37.  Plaintiff has visited Defendants’ facilities located at 1987 Sam Rittenberg Blvd.,  Charleston, SC, including within the last year, where he experienced unnecessary difficulty and  risk due to excessive slopes in a purportedly accessible parking space and other ADA accessibility  violations as set forth in more detail below.   39.  As a result of Defendants’ non-compliance with the ADA, Plaintiff’s ability to  access and safely use Defendants’ facilities has been significantly impeded.   40.  Plaintiff will be deterred from returning to and fully and safely accessing  Defendants’ facilities, however, so long as Defendants’ facilities remain non-compliant, and so  long as Defendants continue to employ the same policies and practices that have led, and in the  future will lead, to inaccessibility at Defendants’ facilities.   41.  Without injunctive relief, Plaintiff will continue to be unable to fully and safely  access Defendants’ facilities in violation of his rights under the ADA.   42.  As an individual with a mobility disability who is dependent upon a wheelchair,  Plaintiff is directly interested in whether public accommodations, like Defendants’ facilities, have  architectural barriers that impede full accessibility to those accommodations by individuals with  mobility-related disabilities.  II.  Defendants Repeatedly Deny Individuals With Disabilities Full and Equal Access to  Defendants’ Facilities.   43.  Defendants are engaged in the ownership, management, and development of retail  properties, primarily malls and shopping centers, throughout the United States.   44.  As the owner and manager of their properties, Defendants employ centralized  policies, practices, and procedures with regard to the design, construction, alteration, maintenance,  and operation of their facilities.   47.  The fact that individuals with mobility-related disabilities are denied full and equal  access to numerous of Defendants’ facilities, and the fact that each of these facilities deny access  by way of inaccessible parking facilities, is evidence that the inaccessibility Plaintiff experienced  is not isolated, but rather, is caused by Defendants’ systemic disregard for the rights of individuals  with disabilities.   48.  Defendants’ systemic access violations demonstrate that Defendants either employ  policies and practices that fail to design, construct, and alter their facilities so that they are readily  accessible and usable and/or that Defendants employ maintenance and operational policies and  practices that are unable to maintain accessibility.   49.  As evidenced by the widespread inaccessibility of Defendants’ parking facilities,  absent a change in Defendants’ corporate policies and practices, access barriers are likely to  reoccur in Defendants’ facilities even after they have been remediated.   50.  Accordingly, Plaintiff seeks an injunction to remove the barriers currently present  at Defendants’ facilities and an injunction to modify the policies and practices that have created or  allowed, and will create or allow, inaccessibility to affect Defendants’ network of facilities.  52.  Numerosity: The class described above is so numerous that joinder of all individual  members in one action would be impracticable.  The disposition of the individual claims of the  respective class members through this class action will benefit both the parties and this Court and  will facilitate judicial economy.   53.  Typicality:  Plaintiff’s claims are typical of the claims of the members of the class.   The claims of Plaintiff and members of the class are based on the same legal theories and arise  from the same unlawful conduct.   54.  Common Questions of Fact and Law:  There is a well-defined community of  interest and common questions of fact and law affecting members of the class in that they all have  been and/or are being denied their civil rights to full and equal access to, and use and enjoyment  of, Defendants’ facilities and/or services due to Defendants’ failure to make their facilities fully  accessible and independently usable as above described.   55.  Adequacy of Representation:  Plaintiff is an adequate representative of the class  because his interests do not conflict with the interests of the members of the class.  Plaintiff will  fairly, adequately, and vigorously represent and protect the interests of the members of the class,  and he has no interests antagonistic to the members of the class.  Plaintiff has retained counsel who  are competent and experienced in the prosecution of class action litigation, generally, and who  possess specific expertise in the context of class litigation under the ADA.   56.  Class certification is appropriate pursuant to Fed. R. Civ. P. 23(b)(2) because  Defendants have acted or refused to act on grounds generally applicable to the class, making  appropriate both declaratory and injunctive relief with respect to Plaintiff and the class as a whole.    I.  Plaintiff Has Been Denied Full and Equal Access to Defendants’ Facilities.  