51.  Plaintiffs bring this action individually, and on behalf of all persons with mobility  disabilities who use or will use the pedestrian right of way in the City of Seattle, as a class action  under Rule 23(b)(2) of the Federal Rules of Civil Procedure.     61.  Plaintiffs incorporate by reference each and every allegation contained in the  foregoing paragraphs.   62.  Title II of the ADA provides in pertinent part: “[N]o qualified individual with a  disability shall, by reason of such disability, be excluded from participation in or be denied the  benefits of the services, programs, or activities of a public entity, or be subjected to  discrimination by any such entity.”  42 U.S.C. § 12132.    63.   At all times relevant to this action, the City was and is a “public entity” within  the meaning of Title II of the ADA and provides a pedestrian right of way program, service, or  activity to the general public.   77.  Plaintiffs incorporate by reference each and every allegation contained in the  foregoing paragraphs.   78.  Section 504 of the Rehabilitation Act of 1973 provides in pertinent part: “[N]o  otherwise qualified individual with a disability . . . shall, solely by reason of her or his disability, be  excluded from the participation in, be denied the benefits of, or be subjected to discrimination under  any program or activity receiving federal financial assistance . . .”  29 U.S.C. § 794(a).   79.  Plaintiffs are otherwise qualified to participate in the services, programs, or  activities that are provided to individuals in the City.  See 29 U.S.C. § 794(b).    80.  The City is a direct recipient of federal financial assistance sufficient to invoke the  coverage of Section 504, and has received such federal financial assistance at all times relevant to  the claims asserted in this Complaint.   81.  Defendant and its agents and employees have violated and continue to violate the  Rehabilitation Act and the regulations promulgated thereunder by excluding Plaintiffs from  participation in, denying Plaintiffs the benefits of, and subjecting Plaintiffs based solely by reason of  their disability to, discrimination in the benefits and services of the City’s pedestrian right of way  and for the reasons set forth above.   86.  Plaintiffs incorporate by reference each and every allegation contained in the  foregoing paragraphs.   Section 504 of the Rehabilitation Act of 1973  29 U.S.C. § 794 et seq.   Title II of the Americans with Disabilities Act of 1990   42 U.S.C. § 12101 et seq.   Washington Law Against Discrimination  Revised Code of Washington §§ 49.60.010-49.60.505  