27.  Despite this difficulty and risk, Plaintiff plans to return to Defendants’ facilities.  Plaintiff likes Arby’s and enjoys eating there several times a year. Plaintiff would like to return  to this Arby’s in the future, but is deterred from doing so given the limitations of the facility.  Furthermore, Plaintiff intends to return to Defendants’ facilities to ascertain whether those  facilities remain in violation of the ADA.   28.  As a result of Defendants’ non-compliance with the ADA, Plaintiff’s ability to  access and safely use Defendants’ facilities has been significantly impeded.   29.  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.   30.  Without injunctive relief, Plaintiff will continue to be unable to fully and safely  access Defendants’ facilities in violation of his rights under the ADA.   31.  As an individual with mobility disabilities who uses 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.   32.  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.   35.  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.   37.  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.   38.  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.  I.  Plaintiff Has Been Denied Full and Equal Access to Defendants’ Facilities  