UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

HOWARD COHAN, CASE NUMBER: 

Plaintiff, 

V. 

SAHA INTERNATIONAL, INC., 

d/b/a MIAMI SUBS GRILL, 

Defendant. 

COMPLAINT 

Plaintiff, HOWARD COHAN ("Plaintiff'), sues Defendant, SAHA INTERNATIONAL, 

INC., d/b/a MIAMI SUBS GRILL ("Miami Subs" or "Defendant"), and in support thereof states 

as follows: 

JURISDICTION 

1. This is a complaint for breach of contract and injunctive relief seeking enforcement 

of the Settlement Agreement (a copy of same is attached as Exhibit "A") reached in the case of 

HOWARD COHAN v. SAHA INTERNATIONAL, INC., 9:18-cv-81273 -BLOOM/Reinhart 

(S.D. Fla.) ("Prior Action"). 

2. The Prior Action arose out of Plaintiffs claims of discrimination caused by specific 

barriers encountered by Plaintiff at Defendant's real property located at 4513 Lake Worth Road, 

Greenacres, Florida 33463 ("Premises") that prevented Plaintiff from the full and equal enjoyment 

of a place of public accommodation in violation of Title III of the Americans with Disabilities Act 

("ADA"). 

3. This Court is vested with original jurisdiction over this action pursuant to 28 U.S.C. 

§1331 for Plaintiffs claims arising under Title 42 U.S.C. §12182 et. seq., based on Defendant's 

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violations of Title III of the ADA. See also 28 U.S.C. §§2201 and 2202 as well as the 2010 ADA 

Standards. 

4. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(B) and Internal 

Operating Procedures for the United States District Court for the Southern District of Florida in 

that all events giving rise to the lawsuit occurred in the United States Southern District of Florida. 

PARTIES 

5. Plaintiff, HOWARD COHAN is sui juris and is a resident of the State of Florida 

residing in Palm Beach County, Florida. 

6. Upon information and belief, Defendant is the lessee, operator, owner and lessor of 

the Premises, and is the owner of the improvements where the Premises is located. 

7. Defendant is authorized to conduct, and is in fact conducting, business within the 

state of Florida. 

8. Plaintiff is an individual with numerous permanent disabilities including severe 

spinal stenosis of the lumbar spine with spondylolisthesis; severe spinal stenosis of the cervical 

spine with nerve root compromise on the right side; a non-union fracture of the left acromion 

(shoulder); a labral tear of the left shoulder; a full thickness tear of the right rotator cuff; a right 

knee medial meniscal tear; a repaired ACL and bilateral meniscal tear of the left knee; and severe 

basal joint arthritis of the left thumb. The above listed permanent disabilities and symptoms cause 

sudden onsets of severe pain and substantially limit Plaintiffs major life activities. As such, 

Plaintiff suffered from a "qualified disability" under the ADA. 42 U.S.0 § 12101, et seq. 

9. On July 7, 2018, Plaintiff visited the Premises. At the time of Plaintiffs visit to the 

Premises, Plaintiff required the use of fully accessible restrooms. Plaintiff personally visited the 

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Premises, but was denied full and equal access and full and equal enjoyment of the facilities, 

services, goods, and amenities within Miami Subs, even though he was a "bona fide patron". 

10. Defendant's Premises is a place of public accommodation as defined by Title III of 

the ADA and as such is governed by the ADA. 

11. On September 20, 2018, Plaintiff filed the Prior Action seeking judicial intervention 

to have Defendant comply with the ADA and applicable regulations thereto. See Prior Action. 

12. On or about December 14,2018, Plaintiff and Defendant entered into a Confidential 

Settlement Agreement and General Release (Exhibit "A") that required Defendant to complete all 

modifications to the Premises within one (1) year of the date of the Confidential Settlement 

Agreement and Release ("Agreement"), to wit: December 14, 2019. 

13. In connection with said Agreement, on or about December 18, 2018, Plaintiff filed 

a Notice of Voluntary Dismissal without Prejudice of the Prior Action. See Prior Action [D.E. 7] 

14. An Order dismissing the Prior Action without Prejudice was entered by the Court 

on December 18, 2018. See Prior Action [D.E. 8] 

15. On or about August 11, 2020, Plaintiff returned to the Premises and discovered 

that Defendant failed to complete the modifications to the Premises as required under the ADA 

and the Agreement, and Defendant failed to give notice of any reasons or documentation for noncompliance. 

16. Plaintiff required the use of fully accessible restrooms. 

17. Plaintiff was denied full and equal access and full and equal enjoyment of the 

facilities, services, goods, and amenities within the Premises even though he was a "bona fide 

patron". 

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18. Plaintiff, in his individual capacity, has shown that he will absolutely return to the 

Premises and avail himself of the services offered when Defendant modifies the Premises or 

modifies the policies and practices to accommodate individuals who have physical disabilities. 

19. Plaintiff is continuously aware of the violations at Defendant's Premises and is 

aware that it would be a futile gesture to return to the Premises as long as those violations exist, 

and Plaintiff is not willing to suffer additional discrimination. 

20. Plaintiff has suffered, and will continue to suffer, direct and indirect injury as a 

result of Defendant's discrimination until Defendant is compelled to comply with the requirements 

of the ADA. 

21. Plaintiff would like to be able to be a patron of the Premises in the future and be 

able to enjoy the goods and services that are available to the able-bodied public, but is currently 

precluded from doing so as a result of Defendant's discriminatory conduct as described herein. 

Plaintiff will continue to be precluded from using the Premises until corrective measures are taken 

at the Premises to eliminate the discrimination against persons with physical disabilities. 

22. Completely independent of the personal desire to have access to this place of public 

accommodation free of illegal barriers to access, Plaintiff also acts as a "tester" for the purpose of 

discovering, encountering and engaging discrimination against the disabled in public 

accommodations. When acting as a "tester", Plaintiff employs a routine practice. Plaintiff 

personally visits the public accommodation; engages all of the barriers to access, or at least of 

those that Plaintiff is able to access; tests all of those barriers to access to determine whether and 

the extent to which they are illegal barriers to access; proceeds with legal action to enjoin such 

discrimination; and subsequently returns to said premises to verify compliance or non-compliance 

with the ADA and to otherwise use the public accommodation as members of the able-bodied 

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community are able to do. Independent of other subsequent visits, Plaintiff also intends to visit 

the Premises regularly to verify its compliance or non-compliance with the ADA, and its 

maintenance of the accessible features of Premises. In this instance, Plaintiff, in Plaintiffs 

individual capacity and as a "tester", visited Premises, encountered barriers to access at Premises, 

and engaged and tested those barriers, suffered legal harm and legal injury, and will continue to 

suffer such harm and injury as a result of the illegal barriers to access and the ADA violations set 

forth herein. It is Plaintiff's belief that said violations will not be corrected without Court 

intervention, and thus Plaintiff will suffer legal harm and injury in the near future. 

23. Plaintiff, in his capacity as a tester, will absolutely return to the Premises when 

Defendant modifies the Premises or modifies the policies and practices to accommodate 

individuals who have physical disabilities to confirm said modifications have been completed in 

accordance with the requirements of the ADA. 

24. All conditions precedent have occurred, been satisfied or been waived. 

FACTUAL BACKGROUND 

25. On December 13, 2018, Plaintiff and Miami Subs entered into the Agreement. See 

Exhibit "A". 

26. Pursuant to the Agreement, Defendant was required to make specific modifications 

to Miami Subs within one (1) year from the date of the Agreement, to wit: December 14, 2019. 

Plaintiff and Defendant (collectively "Parties" and individually "Party") agreed to attorneys' fees 

and costs in the amount of Three Thousand Two Hundred Fifty Dollars ($3,250.00) ("Payment"). 

See Exhibit "A". 

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27. The Agreement provided that Miami Subs would remain obligated under the terms 

of the Agreement for one (1) year and would make the Payment within twenty (20) days of the 

execution of the Agreement, January 3, 2019. See Exhibit "A". 

28. The Agreement further sets forth: 

"Should either Party to this Agreement institute litigation 

related to this Agreement or the Parties' performance 

hereunder, the prevailing Party in such litigation shall be 

entitled to recover its reasonable attorney's fees and costs, both 

at the trial and appellate level." 

29. On February 15, 2019, Plaintiff sent written correspondence to Miami Subs and his 

Counsel, Peter Weintraub, informing them that Defendant was in breach of the settlement 

agreement because Defendant had not yet paid the settlement amount. As a courtesy, Plaintiff 

informed Defendant they would give him until February 22, 2019, for the balance to be paid. On 

February 26, 2019, Defendants attorney requested, on behalf of Defendant, if payment could be 

accepted the first week of March. As the first week of March approached, no payment was 

received. On March 13, 2019, Plaintiff emailed Defendant again, relaying that Defendant had not 

made the payment. After no response from Defendant from the March 13, 2019 correspondence, 

Defendant made a payment of $400.00 on May 13,2019, despite the Agreement requiring payment 

in full. 

30. On June 28, 2019, Plaintiff sent another written correspondence to Defendant 

asking when the remaining balance would be paid. Defendant responded that a payment of 

$400.00 would be sent the following Wednesday, July 3, 2019, but Defendant made no payment. 

Further, on July 9, 2019, Plaintiff sent written correspondence to Defendant stating no payment 

was received on July 3, 2019. Instead of sending the $400.00 payment previously mentioned, 

Defendant made a $300.00 payment on July 8, 2019. 

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31. After the July 8, 2019 payment was received, Plaintiff sent another correspondence 

on August 20, 2019, seeking the remaining balance of $2,550. Defendant made a $300.00 payment 

on August 20, 2019, instead of the remaining balance owed. 

32. On October 29, 2019, after another correspondence from Plaintiff requesting 

payment, Defendant responded stating that he would make a payment. Ultimately, after the August 

20, 2019 payment was made, no other payment has been received. Plaintiff sent a final written 

correspondence on November 13, 2019, demanding the remaining balance of $2,250 from 

Defendant, which Defendant never answered. 

33. To date, the Payment has not been made to Plaintiff by Miami Subs as required 

under the Agreement. 

34. Plaintiff has retained undersigned counsel and is responsible for payment of 

attorneys' fees and costs. 

35. Pursuant to the Agreement, Plaintiff is entitled to recover attorneys' fees and costs 

expended in enforcing the Agreement. 

COUNT! 

BREACH OF CONTRACT - PAYMENT 

36. Plaintiff realleges and reincorporates paragraphs 1 through 35 above as if fully set 

forth herein. 

37. Plaintiff and Miami Subs entered into the Agreement attached hereto as Exhibit 

38. Plaintiff performed its obligations under the Agreement and was entitled to 

Payment pursuant to same. 

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39. Miami Subs materially breached the Agreement by failing to make the agreed upon 

Payment to Plaintiff as required in the Agreement in the amount of Three Thousand Two Hundred 

Fifty Dollars ($3,250.00). 

40. Defendant has only paid one thousand dollars ($1,000.00) of the amount due. 

41. Plaintiff was damaged by Miami Subs' breach of the Agreement. 

42. Despite numerous courtesies and demands, Defendant has failed to make the agreed 

upon payments to Plaintiffs counsel. 

43. Pursuant to the Agreement, Plaintiff is entitled to recover attorneys' fees and costs 

from Defendant for having to bring this lawsuit. 

WHEREFORE, Plaintiff, HOWARD COHAN, respectfully requests that judgment be 

entered against Defendant, SAHA INTERNATIONAL, INC., in the amount of Two Thousand 

Two Hundred Fifty Dollars ($2,250.00), awarding Plaintiff his attorneys' fees and costs incurred 

in the prosecution of this matter, and granting any other relief the Court deems just and proper. 

COUNT II 

BREACH OF CONTRACT — MODIFICATIONS 

44. Plaintiff adopts and re-alleges the allegations stated in paragraphs 1 through 24 

above as if fully stated herein. 

45. On or about December 14, 2018, the Parties entered into the Agreement. See 

Agreement attached hereto as Exhibit "A". 

46. As a result of the Agreement, Defendant agreed to make modifications to 

Defendant's Premises as outlined in the Agreement. 

47. The Agreement required Defendant to complete all modifications to the Premises 

within one (1) year of the Agreement, to wit: on or before December 14, 2019. 

48. Plaintiff has performed all conditions precedent prior to filing the instant lawsuit. 

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49. Pursuant to the Right to Bring Suit to Enforce provision of the Agreement: 

Plaintiff reserves the right to bring suit against Defendant for 

failure to make the referenced modification(s) listed in 

paragraph 1 and Exhibit "A" any time after the expiration of the 

one (1) year from the date of the signing of this Agreement. 

50. On August 11, 2020, Plaintiff once again returned to the Premises and confirmed 

that Defendant still failed to complete the modifications required by the Agreement. Specifically, 

Defendant failed to address the following violations at the Premises: 

Men's Restroom 

a. Failing to provide toilet paper dispensers in the proper position in front of the 

water closet or at the correct height above the finished floor in violation of 2010 

ADAAG §§604, 604.7 and 309.4 and/or §4.16.6 of the 1991 ADA Standards. 

b. Failing to provide sufficient clear floor space around a water closet without any 

obstructing elements in this space in violation of 2010 ADAAG §§603, 603.2, 

603.2.3, 604, 604.3 and 604.3.1 and/or §§4.16, 4.16.2, 4.22 and 4.22.3 of the 1991 

ADA Standards. 

c. Failing to provide the proper spacing between a grab bar and an object projecting 

out of the wall in violation of 2010 ADAAG §§604, 604.5, 604.5.1, 604.5.2, 609, 

609.3 and 609.4 and/or §§4.16.4, 4.26 and 4.26.2 of the 1991 ADA Standards. 

d. Failing to provide the proper insulation or protection for the plumbing or other 

sharp or abrasive objects under a sink or countertop in violation of 2010 ADAAG 

§§606 and 606.5 and/or §4.24.6 of the 1991 ADA Standards. 

e. Failing to provide the water closet in the proper position relative to the side wall 

or partition in violation of 2010 ADAAG §§604 and 604.2 and/or §§4.16, 4.17.2 

and 4.17.3 of the 1991 ADA Standards. 

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51. Plaintiff has been damaged by Defendant's breach of the Agreement by being 

denied full and equal access to the use of the Premises and once again being subjected to 

discrimination. 

52. Plaintiff has had to retain the services of the undersigned counsel to pursue this 

action for breach of contract. 

53. Pursuant to the Agreement, should either party (Plaintiff or Defendant) institute 

litigation related to the Agreement, the prevailing party in such litigation shall be entitled to recover 

its reasonable attorneys' fees and costs. 

WHEREFORE, Plaintiff demands judgment against Defendant and requests the following 

injunctive and declaratory relief: 

1. That this Court declare that Defendant has failed to comply with the Agreement; 

2. That this Court enter an Order requiring Defendant to alter the Premises to make 

it accessible to and usable by individuals with disabilities to the full extent 

required by Title III of the ADA; 

3. That this Court award reasonable attorneys' fees, all costs (including, but not 

limited to court costs and expert fees) and other expenses of this lawsuit to 

Plaintiff as provided in the Agreement; and 

4. That this Court award such other and further relief as it may deem necessary, just 

and proper. 

COUNT III 

VIOLATIONS OF THE AMERICANS WITH DISABILITIES ACT 

54. Plaintiff adopts and re-alleges the allegations stated in paragraphs 1 through 24 

above as if fully stated herein. 

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55. On July 26, 1990, Congress enacted the ADA, 42 U.S.C. §12101 et. seq. 

Commercial enterprises were provided one and a half (1.5) years from enactment of the statute to 

implement its requirements. The effective date of Title III of the ADA was January 26, 1992, or 

January 26, 1993 if Defendant has ten (10) or fewer employees and gross receipts of $500,000.00 

or less. See 42 U.S.C. §12182; see also 28 C.F.R. §36.508(a). 

56. Congress found, among other things, that: 

a. some 43,000,000 Americans have one or more physical or mental disabilities, and 

this number shall increase as the population continues to grow older; 

b. historically, society has tended to isolate and segregate individuals with disabilities 

and, despite some improvements, such forms of discrimination against disabled 

individuals continue to be a pervasive social problem, requiring serious attention; 

c. discrimination against disabled individuals persists in such critical areas as 

employment, housing, public accommodations, transportation, communication, 

recreation, institutionalization, health services, voting and access to public services 

and public facilities; 

d. individuals with disabilities continually suffer forms of discrimination, including 

outright intentional exclusion, the discriminatory effects of architectural, 

transportation, and communication barriers, failure to make modifications to 

existing facilities and practices, exclusionary qualification standards and criteria, 

segregation, and relegation to lesser services, programs, benefits, or other 

opportunities; and 

e. the continuing existence of unfair and unnecessary discrimination and prejudice 

denies people with disabilities the opportunity to compete on an equal basis and to 

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pursue those opportunities for which our country is justifiably famous, and costs 

the United States billions of dollars in unnecessary expenses resulting from 

dependency and nonproductivity. 

42 .S.C. §12101(a)(1)-(3),(5) and (9). 

57. Congress explicitly stated that the purpose of the ADA was to: 

f. provide a clear and comprehensive national mandate for elimination of 

discrimination against individuals with disabilities; 

g. provide clear, strong, consistent, enforceable standards addressing discrimination 

against individuals with disabilities; and 

h. invoke the sweep of congressional authority, including the power to enforce the 

fourteenth amendment and to regulate commerce, in order to address the major 

areas of discrimination faced on a daily basis by people with disabilities. 

42 U.S.C. §12101(b)(1)(2) and (4). 

58. Pursuant to 42 U.S.C. §12182(7), 28 CFR §36.104 and the 2010 ADA Standards, 

Defendant's Premises is a place of public accommodation covered by the ADA by the fact it 

provides services to the general public and must be in compliance therewith. 

59. Defendant has discriminated, and continues to discriminate against Plaintiff and 

others who are similarly situated by denying access to and full and equal enjoyment of goods, 

services, facilities, privileges, advantages and/or accommodations located at the Premises, as 

prohibited by 42 U.S.C. §12182, and 42 U.S.C. §12101 et. seq., and by failing to remove 

architectural barriers pursuant to 42 U.S.C. §12182(b)(2)(A)(iv). 

60. Plaintiff has visited the Premises and has been denied full and safe equal access to 

the facilities, and therefore suffered an injury in fact. 

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61. Defendant's policies, practices, procedures and/or lack of training its staff to 

efficiently and effectively identify and reasonably modify its services creates an environment 

where individuals with disabilities are not provided goods and services in the most integrated way 

possible. 

62. Plaintiff will return to the Premises in the near future and enjoy the goods, services, 

facilities, privileges, advantages and/or accommodations at the Premises on a planned, or a 

spontaneous, full and equal basis. However, Plaintiff is precluded from doing so by Defendant's 

failure and refusal to provide persons with disabilities with full and equal access to its facilities at 

the Premises. Therefore, Plaintiff continues to suffer from discrimination and injury due to the 

architectural barriers that are in violation of the ADA. 

63. Pursuant to the mandates of 42 U.S.C. §12134(a), on July 26, 1991, the Department 

of Justice, Office of the Attorney General promulgated Federal Regulations to implement the 

requirements of the ADA. See 28 CFR §36 and its successor the 2010 ADA Accessibility 

Guidelines (hereinafter referred to as "ADAAG"), 28 C.F.R. Part 36, under which said Department 

may obtain civil penalties of up to $55,000.00 for the first violation and $110,000.00 for each 

subsequent violation.1 

64. Based on a preliminary inspection of the Premises, Defendant is in violation of 42 

U.S.C. §12182 et. seq. and the 2010 ADA Standards et. seq., and is discriminating against Plaintiff 

as a result of, inter alia, the following specific violations found: 

1Effective April 1, 2014 the civil penalties were increased, based on inflation, from $55,000.00 

to $75,000.00 for the first violation and from $110,000.00 to $150,000.00 for subsequent 

violations. See 28 C.F.R. §§36 and 85. 

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Men's Res tro om 

a. Failing to provide proper signage for an accessible restroom or failure to redirect a 

person with a disability to the closest available accessible restroom facility in 

violation-of 2010 ADAAG §§216, 216.2, 216.6, 216.8, 703, 703.1, 703.2, 703.5 

and 703.7.2.1 and/or §§4.30 and 4.30.1 of the 1991 ADA Standards. 

b. Failing to provide operable parts that are functional or are in the proper reach ranges 

as required for a person with a disability (missing handle) in violation of 2010 

ADAAG §§309, 309.1, 309.3 and 309.4 and/or §§4.27, 4.27.3 and 4.27.4 of the 

1991 ADA Standards. 

c. Failing to provide a paper towel dispenser or its operable part at the correct height 

above the finished floor in violation of 2010 ADAAG §§606, 606.1 and 308 and/or 

§§4.16.6, 4.27, 4.27.3, 4.22.7 and 4.23.7 of the 1991 ADA Standards. 

Restaurant Seating 

d. Failing to provide seating for a person with a disability that has the correct clear 

floor space for forward approach in violation of 2010 ADAAG §§902, 902.2, 305 

and 306 and/or §§4.2.4, 4.2.5, 4.32.2 and 4.5 of the 1991 ADA Standards. 

e. Failing to provide a sufficient amount of seating when dining surfaces are provided 

for the consumption of food or drink for a person(s) with a disability in violation of 

2010 ADAAG §§226, 226.1, 902, 305 and 306 and/or §5.1 of the 1991 ADA 

Standards. 

65. To the best of Plaintiffs belief and knowledge, at the time of filing this lawsuit 

Defendant has failed to eliminate the specific violations set forth in paragraph 64 above. 

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66. Although Defendant is charged with having knowledge of the violations, Defendant 

may not have had actual knowledge of said violations until this Complaint made Defendant aware 

of same. 

67. To date, the readily achievable barrier and violation of the ADA still exists and has 

not been remedied or altered in such a way as to effectuate compliance with the provisions of the 

ADA. 

68. As the owner, lessor, lessee or operator of the Premises, Defendant is required to 

comply with the ADA. To the extent the Premises, or portions thereof, existed and were occupied 

prior to January 26, 1992, the owner, lessor, lessee or operator has been under a continuing 

obligation to remove architectural barriers at the Premises where removal was readily achievable, 

as required by 28 C.F.R. §36.402. 

69. To the extent the Premises, or portions thereof, were constructed for occupancy 

after January 26, 1993 the owner, lessor, lessee or operator of the Premises was under an obligation 

to design and construct such Premises such that it is readily accessible to and usable by individuals 

with disabilities, as required by 28 C.F.R. §36.401. 

70. Pursuant to the ADA, 42 U.S.C. §12101 et. seq., and 28 CFR §36.304, Defendant 

was required to make the Premises, a place of public accommodation, accessible to persons with 

disabilities by January 28, 1992. As of the date of the filing of this Complaint, Defendant has failed 

to comply with this mandate. 

71. Plaintiff has retained undersigned counsel for the filing and prosecution of this 

action. Plaintiff is entitled to have his reasonable attorneys' fees, costs and expenses paid by 

Defendant, pursuant to 42 U.S.C. §12205. 

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72. The violations alleged in paragraph 64 above is readily achievable to modify in 

order to bring the Premises or the Facility/Property into compliance with the ADA. 

73. In the instances where the 2010 ADAAG Standards do not apply to the violations 

listed in paragraph 64 above, the 1991 ADA Standards apply. 

74. Pursuant to 42 U.S.C. §12188, this Court is vested with the authority to grant 

Plaintiffs injunctive relief, including entering an Order to alter the Premises to make it readily 

accessible to and useable by individuals with disabilities to the extent required by the ADA and 

closing the Premises until the requisite modifications are completed. 

WHEREFORE, Plaintiff demands judgment against Defendant and requests the following 

injunctive and declaratory relief: 

1. This Court declare that the Premises owned, operated and/or controlled by 

Defendant is in violation of the ADA; 

2. This Court enter an Order requiring Defendant to alter the Premises and/or its 

facilities to make them accessible to and usable by individuals with disabilities to 

the full extent required by Title III of the ADA; 

3. This Court enter an Order directing Defendant to evaluate and neutralize its 

policies, practices and procedures toward persons with disabilities, for such 

reasonable time so as to allow Defendant to undertake and complete corrective 

procedures to the Premises; 

4. This Court award reasonable attorneys' fees, all costs (including, but not limited to 

the court costs and expert fees) and other expenses of suit to Plaintiff; and 

5. This Court award such other and further relief as it may deem necessary, just and 

proper. 

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Dated: 8/18/2020 

BY: /s/ Jason S. Weiss 

Jason S. Weiss 

Jason@jswlawyer.com 

Florida Bar No. 356890 

WEISS LAW GROUP, P.A. 

5531 N. University Drive, Suite 103 

Coral Springs, FL 33067 

Tel: (954) 573-2800 

Fax: (954) 573-2798 

Attorneys for Plaintiff 

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