UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

 CASE NO.: 0:20-CV-61389-RNS

HOWARD COHAN,

Plaintiff,

vs.

CYPRESS GRANDE LLC, a Florida

limited liability company d/b/a

Fuzzy’s Taco Shop,

Defendant(s).

____________________________________/

JOINT MOTION FOR APPROVAL AND ENTRY OF CONSENT DECREE

Plaintiff, HOWARD COHAN (hereinafter referred to as “Plaintiff”), and CYPRESS 

GRANDE LLC, a Florida limited liability company, d/b/a FUZZY’S TACO SHOP (hereinafter 

referred to as “Defendant”) (Plaintiff and Defendant jointly referenced herein as the “Parties”), 

by and through their respective undersigned counsel, hereby move for the Court’s approval and 

entry of the attached Consent Decree.

1. Plaintiff filed the instant cause of action alleging that the property at issue owned 

and/or operated by Defendant violated Title III of the Americans with Disabilities Act, 42 U.S.C. 

§ 12181 et seq. (“Title III” of the “ADA”).

2. The matters raised by Plaintiff’s Complaint have been resolved in accordance 

with the Consent Decree attached hereto as Exhibit “A.”

3. The Parties agree and submit that the attached Consent Decree is fundamentally 

fair, adequate and reasonable to improve access for persons with disabilities at the properties at 

issue, and otherwise meets the purposes of Title III of the ADA. The Parties further agree that 

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given the completion of the Modifications specified in the Consent Decree all currently readily 

achievable alterations to the Property have been made and that the Properties at the time of 

execution of this Consent Decree are otherwise in compliance with the readily achievable 

requirements of the ADA, ADAAG and FACBC.

4. In accordance therewith, the parties respectfully request that the Court review, 

approve and ratify the Consent Decree. Additionally, the Parties request the Court retain 

jurisdiction to enforce the Consent Decree. See Anago Franchising, Inc. v. Shaz, LLC, 677 F.3d 

1272, 1280 (11th Cir. 2012). 

WHEREFORE, the parties respectfully request that the Court grant this Motion; enter an 

order (a) approving and entering the attached Consent Decree, and (b) retaining jurisdiction to 

enforce the Consent Decree; and grant such additional relief as the Court deems just and proper.

Dated: August 10, 2020 Respectfully submitted,

/s/ Gregory S. Sconzo

Gregory S. Sconzo, Esq. 

Florida Bar No.: 0105553

Sconzo Law Office, P.A.

3825 PGA Boulevard, Suite 207

Palm Beach Gardens, FL 33418

Phone: (561) 729-0940 Fax: (561) 491-9459

sconzolaw@gmail.com

Attorney for Plaintiff, Howard Cohan

/s/ William G. Salim, Jr.

William G. Salim, Jr., Esq.

Florida Bar No.: 750379

Moskowitz, Mandell, Salim & Simowitz, P.A.

800 Corporate Drive, Suite 500

Fort Lauderdale, Florida 33334

Telephone: (954) 491-2000

E-mail: wsalim@mmsslaw.com

Attorney for Defendant

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CERTIFICATE OF SERVICE

I hereby certify that on August 10, 2020, I electronically filed the foregoing document 

with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being 

served this day on all counsel of record or pro se parties identified on the attached Service List in 

the manner specified, either via transmission of Notices of Electronic Filing generated by 

CM/ECF or in some other authorized manner for those counsel or parties who are not authorized 

to receive electronically Notices of Electronic Filing. 

Sconzo Law Office, P.A.

3825 PGA Boulevard, Suite 207

Palm Beach Gardens, FL 33418

Telephone: (561) 729-0940

Facsimile: (561) 491-9459

By: /s/ Gregory S. Sconzo 

GREGORY S. SCONZO, ESQUIRE

Florida Bar No.: 0105553

Service Email: sconzolaw@gmail.com

Primary Email: greg@sconzolawoffice.com

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