23.  Plaintiff has visited Defendant’s facilities located at 9999 W 38th Ave., Wheat  Ridge, Colorado, including within the last year, where he experienced unnecessary difficulty and  risk due to excessive slopes in a purportedly accessible parking area and other ADA accessibility  violations as set forth in more detail below.   24.  Despite this difficulty and risk, Plaintiff plans to return to Defendant’s facilities,  at least six times a year. It is convenient for him to stop by regularly to continue to test  Defendant’s facilities’ compliance with the ADA because Plaintiff and his wife regularly drive  near Defendant’s facilities. Furthermore, Plaintiff intends to return to Defendant’s facilities to  ascertain whether those facilities remain in violation of the ADA.   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 his rights under the ADA.   28.  As an individual with a mobility disability who uses a wheelchair, Plaintiff is  directly interested in whether public accommodations, like Defendant’s 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  Defendant’s Facilities   29.  As the owner and manager of their properties, Defendant employs centralized  policies, practices, and procedures with regard to the design, construction, alteration,  maintenance, and operation of their facilities.   30.  To date, Defendant’s centralized design, construction, alteration, maintenance,  and operational policies and practices have systematically and routinely violated the ADA by  designing, constructing, and altering facilities so that they are not readily accessible and are  usable, by failing to remove architectural barriers, and by failing to maintain and operate  facilities so that the accessible features of Defendants’ facilities are maintained.   32.  The fact that individuals with mobility-related disabilities are denied full and  equal access to numerous of Defendant’s 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 Defendant’s systemic disregard for the rights  of individuals with disabilities.   33.  Defendant’s systemic access violations demonstrate that Defendant either  employs policies and practices that fail to design, construct, and alter its facilities so that they are  readily accessible and usable and/or that Defendant employs maintenance and operational  policies and practices that are unable to maintain accessibility.   35.  Accordingly, Plaintiff seeks an injunction to remove the barriers currently present  at Defendant’s 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 Defendant’s Facilities  