Disney promised to 18 provide a reasonable and enjoyable amusement park experience, and one 19 which complies withDeadline.com applicable law. 20 857. Disney failed or refused to provide the promised experience, and 21 is in breach of contract. 22 858. J.L.C. incurred expenses associated with the family’s wasted trips 23 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 24 25

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1 WHEREFORE, Plaintiff J.L.C. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney breached its contract with J.L.C.; and 4 • Entering judgment for Plaintiff J.L.C. in the amount of her 5 economic monetary damages; and 6 • Awarding reasonable litigation costs as may be determined by 7 the Court in favor of Plaintiff and against Disney; and 8 • Awarding prejudgment interest; and 9 • Such other relief as this Court may find just and equitable. 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 65 13 Negligent Infliction of Emotional Distress 14 E.L.M. v. Disney 15 859. Plaintiff E.L.M. incorporates and re-alleges paragraphs 1through 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 90, above. 17 860. E.L.M. has autism and a social disorder. E.L.M.’s symptoms and 18 stimming patterns include flapping his hands, shaking his head, echolalia, and 19 covering his ears.Deadline.com 20 861. Autism substantially limits a person’s ability to care for himself or 21 herself, perform manual tasks, speak, learn, read, concentrate, think, 22 communicate, perceive the concept of time, pair sights and sounds that 23 happen simultaneously, and work. 24 25

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1 862. E.L.M. is and at all material times has been a disabled person 2 within the meaning of California Government Code §1296(j). 3 863. E.L.M. is six years of age, and is generally in the care of his 4 grandmother, C.P., who is also disabled, and brings this action as E.L.M.’s next 5 friend, grandparent and natural guardian. 6 864. C.P. and E.L.M. are residents of Orange County, California. 7 865. E.L.M.’s cognitive impairments manifest themselves in a certain 8 way during his visits to the parks; E.L.M. is a “repeat rider.” This is a 9 propensity common among autistic persons – a variety of the need for 10 consistency, order and routine. E.L.M. will experience a particular ride or

11 attraction, such as Chip ‘n Dale Treehouse, over and over, for several hours at 12 a time. Disney personnel are very familiar with the repeat rider type of guest. 13 866. Incapable of comprehending the concept of time, it is impossible 14 for E.L.M. to endure significant periods of idle waiting in the present as the 15 cost of enjoying a future experience. He cannot kill time standing around, 16 waiting significant periods of time without his cognitive impairments causing DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 him to experience stimming and meltdowns. Triggers and anxiety will cause 18 E.L.M. to exhibit stimming and maladaptive behaviors until experiencing a 19 meltdown. WhenDeadline.com E.L.M. experiences a meltdown, he will scream loudly, cover 20 his ears, and either roll on the ground, try to run away, or run in circles. It can 21 take hours for E.L.M. to become subdued and fully recovered from a 22 meltdown. 23 867. E.L.M. is incapable of understanding the concept of visiting an 24 attraction in the present only to be told it cannot be experienced until 25

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1 sometime in the future. As such, the new DAS creates avoidable stressors for 2 E.L.M., constantly escalating his stimming patterns toward meltdowns. Since 3 Disney’s implementation of the new DAS, E.L.M. has experienced meltdowns 4 at the Disney Parks. 5 868. E.L.M. has always been fascinated by all things Disney, especially 6 Mickey Mouse. E.L.M. would sit for hours watching videos online about the 7 Disney Parks, including searching for specific rides and researching how those 8 rides operate. E.L.M. would sit for hours watching Disney movies, calling the 9 Disney characters his “friends.”Every day before leaving for school, he tells 10 Mickey he “will be right back.” For E.L.M., the Disney Parks were always the

11 epitome of the Disney experience and his fascination with Mickey; he even 12 referred to the Disney Parks as “Mickey Parks.” 13 869. C.P. first took E.L.M. to the Disney Parks when E.L.M. was three- 14 years-old. During their first trip to the Disney Parks, C.P. and E.L.M. were given 15 no accommodation, even thought C.P. requested one and even though the 16 Disney had the GAC at its disposal. Despite the lack of accommodation, it was DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 generally a good trip for C.P. and E.L.M. 18 870. C.P. would return to the Disney Parks with E.L.M. on April 9, 2014. 19 Upon arriving toDeadline.com Disneyland, C.P. and E.L.M. encountered a 20-minute wait at 20 Guest Services. When C.P. finally was able to speak to a Disney employee at 21 Guest Services, C.P. explained that she was there with her disabled grandson 22 and disabled sister, and needed a pass that would allow them to avoid waiting 23 in line. The Disney employee abruptly replied no such pass existed before 24 dismissively calling the next person in line. 25

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1 871. C.P. replied that she, her sister, and E.L.M. needed disability 2 passes. C.P. explained that E.L.M. was diagnosed with autism and could not 3 wait for extended periods of time. In response, the Disney employee offered 4 two Fastpasses. No other accommodations were provided to E.L.M. or C.P. 5 872. C.P. and E.L.M. left Guest Services already feeling defeated. Hoping 6 to eliminate the feeling of dejection, C.P. and E.L.M. tried to enter the first ride 7 they found. C.P. and E.L.M. were turned away and told to come back in one 8 hour. 9 873. C.P. decided the next best thing to do would be to take E.L.M. to 10 eat. On the way to the restaurant, E.L.M. spotted one of his favorite Disney

11 characters, Pluto. Brimming with excitement, E.L.M. signaled to C.P. that he 12 wanted to see Pluto. C.P., happy to see that E.L.M. was finally smiling, walked 13 over to Pluto to take his picture with E.L.M. Before doing so, however, C.P. hid 14 E.L.M.’s harness in his back pocket because she did not want E.L.M.’s harness 15 to appear in the picture. As C.P. was about to take E.L.M.’s picture with C.P., 16 Pluto reached down and pulled E.L.M.’s harness out of his back pocket. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 874. C.P. asked Pluto not to take out E.L.M.’s harness, and began taking 18 pictures. When C.P. had finished taking pictures of E.L.M. with Pluto, Pluto 19 reached down andDeadline.com again grabbed E.L.M.s harness. To C.P.’s horror, this time 20 Pluto - with harness in hand - began parading E.L.M. around as if E.L.M. were 21 Pluto’s dog. 22 875. E.L.M. began crying and screaming for Pluto to stop. A large crowd 23 gathered and watched as E.L.M. kept shouting “Off!” before suffering a full- 24 blown meltdown. Even still, Pluto, with harness in hand, continued to demean 25

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1 and belittle E.L.M. until C.P. had to rescue her grandson and snatch E.L.M.’s 2 harness from Pluto’s hands. 3 876. C.P. took E.L.M. to a quiet area in the Disney Parks, hoping to calm 4 him down and help him recover from his meltdown. E.L.M. continued to cry, 5 all the while covering his hears with his head hung low. It would take E.L.M. 6 hours to fully recover. 7 877. Once E.L.M. had finally recovered, C.P. resolved to take E.L.M. to 8 see Mickey Mouse, E.L.M.’s favorite Disney character. C.P. knew that she could 9 wash away the pain caused to E.L.M. with just one hug from Mickey Mouse. 10 878. To C.P.’s immediate disappointment, there was a long line to see

11 Mickey Mouse. C.P. went to the Disney employee overseeing the line and 12 explained that E.L.M. could not wait in long lines because he had been 13 diagnosed with autism. The Disney employee robotically responded there was 14 nothing he could do, before directing C.P. to the back of the line, where E.L.M. 15 then experienced yet another meltdown. 16 879. On March 7, 2015, C.P. returned to the Disney Parks with E.L.M.,

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 this time to California Adventure. C.P. and E.L.M.’s first stop was Frozen Fun. 18 However, C.P. and E.L.M. encountered a long line. C.P. approached the Disney 19 employee, who thenDeadline.com directed C.P. to Guest Services to ask about the DAS card. 20 880. At Guest Services, C.P. met Disney employee, “Ashley.” Ashley 21 explained that there were no accommodations available for C.P. and E.L.M. 22 Ashley further explained there was no such thing as the DAS card. Instead, 23 Ashley offered two Fastpasses, with the obvious caveat: “You can only use it 24 once.” 25

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1 881. This time, C.P. refused to take no for an answer. She refused to 2 believe that Disney could not offer her and E.L.M. any accommodation. 3 Instead, Ashley simply handed C.P. two Fastpasses for Frozen Fun, and 4 explained that C.P. and E.L.M. would have to return to Guest Relations to 5 obtain another Fastpass every time they wanted to ride a ride, see a show or 6 meet a character. 7 882. Once again feeling dejected and disappointed, C.P. left Guest 8 Services with E.L.M. and tried to make the most of what would turn out to be 9 another unaccommodating and un-magical day at the Disney Parks. 10 883. Upon returning home, C.P. was saddened to see that E.L.M. no

11 longer had a fascination for all things Disney. E.L.M. no longer sits for hours 12 watching videos online about the Disney Parks. E.L.M. no longer calls the 13 Disney character his friends. And E.L.M. no longer tells Mickey he “will be right 14 back.” Before leaving for school. For E.L.M., the dream that once upon a time 15 was Disney is now a forgotten memory. 16 884. Due to its failure to Disney’s refusal to accommodate the special

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 needs of persons like E.L.M., which leads to an increased propensity for E.L.M. 18 to experience meltdowns, Disney prevents E.L.M. from experiencing the full 19 enjoyment of itsDeadline.com Parks, equal to the experiences of persons without a 20 disability. 21 885. As a result of Disney’s refusal to reasonably accommodate E.L.M.’s 22 needs, E.L.M. and C.P. have been discouraged and deterred from the full use 23 and enjoyment of the Parks' rides and attractions. If Disney had not refused to 24 accommodate the special needs of persons with cognitive impairments, C.P. 25

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1 would continue to frequently visit the Parks with E.L.M. as a guest. But the 2 family’s interest in attending the Parks is substantially reduced. C.P. knows 3 they should avoid attending the Parks in the future because doing so will only 4 lead to the same un-magical experience and un-accommodating 5 discrimination 6 886. Notwithstanding Disney’s highly sophisticated knowledge of the 7 needs of persons with cognitive impairments, and notwithstanding Disney’s 8 historic ability to accommodate E.L.M.’s special needs, Disney personnel 9 refused to conduct individualized assessments of the needs of E.L.M. and 10 persons like him. Disney has repeatedly and continuously refused to modify

11 its policies for accommodating disabled persons. 12 887. Disney personnel have shown no willingness or desire to improve 13 the experience for guests like E.L.M. 14 888. C.P. incurred expenses associated with the family’s wasted trips to 15 the Parks. 16 889. During one or more visits to the Parks, E.L.M. suffered an actual

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 meltdown. 18 890. The symptoms and conditions associated with E.L.M.’s meltdown 19 constitute a physicalDeadline.com injury under California law. 20 891. E.L.M.’s meltdown in the Parks was proximately caused by 21 Disney’s negligent, unlawful, reckless and arbitrary treatment of E.L.M. during 22 his patronage of Disney’s facilities. At all material times, Disney knew E.L.M. 23 to be vulnerable to emotional injury if treated in such a manner by anyone. 24 25

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1 892. E.L.M.’s meltdown and the treatment which proximately caused 2 E.L.M. to experience the meltdown caused him grave and extreme mental 3 anguish and emotional trauma, for which Disney should be held accountable. 4 WHEREFORE, Plaintiff E.L.M., by and through C.P. as E.L.M.’s next 5 friend, parent and natural guardian, prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney negligently inflicted emotional distress 8 upon E.L.M.; and 9 • Finding such infliction to have caused damages to E.L.M.; and 10 • Entering judgment for Plaintiff E.L.M. in the amount of such 11 damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 66 17 Intentional Infliction of Emotional Distress 18 E.L.M. v. Disney 19 893. PlaintiffDeadline.com E.L.M. incorporates and re-alleges paragraphs 1 through 20 90, and 860 through 893, above. 21 894. During one or more visits to the Parks, E.L.M. suffered an actual 22 meltdown. 23 895. The symptoms and conditions associated with E.L.M.’s meltdown 24 constitute a physical injury under California law. 25

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1 896. E.L.M.’s meltdown in the Parks was proximately caused by 2 Disney’s outrageous, unlawful and reckless treatment of E.L.M. during his 3 patronage of Disney’s facilities. At all material times, Disney knew E.L.M. to be 4 vulnerable to emotional injury if treated in such a manner by anyone. 5 897. E.L.M.’s meltdown and the treatment which proximately caused 6 E.L.M. to experience the meltdown caused him grave and extreme mental 7 anguish and emotional trauma, for which Disney should be held accountable. 8 WHEREFORE, Plaintiff E.L.M., by and through C.P. as E.L.M.’s next 9 friend, parent and natural guardian, prays that this Court adjudicate this 10 dispute and enter an Order:

11 • Finding that Disney intentionally inflicted emotional distress 12 upon E.L.M.; and 13 • Finding such infliction to have caused damages to E.L.M.; and 14 • Entering judgment for Plaintiff E.L.M. in the amount of such 15 damages; 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment in favor of Plaintiffs and against Disney for 17 exemplary or punitive damages; and 18 • Awarding reasonable litigation costs as may be determined by 19 the CourtDeadline.com in favor of Plaintiff and against Disney; and 20 • Awarding prejudgment interest; and 21 • Such other relief as this Court may find just and equitable. 22

23 24 25

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1 COUNT 67 2 Violation of the Unruh Civil Rights Act 3 California Civil Code §§51, 52 4 E.L.M. v. Disney 5 898. Plaintiff E.L.M. incorporates and re-alleges paragraphs 1 through 6 91, and 860 through 892 above. 7 899. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 8 provides protection from discrimination by all business establishments in 9 California, including housing and public accommodations, because of age, 10 ancestry, color, disability, national origin, race, religion, sex and sexual

11 orientation. 12 900. Section 52 of the California Civil Code provides that whoever 13 denies aids or incites a denial, or makes any discrimination or distinction 14 contrary to Section 51 is liable for each and every offense. 15 901. Pursuant to California Civil Code Section 51(f), a violation of the 16 ADA also constitutes a violation of California Civil Code Section 51, et seq. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 902. The Parks are “business establishments” within the meaning of 18 the California Code Section 51, et seq. 19 903. ThroughDeadline.com the acts and omissions described in this Complaint, 20 Disney has violated California Civil Code Section 51 by denying Plaintiff 21 E.L.M.’s access to Disney’s programs, services and activities. Disney has 22 instituted and continues to utilize policies which deny or which aid or incite 23 the denial of Plaintiff’s full and equal enjoyment of Disney’s public 24 accommodations in the same manner as non-disabled persons. Disney refuses 25

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1 to modify its policies and procedures to permit fair enjoyment of its facilities 2 by Plaintiff. As a direct and proximate result of the afore-mentioned acts and 3 omissions, Plaintiff has suffered, and continues to suffer, hardship, humiliation 4 and anxiety due to Disney’s failure to provide reasonable accommodations 5 and access as are required by Plaintiff’s cognitive impairments. 6 904. Due to the continuous nature of Disney’s ongoing discriminatory 7 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 8 result of Defendant’s action, Plaintiff is suffering irreparable harm, and thus 9 expeditious relief is appropriate. 10 WHEREFORE, Plaintiffs E.L.M. prays that this Court adjudicate this

11 dispute and enter an Order: 12 • Enjoining Defendant to cease the practices which are causing 13 discrimination against Plaintiffs on account of E.L.M.’s 14 disability; and 15 • Enjoining Defendant to reasonably modify its policies, 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI practices, and procedures to afford Plaintiffs with an 17 opportunity to experience Disney’s goods, services, facilities, 18 privileges, advantages, and accommodations; and 19 • EstablishingDeadline.com Court-approved remedial measures that Disney 20 must implement, to prevent Disney from further discriminating 21 against Plaintiffs when they visit the Disney Parks; and 22 • Establishing Court-approved requirements for information 23 dissemination about Disney’s remedial measures and modified 24 policies, to prevent Disney from further deterring Plaintiffs 25

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1 from visiting Disney Parks as a result of anticipated 2 discrimination; and 3 • Establishing a monitoring program to ensure Disney’s 4 compliance with the Court’s Orders; and 5 • Determining the amount of E.L.M.’s actual damages; and 6 • Entering judgment in favor of Plaintiff and against Disney for 7 an amount up to three times the amounts of Plaintiff’s actual 8 damages, but in no event less than $4,000; and 9 • Awarding reasonable attorney’s fees as may be determined by 10 the Court in favor of Plaintiffs and against Disney; and

11 • Awarding reasonable litigation costs as may be determined by 12 the Court in favor of Plaintiffs and against Disney; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 68 15 Negligent Infliction of Emotional Distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI C.P. v. Disney 17 905. Plaintiff C.P. incorporates and re-alleges paragraphs 1 through 90, 18 860 through 892, 894 through 897, and 899 through 904, above. 19 906. DuringDeadline.com one or more visits to the Parks, C.P.’s beloved grandson 20 E.L.M. suffered an actual meltdown while in C.P.’s presence. 21 907. The symptoms and conditions associated with E.L.M.’s meltdown 22 constitute a physical injury to C.P. under California law. 23 908. E.L.M.’s meltdown in the Parks was proximately caused by 24 Disney’s negligent, unlawful, reckless and arbitrary treatment of E.L.M. during 25

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1 his patronage of Disney’s facilities. At all material times, Disney knew E.L.M. 2 to be vulnerable to emotional injury if treated in such a manner by anyone. 3 909. C.P. directly observed the stressors leading up to the meltdown, 4 E.L.M.’s resulting escalation and his meltdown. Particularly in light of her 5 trust and confidence that Disney would comply with applicable law and act in 6 a gracious and caring manner toward her grandson, C.P. could do nothing 7 reasonable to prevent the meltdown. 8 910. C.P.’s observation of E.L.M.’s meltdown and of the outrageous 9 conduct and treatment which proximately caused E.L.M. to experience the 10 meltdown caused E.L.M. grave and extreme mental anguish and emotional

11 trauma, for which Disney should be held accountable. 12 WHEREFORE, Plaintiff C.P. prays that this Court adjudicate this 13 dispute and enter an Order: 14 • Finding that Disney negligently inflicted emotional distress 15 upon C.P.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Finding such infliction to have caused damages to C.P.; and 17 • Entering judgment for Plaintiff C.P. in the amount of such 18 damages; and 19 • AwardingDeadline.com reasonable litigation costs as may be determined by 20 the Court in favor of Plaintiff and against Disney; and 21 • Awarding prejudgment interest; and 22 • Such other relief as this Court may find just and equitable. 23

24 25

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1 COUNT 69 2 Intentional Infliction of Emotional Distress 3 C.P. v. Disney 4 911. Plaintiff C.P incorporates and re-alleges paragraphs 1 through 90, 5 860 through 892, 894 through 897, and 899 through 904, above. 6 912. During one or more visits to the Parks, C.P.’s beloved grandson 7 E.L.M. suffered an actual meltdown. 8 913. The symptoms and conditions associated with E.L.M.’s meltdown 9 constitute a physical injury under California law. 10 914. E.L.M.’s meltdown in the Parks was proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of E.L.M. during his 12 patronage of Disney’s facilities. At all material times, Disney knew E.L.M. to be 13 vulnerable to emotional injury if treated in such a manner by anyone. 14 915. C.P. directly observed the stressors leading up to the meltdown, 15 E.L.M.’s resulting escalation and his meltdown. Particularly in light of her 16 trust and confidence that Disney would comply with applicable law and act in DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 a gracious and caring manner toward her grandson, C.P. could do nothing 18 reasonable to prevent the meltdown. 19 916. C.P.’sDeadline.com observation of E.L.M.’s meltdown and of the outrageous 20 conduct and treatment which proximately caused E.L.M. to experience the 21 meltdown caused C.P. grave and extreme mental anguish and emotional 22 trauma, for which Disney should be held accountable. 23 WHEREFORE, Plaintiff C.P. prays that this Court adjudicate this 24 dispute and enter an Order: 25

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1 • Finding that Disney intentionally inflicted emotional distress 2 upon C.P.; and 3 • Finding such infliction to have caused damages to C.P.; and 4 • Entering judgment for Plaintiff C.P. in the amount of such 5 damages; 6 • Entering judgment in favor of Plaintiffs and against Disney for 7 exemplary or punitive damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 70 13 Violation of the Unruh Civil Rights Act 14 California Civil Code §§51, 52 15 C.P. v. Disney 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 917. Plaintiff C.P. incorporates and re-alleges 1 through 91, and 860 17 through 892 above. 18 918. C.P. is and at all material times has been a disabled person within 19 the meaning of CaliforniaDeadline.com Government Code §1296(j). 20 919. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 21 provides protection from discrimination by all business establishments in 22 California, including housing and public accommodations, because of age, 23 ancestry, color, disability, national origin, race, religion, sex and sexual 24 orientation. 25

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1 920. Section 52 of the California Civil Code provides that whoever 2 denies aids or incites a denial, or makes any discrimination or distinction 3 contrary to Section 51 is liable for each and every offense. 4 921. Pursuant to California Civil Code Section 51(f), a violation of the 5 ADA also constitutes a violation of California Civil Code Section 51, et seq. 6 922. The Parks are “business establishments” within the meaning of 7 the California Code Section 51, et seq. 8 923. Through the acts and omissions described in this Complaint, 9 Disney has violated California Civil Code Section 51 by denying Plaintiff C.P.’s 10 access to Disney’s programs, services and activities. Disney has instituted and

11 continues to utilize policies which deny or which aid or incite the denial of 12 Plaintiff’s full and equal enjoyment of Disney’s public accommodations in the 13 same manner as non-disabled persons. Disney refuses to modify its policies 14 and procedures to permit fair enjoyment of its facilities by Plaintiff. As a 15 direct and proximate result of the afore-mentioned acts and omissions, 16 Plaintiff has suffered, and continues to suffer, hardship, humiliation and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 anxiety due to Disney’s failure to provide reasonable accommodations and 18 access as are required by Plaintiff’s cognitive impairments. 19 924. Due Deadline.comto the continuous nature of Disney’s ongoing discriminatory 20 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 21 result of Defendant’s action, Plaintiff is suffering irreparable harm, and thus 22 expeditious relief is appropriate. 23 WHEREFORE, Plaintiff C.P. prays that this Court adjudicate this 24 dispute and enter an Order: 25

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1 • Enjoining Defendant to cease the practices which are causing 2 discrimination against Plaintiffs on account of C.P.’s disability; 3 and 4 • Enjoining Defendant to reasonably modify its policies, 5 practices, and procedures to afford Plaintiffs with an 6 opportunity to experience Disney’s goods, services, facilities, 7 privileges, advantages, and accommodations; and 8 • Establishing Court-approved remedial measures that Disney 9 must implement, to prevent Disney from further discriminating 10 against Plaintiffs when they visit the Disney Parks; and

11 • Establishing Court-approved requirements for information 12 dissemination about Disney’s remedial measures and modified 13 policies, to prevent Disney from further deterring Plaintiffs 14 from visiting Disney Parks as a result of anticipated 15 discrimination; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Establishing a monitoring program to ensure Disney’s 17 compliance with the Court’s Orders; and 18 • Determining the amount of C.P.’s actual damages; and 19 • EnteringDeadline.com judgment in favor of Plaintiff and against Disney for 20 an amount up to three times the amounts of Plaintiff’s actual 21 damages, but in no event less than $4,000; and 22 • Awarding reasonable attorney’s fees as may be determined by 23 the Court in favor of Plaintiffs and against Disney; and 24 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiffs and against Disney; and 3 • Such other relief as this Court may find just and equitable. 4 COUNT 71 5 Breach of Contract 6 C.P. v. Disney 7 925. Plaintiff C.P. incorporates and re-alleges paragraphs 1 through 90, 8 860 through 892, 894 through 897, and 899 through 904, above. 9 926. C.P. entered into a contract through which Disney promised to 10 provide a reasonable and enjoyable amusement park experience, and one

11 which complies with applicable law. 12 927. Disney failed or refused to provide the promised experience, and 13 is in breach of contract. 14 928. C.P. incurred expenses associated with the family’s wasted trips to 15 the Parks. Plaintiff is damaged by Disney’s breach of contract. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI WHEREFORE, Plaintiff C.P. prays that this Court adjudicate this 17 dispute and enter an Order: 18 • Finding that Disney breached its contract with C.P.; and 19 • EnteringDeadline.com judgment for Plaintiff C.P. in the amount of her 20 economic monetary damages; and 21 • Awarding reasonable litigation costs as may be determined by 22 the Court in favor of Plaintiff and against Disney; and 23 • Awarding prejudgment interest; and 24 • Such other relief as this Court may find just and equitable. 25

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1 COUNT 72 2 Negligent Infliction of Emotional Distress 3 J.A.S. v. Disney 4 929. Plaintiff J.A.S. incorporates and re-alleges paragraphs 1 through 5 90 above. 6 930. J.A.S. has autism with characteristics of Attention Deficit Disorder 7 (ADD). J.A.S.’s symptoms and stimming patterns include echolalia and running 8 back and forth and running in between people in large crowds. J.A.S. also 9 cannot tolerate idly waiting for events to develop, as this will cause him to 10 become anxious.

11 931. Autism substantially limits a person’s ability to care for himself or 12 herself, perform manual tasks, speak, learn, read, concentrate, think, 13 communicate, perceive the concept of time, pair sights and sounds that 14 happen simultaneously, and work. 15 932. J.A.S. is and at all material times has been a disabled person within 16 the meaning of California Government Code §1296(j). DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 933. J.A.S. is 17 years of age, and is generally in the care of his father, 18 J.F.S., who brings this action as J.A.S.’s next friend, parent and natural 19 guardian. Deadline.com 20 934. J.F.S. and J.A.S. are residents of Los Angeles County, California. 21 935. J.A.S.’s cognitive impairments manifest themselves in a certain 22 way during his visits to the parks; when visiting California Adventure, J.A.S. is 23 incapable of deviating from consistency, order, and routine. J.A.S. enters the 24 park needing to ride exactly four rides: Soarin’; Radiator Springs Racers; 25

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1 Monsters, Inc. Mike & Sulley to the Rescue!; and Flik’s Flyers. So long as J.A.S. 2 can ride these four rides, in no particular order, J.A.S. will have a pleasant 3 Disney experience. 4 936. J.A.S. is incapable of comprehending the concept of time, and thus 5 does understand the need to experience present-tense sacrifice (waiting 6 around) in exchange for future enjoyment (an attraction). He cannot idly 7 stand around, idly waiting significant periods of time to enter a ride or 8 attraction without his cognitive impairments causing him to experience 9 stimming and panic attacks. Triggers and anxiety will cause J.A.S. to exhibit 10 stimming and maladaptive behaviors until experiencing a panic attack. When

11 J.A.S. experiences a panic attack, he will scream loudly and start crying, before 12 running and eventually falling on the floor. 13 937. J.A.S. is incapable of understanding the concept of visiting an 14 attraction in the present only to be told it cannot be experienced until 15 sometime in the future. As such, the new DAS creates avoidable stressors for 16 J.L.M., constantly escalating his stimming patterns toward panic attacks. Since DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disney’s implementation of the new DAS, J.L.M. has experienced several panic 18 attacks at the Disney Parks. 19 938. J.F.S.Deadline.com has been taking J.A.S. to the Disney Parks since J.A.S. was six- 20 months-old. As a life-time resident of California, trips to Disneyland and 21 California Adventure became a regular part of J.F.S. and J.A.S.’s life. J.A.S. and 22 J.F.S. would visit the Disney Parks at least six times per year. During those 23 visits, J.A.S. carried the Guest Assistance Card, and was admirably 24 accommodated. J.A.S. exhibited a nature and extent of joy that he rarely shows 25

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1 in any other setting. Typically, J.F.S. and J.A.S. would arrive to California 2 Adventure, ride the four rides J.A.S. needed to ride, and then spend the rest of 3 the day in the parks enjoying the time together as father and son. J.F.S. was 4 always proud and joyful of the opportunity to bring to his beloved son a level 5 of happiness which he rarely shows elsewhere. Disney employees were 6 always friendly and ready to lift a helping hand. Most importantly, Disney 7 employees made J.MS. and J.A.S. feel welcomed. Everyone was smiling and 8 having a wonderful time. It was a magical experience. 9 939. This changed drastically in January 2014 when J.A.S. and J.F.S. 10 took their first trip to the Disney Parks after Disney unveiled the DAS.

11 940. In January 2014, J.F.S. and J.A.S. returned to the Disney Parks, this 12 time to California Adventure. Like most every time before, J.F.S. and J.A.S. 13 began their trip to the Disney Parks at Guest Services. J.F.S. requested a GAC 14 for J.A.S., to which the Disney employee replied the GAC was no longer 15 available. 16 941. J.F.S. asked the Disney employee why they no longer offered the

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 GAC as an accommodation, to which the Cast Member responded “People 18 were taking advantage of the prior system” before issuing a DAS. The 19 response soundedDeadline.com scripted and unauthentic. J.F.S. explained that he had never 20 seen someone take advantage of the system before – nobody would take 21 advantage of that system. Nevertheless, the Cast Member next asked where 22 J.F.S. and J.A.S. wanted to go first. J.F.S. told the Cast Member “Soarin’”. 23 However, Soarin’ already had a 45 minute wait. 24 25

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1 942. J.F.S. explained that this would not work for J.A.S.; J.A.S. could not 2 wait 45 minutes to ride Soarin’. The Disney employee responded that it would 3 be best for J.F.S. and J.A.S. to go on another ride, or walk around. J.F.S. repeated 4 that that would not work; given J.A.S.’s cognitive impairments, J.A.S. had to go 5 on Soarin’ before any other ride at California Adventure. The back and forth 6 dialogue quickly turned into an argument after which the Disney employee 7 threatened to take away J.A.S.’s DAS. 8 943. J.F.S. left Guest Services upset, but was determined to try the new 9 system and hope that it would work for J.A.S. 10 944. At Soarin’, J.F.S. and J.A.S. encountered a 45 minute wait. J.F.S.

11 tried everything to keep J.A.S. calm and support him while they waited, but it 12 was too much for J.A.S. Soon J.A.S. began crying, before finally suffering a panic 13 attack. It would take J.A.S. 15 minutes more to calm down. 14 945. J.F.S. and J.A.S. went to the next ride on J.A.S.’s list: Radiator 15 Springs Racers. To J.F.S.’s horror, there was a two hour wait. Again, J.F.S. and 16 J.A.S. went through the torture of waiting, J.F.S. doing everything he could as a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 parent to keep J.A.S. calm, including shopping and walking around. The entire 18 time, J.A.S. altered between states of anxiousness, and bouts of crying. While 19 J.F.S. and J.A.S. wereDeadline.com able to endure the two hour wait, it was far from the 20 enjoyable experience J.F.S. and J.A.S. used to have at the Disney Parks. 21 946. The same pattern continued as J.F.S. and J.A.S. made their way 22 through California Adventure that day. J.A.S. would suffer multiple panic 23 attacks throughout the day, the worse one yet at Indiana Jones Adventure. 24 25

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1 947. Indiana Jones Adventure had a one hour and 35 minute wait. The 2 Cast Member wrote down a return time and J.A.S. and J.F.S. waited. When they 3 returned to the ride, after waiting the allotted time, they had to wait an 4 additional 35 minutes. J.F.S. asked why, after already waiting one hour and 35 5 minutes, they had to now wait another 35 minutes. The Disney employee 6 explained that she had written the time down wrong and that there was 7 nothing she could do; they would just have to wait. J.A.S. could not just wait, 8 not anymore. He fell to the ground, began crying, and suffered yet another 9 panic attack. 10 948. J.F.S. would return to the Disney Parks with J.A.S. again after that

11 fateful day, noting that each time they returned the experience would be even 12 worse than the last. 13 949. J.F.S. contacted Disney about the treatment he and J.A.S. received 14 at the Disney Parks. The Cast Member explained there was nothing Disney 15 could do about it: “it’s the higher ups who have decided to do this.” 16 950. Due to its failure to Disney’s refusal to accommodate the special

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 needs of persons like J.A.S., which leads to an increased propensity for J.A.S. to 18 experience a panic attack, Disney prevents J.A.S. from experiencing the full 19 enjoyment of itsDeadline.com Parks, equal to the experiences of persons without a 20 disability. 21 951. After October 9, 2013, J.A.S., no longer received the type of 22 accommodation and attention J.A.S. and J.F.S. had received when they visited 23 the Parks in the past. 24 25

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1 952. As a result of Disney’s refusal to modify its procedures to 2 reasonably accommodate J.A.S.’s needs, J.A.S. and J.F.S. have been discouraged 3 and deterred from the full use and enjoyment of the Parks' rides and 4 attractions. If Disney had not abandoned its past policy of accommodating the 5 special needs of persons with cognitive impairments, J.A.S. would continue to 6 frequently visit the Parks with J.A.S. as a guest. But the family’s interest in 7 attending the Parks is substantially reduced. J.A.S. knows they should avoid 8 attending the Parks in the future because doing so will only lead to the same 9 un-magical experience and un-accommodating discrimination 10 953. Notwithstanding Disney’s highly sophisticated knowledge of the

11 needs of persons with cognitive impairments, and notwithstanding Disney’s 12 historic ability to accommodate J.A.S.’s special needs, Disney personnel began 13 in October of 2013 to offer blanket accommodations, and implemented a 14 policy of systematically refusing to conduct individualized assessments of the 15 needs of J.A.S. and persons like him. Since October of 2013, Disney has 16 repeatedly and continuously refused to modify its policies for accommodating DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 disabled persons, choosing instead to robotically follow the DAS. Disney fails 18 and refuses to modify the DAS to allow J.A.S. to enjoy the same benefits and 19 privileges as nonDeadline.com-disabled patrons. 20 954. Disney personnel have shown no willingness or desire to improve 21 the experience for guests like J.A.S. 22 955. J.A.S. incurred expenses associated with the family’s wasted trips 23 to the Parks. 24 25

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1 956. During one or more visits to the Parks, J.A.S. suffered an actual 2 panic attack. 3 957. The symptoms and conditions associated with J.A.S.’s panic attack 4 constitute a physical injury under California law. 5 958. J.A.S.’s panic attack in the Parks was proximately caused by 6 Disney’s negligent, unlawful, reckless and arbitrary treatment of J.A.S. during 7 his patronage of Disney’s facilities. At all material times, Disney knew J.A.S. to 8 be vulnerable to emotional injury if treated in such a manner by anyone. 9 959. J.A.S.’s panic attack and the treatment which proximately caused 10 J.A.S. to experience the panic attack caused him grave and extreme mental

11 anguish and emotional trauma, for which Disney should be held accountable. 12 WHEREFORE, Plaintiff J.A.S., by and through J.F.S. as J.A.S.’s next 13 friend, parent and natural guardian, prays that this Court adjudicate this 14 dispute and enter an Order: 15 • Finding that Disney negligently inflicted emotional distress 16 upon J.A.S.; and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 • Finding such infliction to have caused damages to J.A.S.; and 18 • Entering judgment for Plaintiff J.A.S. in the amount of such 19 damages;Deadline.com and 20 • Awarding reasonable litigation costs as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 • Awarding prejudgment interest; and 23 • Such other relief as this Court may find just and equitable. 24

25

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1 COUNT 73 2 Intentional Infliction of Emotional Distress 3 J.A.S. v. Disney 4 960. Plaintiff J.A.S. incorporates and re-alleges paragraphs 1 through 5 90, and 930 through 959, above. 6 961. During one or more visits to the Parks, J.A.S. suffered an actual 7 panic attack. 8 962. The symptoms and conditions associated with J.A.S.’s panic attack 9 constitute a physical injury under California law. 10 963. J.A.S.’s panic attack in the Parks was proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of J.A.S. during his 12 patronage of Disney’s facilities. At all material times, Disney knew J.A.S. to be 13 vulnerable to emotional injury if treated in such a manner by anyone. 14 964. J.A.S.’s panic attack and the treatment which proximately caused 15 J.A.S. to experience the panic attack caused him grave and extreme mental 16 anguish and emotional trauma, for which Disney should be held accountable. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 WHEREFORE, Plaintiff J.A.S., by and through J.F.S. as J.A.S.’s next 18 friend, parent and natural guardian, prays that this Court adjudicate this 19 dispute and enterDeadline.com an Order: 20 • Finding that Disney intentionally inflicted emotional distress 21 upon J.A.S.; and 22 • Finding such infliction to have caused damages to J.A.S.; and 23 • Entering judgment for Plaintiff J.A.S. in the amount of such 24 damages; 25

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1 • Entering judgment in favor of Plaintiffs and against Disney for 2 exemplary or punitive damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 74 8 Violation of the Unruh Civil Rights Act 9 California Civil Code §§51, 52 10 J.A.S. v. Disney

11 965. Plaintiff J.A.S. incorporates and re-alleges paragraphs 1 through 12 91, and 930 through 959 above. 13 966. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 14 provides protection from discrimination by all business establishments in 15 California, including housing and public accommodations, because of age, 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI ancestry, color, disability, national origin, race, religion, sex and sexual 17 orientation. 18 967. Section 52 of the California Civil Code provides that whoever 19 denies aids or incitesDeadline.com a denial, or makes any discrimination or distinction 20 contrary to Section 51 is liable for each and every offense. 21 968. Pursuant to California Civil Code Section 51(f), a violation of the 22 ADA also constitutes a violation of California Civil Code Section 51, et seq. 23 969. The Parks are “business establishments” within the meaning of 24 the California Code Section 51, et seq. 25

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1 970. Through the acts and omissions described in this Complaint, 2 Disney has violated California Civil Code Section 51 by denying Plaintiff J.A.S.’s 3 access to Disney’s programs, services and activities. Disney has instituted and 4 continues to utilize policies which deny or which aid or incite the denial of 5 Plaintiff’s full and equal enjoyment of Disney’s public accommodations in the 6 same manner as non-disabled persons. Disney refuses to modify its policies 7 and procedures to permit fair enjoyment of its facilities by Plaintiff. As a 8 direct and proximate result of the afore-mentioned acts and omissions, 9 Plaintiff has suffered, and continues to suffer, hardship, humiliation and 10 anxiety due to Disney’s failure to provide reasonable accommodations and

11 access as are required by Plaintiff’s cognitive impairments. 12 971. Due to the continuous nature of Disney’s ongoing discriminatory 13 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 14 result of Defendant’s action, Plaintiff is suffering irreparable harm, and thus 15 expeditious relief is appropriate. 16 WHEREFORE, Plaintiffs J.A.S. prays that this Court adjudicate this DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 dispute and enter an Order: 18 • Enjoining Defendant to cease the practices which are causing 19 discriminationDeadline.com against Plaintiffs on account of J.A.S.’s disability; 20 and 21 • Enjoining Defendant to reasonably modify its policies, 22 practices, and procedures to afford Plaintiffs with an 23 opportunity to experience Disney’s goods, services, facilities, 24 privileges, advantages, and accommodations; and 25

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1 • Establishing Court-approved remedial measures that Disney 2 must implement, to prevent Disney from further discriminating 3 against Plaintiffs when they visit the Disney Parks; and 4 • Establishing Court-approved requirements for information 5 dissemination about Disney’s remedial measures and modified 6 policies, to prevent Disney from further deterring Plaintiffs 7 from visiting Disney Parks as a result of anticipated 8 discrimination; and 9 • Establishing a monitoring program to ensure Disney’s 10 compliance with the Court’s Orders; and

11 • Determining the amount of J.A.S.’s actual damages; and 12 • Entering judgment in favor of Plaintiff and against Disney for 13 an amount up to three times the amounts of Plaintiff’s actual 14 damages, but in no event less than $4,000; and 15 • Awarding reasonable attorney’s fees as may be determined by 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI the Court in favor of Plaintiffs and against Disney; and 17 • Awarding reasonable litigation costs as may be determined by 18 the Court in favor of Plaintiffs and against Disney; and 19 • SuchDeadline.com other relief as this Court may find just and equitable. 20 COUNT 75 21 Negligent Infliction of Emotional Distress 22 J.F.S. v. Disney 23 972. Plaintiff J.F.S. incorporates and re-alleges paragraphs 1 through 24 90, 930 through 959, 961 through 964, and 965 through 971, above. 25

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1 973. During one or more visits to the Parks, J.F.S.’s beloved son J.A.S. 2 suffered an actual panic attack while in J.F.S.’s presence. 3 974. The symptoms and conditions associated with J.A.S.’s panic attack 4 constitute a physical injury to J.F.S. under California law. 5 975. J.A.S.’s panic attack in the Parks was proximately caused by 6 Disney’s negligent, unlawful, reckless and arbitrary treatment of J.A.S. during 7 his patronage of Disney’s facilities. At all material times, Disney knew J.A.S. to 8 be vulnerable to emotional injury if treated in such a manner by anyone. 9 976. J.F.S. directly observed the stressors leading up to the panic 10 attack, J.A.S.’s resulting escalation and his panic attack. Particularly in light of

11 his trust and confidence that Disney would comply with applicable law and act 12 in a gracious and caring manner toward his son, J.F.S. could do nothing 13 reasonable to prevent the panic attack. 14 977. J.F.S.’s observation of J.A.S.’s panic attack and of the outrageous 15 conduct and treatment which proximately caused J.A.S. to experience the 16 panic attack caused J.A.S. grave and extreme mental anguish and emotional DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 trauma, for which Disney should be held accountable. 18 WHEREFORE, Plaintiff J.F.S. prays that this Court adjudicate this 19 dispute and enterDeadline.com an Order: 20 • Finding that Disney negligently inflicted emotional distress 21 upon J.F.S.; and 22 • Finding such infliction to have caused damages to J.F.S.; and 23 • Entering judgment for Plaintiff J.F.S. in the amount of such 24 damages; and 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding prejudgment interest; and 4 • Such other relief as this Court may find just and equitable. 5 COUNT 76 6 Intentional Infliction of Emotional Distress 7 J.F.S. v. Disney 8 978. Plaintiff J.F.S. incorporates and re-alleges paragraphs 1 through 9 90, 930 through 959, 961 through 964, and 965 through 971. 10 979. During one or more visits to the Parks, J.F.S.’s beloved son J.A.S. 11 suffered an actual panic attack. 12 980. The symptoms and conditions associated with J.A.S.’s panic attack 13 constitute a physical injury under California law. 14 981. J.A.S.’s panic attack in the Parks was proximately caused by 15 Disney’s outrageous, unlawful and reckless treatment of J.A.S. during his 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI patronage of Disney’s facilities. At all material times, Disney knew J.A.S. to be 17 vulnerable to emotional injury if treated in such a manner by anyone. 18 982. J.F.S. directly observed the stressors leading up to the panic 19 attack, J.A.S.’s resultingDeadline.com escalation and his panic attack. Particularly in light of 20 his trust and confidence that Disney would comply with applicable law and act 21 in a gracious and caring manner toward his son, J.F.S. could do nothing 22 reasonable to prevent the panic attack. 23 983. J.F.S.’s observation of J.A.S.’s panic attack and of the outrageous 24 conduct and treatment which proximately caused J.A.S. to experience the 25

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1 panic attack caused J.F.S. grave and extreme mental anguish and emotional 2 trauma, for which Disney should be held accountable. 3 WHEREFORE, Plaintiff J.F.S. prays that this Court adjudicate this 4 dispute and enter an Order: 5 • Finding that Disney intentionally inflicted emotional distress 6 upon J.F.S.; and 7 • Finding such infliction to have caused damages to J.F.S.; and 8 • Entering judgment for Plaintiff J.F.S. in the amount of such 9 damages; 10 • Entering judgment in favor of Plaintiffs and against Disney for

11 exemplary or punitive damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 77 17 Breach of Contract 18 J.F.S. v. Disney 19 984. PlaintiffDeadline.com J.F.S. incorporates and re-alleges paragraphs 1 through 20 90, 930 through 959, 961 through 964, and 965 through 971. 21 985. J.F.S. entered into a contract through which Disney promised to 22 provide a reasonable and enjoyable amusement park experience, and one 23 which complies with applicable law. 24 25

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1 986. Disney failed or refused to provide the promised experience, and 2 is in breach of contract. 3 987. J.F.S. incurred expenses associated with the family’s wasted trips 4 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 5 WHEREFORE, Plaintiff J.F.S. prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney breached its contract with J.F.S.; and 8 • Entering judgment for Plaintiff J.F.S. in the amount of his 9 economic monetary damages; and 10 • Awarding reasonable litigation costs as may be determined by 11 the Court in favor of Plaintiff and against Disney; and 12 • Awarding prejudgment interest; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 78 15 Negligent Infliction of Emotional Distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI E.W.V. v. Disney 17 988. Plaintiff E.W.V. incorporates and re-alleges paragraphs 1 through 18 90 above. 19 989. E.W.V.Deadline.com has autism, Attention Deficit Hyperactivity Disorder 20 (“ADHD”), is developmentally delayed, and suffers from mobility impairments. 21 E.W.V.’s symptoms and stimming patterns include slapping, making high- 22 pitched noises, and chewing on things. 23 990. Autism substantially limits a person’s ability to care for himself or 24 herself, perform manual tasks, speak, learn, read, concentrate, think, 25

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1 communicate, perceive the concept of time, pair sights and sounds that 2 happen simultaneously, and work. 3 991. E.W.V. is and at all material times has been a disabled person 4 within the meaning of California Government Code §1296(j). 5 992. E.W.V. is six years of age, and is generally in the care of his 6 mother, A.M.P., who brings this action as E.W.V.’s next friend, parent and 7 natural guardian. 8 993. A.M.P. and E.W.V. are residents of Maricopa County, Phoenix. 9 994. E.W.V.’s cognitive impairments manifest themselves in a certain 10 way during his visits to the parks; E.W.V. is incapable of deviating from

11 consistency, order, and routine. E.W.V. has to plan his trip to the Disney Parks 12 in advance. E.W.V. knows beforehand exactly what ride he is going to ride and 13 in what order he is going to ride it in. Any deviation from his plan will cause 14 E.W.V. to become upset, and likely lead to a meltdown. 15 995. E.W.V. cannot appreciate the concept of time, of trading a present 16 tense sacrifice (waiting around) for a future tense enjoyment (an attraction). DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 He is thus standing around, idly waiting significant periods of time to enter a 18 ride or attraction, without his cognitive impairments causing him to 19 experience stimmingDeadline.com and meltdowns. Triggers and anxiety will cause E.W.V. to 20 exhibit stimming and maladaptive behaviors until experiencing a meltdown. 21 When E.W.V. experiences a meltdown, he will emit a high-pitched scream, hit 22 himself, bang his head on the ground, and cry uncontrollably. 23 996. E.W.V. is incapable of understanding the concept of visiting an 24 attraction in the present only to be told it cannot be experienced until 25

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1 sometime in the future. As such, the new DAS creates avoidable stressors for 2 E.W.V., constantly escalating his stimming patterns toward meltdowns. Since 3 Disney’s implementation of the new DAS, E.W.V. has experienced meltdowns 4 at the Disney Parks. 5 997. A.M.P. first took E.W.V. to the Disney Parks when he was three 6 years old. During this visit, E.W.V. carried the Guest Assistance Card and was 7 admirably accommodated. E.W.V. exhibited a nature and extent of joy that he 8 rarely shows in other settings. A.M.P. and E.W.V. arrived to the Disney Parks 9 and obtained a GAC within the first five minutes of their visit. A.M.P. and 10 E.W.V. then spent the day riding rides E.W.V. wanted to ride, and in the order

11 he wanted to ride them in. A.M.P. was proud and joyful of the opportunity to 12 bring to her beloved son a level of happiness which he rarely showed 13 elsewhere. Disney employees were always friendly and outgoing. Everyone 14 was smiling and having a great time. It was a magical first-time Disney 15 experience. 16 998. This changed on July 26, 2014 when A.M.P. took E.W.V. to the

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disney Parks for the first time after Disney had released the DAS. Once A.M.P. 18 arrived at Disneyland, she went straight to Guest Services, where she 19 encountered a 30Deadline.com minute wait before obtaining the DAS. 20 999. A.M.P. and E.W.V. then made their way over to the first kiosk they 21 could find and received a 30 minute return time for Peter Pan’s Flight. While 22 waiting for the return time, A.M.P. and E.W.V. had to break from E.W.V.’s 23 routine in order to ride King Triton’s Carousel. 24 25

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1 1000. A.M.P. and E.W.V. then went to Peter Pan’s Flight, but were forced 2 to wait 10 additional minutes in the Fastpass line. E.W.V. did not understand 3 why he still had to wait, and suffered his first meltdown of the day. 4 1001. Once A.M.P. and E.W.V. finished Peter Pan’s Flight, A.M.P. went to 5 the nearest kiosk and asked for the ride with the shortest wait time. In 6 response, A.M.P. and E.W.V. received a return time for Dumbo the Flying 7 Elephant. 8 1002. Before A.M.P. and E.W.V. could make it to Dumbo the Flying 9 Elephant, A.M.P. and E.W.V. had to stop to rest and seek solace from the sun. 10 The extra walking back and forth from kiosk to ride and back to the kiosk

11 increased E.W.V.’s anxiety to a level he could not tolerate for much longer. 12 1003. At Dumbo the Flying Elephant, A.M.P. and E.W.V. encountered 13 another ten minute Fastpass line. After Dumbo the Flying Elephant, A.M.P. and 14 E.W.V. had to again trek back to the closest kiosk. This time they would not be 15 as lucky as the last; the next shortest ride wait time was Buzz Lightyear Astro 16 Blasters with a 30 minute return time. E.W.V. had finally reached his breaking DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 point and could take no more. Hot, exhausted, and thirsty E.W.V. broke down 18 in a fit of tears, before walking away. A.M.P., desperate for her son to find 19 relief, requestedDeadline.com to speak with a manager. 20 1004. The trip to City Hall to speak with a manager - much like the 21 entire trip to the Disney Parks that day – resulted in further frustration and 22 un-accommodation. A Disney manager spoke with A.M.P. and offered her and 23 E.W.V. one day passes to return at a future date. Despite free passes to do so, 24 E.M.V. and A.M.P. have not returned to the Disney Parks since July 26, 2014. 25

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1 1005. The entire experience at the Disney Parks led to multiple 2 meltdowns for E.W.V. The new DAS procedure requiring E.W.V. and A.M.P. to 3 constantly walk back and forth from ride to kiosk only to encounter more 4 lines and more waiting, triggered E.W.V.’s meltdowns on July 26, 2014. 5 1006. Due to Disney’s refusal to accommodate the special needs of 6 persons like E.W.V., which leads to an increased propensity for E.W.V. to 7 experience meltdowns, Disney prevents E.W.V. from experiencing the full 8 enjoyment of its Parks, equal to the experiences of persons without a 9 disability. 10 1007. After October 9, 2013, E.W.V., no longer received the type of

11 accommodation and attention E.W.V. and A.M.P. had received when they 12 visited the Parks in the past. 13 1008. As a result of Disney’s refusal to modify its procedures to 14 reasonably accommodate E.W.V.’s needs, E.W.V. and A.M.P. have been 15 discouraged and deterred from the full use and enjoyment of the Parks' rides 16 and attractions. If Disney had not abandoned its past policy of DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 accommodating the special needs of persons with cognitive impairments, 18 E.W.V. would continue to frequent the Parks with E.W.V. as a guest. But the 19 family’s interest Deadline.comin attending the Parks is substantially reduced. E.W.V. knows 20 they should avoid attending the Parks in the future because doing so will only 21 lead to the same un-magical experience and un-accommodating 22 discrimination 23 1009. Notwithstanding Disney’s highly sophisticated knowledge of the 24 needs of persons with cognitive impairments, and notwithstanding Disney’s 25

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1 historic ability to accommodate E.W.V.’s special needs, Disney personnel 2 began in October of 2013 to offer blanket accommodations, and implemented 3 a policy of systematically refusing to conduct individualized assessments of 4 the needs of E.W.V. and persons like him. Since October of 2013, Disney has 5 repeatedly and continuously refused to modify its policies for accommodating 6 disabled persons, choosing instead to robotically follow the DAS. Disney fails 7 and refuses to modify the DAS to allow E.W.V. to enjoy the same benefits and 8 privileges as non-disabled patrons. 9 1010. Disney personnel have shown no willingness or desire to improve 10 the experience for guests like E.W.V.

11 1011. A.M.P. incurred expenses associated with the family’s wasted trips 12 to the Parks. 13 1012. During one or more visits to the Parks, E.W.V. suffered an actual 14 meltdown. 15 1013. The symptoms and conditions associated with E.W.V.’s meltdown 16 constitute a physical injury under California law. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1014. E.W.V.’s meltdown in the Parks was proximately caused by 18 Disney’s negligent, unlawful, reckless and arbitrary treatment of E.W.V. during 19 his patronage ofDeadline.com Disney’s facilities. At all material times, Disney knew E.W.V. 20 to be vulnerable to emotional injury if treated in such a manner by anyone. 21 1015. E.W.V.’s meltdown and the treatment which proximately caused 22 E.W.V. to experience the meltdown caused him grave and extreme mental 23 anguish and emotional trauma, for which Disney should be held accountable. 24 25

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1 WHEREFORE, Plaintiff E.W.V., by and through A.M.P. as E.W.V.’s next 2 friend, parent and natural guardian, prays that this Court adjudicate this 3 dispute and enter an Order: 4 • Finding that Disney negligently inflicted emotional distress 5 upon E.W.V.; and 6 • Finding such infliction to have caused damages to E.W.V.; and 7 • Entering judgment for Plaintiff E.W.V. in the amount of such 8 damages; and 9 • Awarding reasonable litigation costs as may be determined by 10 the Court in favor of Plaintiff and against Disney; and

11 • Awarding prejudgment interest; and 12 • Such other relief as this Court may find just and equitable. 13 COUNT 79 14 Intentional Infliction of Emotional Distress 15 E.W.V. v. Disney 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 1016. Plaintiff E.W.V. incorporates and re-alleges paragraphs 1 through 17 90, and 989 through 1015, above. 18 1017. During one or more visits to the Parks, E.W.V. suffered an actual 19 meltdown. Deadline.com 20 1018. The symptoms and conditions associated with E.W.V.’s meltdown 21 constitute a physical injury under California law. 22 1019. E.W.V.’s meltdown in the Parks was proximately caused by 23 Disney’s outrageous, unlawful and reckless treatment of E.W.V. during his 24 25

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1 patronage of Disney’s facilities. At all material times, Disney knew E.W.V. to 2 be vulnerable to emotional injury if treated in such a manner by anyone. 3 1020. E.W.V.’s meltdown and the treatment which proximately caused 4 E.W.V. to experience the meltdown caused him grave and extreme mental 5 anguish and emotional trauma, for which Disney should be held accountable. 6 WHEREFORE, Plaintiff E.W.V., by and through A.M.P. as E.W.V.’s next 7 friend, parent and natural guardian, prays that this Court adjudicate this 8 dispute and enter an Order: 9 • Finding that Disney intentionally inflicted emotional distress 10 upon E.W.V.; and

11 • Finding such infliction to have caused damages to E.W.V.; and 12 • Entering judgment for Plaintiff E.W.V. in the amount of such 13 damages; 14 • Entering judgment in favor of Plaintiffs and against Disney for 15 exemplary or punitive damages; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Awarding reasonable litigation costs as may be determined by 17 the Court in favor of Plaintiff and against Disney; and 18 • Awarding prejudgment interest; and 19 • SuchDeadline.com other relief as this Court may find just and equitable. 20

21 22 23 24 25

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1 COUNT 80 2 Violation of the Unruh Civil Rights Act 3 California Civil Code §§51, 52 4 E.W.V. v. Disney 5 1021. Plaintiff E.W.V. incorporates and re-alleges paragraphs 1 through 6 91, and 989 through 1015 above. 7 1022. E.W.V. is and at all material times has been a disabled person 8 within the meaning of California Government Code §1296(j). 9 1023. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 10 provides protection from discrimination by all business establishments in

11 California, including housing and public accommodations, because of age, 12 ancestry, color, disability, national origin, race, religion, sex and sexual 13 orientation. 14 1024. Section 52 of the California Civil Code provides that whoever 15 denies aids or incites a denial, or makes any discrimination or distinction 16 contrary to Section 51 is liable for each and every offense. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1025. Pursuant to California Civil Code Section 51(f), a violation of the 18 ADA also constitutes a violation of California Civil Code Section 51, et seq. 19 1026. The Deadline.comParks are “business establishments” within the meaning of 20 the California Code Section 51, et seq. 21 1027. Through the acts and omissions described in this Complaint, 22 Disney has violated California Civil Code Section 51 by denying Plaintiff 23 E.W.V.’s access to Disney’s programs, services and activities. Disney has 24 instituted and continues to utilize policies which deny or which aid or incite 25

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1 the denial of Plaintiff’s full and equal enjoyment of Disney’s public 2 accommodations in the same manner as non-disabled persons. Disney refuses 3 to modify its policies and procedures to permit fair enjoyment of its facilities 4 by Plaintiff. As a direct and proximate result of the afore-mentioned acts and 5 omissions, Plaintiff has suffered, and continues to suffer, hardship, humiliation 6 and anxiety due to Disney’s failure to provide reasonable accommodations 7 and access as are required by Plaintiff’s cognitive impairments. 8 1028. Due to the continuous nature of Disney’s ongoing discriminatory 9 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 10 result of Defendant’s action, Plaintiff is suffering irreparable harm, and thus

11 expeditious relief is appropriate. 12 WHEREFORE, Plaintiffs E.W.V. prays that this Court adjudicate this 13 dispute and enter an Order: 14 • Enjoining Defendant to cease the practices which are causing 15 discrimination against Plaintiffs on account of E.W.V.’s 16 disability; and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 • Enjoining Defendant to reasonably modify its policies, 18 practices, and procedures to afford Plaintiffs with an 19 opportunityDeadline.com to experience Disney’s goods, services, facilities, 20 privileges, advantages, and accommodations; and 21 • Establishing Court-approved remedial measures that Disney 22 must implement, to prevent Disney from further discriminating 23 against Plaintiffs when they visit the Disney Parks; and 24 25

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1 • Establishing Court-approved requirements for information 2 dissemination about Disney’s remedial measures and modified 3 policies, to prevent Disney from further deterring Plaintiffs 4 from visiting Disney Parks as a result of anticipated 5 discrimination; and 6 • Establishing a monitoring program to ensure Disney’s 7 compliance with the Court’s Orders; and 8 • Determining the amount of E.W.V.’s actual damages; and 9 • Entering judgment in favor of Plaintiff and against Disney for 10 an amount up to three times the amounts of Plaintiff’s actual

11 damages, but in no event less than $4,000; and 12 • Awarding reasonable attorney’s fees as may be determined by 13 the Court in favor of Plaintiffs and against Disney; and 14 • Awarding reasonable litigation costs as may be determined by 15 the Court in favor of Plaintiffs and against Disney; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Such other relief as this Court may find just and equitable. 17 COUNT 81 18 Negligent Infliction of Emotional Distress 19 Deadline.comA.M.P. v. Disney 20 1029. Plaintiff A.M.P. incorporates and re-alleges paragraphs 1 through 21 90, 989 through 1015, 1017 through 1020, and 1022 through 1028, above. 22 1030. During one or more visits to the Parks, A.M.P.’s beloved son E.W.V. 23 suffered an actual meltdown while in A.M.P.’s presence. 24 25

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1 1031. The symptoms and conditions associated with E.W.V.’s meltdown 2 constitute a physical injury to A.M.P. under California law. 3 1032. E.W.V.’s meltdown in the Parks was proximately caused by 4 Disney’s negligent, unlawful, reckless and arbitrary treatment of E.W.V. during 5 his patronage of Disney’s facilities. At all material times, Disney knew E.W.V. 6 to be vulnerable to emotional injury if treated in such a manner by anyone. 7 1033. A.M.P. directly observed the stressors leading up to the meltdown, 8 E.W.V.’s resulting escalation and his meltdown. Particularly in light of her 9 trust and confidence that Disney would comply with applicable law and act in 10 a gracious and caring manner toward her son, A.M.P. could do nothing

11 reasonable to prevent the meltdown. 12 1034. A.M.P.’s observation of E.W.V.’s meltdown and of the outrageous 13 conduct and treatment which proximately caused E.W.V. to experience the 14 meltdown caused E.W.V. grave and extreme mental anguish and emotional 15 trauma, for which Disney should be held accountable. 16 WHEREFORE, Plaintiff A.M.P. prays that this Court adjudicate this DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 dispute and enter an Order: 18 • Finding that Disney negligently inflicted emotional distress 19 uponDeadline.com A.M.P.; and 20 • Finding such infliction to have caused damages to A.M.P.; and 21 • Entering judgment for Plaintiff A.M.P. in the amount of such 22 damages; and 23 • Awarding reasonable litigation costs as may be determined by 24 the Court in favor of Plaintiff and against Disney; and 25

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1 • Awarding prejudgment interest; and 2 • Such other relief as this Court may find just and equitable. 3 COUNT 82 4 Intentional Infliction of Emotional Distress 5 A.M.P. v. Disney 6 1035. Plaintiff A.M.P. incorporates and re-alleges paragraphs 1 through 7 90, 989 through 1015, 1017 through 1020, and 1022 through 1028, above. 8 1036. During one or more visits to the Parks, A.M.P.’s beloved son E.W.V. 9 suffered an actual meltdown. 10 1037. The symptoms and conditions associated with E.W.V.’s meltdown

11 constitute a physical injury under California law. 12 1038. E.W.V.’s meltdown in the Parks was proximately caused by 13 Disney’s outrageous, unlawful and reckless treatment of E.W.V. during his 14 patronage of Disney’s facilities. At all material times, Disney knew E.W.V. to 15 be vulnerable to emotional injury if treated in such a manner by anyone. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 1039. A.M.P. directly observed the stressors leading up to the meltdown, 17 E.W.V.’s resulting escalation and his meltdown. Particularly in light of her 18 trust and confidence that Disney would comply with applicable law and act in 19 a gracious and Deadline.comcaring manner toward her son, A.M.P. could do nothing 20 reasonable to prevent the meltdown. 21 1040. A.M.P.’s observation of E.W.V.’s meltdown and of the outrageous 22 conduct and treatment which proximately caused E.W.V. to experience the 23 meltdown caused A.M.P. grave and extreme mental anguish and emotional 24 trauma, for which Disney should be held accountable. 25

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1 WHEREFORE, Plaintiff A.M.P. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney intentionally inflicted emotional distress 4 upon A.M.P.; and 5 • Finding such infliction to have caused damages to A.M.P.; and 6 • Entering judgment for Plaintiff A.M.P. in the amount of such 7 damages; 8 • Entering judgment in favor of Plaintiffs and against Disney for 9 exemplary or punitive damages; and 10 • Awarding reasonable litigation costs as may be determined by

11 the Court in favor of Plaintiff and against Disney; and 12 • Awarding prejudgment interest; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 83 15 Breach of Contract 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI A.M.P. v. Disney 17 1041. Plaintiff A.M.P. incorporates and re-alleges paragraphs 1 through 18 90, 989 through 1015, 1017 through 1020, and 1022 through 1028 above. 19 1042. A.M.P.Deadline.com entered into a contract through which Disney promised to 20 provide a reasonable and enjoyable amusement park experience, and one 21 which complies with applicable law. 22 1043. Disney failed or refused to provide the promised experience, and 23 is in breach of contract. 24 25

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1 1044. A.M.P. incurred expenses associated with the family’s wasted trips 2 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 3 WHEREFORE, Plaintiff A.M.P. prays that this Court adjudicate this 4 dispute and enter an Order: 5 • Finding that Disney breached its contract with A.M.P.; and 6 • Entering judgment for Plaintiff A.M.P. in the amount of her 7 economic monetary damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 84 13 Negligent Infliction of Emotional Distress 14 T.J.A. v. Disney 15 1045. Plaintiff T.J.A. incorporates and re-alleges paragraphs 1 through 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 90 above. 17 1046. T.J.A. has autism. T.J.A.’s symptoms and stimming patterns include 18 banging on items, hitting himself and fidgeting and playing with items around 19 him. T.J.A. also cannotDeadline.com tolerate idly waiting for events to develop, as this will 20 cause him to become angry and frustrated. 21 1047. Autism substantially limits a person’s ability to care for himself or 22 herself, perform manual tasks, speak, learn, read, concentrate, think, 23 communicate, perceive the concept of time, pair sights and sounds that 24 happen simultaneously, and work. 25

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1 1048. T.J.A. is and at all material times has been a disabled person 2 within the meaning of California Government Code §1296(j). 3 1049. T.J.A. is 16 years of age, and is generally in the care of his mother, 4 L.A., who brings this action as T.J.A.’s next friend, parent and natural guardian. 5 1050. T.J.A. and L.A. are residents of Bergen County, New Jersey. 6 1051. T.J.A.’s cognitive impairments manifest themselves in a certain 7 way during his visits to the parks; T.J.A. is a “repeat rider.” This is a 8 propensity common among autistic persons – a variety of the need for 9 consistency, order and routine. T.J.A. will experience a particular ride or 10 attraction, such as Splash Mountain at Walt Disney World or Matterhorn

11 Bobsleds at Disneyland, over and over, for several hours at a time. Disney 12 personnel are very familiar with the repeat rider type of guest. 13 1052. T.J.A. is incapable of waiting significant periods of time to enter a 14 ride or attraction. If instructed to do so, the stimming patterns described 15 above will intensify toward meltdown. 16 1053. T.J.A. is incapable of understanding the concept of visiting an

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 attraction in the present only to be told it cannot be experienced until 18 sometime in the future. As such, the new DAS creates avoidable stressors for 19 T.J.A., constantlyDeadline.com escalating his stimming patterns toward meltdowns. Since 20 Disney’s implementation of the new DAS, T.J.A. has experienced multiple 21 meltdowns at the Disney Parks. 22 1054. T.J.A. cannot comprehend the concept of time, of trading a present 23 tense sacrifice (waiting around) for a future pleasure (an attraction). T.J.A. is 24 incapable of standing idly around waiting for anything, without his cognitive 25

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1 impairments causing him to experience stimming and meltdowns when 2 required to wait in a line for any significant period. Triggers and anxiety will 3 cause T.J.A. to exhibit stimming and maladaptive behaviors, including banging 4 his head against the wall, hitting and biting himself, and making noises. 5 1055. L.A. grew up a Disney fan, and has been taking T.J.A. to the Disney 6 Parks since T.J.A. was one-year-old. L.A. has regularly returned to the Disney 7 Parks at least once per year - typically in August. Trips to the Disney Parks 8 have included both Walt Disney World and Disneyland. Before August 20, 9 2014, T.J.A. always carried the Guest Assistance Card, and was admirably 10 accommodated. During those visits, T.J.A. exhibited a nature and extent of joy

11 that he rarely shows in any other setting. Typically, T.J.A. and L.A. would be 12 able to ride the rides T.J.A. wanted to ride in the order he needed to ride them 13 in. T.J.A. would be able to repeat ride the rides he wanted to ride, and would 14 gain access to rides through an alternate entrance, thus reducing the overall 15 stimulation T.J.A. would encounter while in the Disney Parks. Disney 16 employees were always friendly and outgoing. Everyone was smiling and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 having a good time. It was a magical experience. 18 1056. This changed drastically on August 20, 2014 when L.A. and T.J.A. 19 attended the DisneyDeadline.com Parks for the first time after the DAS replaced the GAC. 20 1057. L.A. heard about the changes to Disney’s policies and called 21 Disney Guest Services before their planned trip to ask about those changes. 22 The Disney employee assured L.A. that Disney would treat every disabled 23 person on a case by case basis and give an individualized assessment. What 24 25

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1 T.J.A. actually received on August 20, 2014 was everything but an 2 individualized assessment of T.J.A.’s needs. 3 1058. Upon arriving to the Disney Parks on August 20, 2014, L.A. and 4 T.J.A. first visited Epcot, where L.A. started the day at Guest Services. T.J.A. 5 usually used a wheelchair, but this time L.A. asked that T.J.A. walk because L.A. 6 had heard disabled guests in wheelchairs were required to wait in the standby 7 line. 8 1059. At Guest Services, L.A. requested to speak with supervisor. 30 9 minutes later, Disney supervisor “Rafael” appeared on scene. L.A. explained to 10 Rafael that that T.J.A. could not idly wait around, especially given the

11 especially warm temperature outside, and requested an accommodation for 12 T.J.A. Rafael responded by yelling at T.J.A., which immediately caused L.A. to 13 begin crying. T.J.A., upon seeing L.A. become visibly upset and start crying, 14 experienced a meltdown. In an attempt to assuage the situation, Rafael gave 15 L.A. and T.J.A. three “yellow passes” for everyone in L.A.’s party. Rafael did not 16 mention the DAS, nor offer T.J.A. any kind of individual accommodation. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1060. L.A. and T.J.A. made every attempt to recover from the horrible 18 experience at Guest Services, and make the most of their first day at Epcot. 19 Unfortunately forDeadline.com L.A. and T.J.A., they would never fully recover from their 20 encounter with Rafael at Disney Guest Services, and would spend the 21 remainder of the day at Epcot hot, miserable, and disappointed. L.A. and T.J.A. 22 left Epcot to spend the rest of the afternoon in their hotel room, hoping for a 23 better experience at Magic Kingdom the next day. 24 25

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1 1061. On the second day of their trip to the Disney Parks, L.A. and T.J.A. 2 went to Magic Kingdom. Like the day before, it started at Guest Services. L.A. 3 told the Disney employee at Guest Services about her and T.J.A.’s experience 4 the day before, especially the abrasive interaction with Rafael. The Disney 5 employee explained to L.A. how the DAS card work, and offered it to L.A. for 6 T.J.A., along with five yellow passes. 7 1062. L.A. and T.J.A. immediately went to Splash Mountain and 8 requested a return time with their DAS. While waiting for the return time for 9 Splash Mountain, L.A. and T.J.A. made their way to Big Thunder Mountain 10 Railroad to request another ride time so L.A. and T.J.A. would be able to

11 seamlessly transition from one ride to another, as L.A. and T.J.A. had done 12 during prior trips to the Disney Parks. At Big Thunder Mountain Railroad, a 13 Disney employee noticed that T.J.A.’s DAS already contained a return time for 14 Splash Mountain. The Disney employee explained to L.A. that she and T.J.A. 15 could only wait for one ride at a time with the DAS, and suggested they go eat 16 or sit in a show while they waited for Splash Mountain. L.A. pleaded with the DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disney employee for a return time for Big Thunder Mountain, to no avail. 18 1063. L.A. requested to speak to a manager. While waiting for the 19 manager to appear,Deadline.com T.J.A., tired, frustrated, and upset, experienced a meltdown 20 outside of Big Thunder Meltdown. L.A. was able to calm him down just in time 21 to speak with a Disney manager. 22 1064. The Disney manager arrived on scene 30 minutes later, offering 23 the same explanation as the Disney employee beforehand, with one change: 24 the Disney manager told L.A. she understood how difficult it was because she 25

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1 had a cousin diagnosed with autism. Still, the Disney manager explained, there 2 was nothing she or Disney could do other than to offer what the DAS already 3 offered. 4 1065. L.A. and T.J.A. were able to salvage some of the day at Magic 5 Kingdom due in large part to the yellow passes given to them beforehand. 6 Overall, the day was an un-accommodating and un-magical experience, wholly 7 unlike every trip to the Disney Parks before. 8 1066. L.A. and T.J.A. would not return to the Disney Parks during the 9 third day of their vacation, despite already purchasing passes to do so. For 10 L.A., it simply was not worth the risk of bringing T.J.A. further pain and

11 disappointment due to Disney’s failure to accommodate T.J.A. during the prior 12 two days. 13 1067. The new DAS procedure triggered T.J.A.’s meltdowns on August 14 20 and 21, 2014. 15 1068. Due to its failure to Disney’s refusal to accommodate the special 16 needs of persons like T.J.A., which leads to an increased propensity for T.J.A. to DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 experience meltdowns, Disney prevents T.J.A. from experiencing the full 18 enjoyment of its Parks, equal to the experiences of persons without a 19 disability. Deadline.com 20 1069. After October 9, 2013, T.J.A., no longer received the type of 21 accommodation and attention L.A. and T.J.A. had received when they visited 22 the Parks in the past. 23 1070. As a result of Disney’s refusal to modify its procedures to 24 reasonably accommodate T.J.A.’s needs, L.A. and T.J.A. have been discouraged 25

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1 and deterred from the full use and enjoyment of the Parks' rides and 2 attractions. If Disney had not abandoned its past policy of accommodating the 3 special needs of persons with cognitive impairments, L.A. would continue to 4 frequently visit the Parks with T.J.A. as a guest. But the family’s interest in 5 attending the Parks is substantially reduced. L.A. knows they should avoid 6 attending the Parks in the future because doing so will only lead to the same 7 un-magical experience and un-accommodating discrimination 8 1071. Notwithstanding Disney’s highly sophisticated knowledge of the 9 needs of persons with cognitive impairments, and notwithstanding Disney’s 10 historic ability to accommodate T.J.A.’s special needs, Disney personnel began

11 in October of 2013 to offer blanket accommodations, and implemented a 12 policy of systematically refusing to conduct individualized assessments of the 13 needs of T.J.A. and persons like him. Since October of 2013, Disney has 14 repeatedly and continuously refused to modify its policies for accommodating 15 disabled persons, choosing instead to robotically follow the DAS. Disney fails 16 and refuses to modify the DAS to allow T.J.A. to enjoy the same benefits and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 privileges as non-disabled patrons. 18 1072. Disney personnel have shown no willingness or desire to improve 19 the experience forDeadline.com guests like T.J.A. 20 1073. L.A. incurred expenses associated with the family’s wasted trips to 21 the Parks. 22 1074. During one or more visits to the Parks, T.J.A. suffered an actual 23 meltdown. 24 25

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1 1075. The symptoms and conditions associated with T.J.A.’s meltdown 2 constitute a physical injury under California and Florida law. 3 1076. T.J.A.’s meltdown in the Parks was proximately caused by Disney’s 4 negligent, unlawful, reckless and arbitrary treatment of T.J.A. during his 5 patronage of Disney’s facilities. At all material times, Disney knew T.J.A. to be 6 vulnerable to emotional injury if treated in such a manner by anyone. 7 1077. T.J.A.’s meltdown and the treatment which proximately caused 8 T.J.A. to experience the meltdown caused him grave and extreme mental 9 anguish and emotional trauma, for which Disney should be held accountable. 10 WHEREFORE, Plaintiff T.J.A., by and through L.A. as T.J.A.’s next

11 friend, parent and natural guardian, prays that this Court adjudicate this 12 dispute and enter an Order: 13 • Finding that Disney negligently inflicted emotional distress 14 upon T.J.A.; and 15 • Finding such infliction to have caused damages to T.J.A.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment for Plaintiff T.J.A. in the amount of such 17 damages; and 18 • Awarding reasonable litigation costs as may be determined by 19 the CourtDeadline.com in favor of Plaintiff and against Disney; and 20 • Awarding prejudgment interest; and 21 • Such other relief as this Court may find just and equitable. 22

23 24 25

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1 COUNT 85 2 Intentional Infliction of Emotional Distress 3 T.J.A. v. Disney 4 1078. Plaintiff T.J.A. incorporates and re-alleges paragraphs 1 through 5 90, and 1046 through 1077 above. 6 1079. During one or more visits to the Parks, T.J.A. suffered an actual 7 meltdown. 8 1080. The symptoms and conditions associated with T.J.A.’s meltdown 9 constitute a physical injury under California and Florida law. 10 1081. T.J.A.’s meltdown in the Parks was proximately caused by Disney’s

11 outrageous, unlawful and reckless treatment of T.J.A. during his patronage of 12 Disney’s facilities. At all material times, Disney knew T.J.A. to be vulnerable to 13 emotional injury if treated in such a manner by anyone. 14 1082. T.J.A.’s meltdown and the treatment which proximately caused 15 T.J.A. to experience the meltdown caused him grave and extreme mental 16 anguish and emotional trauma, for which Disney should be held accountable. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 WHEREFORE, Plaintiff T.J.A., by and through L.A. as T.J.A.’s next 18 friend, parent and natural guardian, prays that this Court adjudicate this 19 dispute and enterDeadline.com an Order: 20 • Finding that Disney intentionally inflicted emotional distress 21 upon T.J.A.; and 22 • Finding such infliction to have caused damages to T.J.A.; and 23 • Entering judgment for Plaintiff T.J.A. in the amount of such 24 damages; 25

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1 • Entering judgment in favor of Plaintiffs and against Disney for 2 exemplary or punitive damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 86 8 Violation of the Unruh Civil Rights Act 9 California Civil Code §§51, 52 10 T.J.A. v. Disney

11 1083. Plaintiff T.J.A. incorporates and re-alleges paragraphs 1 through 12 91, and 1046 through 1077 above. 13 1084. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 14 provides protection from discrimination by all business establishments in 15 California, including housing and public accommodations, because of age, 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI ancestry, color, disability, national origin, race, religion, sex and sexual 17 orientation. 18 1085. Section 52 of the California Civil Code provides that whoever 19 denies aids or incitesDeadline.com a denial, or makes any discrimination or distinction 20 contrary to Section 51 is liable for each and every offense. 21 1086. Pursuant to California Civil Code Section 51(f), a violation of the 22 ADA also constitutes a violation of California Civil Code Section 51, et seq. 23 1087. The Parks are “business establishments” within the meaning of 24 the California Code Section 51, et seq. 25

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1 1088. Through the acts and omissions described in this Complaint, 2 Disney has violated California Civil Code Section 51 by denying Plaintiff T.J.A.’s 3 access to Disney’s programs, services and activities. Disney has instituted and 4 continues to utilize policies which deny or which aid or incite the denial of 5 Plaintiff’s full and equal enjoyment of Disney’s public accommodations in the 6 same manner as non-disabled persons. Disney refuses to modify its policies 7 and procedures to permit fair enjoyment of its facilities by Plaintiff. As a 8 direct and proximate result of the afore-mentioned acts and omissions, 9 Plaintiff has suffered, and continues to suffer, hardship, humiliation and 10 anxiety due to Disney’s failure to provide reasonable accommodations and

11 access as are required by Plaintiff’s cognitive impairments. 12 1089. Due to the continuous nature of Disney’s ongoing discriminatory 13 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 14 result of Defendant’s action, Plaintiff is suffering irreparable harm, and thus 15 expeditious relief is appropriate. 16 WHEREFORE, Plaintiffs T.J.A. prays that this Court adjudicate this DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 dispute and enter an Order: 18 • Enjoining Defendant to cease the practices which are causing 19 discriminationDeadline.com against Plaintiffs on account of T.J.A.’s disability; 20 and 21 • Enjoining Defendant to reasonably modify its policies, 22 practices, and procedures to afford Plaintiffs with an 23 opportunity to experience Disney’s goods, services, facilities, 24 privileges, advantages, and accommodations; and 25

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1 • Establishing Court-approved remedial measures that Disney 2 must implement, to prevent Disney from further discriminating 3 against Plaintiffs when they visit the Disney Parks; and 4 • Establishing Court-approved requirements for information 5 dissemination about Disney’s remedial measures and modified 6 policies, to prevent Disney from further deterring Plaintiffs 7 from visiting Disney Parks as a result of anticipated 8 discrimination; and 9 • Establishing a monitoring program to ensure Disney’s 10 compliance with the Court’s Orders; and

11 • Determining the amount of T.J.A.’s actual damages; and 12 • Entering judgment in favor of Plaintiff and against Disney for 13 an amount up to three times the amounts of Plaintiff’s actual 14 damages, but in no event less than $4,000; and 15 • Awarding reasonable attorney’s fees as may be determined by 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI the Court in favor of Plaintiffs and against Disney; and 17 • Awarding reasonable litigation costs as may be determined by 18 the Court in favor of Plaintiffs and against Disney; and 19 • SuchDeadline.com other relief as this Court may find just and equitable. 20 COUNT 87 21 Negligent Infliction of Emotional Distress 22 L.A. v. Disney 23 1090. Plaintiff T.J.A. incorporates and re-alleges paragraphs 1 through 24 90 above. 25

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1 1091. During one or more visits to the Parks, L.A.’s beloved son T.J.A. 2 suffered an actual meltdown while in L.A.’s presence. 3 1092. The symptoms and conditions associated with T.J.A.’s meltdown 4 constitute a physical injury to T.J.A. under California and Florida law. 5 1093. T.J.A.’s meltdown in the Parks was proximately caused by Disney’s 6 negligent, unlawful, reckless and arbitrary treatment of T.J.A. during his 7 patronage of Disney’s facilities. At all material times, Disney knew T.J.A. to be 8 vulnerable to emotional injury if treated in such a manner by anyone. 9 1094. L.A. directly observed the stressors leading up to the meltdown, 10 T.J.A.’s resulting escalation and his meltdown. Particularly in light of her trust

11 and confidence that Disney would comply with applicable law and act in a 12 gracious and caring manner toward her son, L.A. could do nothing reasonable 13 to prevent the meltdown. 14 1095. L.A.’s observation of T.J.A.’s meltdown and of the outrageous 15 conduct and treatment which proximately caused T.J.A. to experience the 16 meltdown caused L.A. grave and extreme mental anguish and emotional DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 trauma, for which Disney should be held accountable. 18 WHEREFORE, Plaintiff L.A. prays that this Court adjudicate this 19 dispute and enterDeadline.com an Order: 20 • Finding that Disney negligently inflicted emotional distress 21 upon L.A.; and 22 • Finding such infliction to have caused damages to L.A. ; and 23 • Entering judgment for Plaintiff L.A. in the amount of such 24 damages; and 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding prejudgment interest; and 4 • Such other relief as this Court may find just and equitable. 5 COUNT 88 6 Intentional Infliction of Emotional Distress 7 L.A. v. Disney 8 1096. Plaintiff T.J.A. incorporates and re-alleges paragraphs 1 through 9 90, and 1091 through 1095 above. 10 1097. During one or more visits to the Parks, L.A.’s beloved son T.J.A. 11 suffered an actual meltdown. 12 1098. The symptoms and conditions associated with T.J.A.’s meltdown 13 constitute a physical injury under California and Florida law. 14 1099. T.J.A.’s meltdown in the Parks was proximately caused by Disney’s 15 outrageous, unlawful and reckless treatment of T.J.A. during his patronage of 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI Disney’s facilities. At all material times, Disney knew T.J.A. to be vulnerable to 17 emotional injury if treated in such a manner by anyone. 18 1100. L.A. directly observed the stressors leading up to the meltdown, 19 T.J.A.’s resulting Deadline.comescalation and his meltdown. Particularly in light of her trust 20 and confidence that Disney would comply with applicable law and act in a 21 gracious and caring manner toward her son, L.A. could do nothing reasonable 22 to prevent the meltdown. 23 1101. L.A.’s observation of T.J.A.’s meltdown and of the outrageous 24 conduct and treatment which proximately caused T.J.A. to experience the 25

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1 meltdown caused L.A. grave and extreme mental anguish and emotional 2 trauma, for which Disney should be held accountable. 3 WHEREFORE, Plaintiff L.A. prays that this Court adjudicate this 4 dispute and enter an Order: 5 • Finding that Disney intentionally inflicted emotional distress 6 upon L.A. ; and 7 • Finding such infliction to have caused damages to L.A. ; and 8 • Entering judgment for Plaintiff L.A. in the amount of such 9 damages; 10 • Entering judgment in favor of Plaintiffs and against Disney for

11 exemplary or punitive damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 89 17 Breach of Contract 18 L.A. v. Disney 19 1102. PlaintiffDeadline.com L.A. incorporates and re-alleges paragraphs 1 through 90, 20 and 1091 through 1095 above. 21 1103. L.A. entered into a contract through which Disney promised to 22 provide a reasonable and enjoyable amusement park experience, and one 23 which complies with applicable law. 24 25

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1 1104. Disney failed or refused to provide the promised experience, and 2 is in breach of contract. 3 1105. L.A. incurred expenses associated with the family’s wasted trips to 4 the Parks. Plaintiff is damaged by Disney’s breach of contract. 5 WHEREFORE, Plaintiff L.A. prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney breached its contract with L.A. ; and 8 • Entering judgment for Plaintiff L.A. in the amount of her 9 economic monetary damages; and 10 • Awarding reasonable litigation costs as may be determined by 11 the Court in favor of Plaintiff and against Disney; and 12 • Awarding prejudgment interest; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 90 15 Negligent Infliction of Emotional Distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI V.T.V. v. Disney 17 1106. Plaintiff V.T.V. incorporates and re-alleges paragraphs 1 through 18 90 above. 19 1107. V.T.V.Deadline.com has autism and a rare heart condition resulting from an 20 inoperable cardiac fibroma tumor. V.T.V.’s symptoms and stimming patterns 21 include flapping his arms and playing with his hands. V.T.V. is uncomfortable 22 in large crowds; he needs space around him. V.T.V. usually wears headphones 23 to limit the amount of noise and stimulation he is exposed to; loud noises 24 cause V.T.V. to become overly anxious. V.T.V. also cannot tolerate unnecessary 25

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1 physical exhaustion due to his heart condition. V.T.V. must limit the time he 2 walks and stands, and the amount of time spent in the heat and sun standing 3 and walking. 4 1108. Autism substantially limits a person’s ability to care for himself or 5 herself, perform manual tasks, speak, learn, read, concentrate, think, 6 communicate, perceive the concept of time, pair sights and sounds that 7 happen simultaneously, and work. 8 1109. V.T.V. is and at all material times has been a disabled person 9 within the meaning of California Government Code §1296(j). 10 1110. V.T.V. is eleven years of age, and is generally in the care of his

11 mother, N.L.C., who brings this action as V.T.V.’s next friend, parent and 12 natural guardian. 13 1111. N.L.C. and V.T.V. are residents of San Mateo County, California. 14 1112. V.T.V.’s cognitive impairments manifest themselves in a certain 15 way during his visits to the parks; V.T.V. is incapable of deviating from 16 consistency, order, and routine. Any deviation from that routine will cause DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 V.T.V. to become very upset, and invariable lead to V.T.V. suffering a 18 meltdown. Every trip to the Disney Parks must begin with a visit to Splash 19 Mountain, followedDeadline.com by Space Mountain, Pirates of the Caribbean and Indiana 20 Jones Adventure. 21 1113. V.T.V. is incapable of understanding the concept of time, of 22 waiting significant periods of time to enter a ride or attraction. If instructed to 23 do so, the stimming patterns described above will intensify toward meltdown. 24 When V.T.V. suffers a meltdown, he will scream loudly, cry, and become angry. 25

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1 V.T.V. will shut down and no longer listen to those around him, including 2 N.L.C. It can take V.T.V. hours to recover from a meltdown. 3 1114. V.T.V. is incapable of understanding the concept of visiting an 4 attraction in the present only to be told it cannot be experienced until 5 sometime in the future. As such, the new DAS creates avoidable stressors for 6 V.T.V., constantly escalating his stimming patterns toward meltdowns. Since 7 Disney’s implementation of the new DAS, V.T.V. has experienced multiple 8 meltdowns at the Disney Parks. 9 1115. N.L.C. grew up a Disney Fan. Her baby shower for V.T.V. was 10 Disney themed. N.L.C. even attended the Disney Parks while she was pregnant

11 with V.T.V. Shortly after he was born, N.L.C. returned to the Disney Parks with 12 V.T.V., and would do so at least five times per year. Trips to the Disney Parks 13 included trips to both Disneyland and Walt Disney World. During those visits, 14 N.L.C. carried the Guest Assistance Card, and was admirably accommodated. 15 During those visits, V.T.V. exhibited a nature and extent of joy that he rarely 16 shows in any other setting. Typically, N.L.C. and V.T.V. would drive seven DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 hours to visit the Disneyland Parks. Shortly after N.L.C. and V.T.V. arrived, they 18 would go to Guest Services. At Guest Services, in addition to the GAC, N.L.C. 19 and V.T.V. wouldDeadline.com also receive a “Red Pass” through the Make-A-Wish 20 Foundation. From the first time receiving the Red Pass, N.L.C. always received 21 the assurance from Disney employees that every trip to the Disney Parks 22 would include the Red Pass – that N.L.C. would always receive the same pass 23 anytime N.L.C. visited the Disney Parks. The wait was never long than 10 24 minutes. N.L.C. and V.T.V. would then spend the day riding the rides in the 25

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1 order V.T.V. needed to ride them. Wait times, physical activity, and stress and 2 stimulation were minimal. N.L.C. was always proud and joyful of the 3 opportunity to bring to her beloved son a level of happiness which he rarely 4 shows elsewhere. Disney employees were always friendly and outgoing. 5 Everyone was smiling and having a good time. It really was a magical 6 experience. 7 1116. This changed drastically in March 2014 when N.L.C. and V.T.V. 8 took their first trip to the Disney Parks after Disney released the DAS. 9 1117. Like every trip in the past, N.L.C. went to Guest Services to request 10 a GAC and receive her Red Pass through Make-A-Wish Foundation. The Disney

11 employee explained that Disney was using a different system; neither the GAC 12 nor the Red Pass would be available. N.L.C., shocked because she had received 13 assurance before that she would always receive the Red Pass, asked how 14 Disney could just decide to change the system. As the Disney employee 15 explained the ins and outs of the DAS, N.L.C. grew more upset because she 16 knew with V.T.V.’s heart condition, walking back and forth from kiosk to kiosk DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 would not be an option. Even more so, without the ability to ride the rides in 18 the order V.T.V. needed to ride them in, N.L.C. knew the day was sure to be a 19 disappointment.Deadline.com N.L.C., confused at how the same Disney that once welcomed 20 her and V.T.V. with open arms, could now so easily turn its back on them. 21 1118. N.L.C. offered to show the Disney employee V.T.V.’s doctors’ notes 22 and medical records, but the Disney employee simply refused. The Disney 23 employee then took V.T.V.’s picture and offered no additional Fastpasses 24 25

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1 before issuing V.T.V. his DAS – the entire process taking roughly 30 minutes to 2 complete. 3 1119. N.L.C. then began searching for the nearest kiosk in order to sign 4 up for Splash Mountain because every ride to Disneyland had to start with a 5 visit to Splash Mountain. When N.L.C. finally reached a kiosk and inquired 6 about return times for Splash Mountain, she was horrified to learn that the 7 return times were too long. Facing no other choice, N.L.C. signed up for the 8 next ride in V.T.V.’s routine – Space Mountain. 9 1120. Space Mountain had a 50 minute return time. V.T.V. was already 10 upset because this was out of his routine; V.T.V. fully expected to ride Splash

11 Mountain first. N.L.C. asked the Disney employee what her and V.T.V. could do 12 while they waited the 50 minutes to ride Space Mountain. The Disney 13 employee suggested they ride another ride. N.L.C. asked how this would be 14 possible if you could only wait for one ride at a time with the DAS. The Disney 15 employee suggested they wait in a standby line at another ride while waiting 16 for the 50 minutes to elapse. For V.T.V., waiting in such a line, or for such a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 time, surrounded by people and stimulation is not possible. N.L.C. explained 18 this to the Disney employee to no avail. N.L.C. explained that V.T.V. become 19 accustomed to theDeadline.com prior system, which accommodated V.T.V.’s special needs 20 by permitting him to enter attractions through an alternate entrance. To all of 21 which the Disney employee gave only one reply, and did so with emphasis: a 22 silent, blank stare. 23 1121. N.L.C. and V.T.V. tried to make the most of their day at the Disney 24 Parks. Unfortunately for N.L.C. and V.T.V., the horrible start would be a 25

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1 premonition of the day to follow; miserable, un-accommodating, and un- 2 magical. 3 1122. N.L.C. and V.T.V. returned to the Disney Parks during the last week 4 of October, 2014. It was an annual tradition to visit the Disney Parks during 5 N.L.C. and V.T.V.’s birthdays. N.L.C. and V.T.V. were determined not to let 6 Disney’s new policy and their last trip to the Disney Parks ruin a timeless 7 tradition. 8 1123. Every expectation and hope that N.L.C. possessed for their return 9 visit to the Disney Parks quickly turned into greater disappointment and 10 dejection during their October 2014 visit. N.L.C. and V.T.V. encountered even

11 longer lines at Guest Services. This coupled with the need to return to Guest 12 Services three separate times throughout their trip guaranteed a frustrating 13 and un-accommodating start to each and every day at the Disney Parks. 14 1124. To make matters worse, N.L.C. and V.T.V. were repeatedly turned 15 away from the kiosks due to the picture on V.T.V.’s DAS card not being clear 16 enough for the Disney employees to identify V.T.V. Eventually, N.L.C. and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 V.T.V. had to return to Guest Services again to request that V.T.V.’s picture be 18 retaken, and new DAS issued. 19 1125. On oneDeadline.com occasion, a Disney employee asked N.L.C. if the DAS card 20 was “working okay” for N.L.C. and V.T.V. N.L.C., taken aback by the question, 21 responded that it was not. The Disney employee apologized before stating 22 “This is all we have.” 23 1126. Ultimately, their days were consumed with walking back and 24 forth between the limited kiosks and the rides – specifically this trip, Splash 25

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1 Mountain – and finding ways to distract V.T.V. while waiting for the return 2 time. Much like their last trip, N.L.C. and V.T.V. left the Disney Parks 3 disappointed and unsatisfied. If it were not for V.T.V.’s love of all things 4 Disney, N.L.C. would have sworn off Disney from then on. But the only feeling 5 worse than leaving the Disney Parks disappointed was telling V.T.V. they 6 could not return to the Disney Parks, at all. 7 1127. N.L.C. and V.T.V. returned to the Disney Parks on January 7, 2015. 8 At Guest Services at Disneyland, N.L.C. spoke with a Disney employee who 9 asked the following questions: 10 a. “What is wrong with him?”

11 b. “Why is he unable to do the rides?” 12 c. “What makes him not want to be in the line?” 13 1128. N.L.C. was offended by the Disney employee’s questions, but 14 endured the interrogation with the hope that, this time, Disney would offer an 15 actual accommodation. 16 1129. Instead, the Disney employee issued J.V. a newer version of the

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 same failed system; the digital DAS. 18 1130. N.L.C. and V.T.V. would have to scan their annual pass or day 19 ticket, instead ofDeadline.com the DAS card. N.L.C. would be responsible for writing down 20 her own return times, and keeping track of those return times while in the 21 Disney Parks. 22 1131. N.L.C. requested Splash Mountain for their first return time. The 23 Disney employee promptly responded: “Why would your son want to go on a 24 water ride?” N.L.C. responded by explaining V.T.V.’s routine, and that 25

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1 currently, Splash Mountain was “his” ride. With that, N.L.C. and V.T.V. walked 2 to Splash Mountain. When N.L.C. and V.T.V. arrived at Splash Mountain at the 3 designated return time, however, she learned that the Disney employee at 4 Guest Services made a mistake and had reserved N.L.C. and V.T.V. for Space 5 Mountain instead. 6 1132. N.L.C. explained to the Disney employee that V.T.V. only wanted to 7 ride Splash Mountain and that a mistake had been made, thinking maybe the 8 Disney employee would understand her plight and allow N.L.C. and V.T.V. 9 access to Splash Mountain. Instead, the Disney employee explained that 10 Disney employees had no way of communicating with each other.

11 Consequently, N.L.C. and V.T.V. would have to return the kiosk to change the 12 reservation. 13 1133. N.L.C. and V.T.V. walked back to the nearest kiosk, where N.L.C. 14 explained the mishap to the Disney employee who then changed her and 15 V.T.V.’s reservation from Space Mountain to Splash Mountain. 16 1134. N.L.C. and V.T.V. walked back to Splash Mountain, this time to

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 learn that the system had not been updated yet. N.L.C. and V.T.V. must return 18 to the kiosk again. 19 1135. V.T.V.Deadline.com finally reached his breaking point. In front of Splash 20 Mountain, V.T.V. suffered a horrible and debilitating meltdown. 21 1136. When N.L.C. thought it could not get worse, Disney could not be 22 any more un-accommodating, N.L.C. was surprised by Disney yet again. On the 23 last day of their trip to the Disney Parks, N.L.C. developed a staph infection. 24 N.L.C. went to the First Aid center at the Disney Parks and requested 25

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1 assistance as she felt weak and could not stand. The Disney employee at the 2 First Aid center offered a wheelchair to escort her to a taxi. Then, while 3 requesting the wheelchair, the Disney employee changed her mind, and 4 explained Disney could no longer provide N.L.C. with a wheelchair; she was on 5 her own. 6 1137. N.L.C. and V.T.V. returned to the Disney Parks on April 19, 2015 7 and had an equally un-magical and unaccommodating experience. 8 1138. The new DAS procedure triggered V.T.V.’s meltdowns during 9 multiple trips to the Disney Parks. 10 1139. Due to its failure to Disney’s refusal to accommodate the special

11 needs of persons like V.T.V., which leads to an increased propensity for V.T.V. 12 to experience meltdowns, Disney prevents V.T.V. from experiencing the full 13 enjoyment of its Parks, equal to the experiences of persons without a 14 disability. 15 1140. After October 9, 2013, V.T.V., no longer received the type of 16 accommodation and attention V.T.V. and N.L.C. had received when they visited DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 the Parks in the past. 18 1141. As a result of Disney’s refusal to modify its procedures to 19 reasonably accommodateDeadline.com V.T.V.’s needs, V.T.V. and N.L.C. have been 20 discouraged and deterred from the full use and enjoyment of the Parks' rides 21 and attractions. If Disney had not abandoned its past policy of 22 accommodating the special needs of persons with cognitive impairments, 23 V.T.V. would continue to frequently visit the Parks with V.T.V. as a guest. But 24 the family’s interest in attending the Parks is substantially reduced. V.T.V. 25

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1 knows they should avoid attending the Parks in the future because doing so 2 will only lead to the same un-magical experience and un-accommodating 3 discrimination 4 1142. Notwithstanding Disney’s highly sophisticated knowledge of the 5 needs of persons with cognitive impairments, and notwithstanding Disney’s 6 historic ability to accommodate V.T.V.’s special needs, Disney personnel began 7 in October of 2013 to offer blanket accommodations, and implemented a 8 policy of systematically refusing to conduct individualized assessments of the 9 needs of V.T.V. and persons like him. Since October of 2013, Disney has 10 repeatedly and continuously refused to modify its policies for accommodating

11 disabled persons, choosing instead to robotically follow the DAS. Disney fails 12 and refuses to modify the DAS to allow V.T.V. to enjoy the same benefits and 13 privileges as non-disabled patrons. 14 1143. Disney personnel have shown no willingness or desire to improve 15 the experience for guests like V.T.V. 16 1144. V.T.V. incurred expenses associated with the family’s wasted trips

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 to the Parks. 18 1145. During one or more visits to the Parks, V.T.V. suffered an actual 19 meltdown. Deadline.com 20 1146. The symptoms and conditions associated with V.T.V.’s meltdown 21 constitute a physical injury under California and Florida law. 22 1147. V.T.V.’s meltdown in the Parks was proximately caused by 23 Disney’s negligent, unlawful, reckless and arbitrary treatment of V.T.V. during 24 25

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1 his patronage of Disney’s facilities. At all material times, Disney knew V.T.V. to 2 be vulnerable to emotional injury if treated in such a manner by anyone. 3 1148. V.T.V.’s meltdown and the treatment which proximately caused 4 V.T.V. to experience the meltdown caused him grave and extreme mental 5 anguish and emotional trauma, for which Disney should be held accountable. 6 WHEREFORE, Plaintiff V.T.V., by and through N.L.C. as V.T.V.’s next 7 friend, parent and natural guardian, prays that this Court adjudicate this 8 dispute and enter an Order: 9 • Finding that Disney negligently inflicted emotional distress 10 upon V.T.V.; and

11 • Finding such infliction to have caused damages to V.T.V.; and 12 • Entering judgment for Plaintiff V.T.V. in the amount of such 13 damages; and 14 • Awarding reasonable litigation costs as may be determined by 15 the Court in favor of Plaintiff and against Disney; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Awarding prejudgment interest; and 17 • Such other relief as this Court may find just and equitable. 18 COUNT 91 19 IntentionalDeadline.com Infliction of Emotional Distress 20 V.T.V. v. Disney 21 1149. Plaintiff V.T.V. incorporates and re-alleges paragraphs 1 through 22 90, and 1107 through 1148 above. 23 1150. During one or more visits to the Parks, V.T.V. suffered an actual 24 meltdown. 25

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1 1151. The symptoms and conditions associated with V.T.V.’s meltdown 2 constitute a physical injury under California and Florida law. 3 1152. V.T.V.’s meltdown in the Parks was proximately caused by 4 Disney’s outrageous, unlawful and reckless treatment of V.T.V. during his 5 patronage of Disney’s facilities. At all material times, Disney knew V.T.V. to be 6 vulnerable to emotional injury if treated in such a manner by anyone. 7 1153. V.T.V.’s meltdown and the treatment which proximately caused 8 V.T.V. to experience the meltdown caused him grave and extreme mental 9 anguish and emotional trauma, for which Disney should be held accountable. 10 WHEREFORE, Plaintiff V.T.V., by and through N.L.C. as V.T.V.’s next

11 friend, parent and natural guardian, prays that this Court adjudicate this 12 dispute and enter an Order: 13 • Finding that Disney intentionally inflicted emotional distress 14 upon V.T.V.; and 15 • Finding such infliction to have caused damages to V.T.V.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment for Plaintiff V.T.V. in the amount of such 17 damages; 18 • Entering judgment in favor of Plaintiffs and against Disney for 19 exemplaryDeadline.com or punitive damages; and 20 • Awarding reasonable litigation costs as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 • Awarding prejudgment interest; and 23 • Such other relief as this Court may find just and equitable. 24

25

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1 COUNT 92 2 Violation of the Unruh Civil Rights Act 3 California Civil Code §§51, 52 4 V.T.V. v. Disney 5 1154. Plaintiff V.T.V. incorporates and re-alleges paragraphs 1 through 6 91, and 1107 through 1148 and above. 7 1155. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 8 provides protection from discrimination by all business establishments in 9 California, including housing and public accommodations, because of age, 10 ancestry, color, disability, national origin, race, religion, sex and sexual

11 orientation. 12 1156. Section 52 of the California Civil Code provides that whoever 13 denies aids or incites a denial, or makes any discrimination or distinction 14 contrary to Section 51 is liable for each and every offense. 15 1157. Pursuant to California Civil Code Section 51(f), a violation of the 16 ADA also constitutes a violation of California Civil Code Section 51, et seq. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1158. The Parks are “business establishments” within the meaning of 18 the California Code Section 51, et seq. 19 1159. ThroughDeadline.com the acts and omissions described in this Complaint, 20 Disney has violated California Civil Code Section 51 by denying Plaintiff 21 V.T.V.’s access to Disney’s programs, services and activities. Disney has 22 instituted and continues to utilize policies which deny or which aid or incite 23 the denial of Plaintiff’s full and equal enjoyment of Disney’s public 24 accommodations in the same manner as non-disabled persons. Disney refuses 25

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1 to modify its policies and procedures to permit fair enjoyment of its facilities 2 by Plaintiff. As a direct and proximate result of the afore-mentioned acts and 3 omissions, Plaintiff has suffered, and continues to suffer, hardship, humiliation 4 and anxiety due to Disney’s failure to provide reasonable accommodations 5 and access as are required by Plaintiff’s cognitive impairments. 6 1160. Due to the continuous nature of Disney’s ongoing discriminatory 7 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 8 result of Defendant’s action, Plaintiff is suffering irreparable harm, and thus 9 expeditious relief is appropriate. 10 WHEREFORE, Plaintiffs V.T.V. prays that this Court adjudicate this

11 dispute and enter an Order: 12 • Enjoining Defendant to cease the practices which are causing 13 discrimination against Plaintiffs on account of V.T.V.’s 14 disability; and 15 • Enjoining Defendant to reasonably modify its policies, 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI practices, and procedures to afford Plaintiffs with an 17 opportunity to experience Disney’s goods, services, facilities, 18 privileges, advantages, and accommodations; and 19 • EstablishingDeadline.com Court-approved remedial measures that Disney 20 must implement, to prevent Disney from further discriminating 21 against Plaintiffs when they visit the Disney Parks; and 22 • Establishing Court-approved requirements for information 23 dissemination about Disney’s remedial measures and modified 24 policies, to prevent Disney from further deterring Plaintiffs 25

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1 from visiting Disney Parks as a result of anticipated 2 discrimination; and 3 • Establishing a monitoring program to ensure Disney’s 4 compliance with the Court’s Orders; and 5 • Entering judgment for Plaintiff V.T.V. in the amount of his non- 6 economic monetary damages; and 7 • Determining the amount of V.T.V.’s actual damages; and 8 • Entering judgment in favor of Plaintiff and against Disney for 9 an amount up to three times the amounts of Plaintiff’s actual 10 damages, but in no event less than $4,000; and

11 • Awarding reasonable litigation costs as may be determined by 12 the Court in favor of Plaintiffs and against Disney; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 93 15 Negligent Infliction of Emotional Distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI N.L.C. v. Disney 17 1161. Plaintiff N.L.C. incorporates and re-alleges paragraphs 1 through 18 90, 1107 through 1148, 1150 through 1153, and 1155 through 1160 above. 19 1162. DuringDeadline.com one or more visits to the Parks, N.L.C.’s beloved son V.T.V. 20 suffered an actual meltdown while in N.L.C.’s presence. 21 1163. The symptoms and conditions associated with V.T.V.’s meltdown 22 constitute a physical injury to N.L.C. under California and Florida law. 23 1164. V.T.V.’s meltdown in the Parks was proximately caused by 24 Disney’s negligent, unlawful, reckless and arbitrary treatment of V.T.V. during 25

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1 his patronage of Disney’s facilities. At all material times, Disney knew V.T.V. to 2 be vulnerable to emotional injury if treated in such a manner by anyone. 3 1165. N.L.C. directly observed the stressors leading up to the meltdown, 4 V.T.V.’s resulting escalation and his meltdown. Particularly in light of her trust 5 and confidence that Disney would comply with applicable law and act in a 6 gracious and caring manner toward her son, N.L.C. could do nothing 7 reasonable to prevent the meltdown. 8 1166. N.L.C.’s observation of V.T.V.’s meltdown and of the outrageous 9 conduct and treatment which proximately caused V.T.V. to experience the 10 meltdown caused V.T.V. grave and extreme mental anguish and emotional

11 trauma, for which Disney should be held accountable. 12 WHEREFORE, Plaintiff N.L.C. prays that this Court adjudicate this 13 dispute and enter an Order: 14 • Finding that Disney negligently inflicted emotional distress 15 upon N.L.C.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Finding such infliction to have caused damages to N.L.C.; and 17 • Entering judgment for Plaintiff N.L.C. in the amount of such 18 damages; and 19 • AwardingDeadline.com reasonable litigation costs as may be determined by 20 the Court in favor of Plaintiff and against Disney; and 21 • Awarding prejudgment interest; and 22 • Such other relief as this Court may find just and equitable. 23

24 25

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1 COUNT 94 2 Intentional Infliction of Emotional Distress 3 N.L.C. v. Disney 4 1167. Plaintiff N.L.C. incorporates and re-alleges paragraphs 1 through 5 90, 1107 through 1148, 1150 through 1153, and 1155 through 1160 above. 6 1168. During one or more visits to the Parks, N.L.C.’s beloved son V.T.V. 7 suffered an actual meltdown. 8 1169. The symptoms and conditions associated with V.T.V.’s meltdown 9 constitute a physical injury under California and Florida law. 10 1170. V.T.V.’s meltdown in the Parks was proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of V.T.V. during his 12 patronage of Disney’s facilities. At all material times, Disney knew V.T.V. to be 13 vulnerable to emotional injury if treated in such a manner by anyone. 14 1171. N.L.C. directly observed the stressors leading up to the meltdown, 15 V.T.V.’s resulting escalation and his meltdown. Particularly in light of her trust 16 and confidence that Disney would comply with applicable law and act in a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 gracious and caring manner toward her son, N.L.C. could do nothing 18 reasonable to prevent the meltdown. 19 1172. N.L.C.’sDeadline.com observation of V.T.V.’s meltdown and of the outrageous 20 conduct and treatment which proximately caused V.T.V. to experience the 21 meltdown caused N.L.C. grave and extreme mental anguish and emotional 22 trauma, for which Disney should be held accountable. 23 WHEREFORE, Plaintiff N.L.C. prays that this Court adjudicate this 24 dispute and enter an Order: 25

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1 • Finding that Disney intentionally inflicted emotional distress 2 upon N.L.C.; and 3 • Finding such infliction to have caused damages to N.L.C.; and 4 • Entering judgment for Plaintiff N.L.C. in the amount of such 5 damages; 6 • Entering judgment in favor of Plaintiffs and against Disney for 7 exemplary or punitive damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 95 13 Breach of Contract 14 N.L.C. v. Disney 15 1173. Plaintiff N.L.C. incorporates and re-alleges paragraphs 1 through 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 90, 1107 through 1148, 1150 through 1153, and 1155 through 1160 above. 17 1174. N.L.C. entered into a contract through which Disney promised to 18 provide a reasonable and enjoyable amusement park experience, and one 19 which complies withDeadline.com applicable law. 20 1175. Disney failed or refused to provide the promised experience, and 21 is in breach of contract. 22 1176. N.L.C. incurred expenses associated with the family’s wasted trips 23 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 24 25

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1 WHEREFORE, Plaintiff N.L.C. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney breached its contract with N.L.C.; and 4 • Entering judgment for Plaintiff N.L.C. in the amount of his 5 economic monetary damages; and 6 • Awarding reasonable litigation costs as may be determined by 7 the Court in favor of Plaintiff and against Disney; and 8 • Awarding prejudgment interest; and 9 • Such other relief as this Court may find just and equitable. 10 COUNT 96

11 Negligent Infliction of Emotional Distress 12 P.F.E. v. Disney 13 1177. Plaintiff P.F.E. incorporates and re-alleges paragraphs 1 through 14 90 above. 15 1178. P.F.E. has autism. P.F.E.’s symptoms and stimming patterns 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI include fidgeting with her hands and pulling on her hair, sometimes to the 17 point of pulling her hair out of her scalp. 18 1179. Autism substantially limits a person’s ability to care for himself or 19 herself, performDeadline.com manual tasks, speak, learn, read, concentrate, think, 20 communicate, perceive the concept of time, pair sights and sounds that 21 happen simultaneously, and work. 22 1180. P.F.E. is and at all material times has been a disabled person 23 within the meaning of California Government Code §12926(j). 24 25

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1 1181. P.F.E. is eight years of age, and is generally in the care of her 2 father, B.P.E., who brings this action as P.F.E.’s next friend, parent and natural 3 guardian. 4 1182. B.P.E. and P.F.E. are residents of Henrico County, Virginia. 5 1183. P.F.E.’s cognitive impairments manifest themselves in a certain 6 way during her visits to the parks. P.F.E. becomes fixated on certain rides or 7 Character Experiences, and will not be satisfied until she can experience that 8 ride or Character Experience. Any attempt to deviate from that temporary 9 fixation will likely result in a meltdown. For example, a common fixation for 10 P.F.E. is to begin any trip to the Disney Parks with It’s a Small World. Any

11 deviation from that fixation would likely lead to P.F.E. experiencing a 12 meltdown. 13 1184. P.F.E. is incapable of understanding the concept of time, of waiting 14 significant periods of time in the present in exchange for a pleasure to be 15 experienced in the future. If instructed to wait a significant period of time to 16 experience a Disney attraction, especially one which is already the subject of a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 fixation, P.F.E.’s stimming patterns will intensify toward meltdown. P.F.E.’s 18 meltdowns are physical and can consist of P.F.E. dropping to the ground, 19 screaming, and hittingDeadline.com and scratching herself. 20 1185. P.F.E. is incapable of understanding the concept of visiting an 21 attraction in the present only to be told it cannot be experienced until 22 sometime in the future. As such, the new DAS creates avoidable stressors for 23 P.F.E., constantly escalating her stimming patterns toward meltdowns. Since 24 25

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1 Disney’s implementation of the new DAS, P.F.E. has experienced meltdowns at 2 the Disney Parks. 3 1186. P.F.E. is incapable of understanding the concept of time, and thus 4 cannot comprehend exchanging a present tense sacrifice (waiting around) for 5 a future tense pleasure (an attraction). Consequently, she cannot endure 6 significant times idly waiting around, without her cognitive impairments 7 causing her to experience stimming and meltdowns. Triggers and anxiety will 8 cause P.F.E. to exhibit stimming and maladaptive behaviors. 9 1187. B.P.E. has been taking P.F.E. to the Disney Parks since P.F.E. was 10 four years old. B.P.E. has regularly returned to the Disney Parks at least once

11 per year, including trips to both Walt Disney World and Disneyland. Before 12 October 9, 2013, P.F.E. always carried the Guest Assistance Card, and was 13 admirably accommodated. During those visits, P.F.E. exhibited a nature and 14 extent of joy that she rarely shows in any other setting. The GAC allowed P.F.E. 15 to access many different Character Experiences throughout the Disney Parks, 16 in addition to her usual fixations: It’s a Small World and Peter Pan’s Flight. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 B.P.E. was always proud and joyful of the opportunity to bring to his beloved 18 daughter a level of happiness which she rarely shows elsewhere. Disney 19 employees wereDeadline.com always friendly and outgoing. Everyone was smiling and 20 having a good time. It was a magical experience. 21 1188. This drastically changed in December 2013 when B.P.E. and P.F.E. 22 attended the Disney Parks for the first time after Disney unveiled the DAS. 23 24 25

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1 1189. B.P.E. planned a 13-day stay for him and his family from 2 December 7 through December 20, 2013. Most of those days were spent at 3 Walt Disney World. 4 1190. Upon first arriving to Walt Disney World, B.P.E. and P.F.E. went to 5 Guest Services where B.P.E. waited with P.F.E. for 30 minutes before speaking 6 with a Disney employee. With no one else there to keep P.F.E. occupied or 7 distract her from the idle wait, P.F.E. grew anxious and frustrated, teetering on 8 the edge of a meltdown. Eventually, B.P.E. received a short explanation about 9 how the DAS worked, P.F.E.’s picture was taken, and B.P.E. and P.F.E.’s first 10 day in Walt Disney World began.

11 1191. The remainder of the day at Walt Disney World was spent trying 12 to adapt to the DAS. Because P.F.E. had grown accustomed to the GAC, 13 adjusting to the new procedures of the DAS was frustrating and led to multiple 14 meltdowns throughout the day. For P.F.E., the greatest source of 15 dissatisfaction was arriving to a ride, only to receive a return time, and having 16 to leave the ride without actually riding the ride at that time. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1192. Most notably, P.F.E. suffered a meltdown at The Magic Carpets of 18 Aladdin after being issued a return time upon arrival, instead of riding the ride 19 at that time. B.P.E.Deadline.com had to sit with P.F.E. in a nearby family restroom until 20 P.F.E. recovered completely from her meltdown. 21 1193. Most of the remaining 10 days of B.P.E. and P.F.E.’s visit were 22 spent in Walt Disney World. While some days were more tolerable than 23 others, all were unsatisfying and unaccommodating, lacking the same Disney 24 magic when B.P.E. and P.F.E. visited the Disney Parks in the past under the 25

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1 GAC. B.P.E. left Walt Disney World disappointed about their experience, but 2 hopeful future visits to the Disney Parks would someday be as satisfying as 3 before. 4 1194. In April 2014, B.P.E. and P.F.E. returned to the Disney Parks, this 5 time to Disneyland. B.P.E. hoped for a better experience the second time 6 around. Unfortunately for B.P.E., this trip would prove to be just as 7 unsatisfying and un-magical as the family’s December 2013 trip. 8 1195. Again, the visit started at Guest Services where a Disney employee 9 gave B.P.E. a map of Disneyland with kiosks locations circled where B.P.E. and 10 P.F.E. were to obtain DAS return times. However, B.P.E. noticed immediately

11 that the kiosk locations were sparse and scattered throughout Disneyland, 12 requiring B.P.E. and P.F.E. to walk great distances throughout the day to 13 obtain DAS return times. 14 1196. Once B.P.E. actually found the kiosk, he usually encountered a 15 crowd of chaos as other guests waited frantically while, on average, two 16 Disney employees, with tablets in hand, attempted to service a mass of guests DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 with questions and requests for DAS return times. It usually took B.P.E. ten 18 minutes just to receive a return time for the ride P.F.E. wanted to ride at that 19 time. Deadline.com 20 1197. During these long wait to obtain DAS return times, P.F.E. 21 sometimes would see another ride or Character Experience she wanted to 22 visit which would quickly replace the current fixation she had - the current 23 fixation B.P.E. was waiting to receive a return time for. Once B.P.E. finally 24 received a return time for a specific ride, B.P.E. usually encountered 25

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1 disappointment at learning that P.F.E. now wanted to ride a different ride or 2 visit a different Character Experience after B.P.E. had already obtained a DAS 3 return time for another ride. 4 1198. B.P.E. would then have to march back to the kiosk, wait an 5 additional ten minutes, and receive a DAS return time for the ride P.F.E. had 6 become fixated on while P.F.E. was waiting for B.P.E. to obtain a DAS return 7 time for the first ride P.F.E. wanted to ride. 8 1199. In order to continue repeating this pattern, B.P.E. was forced to 9 plan out routes for P.F.E. that avoided passing by other rides or Character 10 Experiences for fear that P.F.E. would change her mind mid-course, requiring

11 B.P.E. to start the process of returning the kiosk to obtain a DAS return time all 12 over again, and risk P.F.E. experiencing a meltdown. 13 1200. No matter how much B.P.E. planned, he simply could not avoid 14 passing every ride or Character Experience that might offer P.F.E. a new 15 fixation. With the GAC, this was never a problem; B.P.E. and P.F.E. could simply 16 approach the ride once P.F.E. became fixated, wait the reduced amount of time DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 allowed by the GAC, and move on to the next ride. In one fell swoop, the DAS 18 eliminated this accommodation and made trips such as this one to Disneyland 19 unpredictable quagmires.Deadline.com 20 1201. On one occasion, B.P.E. and P.F.E. passed Dumbo the Flying 21 Elephant which B.P.E. had not obtained a DAS return time for. P.F.E. indicated 22 she wished to ride it at that moment. B.P.E. noticed the wait time for the 23 standby line was only 10 minutes. B.P.E. approached the Disney employee and 24 presented the DAS card and asked if they could ride the ride, or at least 25

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1 receive a return time. The Disney employee told B.P.E. that because the wait 2 time was only 10 minutes in the standby line, they could wait in the standby 3 line. Twenty minutes later, P.F.E. experienced a horrible and debilitating 4 meltdown while still waiting in the standby line. 5 1202. B.P.E. returned to the Disney Parks with P.F.E. in October 2014, 6 January 2015, and April 2015. Each trip was as unsatisfying and un- 7 accommodating as the last. Most notably, during their April 2015 visit to Walt 8 Disney World, P.F.E. encountered inconsistent treatment from one Disney 9 employee to the next; some Disney employees allowed B.P.E. and P.F.E. to 10 enter through the Fastpass entrance, while others forced B.P.E. and P.F.E. to

11 wait in the standby line, and then enter through the standby entrance. This 12 arbitrary and capricious treatment increased B.P.E.’s frequency of meltdowns, 13 including a meltdown at Space Mountain upon receiving a 55 minute return 14 time. B.P.E., unable to distract P.F.E. any longer, had to remove her from Space 15 Mountain and seek solace in a separate area of Walt Disney World while P.F.E. 16 recovered. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1203. B.P.E. also experienced meltdowns as a result of not being able to 18 visit certain Character Experiences due to that Character Experience not 19 accepting DAS returnDeadline.com times that day or allowing Fastpass access. 20 1204. The new DAS procedure triggered P.F.E.’s meltdowns in 21 December 2013, April 2014, October 2014, January 2015, and April 2015. 22 1205. Due to its failure to Disney’s refusal to accommodate the special 23 needs of persons like P.F.E., which leads to an increased propensity for P.F.E. 24 to experience meltdowns, Disney prevents P.F.E. from experiencing the full 25

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1 enjoyment of its Parks, equal to the experiences of persons without a 2 disability. 3 1206. After October 9, 2013, P.F.E., no longer received the type of 4 accommodation and attention P.F.E. and B.P.E. had received when they visited 5 the Parks in the past. 6 1207. As a result of Disney’s refusal to modify its procedures to 7 reasonably accommodate P.F.E.’s needs, P.F.E. and B.P.E. have been 8 discouraged and deterred from the full use and enjoyment of the Parks' rides 9 and attractions. B.P.E. knows they should avoid attending the Parks in the 10 future because doing so will only lead to the same un-magical experience and

11 un-accommodating discrimination. Nevertheless, given P.F.E.’s ardent love for 12 all things Disney, B.P.E. knows he will continue to return to the Parks, hoping 13 one day Disney will revert back to a system that once again accommodates 14 P.F.E.’s special needs. 15 1208. Notwithstanding Disney’s highly sophisticated knowledge of the 16 needs of persons with cognitive impairments, and notwithstanding Disney’s DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 historic ability to accommodate P.F.E.’s special needs, Disney personnel began 18 in October of 2013 to offer blanket accommodations, and implemented a 19 policy of systematicallyDeadline.com refusing to conduct individualized assessments of the 20 needs of P.F.E. and persons like her. Since October of 2013, Disney has 21 repeatedly and continuously refused to modify its policies for accommodating 22 disabled persons, choosing instead to robotically follow the DAS. Disney fails 23 and refuses to modify the DAS to allow P.F.E. to enjoy the same benefits and 24 privileges as non-disabled patrons. 25

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1 1209. Disney personnel have shown no willingness or desire to improve 2 the experience for guests like P.F.E. 3 1210. B.P.E. incurred expenses associated with the family’s wasted trips 4 to the Parks. 5 1211. During one or more visits to the Parks, P.F.E. suffered an actual 6 meltdown. 7 1212. The symptoms and conditions associated with P.F.E.’s meltdown 8 constitute a physical injury under California and Florida law. 9 1213. P.F.E.’s meltdown in the Parks was proximately caused by 10 Disney’s negligent, unlawful, reckless and arbitrary treatment of P.F.E. during

11 her patronage of Disney’s facilities. At all material times, Disney knew P.F.E. 12 to be vulnerable to emotional injury if treated in such a manner by anyone. 13 1214. P.F.E.’s meltdown and the treatment which proximately caused 14 P.F.E. to experience the meltdown caused her grave and extreme mental 15 anguish and emotional trauma, for which Disney should be held accountable. 16 WHEREFORE, Plaintiff P.F.E., by and through B.P.E. as P.F.E.’s next DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 friend, parent and natural guardian, prays that this Court adjudicate this 18 dispute and enter an Order: 19 • FindingDeadline.com that Disney negligently inflicted emotional distress 20 upon P.F.E.; and 21 • Finding such infliction to have caused damages to P.F.E.; and 22 • Entering judgment for Plaintiff P.F.E. in the amount of such 23 damages; and 24 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding prejudgment interest; and 4 • Such other relief as this Court may find just and equitable. 5 COUNT 97 6 Intentional Infliction of Emotional Distress 7 P.F.E. v. Disney 8 1215. Plaintiff P.F.E. incorporates and re-alleges paragraphs 1 through 9 90, and 1178 through 1214 above. 10 1216. During one or more visits to the Parks, P.F.E. suffered an actual 11 meltdown. 12 1217. The symptoms and conditions associated with P.F.E.’s meltdown 13 constitute a physical injury under California and Florida law. 14 1218. P.F.E.’s meltdown in the Parks was proximately caused by 15 Disney’s outrageous, unlawful and reckless treatment of P.F.E. during his 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI patronage of Disney’s facilities. At all material times, Disney knew P.F.E. to be 17 vulnerable to emotional injury if treated in such a manner by anyone. 18 1219. P.F.E.’s meltdown and the treatment which proximately caused 19 P.F.E. to experienceDeadline.com the meltdown caused her grave and extreme mental 20 anguish and emotional trauma, for which Disney should be held accountable. 21 WHEREFORE, Plaintiff P.F.E., by and through B.P.E. as P.F.E.’s next 22 friend, parent and natural guardian, prays that this Court adjudicate this 23 dispute and enter an Order: 24 25

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1 • Finding that Disney intentionally inflicted emotional distress 2 upon P.F.E.; and 3 • Finding such infliction to have caused damages to P.F.E.; and 4 • Entering judgment for Plaintiff P.F.E. in the amount of such 5 damages; 6 • Entering judgment in favor of Plaintiffs and against Disney for 7 exemplary or punitive damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 98 13 Violation of the Unruh Civil Rights Act 14 California Civil Code §§51, 52 15 P.F.E. v. Disney 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 1220. Plaintiff P.F.E. incorporates and re-alleges paragraphs 1 through 17 91, and 1178 through 1214 above. 18 1221. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 19 provides protectionDeadline.com from discrimination by all business establishments in 20 California, including housing and public accommodations, because of age, 21 ancestry, color, disability, national origin, race, religion, sex and sexual 22 orientation. 23 24 25

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1 1222. Section 52 of the California Civil Code provides that whoever 2 denies aids or incites a denial, or makes any discrimination or distinction 3 contrary to Section 51 is liable for each and every offense. 4 1223. Pursuant to California Civil Code Section 51(f), a violation of the 5 ADA also constitutes a violation of California Civil Code Section 51, et seq. 6 1224. The Parks are “business establishments” within the meaning of 7 the California Code Section 51, et seq. 8 1225. Through the acts and omissions described in this Complaint, 9 Disney has violated California Civil Code Section 51 by denying P.F.E.’s access 10 to Disney’s programs, services and activities. Disney has instituted and

11 continues to utilize policies which deny or which aid or incite the denial of 12 P.F.E.’s full and equal enjoyment of Disney’s public accommodations in the 13 same manner as non-disabled persons. Disney refuses to modify its policies 14 and procedures to permit fair enjoyment of its facilities by P.F.E. As a direct 15 and proximate result of the afore-mentioned acts and omissions, P.F.E. has 16 suffered, and continues to suffer, hardship, humiliation and anxiety due to DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disney’s failure to provide reasonable accommodations and access as are 18 required by P.F.E.’s cognitive impairments. 19 1226. Due Deadline.comto the continuous nature of Disney’s ongoing discriminatory 20 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 21 result of Disney’s action, P.F.E. is suffering irreparable harm, and thus 22 expeditious relief is appropriate. 23 24 25

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1 WHEREFORE, Plaintiff P.F.E., by and through B.P.E. as his next friend, 2 parent and natural guardian, prays that this Court adjudicate this dispute 3 and enter an Order: 4 • Enjoining Defendant to cease the practices which are causing 5 discrimination against Plaintiff on account of P.F.E.’s disability; 6 and 7 • Enjoining Defendant to reasonably modify its policies, 8 practices, and procedures to afford Plaintiff with an 9 opportunity to experience Disney’s goods, services, facilities, 10 privileges, advantages, and accommodations; and

11 • Establishing Court-approved remedial measures that Disney 12 must implement, to prevent Disney from further discriminating 13 against Plaintiff when they visit the Disney Parks; and 14 • Establishing Court-approved requirements for information 15 dissemination about Disney’s remedial measures and modified 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI policies, to prevent Disney from further deterring Plaintiff from 17 visiting Disney Parks as a result of anticipated discrimination; 18 and 19 • EstablishingDeadline.com a monitoring program to ensure Disney’s 20 compliance with the Court’s Orders; and 21 • Determining the amount of P.F.E.’s actual damages; and 22 • Entering judgment in favor of Plaintiff and against Disney for 23 an amount up to three times the amounts of Plaintiff’s actual 24 damages, but in no event less than $4,000; and 25

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1 • 2 • Awarding reasonable attorney’s fees as may be determined by 3 the Court in favor of Plaintiff and against Disney; and 4 • Awarding reasonable litigation costs as may be determined by 5 the Court in favor of Plaintiff and against Disney; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 99 8 Negligent Infliction of Emotional Distress 9 B.P.E. v. Disney 10 1227. Plaintiff B.P.E. incorporates and re-alleges paragraphs 1 through

11 91, 1178 through 1214, 1216 through 1219, and 1221 through 1226 above. 12 1228. During one or more visits to the Parks, B.P.E.’s beloved daughter 13 P.F.E. suffered an actual meltdown while in B.P.E.’s presence. 14 1229. The symptoms and conditions associated with P.F.E.’s meltdown 15 constitute a physical injury to B.P.E. under California and Florida law. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 1230. P.F.E.’s meltdown in the Parks was proximately caused by 17 Disney’s negligent, unlawful, reckless and arbitrary treatment of P.F.E. during 18 her patronage of Disney’s facilities. At all material times, Disney knew P.F.E. 19 to be vulnerable Deadline.comto emotional injury if treated in such a manner by anyone. 20 1231. B.P.E. directly observed the stressors leading up to the meltdown, 21 P.F.E.’s resulting escalation and his meltdown. Particularly in light of his trust 22 and confidence that Disney would comply with applicable law and act in a 23 gracious and caring manner toward his daughter, B.P.E. could do nothing 24 reasonable to prevent the meltdown. 25

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1 1232. B.P.E.’s observation of P.F.E.’s meltdown and of the outrageous 2 conduct and treatment which proximately caused P.F.E. to experience the 3 meltdown caused P.F.E. grave and extreme mental anguish and emotional 4 trauma, for which Disney should be held accountable. 5 WHEREFORE, Plaintiff B.P.E. prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney negligently inflicted emotional distress 8 upon B.P.E.; and 9 • Finding such infliction to have caused damages to B.P.E.; and 10 • Entering judgment for Plaintiff B.P.E. in the amount of such 11 damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 100 17 Intentional Infliction of Emotional Distress 18 B.P.E. v. Disney 19 1233. PlaintiffDeadline.com B.P.E. incorporates and re-alleges paragraphs 1 through 20 91, 1178 through 1214, 1216 through 1219, and 1221 through 1226 above. 21 1234. During one or more visits to the Parks, B.P.E.’s beloved daughter 22 P.F.E. suffered an actual meltdown. 23 1235. The symptoms and conditions associated with P.F.E.’s meltdown 24 constitute a physical injury under California and Florida law. 25

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1 1236. P.F.E.’s meltdown in the Parks was proximately caused by 2 Disney’s outrageous, unlawful and reckless treatment of P.F.E. during his 3 patronage of Disney’s facilities. At all material times, Disney knew P.F.E. to be 4 vulnerable to emotional injury if treated in such a manner by anyone. 5 1237. B.P.E. directly observed the stressors leading up to the meltdown, 6 P.F.E.’s resulting escalation and his meltdown. Particularly in light of his trust 7 and confidence that Disney would comply with applicable law and act in a 8 gracious and caring manner toward his daughter, B.P.E. could do nothing 9 reasonable to prevent the meltdown. 10 1238. B.P.E.’s observation of P.F.E.’s meltdown and of the outrageous

11 conduct and treatment which proximately caused P.F.E. to experience the 12 meltdown caused B.P.E. grave and extreme mental anguish and emotional 13 trauma, for which Disney should be held accountable. 14 WHEREFORE, Plaintiff B.P.E. prays that this Court adjudicate this 15 dispute and enter an Order: 16 • Finding that Disney intentionally inflicted emotional distress DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 upon B.P.E.; and 18 • Finding such infliction to have caused damages to B.P.E.; and 19 • EnteringDeadline.com judgment for Plaintiff B.P.E. in the amount of such 20 damages; 21 • Entering judgment in favor of Plaintiffs and against Disney for 22 exemplary or punitive damages; and 23 • Awarding reasonable litigation costs as may be determined by 24 the Court in favor of Plaintiff and against Disney; and 25

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1 • Awarding prejudgment interest; and 2 • Such other relief as this Court may find just and equitable. 3 COUNT 101 4 Breach of Contract 5 B.P.E. v. Disney 6 1239. Plaintiff B.P.E. incorporates and re-alleges paragraphs 1 through 7 91, 1178 through 1214, 1216 through 1219, and 1221 through 1226 above. 8 1240. B.P.E. entered into a contract through which Disney promised to 9 provide a reasonable and enjoyable amusement park experience, and one 10 which complies with applicable law.

11 1241. Disney failed or refused to provide the promised experience, and 12 is in breach of contract. 13 1242. B.P.E. incurred expenses associated with the family’s wasted trips 14 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 15 WHEREFORE, Plaintiff B.P.E. prays that this Court adjudicate this 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI dispute and enter an Order: 17 • Finding that Disney breached its contract with B.P.E.; and 18 • Entering judgment for Plaintiff B.P.E. in the amount of his 19 economicDeadline.com monetary damages; and 20 • Awarding reasonable litigation costs as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 23 • Awarding prejudgment interest; and 24 • Such other relief as this Court may find just and equitable. 25

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1 COUNT 102 2 Negligent Infliction of Emotional Distress 3 Y.Z. v. Disney 4 1243. Plaintiff Y.Z. incorporates and re-alleges paragraphs 1 through 90 5 above. 6 1244. Y.Z. has autism. Y.Z.’s symptoms and stimming patterns include 7 screaming, kicking, and self-injurious behavior such as throwing himself on 8 the floor and hitting himself. Y.Z. also cannot tolerate when others – especially 9 strangers – touch or hold him. Doing so will likely lead to Y.Z. experiencing a 10 meltdown which can take Y.Z. hours to fully recover from.

11 1245. Autism substantially limits a person’s ability to care for himself or 12 herself, perform manual tasks, speak, learn, read, concentrate, think, 13 communicate, perceive the concept of time, pair sights and sounds that 14 happen simultaneously, and work. 15 1246. Y.Z. is and at all material times has been a disabled person within 16 the meaning of California Government Code §12926(j). DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1247. Y.Z. is five years of age, and is generally in the care of his mother, 18 M.Y.R., who brings this action as Y.Z.’s next friend, parent and natural 19 guardian. Deadline.com 20 1248. M.Y.R. and Y.Z. are residents of Alameda County, California. 21 1249. Y.Z.’s cognitive impairments manifest themselves in a certain way 22 during his visits to the parks; Y.Z. is incapable of deviating from consistency, 23 order, and routine. Y.Z. enters the park expecting to ride certain rides during 24 his visit to the Disney Parks. Rides which are Y.Z.’s favorites, Y.Z. fully expects 25

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1 to be able to ride multiple times, back to back. If Y.Z. is unable to ride those 2 rides, or is denied the opportunity to repeat ride his handful of favorite rides, 3 he is likely to experience a meltdown. M.Y.R. can prevent Y.Z.’s meltdown so 4 long as she can quickly divert his attention to another ride. 5 1250. Y.Z. is incapable of waiting significant periods of time to enter a 6 ride or attraction. If instructed to do so, the stimming patterns described 7 above will intensify toward meltdown. When Y.Z. experiences a meltdown, he 8 will first attempt to run away (elope) and leave the situation as fast as 9 possible. If he is unsuccessful and restrained, he will scream and kick before 10 throwing himself to the ground.

11 1251. Y.Z. is incapable of understanding the concept of visiting an 12 attraction in the present only to be told it cannot be experienced until 13 sometime in the future. As such, the new DAS creates avoidable stressors for 14 Y.Z., constantly escalating his stimming patterns toward meltdowns. Since 15 Disney’s implementation of the new DAS, Y.Z. has experienced multiple 16 meltdowns at the Disney Parks. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1252. Y.Z. is incapable of understanding the concept of time, of waiting 18 around with the expectation of some future gain in exchange for the waiting 19 around. His cognitiveDeadline.com impairments will cause him to experience stimming and 20 meltdowns when required to idly wait around, biding time, for any significant 21 period. M.Y.R. always brings entertainment and “distractions” for Y.Z., such as 22 lollipops, sunflower seeds, and games. Even still, triggers and anxiety will 23 cause Y.Z. to exhibit stimming and maladaptive behaviors including 24 attempting to elope, screaming, and kicking. 25

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1 1253. M.Y.R. first took Y.Z. to Disneyland in May 2013. During this visit, 2 Y.Z. carried the Guest Assistance Card, and was admirably accommodated. Y.Z. 3 exhibited a nature and extent of joy that he rarely showed in any other setting. 4 M.Y.R. and Y.Z. spent an entire day at Disneyland, riding rides, watching 5 fireworks, and later relaxing at the hotel. M.Y.R. was always proud and joyful 6 of the opportunity to bring to her beloved son a level of happiness which he 7 rarely shows elsewhere. With the GAC, Y.Z. was able to repeat rides his 8 favorite rides, and gain access to those rides through the alternate entrance, 9 reducing triggers and stimulus. Disney employees were friendly and outgoing. 10 Everyone was smiling and having a good time. It was a magical experience.

11 1254. M.Y.R. and Y.Z. had a markedly different Disney experience with 12 they returned to Disneyland in November 2013, after Disney had already 13 unveiled the DAS. 14 1255. M.Y.R. heard of the changes to the GAC before arriving the 15 Disneyland, but did not expect the experience to be as miserable and 16 unaccommodating as it actually was. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1256. The first hurdle M.Y.R. had to overcome was learning how the DAS 18 worked. The Disney employee’s brief tutorial at Guest Services was 19 insufficient and inadequate.Deadline.com M.Y.R. entered Disneyland confused and unsure of 20 how to use the DAS. 21 1257. M.Y.R. and Y.Z. approached the first kiosk they could find, and 22 obtained a DAS return time for Finding Nemo Submarine Voyage. According to 23 the DAS return time received, the wait was over an hour. M.Y.R. scrambled to 24 try to obtain a second DAS return time for another ride in order to keep Y.Z. 25

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1 occupied while they waited for the first DAS return time to elapse. 2 Unfortunately, M.Y.R. eventually learned this was not possible with the DAS. 3 1258. In the meantime, other members of her family without the DAS 4 embarked to ride Dumbo the Flying Elephant. They were able to wait in the 5 standby line, ride the ride, and come back to M.Y.R. and Y.Z. only to find them 6 still waiting to ride Finding Nemo Submarine Voyage. 7 1259. Frustrated and confused, M.Y.R. gave up on trying to use the DAS 8 during their first day in Disneyland. Luckily, Disneyland was not crowded on 9 this particular day, and wait times for most of the rides were short and 10 bearable for Y.Z. M.Y.R. and Y.Z. survived their first day at Disneyland only

11 after they gave up on the DAS. 12 1260. During the second day at Disneyland, M.Y.R. and Y.Z. encountered 13 much larger crowds and with the larger crowds, much longer waits. Unable to 14 withstand the regular wait times, M.Y.R. resorted to trying to use the DAS 15 again. What resulted was anything but an accommodating and enjoyable 16 experience. Instead, M.Y.R. and Y.Z. spent the day walking from kiosk to ride, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 and back to the kiosk again leaving M.Y.R. and Y.Z. exhausted. DAS return 18 times were extensive, preventing Y.Z. from riding many of the rides he wanted 19 to ride. This in conjunctionDeadline.com with the empty promise of arriving at the kiosk 20 only to receive a DAS return time for a ride not to be ridden until sometimes 21 hours later, led to a miserable and unfulfilling experience. 22 1261. The combination of disappointment and exhaustion was too much 23 for Y.Z. to tolerate. Y.Z. suffered multiple meltdowns during the second day in 24 Disneyland. The worse taking place at Splash Mountain. After waiting the 25

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1 prescribed amount of time, M.Y.R. approached the entrance with Y.Z. The 2 Disney employee, without warning, reached out to grab Y.Z. and in order to 3 measure his height. Y.Z. immediately began screaming and jumped back when 4 the Disney employee touched him, and a terrible meltdown ensued. 5 1262. The new DAS procedure triggered Y.Z.’s meltdowns in November 6 2013. 7 1263. Due to its failure to Disney’s refusal to accommodate the special 8 needs of persons like Y.Z., which leads to an increased propensity for Y.Z. to 9 experience meltdowns, Disney prevents Y.Z. from experiencing the full 10 enjoyment of its Parks, equal to the experiences of persons without a

11 disability. 12 1264. After October 9, 2013, Y.Z., no longer received the type of 13 accommodation and attention Y.Z. and M.Y.R. had received when they visited 14 the Parks in the past. 15 1265. As a result of Disney’s refusal to modify its procedures to 16 reasonably accommodate Y.Z.’s needs, Y.Z. and M.Y.R. have been discouraged DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 and deterred from the full use and enjoyment of the Parks' rides and 18 attractions. If Disney had not abandoned its past policy of accommodating the 19 special needs of Deadline.compersons with cognitive impairments, M.Y.R. would continue to 20 frequently visit the Parks with Y.Z. as a guest. But the family’s interest in 21 attending the Parks is substantially reduced. M.Y.R. knows they should avoid 22 attending the Parks in the future because doing so will only lead to the same 23 un-magical experience and un-accommodating discrimination 24 25

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1 1266. Notwithstanding Disney’s highly sophisticated knowledge of the 2 needs of persons with cognitive impairments, and notwithstanding Disney’s 3 historic ability to accommodate Y.Z.’s special needs, Disney personnel began 4 in October of 2013 to offer blanket accommodations, and implemented a 5 policy of systematically refusing to conduct individualized assessments of the 6 needs of Y.Z. and persons like him. Since October of 2013, Disney has 7 repeatedly and continuously refused to modify its policies for accommodating 8 disabled persons, choosing instead to robotically follow the DAS. Disney fails 9 and refuses to modify the DAS to allow Y.Z. to enjoy the same benefits and 10 privileges as non-disabled patrons.

11 1267. Disney personnel have shown no willingness or desire to improve 12 the experience for guests like Y.Z. 13 1268. M.Y.R. incurred expenses associated with the family’s wasted trips 14 to the Parks. 15 1269. During one or more visits to the Parks, Y.Z. suffered an actual 16 meltdown. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1270. The symptoms and conditions associated with Y.Z.’s meltdown 18 constitute a physical injury under California law. 19 1271. Y.Z.’sDeadline.com meltdown in the Parks was proximately caused by Disney’s 20 negligent, unlawful, reckless and arbitrary treatment of Y.Z. during his 21 patronage of Disney’s facilities. At all material times, Disney knew Y.Z. to be 22 vulnerable to emotional injury if treated in such a manner by anyone. 23 24 25

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1 1272. Y.Z.’s meltdown and the treatment which proximately caused Y.Z. 2 to experience the meltdown caused him grave and extreme mental anguish 3 and emotional trauma, for which Disney should be held accountable. 4 WHEREFORE, Plaintiff Y.Z., by and through M.Y.R. as Y.Z.’s next 5 friend, parent and natural guardian, prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney negligently inflicted emotional distress 8 upon Y.Z.; and 9 • Finding such infliction to have caused damages to Y.Z.; and 10 • Entering judgment for Plaintiff Y.Z. in the amount of such 11 damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 103 17 Intentional Infliction of Emotional Distress 18 Y.Z. v. Disney 19 1273. PlaintiffDeadline.com Y.Z. incorporates and re-alleges paragraphs 1 through 90, 20 and 1244 through 1272 above. 21 1274. During one or more visits to the Parks, Y.Z. suffered an actual 22 meltdown. 23 1275. The symptoms and conditions associated with Y.Z.’s meltdown 24 constitute a physical injury under California law. 25

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1 1276. Y.Z.’s meltdown in the Parks was proximately caused by Disney’s 2 outrageous, unlawful and reckless treatment of Y.Z. during his patronage of 3 Disney’s facilities. At all material times, Disney knew Y.Z. to be vulnerable to 4 emotional injury if treated in such a manner by anyone. 5 1277. Y.Z.’s meltdown and the treatment which proximately caused Y.Z. 6 to experience the meltdown caused him grave and extreme mental anguish 7 and emotional trauma, for which Disney should be held accountable. 8 WHEREFORE, Plaintiff Y.Z., by and through M.Y.R. as Y.Z.’s next 9 friend, parent and natural guardian, prays that this Court adjudicate this 10 dispute and enter an Order:

11 • Finding that Disney intentionally inflicted emotional distress 12 upon Y.Z.; and 13 • Finding such infliction to have caused damages to Y.Z.; and 14 • Entering judgment for Plaintiff Y.Z. in the amount of such 15 damages; 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment in favor of Plaintiffs and against Disney for 17 exemplary or punitive damages; and 18 • Awarding reasonable litigation costs as may be determined by 19 the CourtDeadline.com in favor of Plaintiff and against Disney; and 20 • Awarding prejudgment interest; and 21 • Such other relief as this Court may find just and equitable. 22

23 24 25

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1 COUNT 104 2 Violation of the Unruh Civil Rights Act 3 California Civil Code §§51, 52 4 Y.Z. v. Disney 5 1278. Plaintiff Y.Z. incorporates and re-alleges paragraphs 1 through 91, 6 and 1244 through 1272 above. 7 1279. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 8 provides protection from discrimination by all business establishments in 9 California, including housing and public accommodations, because of age, 10 ancestry, color, disability, national origin, race, religion, sex and sexual

11 orientation. 12 1280. Section 52 of the California Civil Code provides that whoever 13 denies aids or incites a denial, or makes any discrimination or distinction 14 contrary to Section 51 is liable for each and every offense. 15 1281. Pursuant to California Civil Code Section 51(f), a violation of the 16 ADA also constitutes a violation of California Civil Code Section 51, et seq. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1282. The Parks are “business establishments” within the meaning of 18 the California Code Section 51, et seq. 19 1283. ThroughDeadline.com the acts and omissions described in this Complaint, 20 Disney has violated California Civil Code Section 51 by denying Y.Z. access to 21 Disney’s programs, services and activities. Disney has instituted and 22 continues to utilize policies which deny or which aid or incite the denial of 23 Y.Z.’s full and equal enjoyment of Disney’s public accommodations in the same 24 manner as non-disabled persons. Disney refuses to modify its policies and 25

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1 procedures to permit fair enjoyment of its facilities by Y.Z. As a direct and 2 proximate result of the afore-mentioned acts and omissions, Y.Z. has suffered, 3 and continues to suffer, hardship, humiliation and anxiety due to Disney’s 4 failure to provide reasonable accommodations and access as are required by 5 Y.Z.’s cognitive impairments. 6 1284. Due to the continuous nature of Disney’s ongoing discriminatory 7 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 8 result of Disney’s action, Y.Z. is suffering irreparable harm, and thus 9 expeditious relief is appropriate. 10 WHEREFORE, Plaintiff Y.Z., by and through M.Y.R. as his next friend,

11 parent and natural guardian, prays that this Court adjudicate this dispute 12 and enter an Order: 13 • Enjoining Defendant to cease the practices which are causing 14 discrimination against Plaintiff on account of Y.Z.’s disability; 15 and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Enjoining Defendant to reasonably modify its policies, 17 practices, and procedures to afford Plaintiff with an 18 opportunity to experience Disney’s goods, services, facilities, 19 privileges,Deadline.com advantages, and accommodations; and 20 • Establishing Court-approved remedial measures that Disney 21 must implement, to prevent Disney from further discriminating 22 against Plaintiff when they visit the Disney Parks; and 23 • Establishing Court-approved requirements for information 24 dissemination about Disney’s remedial measures and modified 25

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1 policies, to prevent Disney from further deterring Plaintiff from 2 visiting Disney Parks as a result of anticipated discrimination; 3 and 4 • Establishing a monitoring program to ensure Disney’s 5 compliance with the Court’s Orders; and 6 • Determining the amount of Y.Z.’s actual damages; and 7 • Entering judgment in favor of Plaintiff and against Disney for 8 an amount up to three times the amounts of Plaintiff’s actual 9 damages, but in no event less than $4,000; and 10 • Awarding reasonable attorney’s fees as may be determined by

11 the Court in favor of Plaintiff and against Disney; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Such other relief as this Court may find just and equitable. 15 COUNT 105 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI Negligent Infliction of Emotional Distress 17 M.Y.R. v. Disney 18 1285. Plaintiff M.Y.R. incorporates and re-alleges paragraphs 1 through 19 90, 1244 throughDeadline.com 1272, 1274 through 1277, and 1279 through 1284 above. 20 1286. During one or more visits to the Parks, M.Y.R.’s beloved son Y.Z. 21 suffered an actual meltdown while in M.Y.R.’s presence. 22 1287. The symptoms and conditions associated with Y.Z.’s meltdown 23 constitute a physical injury to M.Y.R. under California law. 24 25

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1 1288. Y.Z.’s meltdown in the Parks was proximately caused by Disney’s 2 negligent, unlawful, reckless and arbitrary treatment of Y.Z. during his 3 patronage of Disney’s facilities. At all material times, Disney knew Y.Z. to be 4 vulnerable to emotional injury if treated in such a manner by anyone. 5 1289. M.Y.R. directly observed the stressors leading up to the meltdown, 6 Y.Z.’s resulting escalation and his meltdown. Particularly in light of her trust 7 and confidence that Disney would comply with applicable law and act in a 8 gracious and caring manner toward her son, M.Y.R. could do nothing 9 reasonable to prevent the meltdown. 10 1290. M.Y.R.’s observation of Y.Z.’s meltdown and of the outrageous

11 conduct and treatment which proximately caused Y.Z. to experience the 12 meltdown caused Y.Z. grave and extreme mental anguish and emotional 13 trauma, for which Disney should be held accountable. 14 WHEREFORE, Plaintiff M.Y.R. prays that this Court adjudicate this 15 dispute and enter an Order: 16 • Finding that Disney negligently inflicted emotional distress DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 upon M.Y.R.; and 18 • Finding such infliction to have caused damages to M.Y.R.; and 19 • EnteringDeadline.com judgment for Plaintiff M.Y.R. in the amount of such 20 damages; and 21 • Awarding reasonable litigation costs as may be determined by 22 the Court in favor of Plaintiff and against Disney; and 23 • Awarding prejudgment interest; and 24 • Such other relief as this Court may find just and equitable. 25

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1 COUNT 106 2 Intentional Infliction of Emotional Distress 3 M.Y.R. v. Disney 4 1291. Plaintiff M.Y.R. incorporates and re-alleges paragraphs 1 through 5 90, 1244 through 1272, 1274 through 1277, and 1279 through 1284 above. 6 1292. During one or more visits to the Parks, M.Y.R.’s beloved son Y.Z. 7 suffered an actual meltdown. 8 1293. The symptoms and conditions associated with Y.Z.’s meltdown 9 constitute a physical injury under California law. 10 1294. Y.Z.’s meltdown in the Parks was proximately caused by Disney’s

11 outrageous, unlawful and reckless treatment of Y.Z. during his patronage of 12 Disney’s facilities. At all material times, Disney knew Y.Z. to be vulnerable to 13 emotional injury if treated in such a manner by anyone. 14 1295. M.Y.R. directly observed the stressors leading up to the meltdown, 15 Y.Z.’s resulting escalation and his meltdown. Particularly in light of her trust 16 and confidence that Disney would comply with applicable law and act in a DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 gracious and caring manner toward her son, M.Y.R. could do nothing 18 reasonable to prevent the meltdown. 19 1296. M.Y.R.’sDeadline.com observation of Y.Z.’s meltdown and of the outrageous 20 conduct and treatment which proximately caused Y.Z. to experience the 21 meltdown caused M.Y.R. grave and extreme mental anguish and emotional 22 trauma, for which Disney should be held accountable. 23 WHEREFORE, Plaintiff M.Y.R. prays that this Court adjudicate this 24 dispute and enter an Order: 25

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1 • Finding that Disney intentionally inflicted emotional distress 2 upon M.Y.R.; and 3 • Finding such infliction to have caused damages to M.Y.R.; and 4 • Entering judgment for Plaintiff M.Y.R. in the amount of such 5 damages; 6 • Entering judgment in favor of Plaintiffs and against Disney for 7 exemplary or punitive damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 107 13 Breach of Contract 14 M.Y.R. v. Disney 15 1297. Plaintiff M.Y.R. incorporates and re-alleges paragraphs 1 through 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 90, 1244 through 1272, 1274 through 1277, and 1279 through 1284 above. 17 1298. M.Y.R. entered into a contract through which Disney promised to 18 provide a reasonable and enjoyable amusement park experience, and one 19 which complies withDeadline.com applicable law. 20 1299. Disney failed or refused to provide the promised experience, and 21 is in breach of contract. 22 1300. M.Y.R. incurred expenses associated with the family’s wasted trips 23 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 24 25

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1 WHEREFORE, Plaintiff M.Y.R. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney breached its contract with M.Y.R.; and 4 • Entering judgment for Plaintiff M.Y.R. in the amount of her 5 economic monetary damages; and 6 • Awarding reasonable litigation costs as may be determined by 7 the Court in favor of Plaintiff and against Disney; and 8 • Awarding prejudgment interest; and 9 • Such other relief as this Court may find just and equitable. 10 COUNT 108

11 Negligent Infliction of Emotional Distress 12 K.A.R. v. Disney 13 1301. Plaintiff K.A.R. incorporates and re-alleges paragraphs 1 through 14 90 above. 15 1302. K.A.R. has autism and epilepsy. K.A.R.’s symptoms and stimming 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI patterns include echolalia – automatic repetition of vocalizations made by 17 another person – hand gestures in front of her eyes, facial gestures, twitches, 18 and random, unpredictable seizures. K.A.R. is incapable of communicating 19 independent thoughtsDeadline.com and feelings; K.A.R. can only repeat what is said to her 20 or specific, pre-programmed phrases, such as “Fine, thank you,” or “Happy.” 21 1303. Autism substantially limits a person’s ability to care for himself or 22 herself, perform manual tasks, speak, learn, read, concentrate, think, 23 communicate, perceive the concept of time, pair sights and sounds that 24 happen simultaneously, and work. 25

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1 1304. K.A.R. is and at all material times has been a disabled person 2 within the meaning of California Government Code §12926(j). 3 1305. K.A.R. is 18 years of age, and is generally in the care of her mother, 4 C.M.R., and her father, D.R., who brings this action as K.A.R.’s next friend, 5 parent and court-appointed co-guardian. 6 1306. D.R. and K.A.R. are residents of Cook County, Illinois. 7 1307. K.A.R.’s cognitive impairments manifest themselves in a certain 8 way during her visits to the parks; K.A.R. is a “repeat rider.” This is a 9 propensity common among autistic persons – a variety of the need for 10 consistency, order and routine. K.A.R. will experience a particular ride or

11 attraction, such as Space Mountain and Big Thunder Mountain Railroad, over 12 and over, for several hours at a time. Disney personnel are very familiar with 13 the repeat rider type of guest. 14 1308. K.A.R. is similarly incapable of deviating from consistency, order, 15 and routine. K.A.R. enters the park needing to first visit Mickey’s Toontown to 16 meet with Chip n’ Dale and Donald Duck, two of K.A.R.’s favorite Disney DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Character Experiences. K.A.R.’s Disney experience is character driven; any 18 attempt to visit the Disney Parks without experiencing characters such as 19 Donald Duck andDeadline.com Chip n’ Dale will likely lead to a meltdown. 20 1309. K.A.R. is incapable of waiting significant periods of time to enter a 21 ride, attraction, or Character Experience. If instructed to do so, the stimming 22 patterns described above will intensify toward meltdown. When K.A.R. 23 experiences a meltdown, she will bite herself, scream, and jump up and down 24 25

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1 in the same spot. Worse, when K.A.R. experiences a meltdown, she her 2 propensity to have seizures increases significantly. 3 1310. K.A.R. is incapable of understanding the concept of visiting an 4 attraction in the present only to be told it cannot be experienced until 5 sometime in the future. As such, the new DAS creates avoidable stressors for 6 K.A.R., constantly escalating his stimming patterns toward meltdowns. Since 7 Disney’s implementation of the new DAS, K.A.R. has experienced meltdowns at 8 the Disney Parks. 9 1311. K.A.R. is incapable of idly standing around without her cognitive 10 impairments causing her to experience stimming and meltdowns when

11 required to wait in a line for any significant period. Triggers and anxiety will 12 cause K.A.R. to exhibit stimming and maladaptive behaviors including 13 screaming and biting herself. 14 1312. D.R. took K.A.R. to Walt Disney World for the first time when she 15 was only six months old. In 2007, D.R. and K.A.R. took their first trip to 16 Disneyland in California. Then, in 2008, during a second trip to Walt Disney DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 World, K.A.R. carried the Guest Assistance Card for the first time, and was 18 admirably accommodated. During this visit, K.A.R. exhibited a nature and 19 extent of joy thatDeadline.com she rarely shows in any other setting. D.R. and K.A.R. made 20 trip to the Disney Parks an annual tradition, returning at least once a year 21 every year since 2008. The GAC was conducive towards K.A.R.’s condition 22 because it allowed D.R. and K.A.R. to experience more of the Disney Parks in a 23 shorter period of time. D.R. was always proud and joyful of the opportunity to 24 bring to his beloved daughter a level of happiness which she rarely showed 25

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1 elsewhere. Disney employees were always friendly and outgoing. Everyone 2 was smiling and having a good time. It was a magical experience. 3 1313. This drastically changed on August 16, 2014 when D.R. and K.A.R. 4 attended the Disney Parks for the first time after Disney unveiled the DAS. 5 1314. Before visiting Walt Disney World on August 16, 2014, D.R. 6 already saw changes in the way Disney treated K.A.R. and other guests with 7 disabilities. During a trip to Disneyland on May 20, 2013, D.R. was provided no 8 accommodation for K.A.R. despite specifically requesting one. Not even the 9 GAC was offered. 10 1315. On August 16, 2014, D.R. and K.A.R. returned to the Disney Parks,

11 this time to Walt Disney World. D.R. and K.A.R. immediately encountered a 25- 12 minute wait at Guest Services. K.A.R. grew agitated as she was forced to wait 13 in line with her father before even entering Walt Disney World. 14 1316. Upon arriving to the front of Guest Services, the Disney employee 15 explained to D.R. that the GAC was no longer available and had been replaced 16 by the DAS. In order to use the DAS, the Disney employee explained, you had DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 to approach the Disney employee working the attraction. The Disney 18 employee then offered the following explanation for using the DAS: If the line 19 is longer than oneDeadline.com hour, the Disney employee will mark your card and you can 20 return at a later time. If it is less than a certain time – for example, an hour - 21 then the Disney employee might just let you in. Ultimately, it is up to the 22 Disney employee’s discretion at the time you approach. 23 24 25

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1 1317. D.R. asked the Disney employee why Disney changed its system 2 and why the DAS replaced the GAC. The Disney employee simply replied that 3 “Disney had stopped that old system.” 4 1318. D.R. and K.A.R. then visited Tunetown, as was K.A.R.’s routine. D.R. 5 and K.A.R. encountered 35 minute consectutive waits to meet Goofy and then 6 Donald Duck. Because it was still early, K.A.R. maintained her demeanor for 7 the first part of their visit. However, that demeanor would quickly fade as the 8 rest of D.R. and K.A.R.’s day ensued. 9 1319. D.R. and K.A.R. went to The Many Adventures of Winnie the Pooh 10 next, only to receive a DAS return time well in excess of one hour. D.R. knew

11 his daughter could not endure another long wait after having already endured 12 three, back-to-back thirty minute lines beforehand. Unfortunately for K.A.R., it 13 was too late. Once D.R. and K.A.R. turned away from The Many Adventures of 14 Winnie the Pooh, K.A.R. experienced a horrible meltdown. D.R. tried to 15 assuage his daughter by telling her, “We will come back,” to no avail. 16 1320. Once K.A.R. recovered from her meltdown, D.R. and K.A.R. decided

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 to visit another attraction, hoping for better luck and a shorter wait. D.R. and 18 K.A.R. arrived at Peter Pan’s Flight, only to be told that they could not access 19 the ride becauseDeadline.com D.R. and K.A.R. were already signed up for The Many 20 Adventures of Winnie the Pooh. D.R. had no choice but to leave yet another 21 ride with K.A.R. Like bad déjà vu, K.A.R. experienced yet another meltdown 22 once D.R. and K.A.R. turned away to leave Peter Pan’s Flight. Once again, D.R. 23 tried to console his daughter by telling her “We will come back.” Even still, 24 K.A.R. continued to cry and scream. She could not understand why she was 25

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1 being taken to the front of the rides, only to be turned away and told she could 2 not ride the ride until a later time. For K.A.R., being told “We will come back” 3 had the same affect as being told “we will never ride Peter Pan’s Flight again.” 4 1321. It would be the second of five meltdowns experienced by K.A.R. in 5 Walt Disney World that day. D.R. and K.A.R. left Walt Disney World in silent 6 shock, disillusioned and disappointed by their unaccommodating and entirely 7 un-magical visit. 8 1322. K.A.R. and D.R. have not returned to the Disney Parks since their 9 unaccommodating and un-magical visit. Due to Disney’s reliance on the DAS, 10 the annual tradition D.R. was proud to uphold since their first visit to the

11 Disney Parks in 2007 was finally broken. 12 1323. The new DAS procedure triggered K.A.R.’s meltdowns on August 13 16, 2014. 14 1324. Due to its failure to Disney’s refusal to accommodate the special 15 needs of persons like K.A.R., which leads to an increased propensity for K.A.R. 16 to experience meltdowns, Disney prevents K.A.R. from experiencing the full DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 enjoyment of its Parks, equal to the experiences of persons without a 18 disability. 19 1325. AfterDeadline.com October 9, 2013, K.A.R., no longer received the type of 20 accommodation and attention K.A.R. and D.R. had received when they visited 21 the Parks in the past. 22 1326. As a result of Disney’s refusal to modify its procedures to 23 reasonably accommodate K.A.R.’s needs, K.A.R. and D.R. have been 24 discouraged and deterred from the full use and enjoyment of the Parks' rides 25

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1 and attractions. If Disney had not abandoned its past policy of 2 accommodating the special needs of persons with cognitive impairments, D.R. 3 would continue to frequently visit the Parks with K.A.R. as a guest. But the 4 family’s interest in attending the Parks is substantially reduced. D.R. knows 5 they should avoid attending the Parks in the future because doing so will only 6 lead to the same un-magical experience and un-accommodating 7 discrimination 8 1327. Notwithstanding Disney’s highly sophisticated knowledge of the 9 needs of persons with cognitive impairments, and notwithstanding Disney’s 10 historic ability to accommodate K.A.R.’s special needs, Disney personnel began

11 in October of 2013 to offer blanket accommodations, and implemented a 12 policy of systematically refusing to conduct individualized assessments of the 13 needs of K.A.R. and persons like him. Since October of 2013, Disney has 14 repeatedly and continuously refused to modify its policies for accommodating 15 disabled persons, choosing instead to robotically follow the DAS. Disney fails 16 and refuses to modify the DAS to allow K.A.R. to enjoy the same benefits and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 privileges as non-disabled patrons. 18 1328. Disney personnel have shown no willingness or desire to improve 19 the experience forDeadline.com guests like K.A.R. 20 1329. D.R. incurred expenses associated with the family’s wasted trips 21 to the Parks. 22 1330. During one or more visits to the Parks, K.A.R. suffered an actual 23 meltdown. 24 25

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1 1331. The symptoms and conditions associated with K.A.R.’s meltdown 2 constitute a physical injury under California and Florida law. 3 1332. K.A.R.’s meltdown in the Parks was proximately caused by 4 Disney’s negligent, unlawful, reckless and arbitrary treatment of K.A.R. during 5 his patronage of Disney’s facilities. At all material times, Disney knew K.A.R. 6 to be vulnerable to emotional injury if treated in such a manner by anyone. 7 1333. K.A.R.’s meltdown and the treatment which proximately caused 8 K.A.R. to experience the meltdown caused him grave and extreme mental 9 anguish and emotional trauma, for which Disney should be held accountable. 10 WHEREFORE, Plaintiff K.A.R., by and through D.R. as K.A.R.’s next

11 friend, parent and court-appointed guardian, prays that this Court 12 adjudicate this dispute and enter an Order: 13 • Finding that Disney negligently inflicted emotional distress 14 upon K.A.R.; and 15 • Finding such infliction to have caused damages to K.A.R.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment for Plaintiff K.A.R. in the amount of such 17 damages; and 18 • Awarding reasonable litigation costs as may be determined by 19 the CourtDeadline.com in favor of Plaintiff and against Disney; and 20 • Awarding prejudgment interest; and 21 • Such other relief as this Court may find just and equitable. 22

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1 COUNT 109 2 Intentional Infliction of Emotional Distress 3 K.A.R. v. Disney 4 1334. Plaintiff K.A.R. incorporates and re-alleges paragraphs 1 through 5 90, and 1302 through 1333 above. 6 1335. During one or more visits to the Parks, K.A.R. suffered an actual 7 meltdown. 8 1336. The symptoms and conditions associated with K.A.R.’s meltdown 9 constitute a physical injury under California and Florida law. 10 1337. K.A.R.’s meltdown in the Parks was proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of K.A.R. during her 12 patronage of Disney’s facilities. At all material times, Disney knew K.A.R. to be 13 vulnerable to emotional injury if treated in such a manner by anyone. 14 1338. K.A.R.’s meltdown and the treatment which proximately caused 15 K.A.R. to experience the meltdown caused her grave and extreme mental 16 anguish and emotional trauma, for which Disney should be held accountable. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 WHEREFORE, Plaintiff K.A.R., by and through D.R. as K.A.R.’s next 18 friend, parent and court-appointed guardian, prays that this Court 19 adjudicate this disputeDeadline.com and enter an Order: 20 • Finding that Disney intentionally inflicted emotional distress 21 upon K.A.R.; and 22 • Finding such infliction to have caused damages to K.A.R.; and 23 • Entering judgment for Plaintiff K.A.R. in the amount of such 24 damages; 25

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1 • Entering judgment in favor of Plaintiffs and against Disney for 2 exemplary or punitive damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 110 8 Violation of the Unruh Civil Rights Act 9 California Civil Code §§51, 52 10 K.A.R. v. Disney

11 1339. Plaintiff K.A.R. incorporates and re-alleges paragraphs 1 through 12 91, and 1302 through 1333 above. 13 1340. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 14 provides protection from discrimination by all business establishments in 15 California, including housing and public accommodations, because of age, 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI ancestry, color, disability, national origin, race, religion, sex and sexual 17 orientation. 18 1341. Section 52 of the California Civil Code provides that whoever 19 denies aids or incitesDeadline.com a denial, or makes any discrimination or distinction 20 contrary to Section 51 is liable for each and every offense. 21 1342. Pursuant to California Civil Code Section 51(f), a violation of the 22 ADA also constitutes a violation of California Civil Code Section 51, et seq. 23 1343. The Parks are “business establishments” within the meaning of 24 the California Code Section 51, et seq. 25

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1 1344. Through the acts and omissions described in this Complaint, 2 Disney has violated California Civil Code Section 51 by denying K.A.R. K.A.R.’s 3 access to Disney’s programs, services and activities. Disney has instituted and 4 continues to utilize policies which deny or which aid or incite the denial of 5 K.A.R.’s full and equal enjoyment of Disney’s public accommodations in the 6 same manner as non-disabled persons. Disney refuses to modify its policies 7 and procedures to permit fair enjoyment of its facilities by K.A.R.. As a direct 8 and proximate result of the afore-mentioned acts and omissions, K.A.R. has 9 suffered, and continues to suffer, hardship, humiliation and anxiety due to 10 Disney’s failure to provide reasonable accommodations and access as are

11 required by K.A.R.’s cognitive impairments. 12 1345. Due to the continuous nature of Disney’s ongoing discriminatory 13 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 14 result of Disney’s action, K.A.R. is suffering irreparable harm, and thus 15 expeditious relief is appropriate. 16 WHEREFORE, Plaintiff K.A.R., by and through D.R. as his next friend, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 parent and court-appointed guardian, prays that this Court adjudicate this 18 dispute and enter an Order: 19 • EnjoiningDeadline.com Defendant to cease the practices which are causing 20 discrimination against Plaintiff on account of K.A.R.’s disability; 21 and 22 • Enjoining Defendant to reasonably modify its policies, 23 practices, and procedures to afford Plaintiff with an 24 25

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1 opportunity to experience Disney’s goods, services, facilities, 2 privileges, advantages, and accommodations; and 3 • Establishing Court-approved remedial measures that Disney 4 must implement, to prevent Disney from further discriminating 5 against Plaintiff when they visit the Disney Parks; and 6 • Establishing Court-approved requirements for information 7 dissemination about Disney’s remedial measures and modified 8 policies, to prevent Disney from further deterring Plaintiff from 9 visiting Disney Parks as a result of anticipated discrimination; 10 and

11 • Establishing a monitoring program to ensure Disney’s 12 compliance with the Court’s Orders; and 13 • Determining the amount of K.A.R.’s actual damages; and 14 • Entering judgment in favor of Plaintiff and against Disney for 15 an amount up to three times the amounts of Plaintiff’s actual 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI damages, but in no event less than $4,000; and 17 • Awarding reasonable attorney’s fees as may be determined by 18 the Court in favor of Plaintiff and against Disney; and 19 • AwardingDeadline.com reasonable litigation costs as may be determined by 20 the Court in favor of Plaintiff and against Disney; and 21 • Such other relief as this Court may find just and equitable. 22

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1 COUNT 111 2 Negligent Infliction of Emotional Distress 3 D.R. v. Disney 4 1346. Plaintiff D.R. incorporates and re-alleges paragraphs 1 through 90, 5 1302 through 1333, 1335 through 1338, and 1340 through 1345 above. 6 1347. During one or more visits to the Parks, D.R.’s beloved son K.A.R. 7 suffered an actual meltdown while in D.R.’s presence. 8 1348. The symptoms and conditions associated with K.A.R.’s meltdown 9 constitute a physical injury to D.R. under California and Florida law. 10 1349. K.A.R.’s meltdown in the Parks was proximately caused by

11 Disney’s negligent, unlawful, reckless and arbitrary treatment of K.A.R. during 12 her patronage of Disney’s facilities. At all material times, Disney knew K.A.R. 13 to be vulnerable to emotional injury if treated in such a manner by anyone. 14 1350. D.R. directly observed the stressors leading up to the meltdown, 15 K.A.R.’s resulting escalation and her meltdown. Particularly in light of his 16 trust and confidence that Disney would comply with applicable law and act in DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 a gracious and caring manner toward his daughter, D.R. could do nothing 18 reasonable to prevent the meltdown. 19 1351. D.R.’sDeadline.com observation of K.A.R.’s meltdown and of the outrageous 20 conduct and treatment which proximately caused K.A.R. to experience the 21 meltdown caused K.A.R. grave and extreme mental anguish and emotional 22 trauma, for which Disney should be held accountable. 23 WHEREFORE, Plaintiff D.R. prays that this Court adjudicate this 24 dispute and enter an Order: 25

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1 • Finding that Disney negligently inflicted emotional distress 2 upon D.R.; and 3 • Finding such infliction to have caused damages to D.R.; and 4 • Entering judgment for Plaintiff D.R. in the amount of such 5 damages; and 6 • Awarding reasonable litigation costs as may be determined by 7 the Court in favor of Plaintiff and against Disney; and 8 • Awarding prejudgment interest; and 9 • Such other relief as this Court may find just and equitable. 10 COUNT 112

11 Intentional Infliction of Emotional Distress 12 D.R. v. Disney 13 1352. Plaintiff D.R. incorporates and re-alleges paragraphs 1 through 90, 14 1302 through 1333, 1335 through 1338, and 1340 through 1345 above. 15 1353. During one or more visits to the Parks, D.R.’s beloved daughter 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI K.A.R. suffered an actual meltdown. 17 1354. The symptoms and conditions associated with K.A.R.’s meltdown 18 constitute a physical injury under California and Florida law. 19 1355. K.A.R.’sDeadline.com meltdown in the Parks was proximately caused by 20 Disney’s outrageous, unlawful and reckless treatment of K.A.R. during her 21 patronage of Disney’s facilities. At all material times, Disney knew K.A.R. to be 22 vulnerable to emotional injury if treated in such a manner by anyone. 23 1356. D.R. directly observed the stressors leading up to the meltdown, 24 K.A.R.’s resulting escalation and his meltdown. Particularly in light of his trust 25

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1 and confidence that Disney would comply with applicable law and act in a 2 gracious and caring manner toward her son, D.R. could do nothing reasonable 3 to prevent the meltdown. 4 1357. D.R.’s observation of K.A.R.’s meltdown and of the outrageous 5 conduct and treatment which proximately caused K.A.R. to experience the 6 meltdown caused D.R. grave and extreme mental anguish and emotional 7 trauma, for which Disney should be held accountable. 8 WHEREFORE, Plaintiff D.R. prays that this Court adjudicate this 9 dispute and enter an Order: 10 • Finding that Disney intentionally inflicted emotional distress

11 upon D.R.; and 12 • Finding such infliction to have caused damages to D.R.; and 13 • Entering judgment for Plaintiff D.R. in the amount of such 14 damages; 15 • Entering judgment in favor of Plaintiffs and against Disney for 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI exemplary or punitive damages; and 17 • Awarding reasonable litigation costs as may be determined by 18 the Court in favor of Plaintiff and against Disney; and 19 • AwardingDeadline.com prejudgment interest; and 20 • Such other relief as this Court may find just and equitable. 21

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1 COUNT 113 2 Breach of Contract 3 D.R. v. Disney 4 1358. Plaintiff D.R. incorporates and re-alleges paragraphs 1 through 90, 5 1302 through 1333, 1335 through 1338, and 1340 through 1345 above. 6 1359. D.R. entered into a contract through which Disney promised to 7 provide a reasonable and enjoyable amusement park experience, and one 8 which complies with applicable law. 9 1360. Disney failed or refused to provide the promised experience, and 10 is in breach of contract.

11 1361. D.R. incurred expenses associated with the family’s wasted trips 12 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 13 WHEREFORE, Plaintiff D.R. prays that this Court adjudicate this 14 dispute and enter an Order: 15 • Finding that Disney breached its contract with D.R.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment for Plaintiff D.R. in the amount of her 17 economic monetary damages; and 18 • Awarding reasonable litigation costs as may be determined by 19 the CDeadline.comourt in favor of Plaintiff and against Disney; and 20 • Awarding prejudgment interest; and 21 • Such other relief as this Court may find just and equitable. 22

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1 COUNT 114 2 Negligent Infliction of Emotional Distress 3 C.M.H. v. Disney 4 1362. Plaintiff C.M.H. incorporates and re-alleges paragraphs 1 through 5 90 above. 6 1363. C.M.H. has autism. C.M.H.’s symptoms and stimming patterns 7 include yelling loudly, screaming out phrases to his father and sister such as 8 “shut up!” and “I’m not talking to you!”, flapping his arms, and throwing his 9 elbows out to the side while gesticulating his arms. C.M.H. also cannot tolerate 10 idly waiting for events to develop, as this will cause him to become angry,

11 frustrated and verbally abusive towards his caretakers, uttering such phrases 12 as “Can we just go now!” or “No! I am going on now!” 13 1364. Autism substantially limits a person’s ability to care for himself or 14 herself, perform manual tasks, speak, learn, read, concentrate, think, 15 communicate, perceive the concept of time, pair sights and sounds that 16 happen simultaneously, and work. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1365. C.M.H. is and at all material times has been a disabled person 18 within the meaning of California Government Code §12926(j). 19 1366. C.M.H.Deadline.com is 24 years of age, and is generally in the care of his father, 20 A.M.H., and his mother, H.A.H., who brings this action as C.M.H.’s next friend, 21 parent and natural guardian. 22 1367. H.A.H. and C.M.H. are residents of Washington County, Oregon. 23 1368. C.M.H.’s cognitive impairments manifest themselves in a certain 24 way during his visits to the Parks; C.M.H. is incapable of deviating from 25

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1 consistency, order, and routine. C.M.H. enters the park with a specific plan of 2 rides in mind. H.A.H. will ask C.M.H. which ride he wants to ride first. Almost 3 always, the answer will be Big Thunder Mountain Railroad. After Big Thunder 4 Mountain Railroad, C.M.H. will except the routine to move to Space Mountain, 5 followed by Star Tours-The Adventure Continues, Buzz Lightyear Astro 6 Blasters, and Jungle Cruise, before visiting California Adventure. At California 7 Adventure, C.M.H. will ask to ride California Screamin’, Toy Story Midway 8 Mania! Soarin’ Over California, and Radiator Springs Racers – in that order. 9 Any deviation from that order will cause C.M.H. to become anxious, frustrated, 10 and scream out phrases such as: “No Pirates of the Carribean! California

11 Screamin’! Now!” Insistence on deviation from his routine or plan will likely 12 lead to C.M.H. experiencing a meltdown. 13 1369. C.M.H. is incapable of waiting significant periods of time to enter a 14 ride or attraction. If instructed to do so, the stimming patterns described 15 above will intensify toward meltdown. 16 1370. C.M.H. is incapable of understanding the concept of visiting an

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 attraction in the present only to be told it cannot be experienced until 18 sometime in the future. As such, the new DAS creates avoidable stressors for 19 C.M.H., constantlyDeadline.com escalating his stimming patterns toward meltdowns. Since 20 Disney’s implementation of the new DAS, C.M.H. has experienced many 21 meltdowns at the Disney Parks. 22 1371. C.M.H. is also incapable of idly standing around for any significant 23 period without his cognitive impairments causing him to experience stimming 24 25

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1 and meltdowns. Triggers and anxiety will cause C.M.H. to exhibit stimming 2 and maladaptive behaviors including screaming loudly and crying. 3 1372. H.A.H. has been taking C.M.H. to the Disney Parks since C.M.H. was 4 twelve-years-old. H.A.H. has regularly returned with C.M.H. to Disneyland at 5 least once every year since C.M.H.’s first visit. Before October 9, 2013, C.M.H. 6 always carried the Guest Assistance Card, and was admirably accommodated. 7 During those visits, C.M.H. exhibited a nature and extent of joy that he rarely 8 showed in any other setting. Not only did the GAC reduce C.M.H.’s wait time, 9 but it allowed him access to the rides through the alternative entrances, thus 10 reducing his interactions with crowds and other stimuli. C.M.H. became

11 accustomed to entering the rides through the alternate entrances and adopted 12 it as part of his routine. 13 1373. Typically, H.A.H. and C.M.H. would start their day at Disneyland by 14 riding Big Thunder Mountain Railroad. The remainder of their day at 15 Disneyland would be spent riding the rides C.M.H. wanted to ride with 16 occasional visits to various gift shops throughout Disneyland and return trips DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 to the hotel for rest and relaxation before returning to Disneyland to visit 18 more attractions. H.A.H. was always proud and joyful of the opportunity to 19 bring to her belovedDeadline.com son a level of happiness which he rarely shows 20 elsewhere. Disney employees were always friendly and outgoing. Everyone 21 was smiling and having a good time. It was a magical experience. 22 1374. This drastically changed on December 1, 2013 when H.A.H. and 23 C.M.H. attended the Disney Parks for the first time after Disney unveiled the 24 DAS. 25

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1 1375. H.A.H. and C.M.H. immediately encountered a long line at Guest 2 Services upon first arriving at City Hall in Disneyland. Chaos ensued nearby as 3 the father of another child started yelling at a Cast Member at Guest Services. 4 Over the neighboring uproar, the Disney employee speaking with H.A.H. 5 inquired about C.M.H.’s disability and what would happen if C.M.H. were 6 required to wait in a crowd of people, and if C.M.H. was able to climb stairs 7 and enter and exit rides on his own. Meanwhile, C.M.H. grew visibly upset at 8 having to wait with H.A.H. in line, and began shouting at H.A.H. and 9 demanding “Can we just go now!” At the peak of frustration, C.M.H. shouted 10 “I’m out of here!” and started to leave City Hall before H.A.H. instructed him to

11 not leave. 12 1376. After surviving the long wait at Guest Services, with DAS in hand, 13 H.A.H. and C.M.H. embarked on their day in Disneyland. Despite the 14 unaccommodating start, H.A.H. remained optimistic. C.M.H. and H.A.H. went to 15 the first kiosk they could find and obtained a DAS return time for Space 16 Mountain – and so the day of confusion and frustration began. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1377. After leaving Space Mountain, H.A.H. searched for the nearest 18 kiosk. Despite her best efforts, H.A.H. was unable to locate a kiosk and obtain a 19 return time for Deadline.comthe next ride C.M.H. wanted to ride. H.A.H. decided to take a 20 risk, break from C.M.H.’s routine, and try her luck at California Adventure, 21 hoping the search for kiosks would be more fruitful there. Although H.A.H. 22 was not made aware of the fact while at City Hall that she was allowed to 23 obtain DAS return times for the opposite park, H.A.H.’s understanding was 24 that DAS return times were specific to the Disney Park she was in at the time. 25

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1 DAS return times for rides in Disneyland could only be obtained at kiosks 2 located in Disneyland, and DAS return times for rides in California Adventure 3 could only be obtained at kiosks located in California Adventure. 4 1378. Shortly after entering California Adventure, H.A.H. found a kiosk 5 and immediately obtained a DAS return time for California Screamin’. To her 6 disappointment, the wait exceeded her wildest expectations. Knowing she 7 would be unable to keep C.M.H. occupied for that long without riding a ride, 8 C.M.H. took H.A.H. to Toy Story Midway Mania! to attempt to survive the 9 regular wait in time to visit California Screamin’ afterwards. 10 1379. This plan quickly backfired. While attempting to enter Toy Story

11 Midway Mania!, C.M.H. suffered a terrible and debilitating meltdown while 12 trying to enter through the alternate entrance – as he had done every time in 13 the past with the GAC. C.M.H. was immediately turned away and told he must 14 wait in the standby line and access the attraction through the standby 15 entrance. C.M.H. began yelling at H.A.H. and demanding to enter the ride, 16 screaming out “Yes! This way! No that way! I want to go here!” H.A.H. lured DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 C.M.H. away from the ride, as H.A.H. screamed “Why, Mom, why!” H.M.H. 18 waited with C.M.H. as he slowly recovered from his meltdown. 19 1380. OnceDeadline.com C.M.H. recovered completely from his meltdown, H.A.H. and 20 C.M.H. passed the remaining time by touring gift shops before finally riding 21 California Screamin’ at the prescribed DAS return time. 22 1381. H.A.H. left California Adventure utterly disappointed and 23 disillusioned by their Disney experience. H.A.H. would return the next day to 24 Disneyland with C.M.H., but the day would be short-lived. Not long after 25

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1 entering Disneyland on the second day of their vacation, C.M.H. demanded to 2 go back to the hotel. At the hotel, H.A.H. was saddened as her family revealed 3 to her that their vacation was ruined. C.M.H.’s father and sister tried to 4 persuade C.M.H. to return to the Disney Parks. In response, C.M.H. yelled 5 phrases such as “Shut up!” or “I’m not talking to you!” or “Stay out of this, I’m 6 talking to mom!” or “You’re not helping!” H.A.H. tried to breathe new life into 7 her family, but C.M.H. refused to leave their hotel room. H.A.H.’s family, 8 exhausted and disillusioned by their miserable experience at Disneyland as a 9 result of the DAS, each admitted they wanted nothing more than to go home 10 and leave this memory far behind.

11 1382. After every visit to the Disney Parks in the past, H.A.H. and her 12 family left the Disney Parks with excitement and anticipation towards 13 returning, discussing when they would be able to come back. This time, H.A.H. 14 and her family were so relieved for their vacation to finally be over that talks 15 about ever returning were nonexistent. 16 1383. The new DAS procedure triggered C.M.H.’s meltdowns during his

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 visit to Disneyland in December 2013. 18 1384. Due to Disney’s failure and refusal to accommodate the special 19 needs of personsDeadline.com like C.M.H., which leads to an increased propensity for C.M.H. 20 to experience meltdowns, Disney prevents C.M.H. from experiencing the full 21 enjoyment of its Parks, equal to the experiences of persons without a 22 disability. 23 24 25

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1 1385. After October 9, 2013, C.M.H., no longer received the type of 2 accommodation and attention C.M.H. and H.A.H. had received when they 3 visited the Parks in the past. 4 1386. As a result of Disney’s refusal to modify its procedures to 5 reasonably accommodate C.M.H.’s needs, C.M.H. and H.A.H. have been 6 discouraged and deterred from the full use and enjoyment of the Parks' rides 7 and attractions. If Disney had not abandoned its past policy of 8 accommodating the special needs of persons with cognitive impairments, 9 H.A.H. would continue to frequently visit the Parks with C.M.H. as a guest. But 10 the family’s interest in attending the Parks is substantially reduced. H.A.H.

11 knows they should avoid attending the Parks in the future because doing so 12 will only lead to the same un-magical experience and un-accommodating 13 discrimination. 14 1387. Notwithstanding Disney’s highly sophisticated knowledge of the 15 needs of persons with cognitive impairments, and notwithstanding Disney’s 16 historic ability to accommodate C.M.H.’s special needs, Disney personnel DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 began in October of 2013 to offer blanket accommodations, and implemented 18 a policy of systematically refusing to conduct individualized assessments of 19 the needs of C.M.H.Deadline.com and persons like him. Since October of 2013, Disney has 20 repeatedly and continuously refused to modify its policies for accommodating 21 disabled persons, choosing instead to robotically follow the DAS. Disney fails 22 and refuses to modify the DAS to allow C.M.H. to enjoy the same benefits and 23 privileges as non-disabled patrons. 24 25

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1 1388. Disney personnel have shown no willingness or desire to improve 2 the experience for guests like C.M.H. 3 1389. H.A.H. incurred expenses associated with the family’s wasted trips 4 to the Parks. 5 1390. During one or more visits to the Parks, C.M.H. suffered an actual 6 meltdown. 7 1391. The symptoms and conditions associated with C.M.H.’s meltdown 8 constitute a physical injury under California law. 9 1392. C.M.H.’s meltdown in the Parks was proximately caused by 10 Disney’s negligent, unlawful, reckless and arbitrary treatment of C.M.H. during

11 his patronage of Disney’s facilities. At all material times, Disney knew C.M.H. 12 to be vulnerable to emotional injury if treated in such a manner by anyone. 13 1393. C.M.H.’s meltdown and the treatment which proximately caused 14 C.M.H. to experience the meltdown caused him grave and extreme mental 15 anguish and emotional trauma, for which Disney should be held accountable. 16 WHEREFORE, Plaintiff C.M.H., by and through H.A.H. as C.M.H.’s next DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 friend, parent and natural guardian, prays that this Court adjudicate this 18 dispute and enter an Order: 19 • FindingDeadline.com that Disney negligently inflicted emotional distress 20 upon C.M.H.; and 21 • Finding such infliction to have caused damages to C.M.H.; and 22 • Entering judgment for Plaintiff C.M.H. in the amount of such 23 damages; and 24 25

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1 • Awarding reasonable litigation costs as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding prejudgment interest; and 4 • Such other relief as this Court may find just and equitable. 5 COUNT 115 6 Intentional Infliction of Emotional Distress 7 C.M.H. v. Disney 8 1394. Plaintiff C.M.H. incorporates and re-alleges paragraphs 1 through 9 90, and 1363 through 1393 above. 10 1395. During one or more visits to the Parks, C.M.H. suffered an actual 11 meltdown. 12 1396. The symptoms and conditions associated with C.M.H.’s meltdown 13 constitute a physical injury under California law. 14 1397. C.M.H.’s meltdown in the Parks was proximately caused by 15 Disney’s outrageous, unlawful and reckless treatment of C.M.H. during his 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI patronage of Disney’s facilities. At all material times, Disney knew C.M.H. to be 17 vulnerable to emotional injury if treated in such a manner by anyone. 18 1398. C.M.H.’s meltdown and the treatment which proximately caused 19 C.M.H. to experienceDeadline.com the meltdown caused him grave and extreme mental 20 anguish and emotional trauma, for which Disney should be held accountable. 21 WHEREFORE, Plaintiff C.M.H., by and through H.A.H. as C.M.H.’s next 22 friend, parent and natural guardian, prays that this Court adjudicate this 23 dispute and enter an Order: 24 25

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1 • Finding that Disney intentionally inflicted emotional distress 2 upon C.M.H.; and 3 • Finding such infliction to have caused damages to C.M.H.; and 4 • Entering judgment for Plaintiff C.M.H. in the amount of such 5 damages; 6 • Entering judgment in favor of Plaintiffs and against Disney for 7 exemplary or punitive damages; and 8 • Awarding reasonable litigation costs as may be determined by 9 the Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 116 13 Violation of the Unruh Civil Rights Act 14 California Civil Code §§51, 52 15 C.M.H. v. Disney 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 1399. Plaintiff C.M.H. incorporates and re-alleges paragraphs 1 through 17 91, and 1363 through 1393 above. 18 1400. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 19 provides protectionDeadline.com from discrimination by all business establishments in 20 California, including housing and public accommodations, because of age, 21 ancestry, color, disability, national origin, race, religion, sex and sexual 22 orientation. 23 24 25

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1 1401. Section 52 of the California Civil Code provides that whoever 2 denies aids or incites a denial, or makes any discrimination or distinction 3 contrary to Section 51 is liable for each and every offense. 4 1402. Pursuant to California Civil Code Section 51(f), a violation of the 5 ADA also constitutes a violation of California Civil Code Section 51, et seq. 6 1403. The Parks are “business establishments” within the meaning of 7 the California Code Section 51, et seq. 8 1404. Through the acts and omissions described in this Complaint, 9 Disney has violated California Civil Code Section 51 by denying C.M.H. access 10 to Disney’s programs, services and activities. Disney has instituted and

11 continues to utilize policies which deny or which aid or incite the denial of 12 C.M.H.’s full and equal enjoyment of Disney’s public accommodations in the 13 same manner as non-disabled persons. Disney refuses to modify its policies 14 and procedures to permit fair enjoyment of its facilities by C.M.H.. As a direct 15 and proximate result of the afore-mentioned acts and omissions, C.M.H. has 16 suffered, and continues to suffer, hardship, humiliation and anxiety due to DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Disney’s failure to provide reasonable accommodations and access as are 18 required by C.M.H.’s cognitive impairments. 19 1405. Due Deadline.comto the continuous nature of Disney’s ongoing discriminatory 20 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 21 result of Disney’s action, C.M.H. is suffering irreparable harm, and thus 22 expeditious relief is proper. 23 24 25

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1 WHEREFORE, Plaintiff C.M.H., by and through H.A.H. as his next 2 friend, parent and natural guardian, prays that this Court adjudicate this 3 dispute and enter an Order: 4 • Enjoining Defendant to cease the practices which are causing 5 discrimination against Plaintiff on account of C.M.H.’s 6 disability; and 7 • Enjoining Defendant to reasonably modify its policies, 8 practices, and procedures to afford Plaintiff with an 9 opportunity to experience Disney’s goods, services, facilities, 10 privileges, advantages, and accommodations; and

11 • Establishing Court-approved remedial measures that Disney 12 must implement, to prevent Disney from further discriminating 13 against Plaintiff when they visit the Disney Parks; and 14 • Establishing Court-approved requirements for information 15 dissemination about Disney’s remedial measures and modified 16 policies, to prevent Disney from further deterring Plaintiff from DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 visiting Disney Parks as a result of anticipated discrimination; 18 and 19 • EstablishingDeadline.com a monitoring program to ensure Disney’s 20 compliance with the Court’s Orders; and 21 • Determining the amount of C.M.H.’s actual damages; and 22 • Entering judgment in favor of Plaintiff and against Disney for 23 an amount up to three times the amounts of Plaintiff’s actual 24 damages, but in no event less than $4,000; and 25

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1 • Awarding reasonable attorney’s fees as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Such other relief as this Court may find just and equitable. 6 COUNT 117 7 Negligent Infliction of Emotional Distress 8 H.A.H. v. Disney 9 1406. Plaintiff H.A.H. incorporates and re-alleges paragraphs 1 through 10 90, 1363 through 1393, 1395 through 1398, and 1400 through 1405 above.

11 1407. During one or more visits to the Parks, H.A.H.’s beloved son C.M.H. 12 suffered an actual meltdown while in H.A.H.’s presence. 13 1408. The symptoms and conditions associated with C.M.H.’s meltdown 14 constitute a physical injury to H.A.H. under California law. 15 1409. C.M.H.’s meltdown in the Parks was proximately caused by 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI Disney’s negligent, unlawful, reckless and arbitrary treatment of C.M.H. during 17 his patronage of Disney’s facilities. At all material times, Disney knew C.M.H. 18 to be vulnerable to emotional injury if treated in such a manner by anyone. 19 1410. H.A.H.Deadline.com directly observed the stressors leading up to the meltdown, 20 C.M.H.’s resulting escalation and his meltdown. Particularly in light of her 21 trust and confidence that Disney would comply with applicable law and act in 22 a gracious and caring manner toward her son, H.A.H. could do nothing 23 reasonable to prevent the meltdown. 24 25

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1 1411. H.A.H.’s observation of C.M.H.’s meltdown and of the outrageous 2 conduct and treatment which proximately caused C.M.H. to experience the 3 meltdown caused C.M.H. grave and extreme mental anguish and emotional 4 trauma, for which Disney should be held accountable. 5 WHEREFORE, Plaintiff H.A.H. prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney negligently inflicted emotional distress 8 upon H.A.H.; and 9 • Finding such infliction to have caused damages to H.A.H.; and 10 • Entering judgment for Plaintiff H.A.H. in the amount of such 11 damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 118 17 Intentional Infliction of Emotional Distress 18 H.A.H. v. Disney 19 1412. PlaintiffDeadline.com H.A.H. incorporates and re-alleges paragraphs 1 through 20 90, 1363 through 1393, 1395 through 1398, and 1400 through 1405 above. 21 1413. During one or more visits to the Parks, H.A.H.’s beloved son C.M.H. 22 suffered an actual meltdown. 23 1414. The symptoms and conditions associated with C.M.H.’s meltdown 24 constitute a physical injury under California law. 25

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1 1415. C.M.H.’s meltdown in the Parks was proximately caused by 2 Disney’s outrageous, unlawful and reckless treatment of C.M.H. during his 3 patronage of Disney’s facilities. At all material times, Disney knew C.M.H. to be 4 vulnerable to emotional injury if treated in such a manner by anyone. 5 1416. H.A.H. directly observed the stressors leading up to the meltdown, 6 C.M.H.’s resulting escalation and his meltdown. Particularly in light of her 7 trust and confidence that Disney would comply with applicable law and act in 8 a gracious and caring manner toward her son, H.A.H. could do nothing 9 reasonable to prevent the meltdown. 10 1417. H.A.H.’s observation of C.M.H.’s meltdown and of the outrageous

11 conduct and treatment which proximately caused C.M.H. to experience the 12 meltdown caused H.A.H. grave and extreme mental anguish and emotional 13 trauma, for which Disney should be held accountable. 14 WHEREFORE, Plaintiff H.A.H. prays that this Court adjudicate this 15 dispute and enter an Order: 16 • Finding that Disney intentionally inflicted emotional distress DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 upon H.A.H.; and 18 • Finding such infliction to have caused damages to H.A.H.; and 19 • EnteringDeadline.com judgment for Plaintiff H.A.H. in the amount of such 20 damages; 21 • Entering judgment in favor of Plaintiffs and against Disney for 22 exemplary or punitive damages; and 23 • Awarding reasonable litigation costs as may be determined by 24 the Court in favor of Plaintiff and against Disney; and 25

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1 • Awarding prejudgment interest; and 2 • Such other relief as this Court may find just and equitable. 3 COUNT 119 4 Breach of Contract 5 H.A.H. v. Disney 6 1418. Plaintiff H.A.H. incorporates and re-alleges paragraphs 1 through 7 90, 1363 through 1393, 1395 through 1398, and 1400 through 1405 above. 8 1419. H.A.H. entered into a contract through which Disney promised to 9 provide a reasonable and enjoyable amusement park experience, and one 10 which complies with applicable law.

11 1420. Disney failed or refused to provide the promised experience, and 12 is in breach of contract. 13 1421. H.A.H. incurred expenses associated with the family’s wasted trips 14 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 15 WHEREFORE, Plaintiff H.A.H. prays that this Court adjudicate this 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI dispute and enter an Order: 17 • Finding that Disney breached its contract with H.A.H.; and 18 • Entering judgment for Plaintiff H.A.H. in the amount of her 19 economicDeadline.com monetary damages; and 20 • Awarding reasonable litigation costs as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 • Awarding prejudgment interest; and 23 • Such other relief as this Court may find just and equitable. 24

25

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1 COUNT 120 2 Negligent Infliction of Emotional Distress 3 A.S.T. v. Disney 4 1422. Plaintiff A.S.T. incorporates and re-alleges paragraphs 1 through 5 90 above. 6 1423. A.S.T. has autism and is largely non-verbal. A.S.T.’s symptoms and 7 stimming patterns include doing activities repeatedly. When A.S.T. attempts to 8 speak, the words often come out garbled and nonsensical. A.S.T. becomes 9 frustrated at his inability to communicate and will grab the person he is 10 intending to communicate with by the hand and attempt to show him what he

11 is trying to communicate. 12 1424. Autism substantially limits a person’s ability to care for himself or 13 herself, perform manual tasks, speak, learn, read, concentrate, think, 14 communicate, perceive the concept of time, pair sights and sounds that 15 happen simultaneously, and work. 16 1425. A.S.T. is and at all material times has been a disabled person

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 within the meaning of California Government Code §12926(j). 18 1426. A.S.T. is 14 years of age, and is generally in the care of his mother, 19 S.A.B. and his father,Deadline.com S.D.T., who brings this action as A.S.T.’s next friend, 20 parent and natural guardian. 21 1427. S.D.T. and A.S.T. are residents of San Diego County, California. 22 1428. A.S.T.’s cognitive impairments manifest themselves in a certain 23 way during his visits to the parks; A.S.T. is incapable of deviating from 24 consistency, order, and routine. A.S.T. must experience the park with his 25

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1 sister, S.M.T., in the following order: City Hall; Main Street; First Shop on Main 2 Street; Magic Shop on Main Street; Sleeping Beauty Castle Walkthrough; Star 3 Tours – The Adventures Continue; “it’s a small world”; Pinocchio’s Daring 4 Journey; Mr. Toad’s Wild Ride; Snow White’s Scary Adventures; Adventure 5 Park; Pirates of the Caribbean; Haunted Mansion; Jungle Cruise; and a meal at 6 Bengal Barbeque before going back down Main Street and taking the Tram to 7 the car and leaving. Any deviation from this routine will cause instant 8 confusion and A.S.T. to repeat “No! We have to go here first!” If a break from 9 the routine is insisted upon, a meltdown will likely ensue. 10 1429. A.S.T. is incapable of waiting significant periods of time to enter a

11 ride or attraction. If instructed to do so, the stimming patterns described 12 above will intensify toward meltdown. When A.S.T. experiences a meltdown, 13 he will begin banging his head against his parents’ arms before eventually 14 dropping to the ground. Once on the ground, he will scream and cry until his 15 voice grows hoarse. It can take A.S.T. an entire day to recover from a 16 meltdown. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1430. A.S.T. is incapable of understanding the concept of time, and thus 18 cannot comprehend visiting an attraction in the present only to be told it 19 cannot be experiencedDeadline.com until sometime in the future. As such, the new DAS 20 creates avoidable stressors for A.S.T., constantly escalating his stimming 21 patterns toward meltdowns. Since Disney’s implementation of the new DAS, 22 A.S.T. has experienced many meltdowns at the Disney Parks. 23 1431. A.S.T.’s inability to comprehend the concept of time also leaves 24 him unable to wait idly around for significant periods of time without his 25

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1 cognitive impairments causing him to experience stimming and meltdowns. 2 Triggers and anxiety will cause A.S.T. to exhibit stimming and maladaptive 3 behaviors including head banging, screaming, and crying. 4 1432. S.D.T. and S.A.B. took A.S.T. and S.M.T. to the Disney Parks for the 5 first time in 2006. During the first trip to Disneyland in 2006, S.D.T., A.S.T., and 6 S.M.T. had a miserable experience because they were unaware that the Guest 7 Assistance Card existed. A Disney employee noticed S.D.T., A.S.T., and S.M.T. 8 having a difficult time, and told them next time they came to the Disney Parks 9 to bring a doctor’s note and request an accommodation; the GAC (“GAC”). 10 S.D.T., A.S.T., and S.M.T. returned to the Disney Parks again in 2006 and

11 requested the GAC. S.D.T. immediately noticed the difference in their Disney 12 experience – it was like night and day. A.S.T. and S.M.T. were both admirably 13 accommodated and exhibited a nature and extent of joy that they rarely 14 showed in any other setting. A.S.T. and S.M.T. were able to ride the rides they 15 needed to ride together, in the order they needed to ride them in. S.D.T. was 16 always proud and joyful of the opportunity to bring to his beloved son a level DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 of happiness which he rarely shows elsewhere. Disney employees were 18 always friendly and outgoing. Everyone was smiling and having a good time. It 19 was such a magicalDeadline.com experience that in 2006, S.D.T. purchased annual passes, 20 and returned to the Disney Parks with A.S.T. and S.M.T. on a regular basis. 21 1433. This drastically changed in May 2014 when S.D.T. and A.S.T. 22 attended the Disney Parks with S.D.T. and S.A.B. for the first time after Disney 23 unveiled the DAS. 24 25

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1 1434. S.D.T. could sense something was not right the minute he saw City 2 Hall. S.D.T. spent 25 minutes waiting to speak with a Disney employee in the 3 blistering heat; meanwhile, paramedics were on site regularly transporting 4 guests out of the Disney Parks who were suffering from heat strokes. After 5 speaking with the Disney employee at Guest Services, S.D.T. received a DAS, 6 pamphlets with kiosk locations, and a return time for Star Tours – The 7 Adventures Continue. 8 1435. The day that followed was nothing like past days at Disneyland. 9 S.D.T., A.S.T., and S.M.T. spent the day walking from kiosk, to ride, and back to 10 the kiosk to start the process all over again.

11 1436. Because the shortest DAS return time was one hour and thirty 12 minutes, S.D.T., A.S.T., and S.M.T. were only able to ride four rides in 13 Disneyland and three rides California Adventure. 14 1437. A.S.T. and S.M.T. quickly became dehydrated from the constant 15 walking back and forth between kiosks and rides, forcing them to leave 16 Disneyland much sooner than they would otherwise have. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1438. S.D.T. left Disneyland that day feeling disillusioned and 18 dissatisfied by their Disney experience, wholly unlike trips to the Disney Parks 19 in the past. A.S.T.Deadline.com and S.M.T., exhausted, tired, and defeated, were far from the 20 joyous children S.D.T. remembered from the past when leaving the Disney 21 Parks after a day of accommodation with the GAC. Memories of the first time 22 at Disneyland – when they received no accommodation at all – were fresh on 23 S.D.T.’s mind as he contemplated the DAS and lack of Disney magic which 24 followed suit. 25

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1 1439. S.D.T. and S.A.B. returned to Disneyland with A.S.T. and S.M.T. in 2 December 2014, hoping this time the holiday spirit would help bring about a 3 different Disney experience. Instead, A.S.T. and S.M.T. had a similarly 4 miserable and unaccommodating time in the Disney Parks. 5 1440. S.D.T., A.S.T., and S.M.T. immediately encountered long lines, and 6 even longer DAS return times. S.D.T. knew the only way to survive this trip 7 would be to abandon A.S.T. and S.M.T.’s usual routine and try to ride only 8 those rides with short DAS return times. 9 1441. A.S.B. and S.M.T. were able to ride Pinocchio’s Daring Journey, 10 Peter Pan’s Flight, and Casey Jr. Circus Train – the three rides S.D.T. could find

11 with the shortest return times. A.S.T. and S.M.T. grew more and more agitated 12 as the day progressed as this was outside of their usual routine. Finally, A.S.T. 13 and S.M.T. demanded to ride a ride in their usual routine – their favorite ride 14 in the Disney Parks – “it’s a small world.” 15 1442. S.D.T., A.S.T, and S.M.T. made their way to “it’s a small world” to 16 obtain a DAS return time. However, the return time was too long for A.S.T. and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 S.M.T. to bear. They immediately suffered a meltdown upon being told they 18 would not be riding “it’s a small world.” 19 1443. S.D.T.Deadline.com and A.S.B. spent the remainder of the day with A.S.T. and 20 S.M.T. as far away from the rides as possible, choosing instead to walk around 21 the Disney Parks looking at the holiday decorations and shopping. 22 1444. Once again, S.D.T. and A.S.B. left Disneyland feeling disillusioned 23 and disappointed. It was the time of the year when the family was supposed to 24 25

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1 feel the most magic, but instead Disney provided a wholly un-magical and 2 unaccommodating experience. 3 1445. The new DAS procedure triggered A.S.T.’s meltdowns in May and 4 December 2014. 5 1446. Due to Disney’s failure and refusal to accommodate the special 6 needs of persons like A.S.T., which leads to an increased propensity for A.S.T. 7 to experience meltdowns, Disney prevents A.S.T. from experiencing the full 8 enjoyment of its Parks, equal to the experiences of persons without a 9 disability. 10 1447. After October 9, 2013, A.S.T., no longer received the type of

11 accommodation and attention A.S.T. had received when they visited the Parks 12 in the past. 13 1448. As a result of Disney’s refusal to modify its procedures to 14 reasonably accommodate A.S.T.’s needs, A.S.T. and S.D.T. have been 15 discouraged and deterred from the full use and enjoyment of the Parks' rides 16 and attractions. If Disney had not abandoned its past policy of DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 accommodating the special needs of persons with cognitive impairments, 18 S.D.T. would continue to frequently visit the Parks with A.S.T. as a guest. But 19 the family’s interestDeadline.com in attending the Parks is substantially reduced. A.S.T. 20 knows they should avoid attending the Parks in the future because doing so 21 will only lead to the same un-magical experience and un-accommodating 22 discrimination. 23 1449. Notwithstanding Disney’s highly sophisticated knowledge of the 24 needs of persons with cognitive impairments, and notwithstanding Disney’s 25

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1 historic ability to accommodate A.S.T.’s special needs, Disney personnel began 2 in October of 2013 to offer blanket accommodations, and implemented a 3 policy of systematically refusing to conduct individualized assessments of the 4 needs of A.S.T. and persons like him. Since October of 2013, Disney has 5 repeatedly and continuously refused to modify its policies for accommodating 6 disabled persons, choosing instead to robotically follow the DAS. Disney fails 7 and refuses to modify the DAS to allow A.S.T. to enjoy the same benefits and 8 privileges as non-disabled patrons. 9 1450. Disney personnel have shown no willingness or desire to improve 10 the experience for guests like A.S.T.

11 1451. S.D.T. incurred expenses associated with the family’s wasted trips 12 to the Parks. 13 1452. During one or more visits to the Parks, A.S.T. suffered an actual 14 meltdown. 15 1453. The symptoms and conditions associated with A.S.T.’s meltdown 16 constitute a physical injury under California law. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1454. A.S.T.’s meltdown in the Parks was proximately caused by 18 Disney’s negligent, unlawful, reckless and arbitrary treatment of A.S.T. during 19 his patronage of Deadline.comDisney’s facilities. At all material times, Disney knew A.S.T. to 20 be vulnerable to emotional injury if treated in such a manner by anyone. 21 1455. A.S.T.’s meltdown and the treatment which proximately caused 22 A.S.T. to experience the meltdown caused him grave and extreme mental 23 anguish and emotional trauma, for which Disney should be held accountable. 24 25

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1 WHEREFORE, Plaintiff A.S.T., by and through S.D.T. as A.S.T.’s next 2 friend, parent and natural guardian, prays that this Court adjudicate this 3 dispute and enter an Order: 4 • Finding that Disney negligently inflicted emotional distress 5 upon A.S.T.; and 6 • Finding such infliction to have caused damages to A.S.T.; and 7 • Entering judgment for Plaintiff A.S.T. in the amount of such 8 damages; and 9 • Awarding reasonable litigation costs as may be determined by 10 the Court in favor of Plaintiff and against Disney; and

11 • Awarding prejudgment interest; and 12 • Such other relief as this Court may find just and equitable. 13 COUNT 121 14 Intentional Infliction of Emotional Distress 15 A.S.T. v. Disney 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 1456. Plaintiff A.S.T. incorporates and re-alleges paragraphs 1 through 17 90, and 1423 through 1455 above. 18 1457. During one or more visits to the Parks, A.S.T. suffered an actual 19 meltdown. Deadline.com 20 1458. The symptoms and conditions associated with A.S.T.’s meltdown 21 constitute a physical injury under California law. 22 1459. A.S.T.’s meltdown in the Parks was proximately caused by 23 Disney’s outrageous, unlawful and reckless treatment of A.S.T. during his 24 25

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1 patronage of Disney’s facilities. At all material times, Disney knew A.S.T. to be 2 vulnerable to emotional injury if treated in such a manner by anyone. 3 1460. A.S.T.’s meltdown and the treatment which proximately caused 4 A.S.T. to experience the meltdown caused him grave and extreme mental 5 anguish and emotional trauma, for which Disney should be held accountable. 6 WHEREFORE, Plaintiff A.S.T., by and through S.D.T. as A.S.T.’s next 7 friend, parent and natural guardian, prays that this Court adjudicate this 8 dispute and enter an Order: 9 • Finding that Disney intentionally inflicted emotional distress 10 upon A.S.T.; and

11 • Finding such infliction to have caused damages to A.S.T.; and 12 • Entering judgment for Plaintiff A.S.T. in the amount of such 13 damages; 14 • Entering judgment in favor of Plaintiffs and against Disney for 15 exemplary or punitive damages; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Awarding reasonable litigation costs as may be determined by 17 the Court in favor of Plaintiff and against Disney; and 18 • Awarding prejudgment interest; and 19 • SuchDeadline.com other relief as this Court may find just and equitable. 20

21 22 23 24 25

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1 COUNT 122 2 Violation of the Unruh Civil Rights Act 3 California Civil Code §§51, 52 4 A.S.T. v. Disney 5 1461. Plaintiff A.S.T. incorporates and re-alleges paragraphs 1 through 6 91, and 1423 through 1455 above. 7 1462. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 8 provides protection from discrimination by all business establishments in 9 California, including housing and public accommodations, because of age, 10 ancestry, color, disability, national origin, race, religion, sex and sexual

11 orientation. 12 1463. Section 52 of the California Civil Code provides that whoever 13 denies aids or incites a denial, or makes any discrimination or distinction 14 contrary to Section 51 is liable for each and every offense. 15 1464. Pursuant to California Civil Code Section 51(f), a violation of the 16 ADA also constitutes a violation of California Civil Code Section 51, et seq. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1465. The Parks are “business establishments” within the meaning of 18 the California Code Section 51, et seq. 19 1466. ThroughDeadline.com the acts and omissions described in this Complaint, 20 Disney has violated California Civil Code Section 51 by denying A.S.T. A.S.T.’s 21 access to Disney’s programs, services and activities. Disney has instituted and 22 continues to utilize policies which deny or which aid or incite the denial of 23 A.S.T.’s full and equal enjoyment of Disney’s public accommodations in the 24 same manner as non-disabled persons. Disney refuses to modify its policies 25

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1 and procedures to permit fair enjoyment of its facilities by A.S.T.. As a direct 2 and proximate result of the afore-mentioned acts and omissions, A.S.T. has 3 suffered, and continues to suffer, hardship, humiliation and anxiety due to 4 Disney’s failure to provide reasonable accommodations and access as are 5 required by A.S.T.’s cognitive impairments. 6 1467. Due to the continuous nature of Disney’s ongoing discriminatory 7 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 8 result of Disney’s action, A.S.T. is suffering irreparable harm, and thus 9 expeditious relief is appropriate. 10 WHEREFORE, Plaintiff A.S.T., by and through S.D.T. as his next friend,

11 parent and natural guardian, prays that this Court adjudicate this dispute 12 and enter an Order: 13 • Enjoining Defendant to cease the practices which are causing 14 discrimination against Plaintiff on account of A.S.T.’s disability; 15 and 16 • Enjoining Defendant to reasonably modify its policies, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 practices, and procedures to afford Plaintiff with an 18 opportunity to experience Disney’s goods, services, facilities, 19 privileges,Deadline.com advantages, and accommodations; and 20 • Establishing Court-approved remedial measures that Disney 21 must implement, to prevent Disney from further discriminating 22 against Plaintiff when they visit the Disney Parks; and 23 • Establishing Court-approved requirements for information 24 dissemination about Disney’s remedial measures and modified 25 policies, to prevent Disney from further deterring Plaintiff from 26 Page 373 ______COMPLAINT T.P., by and through S.P., et al. v. Walt Disney Parks & Resorts US, Inc. Case No. ______

1 visiting Disney Parks as a result of anticipated discrimination; 2 and 3 • Establishing a monitoring program to ensure Disney’s 4 compliance with the Court’s Orders; and 5 • Determining the amount of A.S.T.’s actual damages; and 6 • Entering judgment in favor of Plaintiff and against Disney for 7 an amount up to three times the amounts of Plaintiff’s actual 8 damages, but in no event less than $4,000; and 9 • Awarding reasonable attorney’s fees as may be determined by 10 the Court in favor of Plaintiff and against Disney; and

11 • Awarding reasonable litigation costs as may be determined by 12 the Court in favor of Plaintiff and against Disney; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 123 15 Negligent Infliction of Emotional Distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI S.M.T. v. Disney 17 1468. Plaintiff S.M.T. incorporates and re-alleges paragraphs 1 through 18 90 above. 19 1469. S.M.T.Deadline.com has autism. S.M.T.’s symptoms and stimming patterns 20 include doing activities repeatedly. S.M.T. possesses very little patience and 21 she becomes frustrated quickly and angers easily. 22 1470. Autism substantially limits a person’s ability to care for himself or 23 herself, perform manual tasks, speak, learn, read, concentrate, think, 24 25

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1 communicate, perceive the concept of time, pair sights and sounds that 2 happen simultaneously, and work. 3 1471. S.M.T. is and at all material times has been a disabled person 4 within the meaning of California Government Code §12926(j). 5 1472. S.M.T. is 12 years of age, and is generally in the care of her mother, 6 S.A.B. and her father, S.D.T., who brings this action as S.M.T.’s next friend, 7 parent and natural guardian. 8 1473. S.D.T. and S.M.T. are residents of San Diego County, California. 9 1474. S.M.T.’s cognitive impairments manifest themselves in a certain 10 way during her visits to the parks; S.M.T. is incapable of deviating from

11 consistency, order, and routine. S.M.T. must experience the park with her 12 brother, A.S.T., in the following order: City Hall; Main Street; First Shop on 13 Main Street; Magic Shop on Main Street; Sleeping Beauty Castle Walkthrough; 14 Star Tours – The Adventures Continue; It’s a Small World; Pinocchio’s Daring 15 Journey; Mr. Toad’s Wild Ride; Snow White’s Scary Adventures; Adventure 16 Park; Pirates of the Caribbean; Haunted Mansion; Jungle Cruise; and a meal at DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 Bengal Barbeque before going back down Main Street and taking the Tram to 18 the car and leaving. Any deviation from this routine will cause instant 19 confusion and S.M.T.Deadline.com to repeat “No! We have to go here first!” If a break from 20 the routine is insisted upon, a meltdown will likely ensue. 21 1475. S.M.T. is incapable of waiting significant periods of time to enter a 22 ride or attraction. If instructed to do so, the stimming patterns described 23 above will intensify toward meltdown. When S.M.T. experiences a meltdown, 24 she becomes verbally aggressive and will yell phrases such as “You don’t love 25

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1 me!” or “You wish I was never born!” S.M.T., like her brother A.S.T., will drop 2 to the ground, scream and cry – taking hours and sometimes an entire day to 3 fully recover. 4 1476. S.M.T. is incapable of understanding the concept of time, and thus 5 cannot comprehend visiting an attraction in the present only to be told it 6 cannot be experienced until sometime in the future. As such, the new DAS 7 creates avoidable stressors for S.M.T., constantly escalating his stimming 8 patterns toward meltdowns. Since Disney’s implementation of the new DAS, 9 S.M.T. has experienced meltdowns at the Disney Parks. 10 1477. S.M.T.’s inability to comprehend the concept of time also leaves

11 her incapable of idly waiting around for significant periods of time, without 12 her cognitive impairments causing her to experience stimming and 13 meltdowns. Triggers and anxiety will cause S.M.T. to exhibit stimming and 14 maladaptive behaviors including dropping to the floor, screaming and crying, 15 taking hours to calm down. 16 1478. S.D.T. and S.A.B. took A.S.T. and S.M.T. to the Disney Parks for the

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 first time in 2006. During the first trip to Disneyland in 2006, S.D.T., A.S.T., and 18 S.M.T. had a miserable experience because they were unaware that the Guest 19 Assistance Card Deadline.comexisted. A Disney employee noticed S.D.T., A.S.T., and S.M.T. 20 having a difficult time, and told them next time they came to the Disney Parks 21 to bring a doctor’s note and request an accommodation; the GAC (“GAC”). 22 S.D.T., A.S.T., and S.M.T. returned to the Disney Parks again in 2006 and 23 requested the GAC. S.D.T. immediately noticed the difference in their Disney 24 experience – it was like night and day. A.S.T. and S.M.T. were both admirably 25

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1 accommodated and exhibited a nature and extent of joy that they rarely 2 showed in any other setting. A.S.T. and S.M.T. were able to ride the rides they 3 needed to ride together, in the order they needed to ride them in. S.D.T. was 4 always proud and joyful of the opportunity to bring to his beloved daughter a 5 level of happiness which she rarely showed elsewhere. Disney employees 6 were always friendly and outgoing. Everyone was smiling and having a good 7 time. It was such a magical experience that in 2006, S.D.T. purchased annual 8 passes, and returned to the Disney Parks with A.S.T. and S.M.T. on a regular 9 basis. 10 1479. This drastically changed in May 2014 when S.D.T. and A.S.T.

11 attended the Disney Parks for the first time after Disney unveiled the DAS. 12 1480. S.D.T. could sense something was not right the minute he saw City 13 Hall. S.D.T. spent 25 minutes waiting to speak with a Disney employee in the 14 blistering heat; meanwhile, paramedics were on site regularly transporting 15 guests out of the Disney Parks who were suffering from heat strokes. After 16 speaking with the Disney employee at Guest Services, S.D.T. received a DAS, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 pamphlets with kiosk locations, and a return time for Star Tours – The 18 Adventures Continue. 19 1481. The Deadline.comday that followed was nothing like past days at Disneyland. 20 S.D.T., A.S.T., and S.M.T. spent the day walking from kiosk, to ride, and back to 21 the kiosk to start the process all over again. 22 1482. Because the shortest DAS return time was one hour and thirty 23 minutes, S.D.T., A.S.T., and S.M.T. were only able to ride four rides in 24 Disneyland and three rides California Adventure. 25

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1 1483. A.S.T. and S.M.T. quickly became dehydrated from the constant 2 walking back and forth between kiosks and rides, forcing them to leave 3 Disneyland much sooner than they would otherwise have. 4 1484. S.D.T. left Disneyland that day feeling disillusioned and 5 dissatisfied by their Disney experience, wholly unlike trips to the Disney Parks 6 in the past. A.S.T. and S.M.T., exhausted, tired, and defeated, were far from the 7 joyous children S.D.T. remembered from the past when leaving the Disney 8 Parks after a day of accommodation with the GAC. Memories of the first time 9 at Disneyland – when they received no accommodation at all – were fresh on 10 S.D.T.’s mind as he contemplated the DAS and lack of Disney magic which

11 followed suit. 12 1485. S.D.T. and S.A.B. returned to Disneyland with A.S.T. and S.M.T. in 13 December 2014, hoping this time the holiday spirit would help bring about a 14 different Disney experience. Instead, A.S.T. and S.M.T. had a similarly 15 miserable and unaccommodating time in the Disney Parks. 16 1486. S.D.T., A.S.T., and S.M.T. immediately encountered long lines, and

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 even longer DAS return times. S.D.T. knew the only way to survive this trip 18 would be to abandon A.S.T. and S.M.T.’s usual routine and try to ride only 19 those rides with Deadline.comshort DAS return times. 20 1487. A.S.B. and S.M.T. were able to ride Pinocchio’s Daring Journey, 21 Peter Pan’s Flight, and Casey Jr. Circus Train – the three rides S.D.T. could find 22 with the shortest return times. A.S.T. and S.M.T. grew more and more agitated 23 as the day progressed as this was outside of their usual routine. Finally, A.S.T. 24 25

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1 and S.M.T. demanded to ride a ride in their usual routine – their favorite ride 2 in the Disney Parks – “it’s a small world.” 3 1488. S.D.T., A.S.T, and S.M.T. made their way to “it’s a small world” to 4 obtain a DAS return time. However, the return time was too long for A.S.T. and 5 S.M.T. to bear. They immediately suffered a meltdown upon being told they 6 would not be riding “it’s a small world.” 7 1489. S.D.T. and A.S.B. spent the remainder of the day with A.S.T. and 8 S.M.T. as far away from the rides as possible, choosing instead to walk around 9 the Disney Parks looking at the holiday decorations and shopping. 10 1490. Once again, S.D.T. and A.S.B. left Disneyland feeling disillusioned

11 and disappointed. It was the time of the year when the family was supposed to 12 feel the most magic, but instead Disney provided a wholly un-magical and 13 unaccommodating experience. 14 1491. The new DAS procedure triggered S.M.T.’s meltdowns in May and 15 December 2014. 16 1492. Due to Disney’s failure and refusal to accommodate the special

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 needs of persons like S.M.T., which leads to an increased propensity for S.M.T. 18 to experience meltdowns, Disney prevents S.M.T. from experiencing the full 19 enjoyment of itsDeadline.com Parks, equal to the experiences of persons without a 20 disability. 21 1493. After October 9, 2013, S.M.T., no longer received the type of 22 accommodation and attention S.M.T. and S.D.T. had received when they visited 23 the Parks in the past. 24 25

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1 1494. As a result of Disney’s refusal to modify its procedures to 2 reasonably accommodate S.M.T.’s needs, S.M.T. and S.D.T. have been 3 discouraged and deterred from the full use and enjoyment of the Parks' rides 4 and attractions. If Disney had not abandoned its past policy of 5 accommodating the special needs of persons with cognitive impairments, 6 S.M.T. would continue to frequently visit the Parks with S.M.T. as a guest. But 7 the family’s interest in attending the Parks is substantially reduced. S.M.T. 8 knows they should avoid attending the Parks in the future because doing so 9 will only lead to the same un-magical experience and un-accommodating 10 discrimination.

11 1495. Notwithstanding Disney’s highly sophisticated knowledge of the 12 needs of persons with cognitive impairments, and notwithstanding Disney’s 13 historic ability to accommodate S.M.T.’s special needs, Disney personnel began 14 in October of 2013 to offer blanket accommodations, and implemented a 15 policy of systematically refusing to conduct individualized assessments of the 16 needs of S.M.T. and persons like him. Since October of 2013, Disney has DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 repeatedly and continuously refused to modify its policies for accommodating 18 disabled persons, choosing instead to robotically follow the DAS. Disney fails 19 and refuses to modifyDeadline.com the DAS to allow S.M.T. to enjoy the same benefits and 20 privileges as non-disabled patrons. 21 1496. Disney personnel have shown no willingness or desire to improve 22 the experience for guests like S.M.T. 23 1497. S.D.T. incurred expenses associated with the family’s wasted trips 24 to the Parks. 25

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1 1498. During one or more visits to the Parks, S.M.T. suffered an actual 2 meltdown. 3 1499. The symptoms and conditions associated with S.M.T.’s meltdown 4 constitute a physical injury under California law. 5 1500. S.M.T.’s meltdown in the Parks was proximately caused by 6 Disney’s negligent, unlawful, reckless and arbitrary treatment of S.M.T. during 7 his patronage of Disney’s facilities. At all material times, Disney knew S.M.T. 8 to be vulnerable to emotional injury if treated in such a manner by anyone. 9 1501. S.M.T.’s meltdown and the treatment which proximately caused 10 S.M.T. to experience the meltdown caused her grave and extreme mental

11 anguish and emotional trauma, for which Disney should be held accountable. 12 WHEREFORE, Plaintiff S.M.T., by and through S.D.T. as S.M.T.’s next 13 friend, parent and natural guardian, prays that this Court adjudicate this 14 dispute and enter an Order: 15 • Finding that Disney negligently inflicted emotional distress 16 upon S.M.T.; and DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 • Finding such infliction to have caused damages to S.M.T.; and 18 • Entering judgment for Plaintiff S.M.T. in the amount of such 19 damages;Deadline.com and 20 • Awarding reasonable litigation costs as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 • Awarding prejudgment interest; and 23 • Such other relief as this Court may find just and equitable. 24

25

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1 COUNT 124 2 Intentional Infliction of Emotional Distress 3 S.M.T. v. Disney 4 1502. Plaintiff S.M.T. incorporates and re-alleges paragraphs 1 through 5 90, and 1469 through 1501 above. 6 1503. During one or more visits to the Parks, S.M.T. suffered an actual 7 meltdown. 8 1504. The symptoms and conditions associated with S.M.T.’s meltdown 9 constitute a physical injury under California law. 10 1505. S.M.T.’s meltdown in the Parks was proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of S.M.T. during her 12 patronage of Disney’s facilities. At all material times, Disney knew S.M.T. to be 13 vulnerable to emotional injury if treated in such a manner by anyone. 14 1506. S.M.T.’s meltdown and the treatment which proximately caused 15 S.M.T. to experience the meltdown caused her grave and extreme mental 16 anguish and emotional trauma, for which Disney should be held accountable. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 WHEREFORE, Plaintiff S.M.T., by and through S.D.T. as S.M.T.’s next 18 friend, parent and natural guardian, prays that this Court adjudicate this 19 dispute and enterDeadline.com an Order: 20 • Finding that Disney intentionally inflicted emotional distress 21 upon S.M.T.; and 22 • Finding such infliction to have caused damages to S.M.T.; and 23 • Entering judgment for Plaintiff S.M.T. in the amount of such 24 damages; 25

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1 • Entering judgment in favor of Plaintiffs and against Disney for 2 exemplary or punitive damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 125 8 Violation of the Unruh Civil Rights Act 9 California Civil Code §§51, 52 10 S.M.T. v. Disney

11 1507. Plaintiff S.M.T. incorporates and re-alleges paragraphs 1 through 12 91, and 1469 through 1501 above. 13 1508. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 14 provides protection from discrimination by all business establishments in 15 California, including housing and public accommodations, because of age, 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI ancestry, color, disability, national origin, race, religion, sex and sexual 17 orientation. 18 1509. Section 52 of the California Civil Code provides that whoever 19 denies aids or incitesDeadline.com a denial, or makes any discrimination or distinction 20 contrary to Section 51 is liable for each and every offense. 21 1510. Pursuant to California Civil Code Section 51(f), a violation of the 22 ADA also constitutes a violation of California Civil Code Section 51, et seq. 23 1511. The Parks are “business establishments” within the meaning of 24 the California Code Section 51, et seq. 25

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1 1512. Through the acts and omissions described in this Complaint, 2 Disney has violated California Civil Code Section 51 by denying S.M.T. S.M.T.’s 3 access to Disney’s programs, services and activities. Disney has instituted and 4 continues to utilize policies which deny or which aid or incite the denial of 5 S.M.T.’s full and equal enjoyment of Disney’s public accommodations in the 6 same manner as non-disabled persons. Disney refuses to modify its policies 7 and procedures to permit fair enjoyment of its facilities by S.M.T.. As a direct 8 and proximate result of the afore-mentioned acts and omissions, S.M.T. has 9 suffered, and continues to suffer, hardship, humiliation and anxiety due to 10 Disney’s failure to provide reasonable accommodations and access as are

11 required by S.M.T.’s cognitive impairments. 12 1513. Due to the continuous nature of Disney’s ongoing discriminatory 13 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 14 result of Disney’s action, S.M.T. is suffering irreparable harm, and thus 15 expeditious relief is appropriate. 16 WHEREFORE, Plaintiff S.M.T., by and through S.D.T. as his next friend, DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 parent and natural guardian, prays that this Court adjudicate this dispute 18 and enter an Order: 19 • EnjoiningDeadline.com Defendant to cease the practices which are causing 20 discrimination against Plaintiff on account of S.M.T.’s disability; 21 and 22 • Enjoining Defendant to reasonably modify its policies, 23 practices, and procedures to afford Plaintiff with an 24 opportunity to experience Disney’s goods, services, facilities, 25 privileges, advantages, and accommodations; and 26 Page 384 ______COMPLAINT T.P., by and through S.P., et al. v. Walt Disney Parks & Resorts US, Inc. Case No. ______

1 • Establishing Court-approved remedial measures that Disney 2 must implement, to prevent Disney from further discriminating 3 against Plaintiff when they visit the Disney Parks; and 4 • Establishing Court-approved requirements for information 5 dissemination about Disney’s remedial measures and modified 6 policies, to prevent Disney from further deterring Plaintiff from 7 visiting Disney Parks as a result of anticipated discrimination; 8 and 9 • Establishing a monitoring program to ensure Disney’s 10 compliance with the Court’s Orders; and

11 • Determining the amount of S.M.T.’s actual damages; and 12 • Entering judgment in favor of Plaintiff and against Disney for 13 an amount up to three times the amounts of Plaintiff’s actual 14 damages, but in no event less than $4,000; and 15 • Awarding reasonable attorney’s fees as may be determined by 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI the Court in favor of Plaintiff and against Disney; and 17 • Awarding reasonable litigation costs as may be determined by 18 the Court in favor of Plaintiff and against Disney; and 19 • SuchDeadline.com other relief as this Court may find just and equitable. 20

21 22 23 24 25

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1 COUNT 126 2 Negligent Infliction of Emotional Distress 3 S.D.T. v. Disney 4 1514. Plaintiff S.D.T. incorporates and re-alleges paragraphs 1 through 5 90, 1423 through 1455, 1457 through 1460, 1462 through 1467, 1469 6 through 1501, 1503 through 1506, and 1508 through 1513 above. 7 1515. During one or more visits to the Parks, S.D.T.’s beloved children, 8 A.S.T. and S.M.T., suffered an actual meltdown while in S.D.T.’s presence. 9 1516. The symptoms and conditions associated with A.S.T. and S.M.T.’s 10 meltdowns constitute a physical injury to S.D.T. under California law.

11 1517. A.S.T. and S.M.T.’s meltdowns in the Parks was proximately 12 caused by Disney’s negligent, unlawful, reckless and arbitrary treatment of 13 A.S.T. and S.M.T. during their patronage of Disney’s facilities. At all material 14 times, Disney knew A.S.T. and S.M.T. to be vulnerable to emotional injury if 15 treated in such a manner by anyone. 16 1518. S.D.T. directly observed the stressors leading up to the meltdown,

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 A.S.T. and S.M.T.’s resulting escalation and his meltdown. Particularly in light 18 of her trust and confidence that Disney would comply with applicable law and 19 act in a graciousDeadline.com and caring manner toward her son, S.D.T. could do nothing 20 reasonable to prevent the meltdown. 21 1519. S.D.T.’s observation of A.S.T. and S.M.T.’s meltdown and of the 22 outrageous conduct and treatment which proximately caused A.S.T. and S.M.T. 23 to experience the meltdowns caused A.S.T. and S.M.T. grave and extreme 24 25

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1 mental anguish and emotional trauma, for which Disney should be held 2 accountable. 3 WHEREFORE, Plaintiff S.D.T. prays that this Court adjudicate this 4 dispute and enter an Order: 5 • Finding that Disney negligently inflicted emotional distress 6 upon S.D.T.; and 7 • Finding such infliction to have caused damages to S.D.T.; and 8 • Entering judgment for Plaintiff S.D.T. in the amount of such 9 damages; and 10 • Awarding reasonable litigation costs as may be determined by

11 the Court in favor of Plaintiff and against Disney; and 12 • Awarding prejudgment interest; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 127 15 Intentional Infliction of Emotional Distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI S.D.T. v. Disney 17 1520. Plaintiff S.D.T. incorporates and re-alleges paragraphs 1 through 18 90, 1423 through 1455, 1457 through 1460, 1462 through 1467, 1469 19 through 1501, 1503Deadline.com through 1506, and 1508 through 1513 above. 20 1521. During one or more visits to the Parks, S.D.T.’s beloved children 21 A.S.T. and S.M.T. suffered an actual meltdown. 22 1522. The symptoms and conditions associated with A.S.T. and S.M.T.’s 23 meltdowns constitute a physical injury under California law. 24 25

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1 1523. A.S.T. and S.M.T.’s meltdown in the Parks was proximately caused 2 by Disney’s outrageous, unlawful and reckless treatment of A.S.T. and S.M.T. 3 during their patronage of Disney’s facilities. At all material times, Disney 4 knew A.S.T. and S.M.T. to be vulnerable to emotional injury if treated in such a 5 manner by anyone. 6 1524. S.D.T. directly observed the stressors leading up to the meltdown, 7 A.S.T. and S.M.T.’s resulting escalation and his meltdown. Particularly in light 8 of her trust and confidence that Disney would comply with applicable law and 9 act in a gracious and caring manner toward her son, S.D.T. could do nothing 10 reasonable to prevent the meltdown.

11 1525. S.D.T.’s observation of A.S.T. and S.M.T.’s meltdown and of the 12 outrageous conduct and treatment which proximately caused A.S.T. and S.M.T. 13 to experience the meltdown caused S.D.T. grave and extreme mental anguish 14 and emotional trauma, for which Disney should be held accountable. 15 WHEREFORE, Plaintiff S.D.T. prays that this Court adjudicate this 16 dispute and enter an Order: DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 • Finding that Disney intentionally inflicted emotional distress 18 upon S.D.T.; and 19 • FindingDeadline.com such infliction to have caused damages to S.D.T.; and 20 • Entering judgment for Plaintiff S.D.T. in the amount of such 21 damages; 22 • Entering judgment in favor of Plaintiffs and against Disney for 23 exemplary or punitive damages; and 24 • Awarding reasonable litigation costs as may be determined by 25 the Court in favor of Plaintiff and against Disney; and

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1 • Awarding prejudgment interest; and 2 • Such other relief as this Court may find just and equitable. 3 COUNT 128 4 Breach of Contract 5 S.D.T. v. Disney 6 1526. Plaintiff S.D.T. incorporates and re-alleges paragraphs 1 through 7 90, 1423 through 1455, 1457 through 1460, 1462 through 1467, 1469 8 through 1501, 1503 through 1506, and 1508 through 1513 above. 9 1527. S.D.T. entered into a contract through which Disney promised to 10 provide a reasonable and enjoyable amusement park experience, and one

11 which complies with applicable law. 12 1528. Disney failed or refused to provide the promised experience, and 13 is in breach of contract. 14 1529. S.D.T. incurred expenses associated with the family’s wasted trips 15 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI WHEREFORE, Plaintiff S.D.T. prays that this Court adjudicate this 17 dispute and enter an Order: 18 • Finding that Disney breached its contract with S.D.T.; and 19 • EnteringDeadline.com judgment for Plaintiff S.D.T. in the amount of his 20 economic monetary damages; and 21 • Awarding reasonable litigation costs as may be determined by 22 the Court in favor of Plaintiff and against Disney; and 23 • Awarding prejudgment interest; and 24 • Such other relief as this Court may find just and equitable. 25

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1 COUNT 129 2 Negligent Infliction of Emotional Distress 3 E.A.P. v. Disney 4 1530. Plaintiff E.A.P. incorporates and re-alleges paragraphs 1 through 5 90 above. 6 1531. E.A.P. has autism and is largely non-verbal. E.A.P.’s symptoms 7 include an inability to understand the concept of time or waiting or to 8 maintain complete control over his physical body, including difficulty going to 9 the bathroom and grasping utensils. E.A.P.’s stimming patterns include 10 flapping his hands, screaming out in pain, and uttering loud noises. E.A.P. also

11 has a tendency to run away (elope) when his surrounding stimuli become 12 overwhelming. 13 1532. Autism substantially limits a person’s ability to care for himself or 14 herself, perform manual tasks, speak, learn, read, concentrate, think, 15 communicate, perceive the concept of time, pair sights and sounds that 16 happen simultaneously, and work. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1533. E.A.P. is and at all material times has been a disabled person 18 within the meaning of California Government Code §12926(j). 19 1534. E.A.P.Deadline.com is eight years of age, and is generally in the care of his 20 father, A.E.P., who brings this action as E.A.P.’s next friend, parent and natural 21 guardian. 22 1535. A.E.P. and E.A.P. are residents of Salt Lake County, Utah. 23 1536. E.A.P.’s cognitive impairments manifest themselves in a certain 24 way during his visits to the parks; E.A.P. is a “repeat rider.” This is a 25

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1 propensity common among autistic persons – a variety of the need for 2 consistency, order and routine. E.A.P. will experience a particular ride or 3 attraction, such as Star Tours – The Adventures Continue and Monsters, Inc. 4 Mike & Sulley to the Rescue!, over and over, for several hours at a time. 5 Disney personnel are very familiar with the repeat rider type of guest. If E.A.P. 6 is denied the opportunity to repeat ride a certain ride, he is likely to 7 experience a meltdown. 8 1537. E.A.P. is incapable of waiting significant periods of time to enter a 9 ride or attraction. If instructed to do so, the stimming patterns described 10 above will intensify toward meltdown. When E.A.P. experiences a meltdown,

11 he will try to run away (elope). If E.A.P. is restrained from running away, he 12 will throw himself on the ground, scream loudly, flail his arms, and hit himself. 13 1538. E.A.P. does not comprehend the passage of time or waiting; he is 14 incapable of understanding the concept of visiting an attraction in the present 15 only to be told it cannot be experienced until sometime in the future. As such, 16 the new DAS creates avoidable stressors for E.A.P., constantly escalating his DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 stimming patterns toward meltdowns. Since Disney’s implementation of the 18 new DAS, E.A.P. has experienced multiple meltdowns at the Disney Parks. 19 1539. E.A.P.Deadline.com’s inability to comprehend the concept of time also leaves 20 him incapable of idly waiting around for any significant period of time; such 21 an experience will cause him to experience stimming and meltdowns. 22 Triggers and anxiety will cause E.A.P. to exhibit stimming and maladaptive 23 behaviors, including screaming, self-injurious behavior, and throwing himself 24 to the ground. 25

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1 1540. A.E.P. has been taking E.A.P. to Disneyland since E.A.P. was four- 2 years-old. After their first trip to Disneyland, E.A.P. returned, pleasantly 3 surprised that they had such a positive experience. Annual trips to Disneyland 4 quickly became a family tradition. Before October 9, 2013, E.A.P. always 5 carried the Guest Assistance Card, and was admirably accommodated. During 6 those visits, E.A.P. exhibited a nature and extent of joy that he rarely shows in 7 any other setting. The GAC provided A.E.P. and his family an opportunity to 8 experience normalcy and enjoy Disneyland together as a family. A.E.P. and 9 E.A.P. would arrive to Disneyland with a plan of attack after reviewing the 10 map beforehand. Typically, A.E.P. and E.A.P. would spend the entire day in

11 Disneyland, repeat riding the rides E.A.P. needed to ride – usually Star Tours – 12 The Adventures Continue and Monsters, Inc. Mike & Sulley to the Rescue! 13 A.E.P. was always proud and joyful of the opportunity to bring to his beloved 14 son a level of happiness which he did not show elsewhere. Disney employees 15 were always friendly and outgoing. Everyone was smiling and having a good 16 time. It was a magical experience for the E.A.P.’s entire family. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1541. This drastically changed on December 1, 2013 when A.E.P. and 18 E.A.P. attended the Disney Parks for the first time after Disney unveiled the 19 DAS at DisneylandDeadline.com. 20 1542. Before attending Disneyland – as was their annual tradition – 21 A.E.P. read about the anticipated changes to the GAC and Disney’s intention to 22 unveil the DAS sometime in October 2013. In October 2013, A.E.P. sent a 23 series of emails to various general mailboxes as well as specific employees at 24 Disney, including Betty Appleton and Mark Jones. In those emails, A.E.P. 25

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1 expressed his concern about Disney’s intention to replace the GAC, and 2 pleaded for Disney to reconsider its intentions, or at least accept and 3 implement feedback regarding any plan to replace the GAC. Sadly, A.E.P.’s 4 emails went unanswered. 5 1543. On December 1, 2013, A.E.P. arrived at Disneyland with E.A.P., 6 nervous about what was in store for his family at the Parks now that Disney 7 had implemented the DAS. A.E.P. paid for the accompaniment of a caretaker 8 for E.A.P. while in the Disney Parks so he would always have a caretaker by his 9 side. A.E.P., having read Disney’s Guide for Guests with Cognitive Disabilities, 10 had a general understanding of how the DAS worked. The Disney employee’s

11 explanation at Guest Services conformed to that understanding, until A.E.P. 12 began asking questions. Almost every question A.E.P. asked was answered 13 with silence as the Disney employee consulted with a Disney Manager before 14 answering A.E.P.’s question. Throughout the process, the Disney employee 15 asked A.E.P. multiple questions about E.A.P’s disability and why he needed the 16 D.A.S. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1544. Before leaving Guest Services, the Disney employee gave A.E.P. 18 four Fastpasses with the accompanying explanation that this was a one-time 19 only accommodationDeadline.com and no additional Fastpasses would be given on this or 20 any future visit to Disneyland. A.E.P. left Guest Services already feeling uneasy 21 about the journey he was about to embark on with E.A.P. 22 1545. Upon entering Disneyland, A.E.P. immediately went to the nearest 23 kiosk and obtained a DAS return time for Star Tours – the Adventures 24 Continue. Astonishingly, when the return time elapsed and A.E.P. and E.A.P. 25

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1 visited the ride, they were allowed to pass through the Fastpass entrance and 2 gain expedited access to the ride. This victory would be short lived. 3 1546. When the ride ended, E.A.P. immediately expressed a desire to 4 ride the ride again – to repeat ride. In the past – when A.E.P. and E.A.P. had the 5 privilege of the GAC – this was never an issue. The GAC allowed A.E.P. and 6 E.A.P. to repeat the ride as many times as A.E.P. needed to until he was 7 satisfied. A.E.P. grew accustomed to this type of experience, and fully expected 8 the same during his December 1, 2013 visit. 9 1547. Instead, A.E.P. was instructed to leave the ride with E.A.P., and 10 obtain another DAS return time in order to ride Star Tours – The Adventures

11 Continue, a second time. A.E.P., desperate to keep E.A.P. from experiencing a 12 meltdown, quickly pulled out his first Fastpass and handed them to the Disney 13 employee so E.A.P. could repeat ride. 14 1548. Once A.E.P. used all of his Fastpasses, the trip took a turn for the 15 worse. A.E.P. and E.A.P. consistently encountered broken rides after receiving 16 DAS return times, requiring E.A.P. and A.E.P. to return to the nearest kiosk to DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 repeat the process all over again. Early in the morning of their first day at 18 Disneyland, E.A.P. experienced his first meltdown going from kiosk to ride and 19 back to the kioskDeadline.com again. 20 1549. A.E.P. and E.A.P. subsequently spent the day chaotically 21 crisscrossing Disneyland, going from kiosk to ride and back to the kiosk in an 22 attempt to appease A.E.P. and keep him from experiencing more meltdowns. 23 Despite A.E.P.’s best attempts, as the day progressed, E.A.P.’s meltdowns were 24 25

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1 more frequent and more intense, culminating in a four-meltdown nightmare 2 at Radiator Springs Racer. E.A.P. and A.E.P. left Disneyland shortly after. 3 1550. E.A.P. and A.E.P. returned to Disneyland the following day. 4 However, their visit was just as unsatisfying, unaccommodating, and un- 5 magical as the first, with E.A.P. experiencing multiple meltdowns throughout 6 the day as a result of Disney’s new DAS procedure. 7 1551. E.A.P. and A.E.P. returned to Disneyland on April 19, 2015, 8 determined to give Disney another chance. This time, A.E.P. paid for his sister 9 to accompany E.A.P. and A.E.P. to the Disney Parks, ensuring that E.A.P. would 10 have a caretaker by his side at all times.

11 1552. Shortly before their trip, A.E.P. again reached out to Mark Jones 12 and Betty Appleton, requesting a different accommodation. Mark Jones 13 replied that there was nothing Disney could provide to E.A.P. above and 14 beyond the DAS. 15 1553. Betty Appleton, instead, forwarded A.E.P.’s email to another 16 Disney employee, who then contacted A.E.P. The Disney employee explained DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 to A.E.P. that he was now in the “Magic Database” and was given a reference 18 number to give Guest Services during the first day of their trip to the Disney 19 Parks. Deadline.com 20 1554. When E.A.P. and A.E.P. arrived to Guest Services on April 19, 2015, 21 A.E.P. went to Guest Services with E.A.P. and told the Disney employee he was 22 a part of Disney’s Magic Database and gave the Disney employee his reference 23 number. 24 25

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1 1555. The Disney employee issued A.E.P. a DAS for E.A.P., along with 2 four daily re-admit passes. Much like his last trip to the Disney Parks, A.E.P. 3 began the trip with eager anticipation that Disney would actually offer his son 4 E.A.P. a reasonable accommodation. 5 1556. Once again, Disney failed to live up to A.E.P.’s expectations. The 6 four re-admit passes proved to be nothing more than a short-term solution to 7 the much bigger problem that is the DAS. 8 1557. With only four re-admit passes, E.A.P. was unable to repeat rides 9 the needed to ride once he used his re-admit passes, leading to meltdowns 10 outside of Splash Mountain, Big Thunder Mountain Railroad, and Star Tours –

11 the Adventures Continue. 12 1558. Making matters worse, on myriad occasions E.A.P. and A.E.P. 13 signed up for DAS return times and waited the proscribed time. However, 14 upon arriving to the ride, E.A.P. and A.E.P. would be devastated to learn the 15 ride was broken or closed for maintenance. 16 1559. Disney’s inability to foresee this problem and allow E.A.P. and

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 A.E.P. to sign up for rides which E.A.P. and A.E.P. would not be able to ride – 18 even after waiting the allotted time – led to E.A.P. experiencing multiple 19 meltdowns whileDeadline.com in the Disney Parks in April, 2015. 20 1560. The new DAS procedure triggered E.A.P.’s meltdowns during the 21 family’s visit to Disneyland in December 2013 and April 2015. 22 1561. Due to Disney’s failure and refusal to accommodate the special 23 needs of persons like E.A.P., which leads to an increased propensity for E.A.P. 24 to experience meltdowns, Disney prevents E.A.P. from experiencing the full 25

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1 enjoyment of its Parks, equal to the experiences of persons without a 2 disability. 3 1562. After October 9, 2013, E.A.P., no longer received the type of 4 accommodation and attention E.A.P. and A.E.P. had received when they visited 5 the Parks in the past. 6 1563. As a result of Disney’s refusal to modify its procedures to 7 reasonably accommodate E.A.P.’s needs, E.A.P. and A.E.P. have been 8 discouraged and deterred from the full use and enjoyment of the Parks' rides 9 and attractions. If Disney had not abandoned its past policy of 10 accommodating the special needs of persons with cognitive impairments,

11 E.A.P. would continue to frequently visit the Parks with E.A.P. as a guest. But 12 the family’s interest in attending the Parks is substantially reduced. E.A.P. 13 knows they should avoid attending the Parks in the future because doing so 14 will only lead to the same un-magical experience and unaccommodating 15 discrimination 16 1564. Notwithstanding Disney’s highly sophisticated knowledge of the

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 needs of persons with cognitive impairments, and notwithstanding Disney’s 18 historic ability to accommodate E.A.P.’s special needs, Disney personnel began 19 in October of 2013Deadline.com to offer blanket accommodations, and implemented a 20 policy of systematically refusing to conduct individualized assessments of the 21 needs of E.A.P. and persons like him. Since October of 2013, Disney has 22 repeatedly and continuously refused to modify its policies for accommodating 23 disabled persons, choosing instead to robotically follow the DAS. Disney fails 24 25

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1 and refuses to modify the DAS to allow E.A.P. to enjoy the same benefits and 2 privileges as non-disabled patrons. 3 1565. Disney personnel have shown no willingness or desire to improve 4 the experience for guests like E.A.P. 5 1566. A.E.P. incurred expenses associated with the family’s wasted trips 6 to the Parks. 7 1567. During one or more visits to the Parks, E.A.P. suffered an actual 8 meltdown. 9 1568. The symptoms and conditions associated with E.A.P.’s meltdown 10 constitute a physical injury under California law.

11 1569. E.A.P.’s meltdown in the Parks was proximately caused by 12 Disney’s negligent, unlawful, reckless and arbitrary treatment of E.A.P. during 13 his patronage of Disney’s facilities. At all material times, Disney knew E.A.P. to 14 be vulnerable to emotional injury if treated in such a manner by anyone. 15 1570. E.A.P.’s meltdown and the treatment which proximately caused 16 E.A.P. to experience the meltdown caused him grave and extreme mental DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 anguish and emotional trauma, for which Disney should be held accountable. 18 WHEREFORE, Plaintiff E.A.P., by and through A.E.P. as E.A.P.’s next 19 friend, parent andDeadline.com natural guardian, prays that this Court adjudicate this 20 dispute and enter an Order: 21 • Finding that Disney negligently inflicted emotional distress 22 upon E.A.P.; and 23 • Finding such infliction to have caused damages to E.A.P.; and 24 25

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1 • Entering judgment for Plaintiff E.A.P. in the amount of such 2 damages; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Awarding prejudgment interest; and 6 • Such other relief as this Court may find just and equitable. 7 COUNT 130 8 Intentional Infliction of Emotional Distress 9 E.A.P. v. Disney 10 1571. Plaintiff E.A.P. incorporates and re-alleges paragraphs 1 through

11 90, and 1531 through 1570 above. 12 1572. During one or more visits to the Parks, E.A.P. suffered an actual 13 meltdown. 14 1573. The symptoms and conditions associated with E.A.P.’s meltdown 15 constitute a physical injury under California law. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 1574. E.A.P.’s meltdown in the Parks was proximately caused by 17 Disney’s outrageous, unlawful and reckless treatment of E.A.P. during his 18 patronage of Disney’s facilities. At all material times, Disney knew E.A.P. to be 19 vulnerable to emotionalDeadline.com injury if treated in such a manner by anyone. 20 1575. E.A.P.’s meltdown and the treatment which proximately caused 21 E.A.P. to experience the meltdown caused him grave and extreme mental 22 anguish and emotional trauma, for which Disney should be held accountable. 23 24 25

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1 WHEREFORE, Plaintiff E.A.P., by and through A.E.P. as E.A.P.’s next 2 friend, parent and natural guardian, prays that this Court adjudicate this 3 dispute and enter an Order: 4 • Finding that Disney intentionally inflicted emotional distress 5 upon E.A.P.; and 6 • Finding such infliction to have caused damages to E.A.P.; and 7 • Entering judgment for Plaintiff E.A.P. in the amount of such 8 damages; 9 • Entering judgment in favor of Plaintiffs and against Disney for 10 exemplary or punitive damages; and

11 • Awarding reasonable litigation costs as may be determined by 12 the Court in favor of Plaintiff and against Disney; and 13 • Awarding prejudgment interest; and 14 • Such other relief as this Court may find just and equitable. 15 COUNT 131 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI Violation of the Unruh Civil Rights Act 17 California Civil Code §§51, 52 18 E.A.P. v. Disney 19 1576. PlaintiffDeadline.com E.A.P. incorporates and re-alleges paragraphs 1 through 20 91, and 1531 through 1570 above. 21 1577. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 22 provides protection from discrimination by all business establishments in 23 California, including housing and public accommodations, because of age, 24 25

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1 ancestry, color, disability, national origin, race, religion, sex and sexual 2 orientation. 3 1578. Section 52 of the California Civil Code provides that whoever 4 denies aids or incites a denial, or makes any discrimination or distinction 5 contrary to Section 51 is liable for each and every offense. 6 1579. Pursuant to California Civil Code Section 51(f), a violation of the 7 ADA also constitutes a violation of California Civil Code Section 51, et seq. 8 1580. The Parks are “business establishments” within the meaning of 9 the California Code Section 51, et seq. 10 1581. Through the acts and omissions described in this Complaint,

11 Disney has violated California Civil Code Section 51 by denying E.A.P. E.A.P.’s 12 access to Disney’s programs, services and activities. Disney has instituted and 13 continues to utilize policies which deny or which aid or incite the denial of 14 E.A.P.’s full and equal enjoyment of Disney’s public accommodations in the 15 same manner as non-disabled persons. Disney refuses to modify its policies 16 and procedures to permit fair enjoyment of its facilities by E.A.P.. As a direct DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 and proximate result of the afore-mentioned acts and omissions, E.A.P. has 18 suffered, and continues to suffer, hardship, humiliation and anxiety due to 19 Disney’s failure Deadline.comto provide reasonable accommodations and access as are 20 required by E.A.P.’s cognitive impairments. 21 1582. Due to the continuous nature of Disney’s ongoing discriminatory 22 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 23 result of Disney’s action, E.A.P. is suffering irreparable harm, and thus 24 expeditious relief is appropriate. 25

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1 WHEREFORE, Plaintiff E.A.P., by and through A.E.P. as his next friend, 2 parent and natural guardian, prays that this Court adjudicate this dispute 3 and enter an Order: 4 • Enjoining Defendant to cease the practices which are causing 5 discrimination against Plaintiff on account of E.A.P.’s disability; 6 and 7 • Enjoining Defendant to reasonably modify its policies, 8 practices, and procedures to afford Plaintiff with an 9 opportunity to experience Disney’s goods, services, facilities, 10 privileges, advantages, and accommodations; and

11 • Establishing Court-approved remedial measures that Disney 12 must implement, to prevent Disney from further discriminating 13 against Plaintiff when they visit the Disney Parks; and 14 • Establishing Court-approved requirements for information 15 dissemination about Disney’s remedial measures and modified 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI policies, to prevent Disney from further deterring Plaintiff from 17 visiting Disney Parks as a result of anticipated discrimination; 18 and 19 • EstablishingDeadline.com a monitoring program to ensure Disney’s 20 compliance with the Court’s Orders; and 21 • Determining the amount of E.A.P.’s actual damages; and 22 • Entering judgment in favor of Plaintiff and against Disney for 23 an amount up to three times the amounts of Plaintiff’s actual 24 damages, but in no event less than $4,000; and 25

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1 • Awarding reasonable attorney’s fees as may be determined by 2 the Court in favor of Plaintiff and against Disney; and 3 • Awarding reasonable litigation costs as may be determined by 4 the Court in favor of Plaintiff and against Disney; and 5 • Such other relief as this Court may find just and equitable. 6 COUNT 132 7 Negligent Infliction of Emotional Distress 8 A.E.P. v. Disney 9 1583. Plaintiff A.E.P. incorporates and re-alleges paragraphs 1 through 10 90, 1531 through 1570, 1572 through 1575, and 1577 through 1582 above.

11 1584. During one or more visits to the Parks, A.E.P.’s beloved son E.A.P. 12 suffered an actual meltdown while in A.E.P.’s presence. 13 1585. The symptoms and conditions associated with E.A.P.’s meltdown 14 constitute a physical injury to A.E.P. under California law. 15 1586. E.A.P.’s meltdown in the Parks was proximately caused by 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI Disney’s negligent, unlawful, reckless and arbitrary treatment of E.A.P. during 17 his patronage of Disney’s facilities. At all material times, Disney knew E.A.P. to 18 be vulnerable to emotional injury if treated in such a manner by anyone. 19 1587. A.E.P.Deadline.com directly observed the stressors leading up to the meltdown, 20 E.A.P.’s resulting escalation and his meltdown. Particularly in light of his trust 21 and confidence that Disney would comply with applicable law and act in a 22 gracious and caring manner toward his son, A.E.P. could do nothing 23 reasonable to prevent the meltdown. 24 25

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1 1588. A.E.P.’s observation of E.A.P.’s meltdown and of the outrageous 2 conduct and treatment which proximately caused E.A.P. to experience the 3 meltdown caused E.A.P. grave and extreme mental anguish and emotional 4 trauma, for which Disney should be held accountable. 5 WHEREFORE, Plaintiff A.E.P. prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney negligently inflicted emotional distress 8 upon A.E.P.; and 9 • Finding such infliction to have caused damages to A.E.P.; and 10 • Entering judgment for Plaintiff A.E.P. in the amount of such 11 damages; and 12 • Awarding reasonable litigation costs as may be determined by 13 the Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 133 17 Intentional Infliction of Emotional Distress 18 A.E.P. v. Disney 19 1589. PlaintiffDeadline.com A.E.P. incorporates and re-alleges paragraphs 1 through 20 90, 1531 through 1570, 1572 through 1575, and 1577 through 1582 above. 21 1590. During one or more visits to the Parks, A.E.P.’s beloved son E.A.P. 22 suffered an actual meltdown. 23 1591. The symptoms and conditions associated with E.A.P.’s meltdown 24 constitute a physical injury under California law. 25

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1 1592. E.A.P.’s meltdown in the Parks was proximately caused by 2 Disney’s outrageous, unlawful and reckless treatment of E.A.P. during his 3 patronage of Disney’s facilities. At all material times, Disney knew E.A.P. to be 4 vulnerable to emotional injury if treated in such a manner by anyone. 5 1593. A.E.P. directly observed the stressors leading up to the meltdown, 6 E.A.P.’s resulting escalation and his meltdown. Particularly in light of his trust 7 and confidence that Disney would comply with applicable law and act in a 8 gracious and caring manner toward his son, A.E.P. could do nothing 9 reasonable to prevent the meltdown. 10 1594. A.E.P.’s observation of E.A.P.’s meltdown and of the outrageous

11 conduct and treatment which proximately caused E.A.P. to experience the 12 meltdown caused A.E.P. grave and extreme mental anguish and emotional 13 trauma, for which Disney should be held accountable. 14 WHEREFORE, Plaintiff A.E.P. prays that this Court adjudicate this 15 dispute and enter an Order: 16 • Finding that Disney intentionally inflicted emotional distress DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 upon A.E.P.; and 18 • Finding such infliction to have caused damages to A.E.P.; and 19 • EnteringDeadline.com judgment for Plaintiff A.E.P. in the amount of such 20 damages; 21 • Entering judgment in favor of Plaintiffs and against Disney for 22 exemplary or punitive damages; and 23 • Awarding reasonable litigation costs as may be determined by 24 the Court in favor of Plaintiff and against Disney; and 25

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1 • Awarding prejudgment interest; and 2 • Such other relief as this Court may find just and equitable. 3 COUNT 134 4 Breach of Contract 5 A.E.P. v. Disney 6 1595. Plaintiff A.E.P. incorporates and re-alleges 1 through 90, 1531 7 through 1570, 1572 through 1575, and 1577 through 1582 above. 8 1596. A.E.P. entered into a contract through which Disney promised to 9 provide a reasonable and enjoyable amusement park experience, and one 10 which complies with applicable law.

11 1597. Disney failed or refused to provide the promised experience, and 12 is in breach of contract. 13 1598. A.E.P. incurred expenses associated with the family’s wasted trips 14 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 15 WHEREFORE, Plaintiff A.E.P. prays that this Court adjudicate this 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI dispute and enter an Order: 17 • Finding that Disney breached its contract with A.E.P.; and 18 • Entering judgment for Plaintiff A.E.P. in the amount of her 19 economicDeadline.com monetary damages; and 20 • Awarding reasonable litigation costs as may be determined by 21 the Court in favor of Plaintiff and against Disney; and 22 • Awarding prejudgment interest; and 23 • Such other relief as this Court may find just and equitable. 24

25

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1 COUNT 135 2 Negligent Infliction of Emotional Distress 3 P.A.D. v. Disney 4 1599. Plaintiff P.A.D. incorporates and re-alleges paragraphs 1 through 5 90 above. 6 1600. P.A.D. has autism and mild mental retardation. P.A.D.’s symptoms 7 and stimming patterns include making ghost noises, vocalization, hand 8 slapping, kicking, and jumping up and down in the same spot. 9 1601. Autism substantially limits a person’s ability to care for himself or 10 herself, perform manual tasks, speak, learn, read, concentrate, think,

11 communicate, perceive the concept of time, pair sights and sounds that 12 happen simultaneously, and work. 13 1602. P.A.D. is and at all material times has been a disabled person 14 within the meaning of California Government Code §12926(j). 15 1603. P.A.D. is 15 years of age, and is generally in the care of his mother, 16 A.C.E., who brings this action as P.A.D.’s next friend, parent and natural DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 guardian. 18 1604. A.C.E. and P.A.D. are residents of Lost Angeles County, California. 19 1605. P.A.D.’sDeadline.com cognitive impairments manifest themselves in a certain 20 way during his visits to the parks; P.A.D. is a “repeat rider.” This is a 21 propensity common among autistic persons – a variety of the need for 22 consistency, order and routine. P.A.D. will experience a particular ride or 23 attraction, such as Space Mountain, over and over, for several hours at a time. 24 Disney personnel are very familiar with the repeat rider type of guest. 25

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1 1606. P.A.D. is incapable of waiting significant periods of time to enter a 2 ride or attraction. If instructed to do so, the stimming patterns described 3 above will intensify toward meltdown. When P.A.D. experiences a meltdown, 4 he will fall to the ground and flail about wildly while making ghost noises and 5 blocking his ears. 6 1607. P.A.D. is incapable of understanding the concept of visiting an 7 attraction in the present only to be told it cannot be experienced until 8 sometime in the future. As such, the new DAS creates avoidable stressors for 9 P.A.D., constantly escalating his stimming patterns toward meltdowns. Since 10 Disney’s implementation of the new DAS, P.A.D. has experienced many

11 meltdowns at the Disney Parks. 12 1608. P.A.D. is incapable of standing in lines without his cognitive 13 impairments causing him to experience stimming and meltdowns when 14 required to wait in a line for any significant period. Triggers and anxiety will 15 cause P.A.D. to exhibit stimming and maladaptive behaviors such as falling to 16 the ground and flaililing about wildly. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1609. A.C.E. has been taking P.A.D. to Disneyland since P.A.D. was five- 18 years-old. A.C.E. has regularly returned to Disneyland at least once per year. 19 Before October Deadline.com9, 2013 P.A.D. carried the Guest Assistance Card, and was 20 admirably accommodated. During those visits, P.A.D. exhibited a nature and 21 extent of joy that he rarely shows in any other setting. Typically, A.C.E. and 22 P.A.D. would spend the entire day in the Disney Parks, riding the rides P.A.D. 23 wanted to ride as many times as P.A.D. needed to ride them, including 24 multiple visits to Space Mountain. A.C.E. was always proud and joyful of the 25

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1 opportunity to bring to her beloved son a level of happiness which he rarely 2 showed elsewhere. For A.C.E., that was “his time.” Disney employees were 3 always friendly and outgoing. Everyone was smiling and having a good time. It 4 was a magical experience. 5 1610. This drastically changed on June 14, 2014 when A.C.E. and P.A.D. 6 attended the Disney Parks for the first time after Disney unveiled the DAS. 7 1611. After a 20 minute wait at Guest Services, A.C.E. finally obtained a 8 DAS. However, because the Disney Cast Member did not explain how the DAS 9 worked or where the kiosks were located, A.C.E. entered California Adventure 10 with P.A.D. confused and unable to locate a nearby kiosk.

11 1612. A.C.E. and P.A.D. walked around California Adventure in search of 12 a kiosk. Eventually, A.C.E. found a kiosk and signed up for a DAS return time 13 for Radiator Springs Racers. A.C.E.’s confusion quickly turned into desperation 14 once she learned that the wait time for Radiator Springs Racers was one hour 15 and fifteen minutes. A.C.E. wanted to give up and leave California Adventure 16 with P.A.D., fearing the long wait without riding a ride would cause A.C.E. to DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 experience a meltdown. But A.C.E. did not have the heart to leave without at 18 least trying to wait and trying to use the DAS. 19 1613. At theDeadline.com direction of a Disney Cast Member, P.A.D. and A.C.E. visited 20 Mater’s Junkyard Jamboree where they were told there was no wait. Upon 21 arriving at Mater’s Junkyard Jamboree, P.A.D. and A.C.E. instead encountered a 22 20-minute wait. A.C.E. did everything in her power to keep P.A.D. calm, to no 23 avail. P.A.D. suffered a meltdown in the line of Mater’s Junkyard Jamboree. 24 25

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1 1614. Not wanting to expose P.A.D. to another situation which could 2 lead to another meltdown, A.C.E. walked around Cars Land with P.A.D. while 3 they waited for their return time to ride Radiator Springs Racers. A.C.E. and 4 P.A.D. walked around Cars Land five times before their return time elapsed, 5 and they were able to ride Radiator Springs Racers. 6 1615. Once P.A.D. and A.C.E. finished riding Radiator Springs Racers, 7 P.A.D. – as he had done every time in the past with the GAC – requested to ride 8 Radiator Springs Racers again. 9 1616. A.C.E. quickly learned that this was not possible under the DAS. 10 Instead, A.C.E. and P.A.D. would have to repeat the process again. A.C.E. tried

11 to explain to P.A.D. he could not go on the ride for another hour. P.A.D. 12 experienced another meltdown. 13 1617. A.C.E., thinking the experience would be different at Disneyland, 14 left California Adventure with P.A.D. 15 1618. At Disneyland, A.C.E. experienced the same scattered kiosk 16 system, but with more distance to travel between kiosks and even more DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 confusion. A map she was given at Guest Services indicated there was a non- 18 existent kiosk next to Sleeping Beauty’s Castle. The chaos combined with the 19 great distances travelDeadline.comed in between obtaining DAS return times and finding 20 ways to pass that time led to a multiple meltdowns at Disneyland. 21 1619. After experiencing a final meltdown at Pirates of the Caribbean, 22 A.C.E. left Disneyland with P.A.D. A.C.E. was devastated by the way Disney had 23 treated her and P.A.D. She wanted nothing more than for P.A.D. to have fun 24 and feel like a normal child. Instead, Disney’s treatment singled P.A.D. out, and 25

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1 guaranteed a uniformly un-magical and un-accommodating experience. A.C.E. 2 left the Disney Parks, vowing to never return until Disney reverted back to a 3 system that actually accommodated her son’s special needs. 4 1620. The new DAS procedure triggered P.A.D.’s meltdowns on June 14, 5 2014. In order to avoid further meltdowns, A.C.E. spent more time than usual 6 purchasing food to assuage P.A.D. 7 1621. Due to its failure to Disney’s refusal to accommodate the special 8 needs of persons like P.A.D., which leads to an increased propensity for P.A.D. 9 to experience meltdowns, Disney prevents P.A.D. from experiencing the full 10 enjoyment of its Parks, equal to the experiences of persons without a

11 disability. 12 1622. After October 9, 2013, P.A.D., no longer received the type of 13 accommodation and attention P.A.D. and A.C.E. had received when they visited 14 the Parks in the past. 15 1623. As a result of Disney’s refusal to modify its procedures to 16 reasonably accommodate P.A.D.’s needs, P.A.D. and A.C.E. have been DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 discouraged and deterred from the full use and enjoyment of the Parks' rides 18 and attractions. If Disney had not abandoned its past policy of accommodating 19 the special needsDeadline.com of persons with cognitive impairments, P.A.D. would 20 continue to frequently visit the Parks with P.A.D. as a guest. But the family’s 21 interest in attending the Parks is substantially reduced. P.A.D. knows they 22 should avoid attending the Parks in the future because doing so will only lead 23 to the same un-magical experience and un-accommodating discrimination 24 25

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1 1624. Notwithstanding Disney’s highly sophisticated knowledge of the 2 needs of persons with cognitive impairments, and notwithstanding Disney’s 3 historic ability to accommodate P.A.D.’s special needs, Disney personnel began 4 in October of 2013 to offer blanket accommodations, and implemented a 5 policy of systematically refusing to conduct individualized assessments of the 6 needs of P.A.D. and persons like him. Since October of 2013, Disney has 7 repeatedly and continuously refused to modify its policies for accommodating 8 disabled persons, choosing instead to robotically follow the DAS. Disney fails 9 and refuses to modify the DAS to allow P.A.D. to enjoy the same benefits and 10 privileges as non-disabled patrons.

11 1625. Disney personnel have shown no willingness or desire to improve 12 the experience for guests like P.A.D. 13 1626. A.C.E. incurred expenses associated with the family’s wasted trips 14 to the Parks. 15 1627. During one or more visits to the Parks, P.A.D. suffered an actual 16 meltdown. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1628. The symptoms and conditions associated with P.A.D.’s meltdown 18 constitute a physical injury under California law. 19 1629. P.A.D.’sDeadline.com meltdown in the Parks was proximately caused by 20 Disney’s negligent, unlawful, reckless and arbitrary treatment of P.A.D. during 21 his patronage of Disney’s facilities. At all material times, Disney knew P.A.D. 22 to be vulnerable to emotional injury if treated in such a manner by anyone. 23 24 25

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1 1630. P.A.D.’s meltdown and the treatment which proximately caused 2 P.A.D. to experience the meltdown caused him grave and extreme mental 3 anguish and emotional trauma, for which Disney should be held accountable. 4 WHEREFORE, Plaintiff P.A.D., by and through A.C.E. as P.A.D.’s next 5 friend, parent and natural guardian, prays that this Court adjudicate this 6 dispute and enter an Order: 7 • Finding that Disney negligently inflicted emotional distress upon 8 P.A.D.; and 9 • Finding such infliction to have caused damages to P.A.D.; and 10 • Entering judgment for Plaintiff P.A.D. in the amount of such 11 damages; and 12 • Awarding reasonable litigation costs as may be determined by the 13 Court in favor of Plaintiff and against Disney; and 14 • Awarding prejudgment interest; and 15 • Such other relief as this Court may find just and equitable. 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI COUNT 136 17 Intentional Infliction of Emotional Distress 18 P.A.D. v. Disney 19 1631. PlaintiffDeadline.com P.A.D. incorporates and re-alleges paragraphs 1 through 20 90, and 1600 through 1630 above. 21 1632. During one or more visits to the Parks, P.A.D. suffered an actual 22 meltdown. 23 1633. The symptoms and conditions associated with P.A.D.’s meltdown 24 constitute a physical injury under California law. 25

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1 1634. P.A.D.’s meltdown in the Parks was proximately caused by 2 Disney’s outrageous, unlawful and reckless treatment of P.A.D. during his 3 patronage of Disney’s facilities. At all material times, Disney knew P.A.D. to be 4 vulnerable to emotional injury if treated in such a manner by anyone. 5 1635. P.A.D.’s meltdown and the treatment which proximately caused 6 P.A.D. to experience the meltdown caused him grave and extreme mental 7 anguish and emotional trauma, for which Disney should be held accountable. 8 WHEREFORE, Plaintiff P.A.D., by and through A.C.E. as P.A.D.’s next 9 friend, parent and natural guardian, prays that this Court adjudicate this 10 dispute and enter an Order:

11 • Finding that Disney intentionally inflicted emotional distress upon 12 P.A.D.; and 13 • Finding such infliction to have caused damages to P.A.D.; and 14 • Entering judgment for Plaintiff P.A.D. in the amount of such 15 damages; 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Entering judgment in favor of Plaintiffs and against Disney for 17 exemplary or punitive damages; and 18 • Awarding reasonable litigation costs as may be determined by the 19 Court inDeadline.com favor of Plaintiff and against Disney; and 20 • Awarding prejudgment interest; and 21 • Such other relief as this Court may find just and equitable. 22

23 24 25

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1 COUNT 137 2 Violation of the Unruh Civil Rights Act 3 California Civil Code §§51, 52 4 P.A.D. v. Disney 5 1636. Plaintiff P.A.D. incorporates and re-alleges paragraphs 1 through 6 91, and 1600 through 1630 above. 7 1637. Section 51 of the California Civil Code, the Unruh Civil Rights Act, 8 provides protection from discrimination by all business establishments in 9 California, including housing and public accommodations, because of age, 10 ancestry, color, disability, national origin, race, religion, sex and sexual

11 orientation. 12 1638. Section 52 of the California Civil Code provides that whoever 13 denies aids or incites a denial, or makes any discrimination or distinction 14 contrary to Section 51 is liable for each and every offense. 15 1639. Pursuant to California Civil Code Section 51(f), a violation of the 16 ADA also constitutes a violation of California Civil Code Section 51, et seq. DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 1640. The Parks are “business establishments” within the meaning of 18 the California Code Section 51, et seq. 19 1641. ThroughDeadline.com the acts and omissions described in this Complaint, 20 Disney has violated California Civil Code Section 51 by denying P.A.D. access 21 to Disney’s programs, services and activities. Disney has instituted and 22 continues to utilize policies which deny or which aid or incite the denial of 23 P.A.D.’s full and equal enjoyment of Disney’s public accommodations in the 24 same manner as non-disabled persons. Disney refuses to modify its policies 25

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1 and procedures to permit fair enjoyment of its facilities by P.A.D. As a direct 2 and proximate result of the afore-mentioned acts and omissions, P.A.D. has 3 suffered, and continues to suffer, hardship, humiliation and anxiety due to 4 Disney’s failure to provide reasonable accommodations and access as are 5 required by P.A.D.’s cognitive impairments. 6 1642. Due to the continuous nature of Disney’s ongoing discriminatory 7 conduct, declaratory and injunctive relief are appropriate. Moreover, as a 8 result of Disney’s action, P.A.D. is suffering irreparable harm, and thus 9 expeditious relief is appropriate. 10 WHEREFORE, Plaintiff P.A.D., by and through A.C.E. as his next friend,

11 parent and natural guardian, prays that this Court adjudicate this dispute 12 and enter an Order: 13 • Enjoining Defendant to cease the practices which are causing 14 discrimination against Plaintiff on account of P.A.D.’s disability; 15 and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Enjoining Defendant to reasonably modify its policies, practices, 17 and procedures to afford Plaintiff with an opportunity to 18 experience Disney’s goods, services, facilities, privileges, 19 advantages,Deadline.com and accommodations; and 20 • Establishing Court-approved remedial measures that Disney must 21 implement, to prevent Disney from further discriminating against 22 Plaintiff when they visit the Disney Parks; and 23 • Establishing Court-approved requirements for information 24 dissemination about Disney’s remedial measures and modified 25

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1 policies, to prevent Disney from further deterring Plaintiff from 2 visiting Disney Parks as a result of anticipated discrimination; and 3 • Establishing a monitoring program to ensure Disney’s compliance 4 with the Court’s Orders; and 5 • Determining the amount of P.A.D.’s actual damages; and 6 • Entering judgment in favor of Plaintiff and against Disney for an 7 amount up to three times the amounts of Plaintiff’s actual 8 damages, but in no event less than $4,000; and 9 • Awarding reasonable attorney’s fees as may be determined by the 10 Court in favor of Plaintiff and against Disney; and

11 • Awarding reasonable litigation costs as may be determined by the 12 Court in favor of Plaintiff and against Disney; and 13 • Such other relief as this Court may find just and equitable. 14 COUNT 138 15 Negligent Infliction of Emotional Distress 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI A.C.E. v. Disney 17 1643. Plaintiff A.C.E. incorporates and re-alleges paragraphs 1 through 18 90, 1600 through 1630, 1632 through 1635 and 1637 through 1642 above. 19 1644. DuringDeadline.com one or more visits to the Parks, A.C.E.’s beloved son P.A.D. 20 suffered an actual meltdown while in A.C.E.’s presence. 21 1645. The symptoms and conditions associated with P.A.D.’s meltdown 22 constitute a physical injury to A.C.E. under California law. 23 1646. P.A.D.’s meltdown in the Parks was proximately caused by 24 Disney’s negligent, unlawful, reckless and arbitrary treatment of P.A.D. during 25

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1 his patronage of Disney’s facilities. At all material times, Disney knew P.A.D. 2 to be vulnerable to emotional injury if treated in such a manner by anyone. 3 1647. A.C.E. directly observed the stressors leading up to the meltdown, 4 P.A.D.’s resulting escalation and his meltdown. Particularly in light of her 5 trust and confidence that Disney would comply with applicable law and act in 6 a gracious and caring manner toward her son, A.C.E. could do nothing 7 reasonable to prevent the meltdown. 8 1648. A.C.E.’s observation of P.A.D.’s meltdown and of the outrageous 9 conduct and treatment which proximately caused P.A.D. to experience the 10 meltdown caused P.A.D. grave and extreme mental anguish and emotional

11 trauma, for which Disney should be held accountable. 12 WHEREFORE, Plaintiff A.C.E. prays that this Court adjudicate this 13 dispute and enter an Order: 14 • Finding that Disney negligently inflicted emotional distress upon 15 A.C.E.; and 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI • Finding such infliction to have caused damages to A.C.E.; and 17 • Entering judgment for Plaintiff A.C.E. in the amount of such 18 damages; and 19 • AwardingDeadline.com reasonable litigation costs as may be determined by the 20 Court in favor of Plaintiff and against Disney; and 21 • Awarding prejudgment interest; and 22 • Such other relief as this Court may find just and equitable. 23

24 25

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1 COUNT 139 2 Intentional Infliction of Emotional Distress 3 A.C.E. v. Disney 4 1649. Plaintiff A.C.E. incorporates and re-alleges paragraphs 1 through 5 90, 1600 through 1630, 1632 through 1635 and 1637 through 1642 above. 6 1650. During one or more visits to the Parks, A.C.E.’s beloved son P.A.D. 7 suffered an actual meltdown. 8 1651. The symptoms and conditions associated with P.A.D.’s meltdown 9 constitute a physical injury under California law. 10 1652. P.A.D.’s meltdown in the Parks was proximately caused by

11 Disney’s outrageous, unlawful and reckless treatment of P.A.D. during his 12 patronage of Disney’s facilities. At all material times, Disney knew P.A.D. to be 13 vulnerable to emotional injury if treated in such a manner by anyone. 14 1653. A.C.E. directly observed the stressors leading up to the meltdown, 15 P.A.D.’s resulting escalation and his meltdown. Particularly in light of her 16 trust and confidence that Disney would comply with applicable law and act in DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 17 a gracious and caring manner toward her son, A.C.E. could do nothing 18 reasonable to prevent the meltdown. 19 1654. A.C.E.’sDeadline.com observation of P.A.D.’s meltdown and of the outrageous 20 conduct and treatment which proximately caused P.A.D. to experience the 21 meltdown caused A.C.E. grave and extreme mental anguish and emotional 22 trauma, for which Disney should be held accountable. 23 WHEREFORE, Plaintiff A.C.E. prays that this Court adjudicate this 24 dispute and enter an Order: 25

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1 • Finding that Disney intentionally inflicted emotional distress upon 2 A.C.E.; and 3 • Finding such infliction to have caused damages to A.C.E.; and 4 • Entering judgment for Plaintiff A.C.E. in the amount of such 5 damages; 6 • Entering judgment in favor of Plaintiffs and against Disney for 7 exemplary or punitive damages; and 8 • Awarding reasonable litigation costs as may be determined by the 9 Court in favor of Plaintiff and against Disney; and 10 • Awarding prejudgment interest; and

11 • Such other relief as this Court may find just and equitable. 12 COUNT 140 13 Breach of Contract 14 A.C.E. v. Disney 15 1655. Plaintiff A.C.E. incorporates and re-alleges paragraphs 1 through 16

DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI 90, 1600 through 1630, 1632 through 1635 and 1637 through 1642 above. 17 1656. A.C.E. entered into a contract through which Disney promised to 18 provide a reasonable and enjoyable amusement park experience, and one 19 which complies withDeadline.com applicable law. 20 1657. Disney failed or refused to provide the promised experience, and 21 is in breach of contract. 22 1658. A.C.E. incurred expenses associated with the family’s wasted trips 23 to the Parks. Plaintiff is damaged by Disney’s breach of contract. 24 25

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1 WHEREFORE, Plaintiff A.C.E. prays that this Court adjudicate this 2 dispute and enter an Order: 3 • Finding that Disney breached its contract with A.C.E.; and 4 • Entering judgment for Plaintiff A.C.E. in the amount of her 5 economic monetary damages; and 6 • Awarding reasonable litigation costs as may be determined by the 7 Court in favor of Plaintiff and against Disney; and 8 • Awarding prejudgment interest; and 9 • Such other relief as this Court may find just and equitable. 10

11 DEMAND FOR JURY TRIAL 12 Each Plaintiff demands trial by jury for all issues which are so triable. 13 14 Dated: May 11, 2015 15

16 /s/ Andy Dogali /s/ Eugene Feldman DOGALI LAW GROUP, P.A. GROUP, LAW DOGALI ANDY DOGALI EUGENE FELDMAN 17 Pro Hac Vice to be submitted California Bar No. 118497 18 Florida Bar No. 0615862 Eugene Feldman, Attorney at Law, 19 Dogali Law Group, P.A. Deadline.com 20 21

22 23 Attorneys for Plaintiffs Attorneys for Plaintiffs 24 25 26 Page 421 ______COMPLAINT T.P., by and through S.P., et al. v. Walt Disney Parks & Resorts US, Inc. Case No. ______

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EXHIBIT 1 Deadline.com

EXHIBIT 2 Deadline.com

EXHIBIT 3 Deadline.com