UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

DEBORAH LAUFER, Individually,

Case No.: 1:19-cv-00200-AW-GRJ

Plaintiff,

v.

ARPAN, LLC, d/b/a AMERICA’S BEST

VALUE INN,

Defendant.

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DEFENDANT’S SUPPLEMENTAL RESPONSE TO PLAINTIFF’S INTERROGATORIES

(amended as to paragraphs #2, #3, #10, #17 and

the addition of a Certificate of Service)

COMES NOW, the Defendant, Arpan, LLC d/b/a America’s Best Value Inn, by and

through its undersigned counsel and serves its Supplemental Response to Plaintiff’s

Interrogatories:

2. State whether the Defendant is an owner and/or operator and/or lessee of the

website identified in the Instructions which is the subject of this action and the date when the

Defendant became the owner, operator and/or lessee of said website.

RESPONSE: The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn is not an owner and/or operator and/or

lessee of the website identified in the Instructions

which is the subject of this action.

3. In the event the Defendant is not the owner, operator, or lessee of the website,

identify the owner and operator of the website and identify the contract entered into in this regard.

RESPONSE: The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn, entered into a contract with Red Lion

Hotels Holding, Inc., 1550 Market Street, Suite

350, Denver, Colorado 80202. A copy of the

contract will be provided to opposing trial counsel

upon receipt.
10. Specifically describe any and all modifications, revisions, alterations made to the

website on or after the date the complaint was filed in the instant action.

RESPONSE: The website contains a revision which details:

“Accessible amenities include accessible bathtub,

vanity, bathing controls, light switch, toilet, room

doors, grab bars in bathroom, telephones adapted

for the hearing impaired, and television with

subtitles or closed captions” on the portion of the

website describing “King Bed Accessible

Non-Smoking”

17. State the facts in support of any denial you assert in the Answer to the Complaint.

RESPONSE: The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn’s denial of paragraph 11 is based on

Arpan, LLC does not own, manage or lease the

website referenced in paragraph 11. Further,

anyone visiting the website has an option, if

available, to book an accessible hotel room.

The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn’s denial of paragraph 18 is based on the

fact its website does not have violations nor would

it infringe upon Plaintiff’s right to travel free of

discrimination and deprive her of the information

required to make meaningful choices for travel.

The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn’s denial of paragraph 19 is based on the

fact the Plaintiff never visited its facility and was

not subjected to direct or indirect injury. Further,

Arpan, LLC d/b/a America’s Best Value Inn denies

there was any discrimination based on the state of

a website it does not own or operate.

The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn’s denial of paragraph 20 is based on the

fact Plaintiff did not suffer any discrimination nor

any direct or indirect damages. Further, Plaintiff

can navigate the website with unfettered access.

The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn’s denial of paragraph 21 is based on the

fact the website did not deny Plaintiff access to, and

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full equal enjoyment of, the goods, services,

facilities, privileges, advantages and/or

accommodations of the subject website. Further, it

does not appear as if Plaintiff actually visited the

property.

The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn’s denial of paragraph 22 is based on its

position that their website did not deny Plaintiff

access to, and full equal enjoyment of, the goods,

services, facilities, privileges, advantages and/or

accommodations of the subject website. Further, it

does not appear as if Plaintiff actually visited the

property.

The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn’s denial of paragraph 23 is based on its

position that its website did not deny Plaintiff

access to, and full equal enjoyment of, the goods,

services, facilities, privileges, advantages and/or

accommodations of the subject website. Further, it

does not appear as if Plaintiff actually visited the

property. Further, the website does not

discriminate against the Plaintiff and those similarly

situated due to any policies. Its policies permit

equal access to anyone.

The Defendant, Arpan, LLC d/b/a America’s Best

Value Inn’s denial of paragraph 24 is based on fact

Plaintiff has not suffered any cognizable

“irreparable harm.” Further, as Plaintiff is

currently not considered a “prevailing party” she is

not entitled to recover attorney’s fees, costs, and

litigation expenses.

I understand that I am swearing or affirming under oath to the truthfulness of the claims

made in my Supplemental Response to Plaintiff’s Interrogatories and that the punishment for

knowingly making a false statement includes fines and/or imprisonment.

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I have electronically filed the foregoing with the Clerk of the

Court by using the CM/ECF system on: Philip Michael Cullen, III, Esquire, 621 South Federal

Highway, Suite 4, Fort Lauderdale, Florida 33301, on this 11th day of March, 2020.

/s/ Jason L. Harr 

JASON L. HARR

Florida Bar No.: 0194336

THE HARR LAW FIRM

The Harr Professional Center

517 South Ridgewood Avenue

Daytona Beach, Florida 32114

Email: jasonharr@harrlawfirm.com

lynnwilkins@harrlawfirm.com

miriamjuarez@harrlawfirm.com

Telephone: (386) 226-4866

Telefax: (386) 226-4886

TRIAL COUNSEL FOR DEFENDANT

ARPAN, LLC d/b/a AMERICA’S BEST

VALUE INN

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