14.  Defendant owns, manages and/or operates many hotels throughout the United  States.   15.  As part of these operations, Defendant provides its customers transportation  services, including, but not limited to, complimentary shuttle services.   16.  Within the applicable limitations period, Plaintiff called the Crowne Plaza located  in King of Prussia, PA, and was told by an agent of Defendant that Crowne Plaza provides a  complimentary shuttle service for guests.   17.  Plaintiff was told that the complimentary shuttle service was not wheelchair  accessible and was told that Defendant would not provide an alternative transportation service.   18.  An investigation performed on Plaintiffs behalf confirmed the allegations made by  Plaintiff above.   21.  Plaintiff brings this action under Rule 23(a) and (b )(2) of the federal rules of civil  procedure and on behalf of herself and the following class: "All individuals who use wheelchairs  or scooters for mobility and who have been, or in the future will be, denied the full and equal  enjoyment of transportation services offered to guests at hotels owned and/or operated by  Defendant because of the lack of equivalent accessible transportation services at those hotels."   23.  Typicality: Plaintiffs 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.   24.  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, Defendant's goods, services and facilities due to the policies and practices described above.   25.  Adequacy of Representation: Plaintiff is an adequate representative of the class  because her 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 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.   26.  Class certification is appropriate pursuant to Fed. R. Civ. P. 23(b)(2) because  Defendant has 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.  27.  Plaintiff incorporates by reference each and every allegation herein.   28.  Plaintiff brings this claim individually and on behalf of the class.   29.  Plaintiff is the guardian of Joy Barbara Levin, an individual with a disability under  the ADA. 42 U.S.C. § 12102(1)(A).   31.  Title Ill of the ADA prohibits discrimination against individuals with disabilities in  the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or  accommodations of any place of public accommodation by any person who owns, leases (or leases  to), or operates a place of public accommodation. 42 U.S.C. § 12182(a).   32.  Defendant operates fixed route systems and demand responsive systems within the  meaning of the ADA. 42 U.S.C. § 12181(3) and (4).   33.  For fixed route systems, Defendant must meet the following requirements: a) for  all purchases or leases after August 25, 1990, vehicles with a seating capacity over 16 passengers  must be wheelchair-accessible; and b) for all purchases or leases after August 25, i990, vehicles  with a seating capacity of under 16 passengers must either be either wheelchair-accessible or  equivalent service must be provided. 42 U.S.C. § 12182(B).   34.  For demand responsive systems, Defendant must provide wheelchair-accessible  vehicles or ensure that equivalent service is provided. 42 U .S.C. § l 2 l 82(C)   35.  Defendant has engaged in illegal disability discrimination by, without limitation,  failing to ensure that transportation vehicles in use at the hotels it manages and/or operates are  readily accessible to and usable by individuals with disabilities, including individuals who use  wheelchairs, by failing to ensure that its hotels provide equivalent accessible transportation  services to such individuals, and/or by failing to ensure that personnel are trained to proficiency  with respect to the provision of accessible transportation services.   Violations of 42 U.S.C. §§ 12181, et seq.  