57.  Upon information and belief, the Class 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.   58.  Typicality: Plaintiffs claims are typical of the claims of the members of the  Class. The claims of the Plaintiff and members of the Class are based on the same legal theories  and arise from the same unlawful conduct.   59.  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 its  facilities fully accessible and independently usable as above described.   61.  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 have 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.   62.  Class certification is appropriate pursuant to Rule 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.  63.  The allegations contained in the previous paragraphs are incorporated by  reference.   64.  Defendants' facilities were required to be altered, designed, or constructed so that  they are readily accessible and usable by disabled individuals, including individuals who use  wheelchairs. See 42 U.S.C. § 12183(a)(l).   65.  The architectural barriers described above demonstrate that Defendants' facilities  were not altered, designed, or constructed in a manner that causes them to be readily accessible  to and usable by individuals who use wheelchairs, including Plaintiff and the class she seeks to  represent.   66.  The architectural barriers described above demonstrate that Defendants have  failed to remove barriers, as required by 42 U.S.C. § 12182(b)(2)(A)(iv).   68.  Defendants are required to provide individuals who use wheelchairs full and equal  enjoyment of its facilities. See 42 U.S.C. § 12182(a).   69.  Defendants have discriminated against Plaintiff and the Class in that it has failed  to make its facilities fully accessible to, and independently usable by, individuals who use  wheelchairs in violation of the ADA, as described above.   70.  Defendants' conduct is ongoing, and, given that Defendants have not complied  with the ADA's requirements that public accommodations be fully accessible to, and  independently usable by, individuals with disabilities, Plaintiff invokes her statutory right to  declaratory and injunctive relief, as well as costs and attorneys' fees.   71.  Without the requested injunctive relief, specifically including the request that the  Court retain jurisdiction of this matter for a period to be determined after the Defendants certify  that it is fully in compliance with the mandatory requirements of the ADA that are discussed  above, Defendants' non-compliance with the ADA's requirements that its facilities be accessible  to, and independently usable, by individuals with disabilities is likely to recur.  VIOLATION OF THE ADA  