56.  Plaintiff brings this action pursuant to Rules 23(a) and 23(b )(2) of the Federal  Rules of Civil Procedure on behalf of herself and all individuals with disabilities who have  attempted to access, or will attempt to access Defendant's facilities, but experienced difficulty or  hazards in ambulating through Defendant's parking facilities ("Class").   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: Plaintiff's 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, Defendant's facilities and/or services due to Defendant's failure to make its  facilities fully accessible and independently usable as above described.   62.  Class certification is appropriate pursuant to Rule 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.  63.  The allegations contained in the previous paragraphs are incorporated by  reference.   64.  Defendant's 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).   66.  The architectural barriers described above demonstrate that Defendant has failed  to remove barriers, as required by 42 U.S.C. § 12182(b)(2)(A)(iv).   67.  Defendant's facilities are required to comply with the DOJ's 2010 Standards or,  in some cases, the 1991 Standards.   68.  Defendant is required to provide individuals who use wheelchairs full and equal  enjoyment of its facilities. See 42 U.S.C. § 12182(a).   69.  Defendant has 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.  Defendant's conduct is ongoing, and, given that Defendant has 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 Defendant certifies  that it is fully in compliance with the mandatory requirements of the ADA that are discussed  above, Defendant's 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  