24.  Plaintiff Murphy visited Defendant’s facilities located at Youngfield Street in  Wheat Ridge, Colorado, where he experienced unnecessary difficulty and risk due to excessive  slopes in a purportedly accessible parking area. As a result of Defendant’s non-compliance with  the ADA, Plaintiff Murphy’s ability to access and safely use Defendant’s facilities has been  significantly impeded.   25.  Despite this difficulty and risk, Plaintiff Murphy plans to return to Defendant’s  facilities. The shopping center Defendant owns is close to Plaintiff Murphy’s residence. The center  features a grocery store and other stores which Plaintiff Murphy regularly visits due to its  proximity to his residence. Furthermore, Plaintiff Murphy intends to return to Defendant’s  facilities to ascertain whether those facilities remain in violation of the ADA.   27.  Despite this difficulty and risk, Plaintiff Kouri plans to return to Defendant’s  facilities. Plaintiff Kouri travels to San Diego frequently for fitness conferences related to his  business, and also to visit numerous friends in the area. The shopping center Defendant owns is  close to the conference locations and/or Plaintiff’s Kouri’s friends in the area, and he intends to  return. Furthermore, Plaintiff Kouri intends to return to Defendant’s facilities to ascertain whether  those facilities remain in violation of the ADA.   28.  Plaintiffs will be deterred from returning to and fully and safely accessing  Defendant’s facilities, however, so long as Defendant’s facilities remain non-compliant, and so  long as Defendant continue to employ the same policies and practices that have led, and in the  future will lead, to inaccessibility at Defendant’s facilities.   29.  Without injunctive relief, Plaintiffs will continue to be unable to fully and safely  access Defendant’s facilities in violation of his rights under the ADA.   30.  As individuals living with a mobility disabilities who use wheelchairs, Plaintiffs  are directly interested in whether public accommodations, like Defendant’s facilities, have  architectural barriers that impede full accessibility to those accommodations by individuals with  mobility-related disabilities.   31.  In June 2018, counsel for Plaintiffs sent a letter to Defendant describing the ADA  violations at issue and requesting a negotiated resolution.  Defendant never even responded to  Plaintiffs’ letter.    II.  Defendant Repeatedly Denies Individuals With Disabilities Full and Equal Access to  Defendant’s Facilities.   33.  To date, Defendant’s centralized design, construction, alteration, maintenance, and  operational policies and practices have systematically and routinely violated the ADA by  designing, constructing, and altering facilities so that they are not readily accessible and are usable,  by failing to remove architectural barriers, and by failing to maintain and operate facilities so that  the accessible features of Defendant’s facilities are maintained.   35.  The fact that individuals with mobility-related disabilities are denied full and equal  access to numerous of Defendant’s facilities, and the fact that each of these facilities deny access  by way of inaccessible parking facilities, is evidence that the inaccessibility Plaintiffs experienced  is not isolated, but rather, is caused by Defendant’s systemic disregard for the rights of individuals  with disabilities.   36.  Defendant’s systemic access violations demonstrate that Defendant either employs  policies and practices that fail to design, construct, and alter their facilities so that they are readily  accessible and usable and/or that Defendant employs maintenance and operational policies and  practices that are unable to maintain accessibility.   37.  As evidenced by the widespread inaccessibility of Defendant’s parking facilities,  absent a change in Defendant’s corporate policies and practices, access barriers are likely to  reoccur in Defendant’s facilities even after they have been remediated.   I.  Plaintiffs Have Been Denied Full and Equal Access to Defendant’s Facilities.  