(Declaratory Relief)   (Disability Discrimination in Violations of NYC Human Rights Law § 8-107(4))  (Injunctive Relief and Damages on Behalf of Plaintiffs)   (Failure to Reasonably Accommodate in violation of NYC Human Rights Law § 8-107(15))   (Injunctive Relief and Damages on Behalf of Plaintiffs)   (Violations of New York State Civil Rights Law)  (Statutory Damages on Behalf of Plaintiffs)   (Violations of New York State Human Rights Law)  (Injunctive Relief and Damages on Behalf of Plaintiffs)   (Violations of the Americans with Disabilities Act)  (Injunctive Relief)   25.  Plaintiff is paralyzed and cannot walk. As a result, he uses a wheelchair for mobility.   27.  Defendant DLP GROUP, LLC owns or operates a public accommodation named Stone  Street Coffee Company located 132 Ninth Avenue, New York, NY.   28.  Throughout 2015 and 2016, Plaintiff entered-attempted to use Defendants' public  accommodation, however was unable to enter because of an unlawful architectural barrier.   29.  Plaintiff resides less than 600 feet from Defendant's public accommodation and is  frequently near Defendant's facility.   30.  Plaintiff is deterred from visiting Defendants’ public accommodation because of the  existing accessibility barriers.    31.  Plaintiff has the intention to return to Defendants’ public accommodation once it  becomes readily accessible to and usable.   32.  The removal of existing architectural barriers is readily achievable.    33.  To date, Defendants have failed to remove the architectural barriers.  34.  Defendants’ facility named Stone Street Coffee Company located 132 Ninth Avenue,  New York, NY is a public accommodation within the meaning of Title III of the ADA, 42  58.  Plaintiff realleges and incorporates by this reference all of the allegations set forth in this  Complaint as if fully set forth herein.   59.  Defendants’ facility named Stone Street Coffee Company located 132 Ninth Avenue,  New York, NY is a public accommodation within the meaning of New York State Human  Rights Law § 292(9).   60.  Defendants have not provided Plaintiff and others similarly situated with evenhanded  treatment in violation of New York State Human Rights Law § 296.   61.  Defendants’ direct or indirect unevenhanded treatment of Plaintiff and others similarly  situated is demonstrated when he was segregated from all other customers.    62.  Defendants have, because of Plaintiff’s disability, directly or indirectly, refused, withheld  from or denied Plaintiff any of the accommodations, advantages, facilities or privileges of their  public accommodation.     63.  Defendants have demonstrated that the patronage or custom thereat of Plaintiff and  others similarly situated, is unwelcome, objectionable or not acceptable, desired or solicited.   64.  Defendants and its agents discriminated against Plaintiff in violation of New York  State Human Rights Law § 296.   65.  Defendants discriminated in against Plaintiff  by creating, fostering, and otherwise failing  to prevent or remedy the discrimination against Plaintiff, in violation of New York State Human  Rights Law § 296.   67.  Plaintiff realleges and incorporates by this reference all of the allegations set forth in this  Complaint as if fully set forth herein.   68.  On the basis of Plaintiff’s disability, Defendants have violated his Civil Rights.   69.  Consequently, Plaintiff is entitled to recover the penalty prescribed by Civil Rights  Law § 40-c and 40-d, in the amount of $500 for each and every violation.   70.  Pursuant to NY Civil Rights law, Defendants are guilty of a class A misdemeanor.   71.  Notice of the action has been served upon the Attorney-General as required by Civil  Rights Law § 40-d.  72.  Plaintiff realleges and incorporates by this reference all of the allegations set forth in this  Complaint as if fully set forth herein.   73.  Defendants’ facility named Stone Street Coffee Company located 132 Ninth Avenue,  New York, NY is a place or provider of public accommodation within the meaning of New  York City Administrative Code § 8-102(9).   74.  In violation of New York City Admin. Code § 8-107(4), Defendants have not reasonably  accommodated Plaintiff and others similarly situated.   76.  In violation of New York City Admin. Code, the owner, lessee, proprietor,  manager,  agent and employee of defendants' public accommodation, have, because of the actual or  perceived disability of the Plaintiff, directly or indirectly, refused, withheld from and denied  Plaintiff the accommodations, advantages, facilities or privileges thereof.   77.  In violation of New York City Admin. Code, on the basis of Plaintiff’s disability,  Defendants have demonstrated that the patronage or custom of Plaintiff and all others similarly  situated, is unwelcome, objectionable, and not acceptable.   78.   Pursuant to New York City Human Rights Law § 8-502, notice of this action has been  served upon New York City's Commission on Human Rights.   79.  As a direct and proximate result of Defendants disability discrimination in violation  of the New York City Human Rights Law, Plaintiff has suffered and continues to suffer  mental anguish and emotional distress, including but not limited to depression, humiliation,  stress, embarrassment, anxiety, loss of self-esteem and self-confidence, and emotional pain  and suffering.  80.  Plaintiff realleges and incorporates by this reference all of the allegations set forth in this  Complaint as if fully set forth herein.   81.  Reasonable accommodations and modifications are necessary to enable Plaintiff and all  others similarly situated the ability to enjoy the non-restricted access and use of the public  accommodation in question.   83.  In violation of New York City Admin. Code 8-102(4) and (18), and 8-107(4) and 8- 107(15), Defendants have not reasonably accommodated Plaintiff and others similarly situated.   84.  In violation of New York City Admin. Code, Defendants have unlawfully discriminated  against Plaintiff and all others similarly situated.   85.  Reasonable accommodations and modifications are necessary to enable Plaintiff and all  others similarly situated the ability to enjoy the non-restricted access and use of the public  accommodation in question.   86.  In violation of New York City Admin. Code, the owner, lessee, proprietor, manager,  agent and employee of defendants' public accommodation, have, because of the actual or  perceived disability of the Plaintiff, directly or indirectly, refused, withheld from and denied  Plaintiff the accommodations, advantages, facilities or privileges thereof.   87.  In violation of New York City Admin. Code, Defendants have demonstrated that,  because of Plaintiff's disability, the patronage or custom of Plaintiff and all others similarly  situated, is unwelcome, objectionable, and not acceptable.   88.  As a direct and proximate result of Defendants disability discrimination in violation  of the New York City Human Rights Law, Plaintiff has suffered and continues to suffer  mental anguish and emotional distress, including but not limited to depression, humiliation,  stress, embarrassment, anxiety, loss of self-esteem and self-confidence, and emotional pain  and suffering.  90.  Plaintiff is entitled to a declaratory judgment concerning the violations committed by  Defendant specifying the rights of Plaintiff and other persons similarly situated as to the  policies, practices, procedures, facilities, goods and services provided by Defendant. 