24.  Despite this difficulty and risk, Plaintiff plans to return to Defendant’s facilities, as  she lives near and visits Defendant’s facilities for goods and services. Specifically, Plaintiff visits  Defendant’s facilities in order to purchase boxes and other supplies for moving and storage.   Furthermore, Plaintiff intends to return to Defendant’s facilities to ascertain whether those  facilities remain in violation of the ADA.   25.  As a result of Defendant’s non-compliance with the ADA, Plaintiff’s ability to  access and safely use Defendant’s facilities has been significantly impeded.   26.  Plaintiff 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 continues to employ the same policies and practices that have led, and in the  future will lead, to inaccessibility at Defendant’s facilities.   27.  Without injunctive relief, Plaintiff will continue to be unable to fully and safely  access Defendant’s facilities in violation of her rights under the ADA.   28.  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.  Defendant’s Facilities are Public Accommodations Operated by Defendant   29.  Defendant is engaged in the operation, management and development of self- storage properties throughout the United States.   31.  While Defendant does own some of the properties in its network of retail moving  stores, it is primarily engaged in operating and managing properties for other companies that have  entered into agreements to license, sell, and distribute Defendant and its subsidiaries’ products and  services on properties not owned by Defendant.   32.  Defendant is a party to numerous “property management agreements” which  designate the Defendant as the “Manager” of retail moving stores, tasked with the responsibility  of managing and operating the properties and their respective facilities.    33.  These property management agreements specify in detail that Defendant has “the  sole and exclusive duty and authority to fully manage the Property and supervise and direct the  business and affairs associated or related to the daily operation thereof”.2   35.  As the operator, owner and/or manager of their properties, Defendant employs  centralized policies, practices and procedures with regard to the operation, maintenance, design,  construction, and/or alteration of its facilities.   36.  To date, Defendant’s centralized policies and practices have systematically and  routinely violated the ADA by failing to ensure that Defendant’s facilities are readily accessible  and independently 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.  I.  Plaintiff Has Been Denied Full and Equal Access to Defendant’s Facilities.  