EXHIBIT A

Case 1:19-cv-00200-AW-GRJ Document 13-1 Filed 02/24/20 Page 1 of 8
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.

 /

DEFENDANT’S RESPONSE TO PLAINTIFF’S INTERROGATORIES

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

through its undersigned counsel and in response to Plaintiff’s Interrogatories, hereby responds as

follows:

1. Identify by name, address, telephone number and title of all persons answering or

assisting in answering these Interrogatories.

RESPONSE: Mr. Paresh M. Gocool, Owner

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

The Harr Law Firm

The Harr Professional Center

517 South Ridgewood Avenue

Daytona Beach, Florida 32114

Telephone: (386) 226-4866

Plaintiff

Jason L. Harr

The Harr Law Firm

The Harr Professional Center

517 South Ridgewood Avenue

Daytona Beach, Florida 32114

Telephone: (386) 226-4866

Attorney for Plaintiff

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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: Mr. Paresh M. Gocool, on behalf of 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: Mr. Paresh M. Gocool, on behalf of 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 on or about May of 2013.

4. State in detail the extent to which the website identifies and describes all accessible

features and rooms at the hotel.

RESPONSE: The subject hotel, America’s Best Value Inn, has

accessible ramps to all public areas, parking spots,

and an accessible chair equipped in pool. 

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.

5. Identify all those who designed or maintained the website since the date it was first

created until the present.

RESPONSE: Ms. Judith A. Jarvis

Red Lion Hotels Holding, Inc.

1550 Market Street 

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Suite 350

Denver, Colorado 80202 

Ms. Andrea Bracken

Red Lion Hotels Holding, Inc.

1550 Market Street 

Suite 350

Denver, Colorado 80202

Mr. Jarvis McCrary

Red Lion Hotels Holding, Inc.

1550 Market Street 

Suite 350

Denver, Colorado 80202

Ms. Melissa Hardaway

Red Lion Hotels Holding, Inc.

1550 Market Street 

Suite 350

Denver, Colorado 80202

6. When was the website first posted, created or generated?

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

Value Inn’s website was first created on or about

May 2013.

7. When was the website last revised?

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

Value Inn’s website was last revised on or about

November 2019.

8. Approximately how many times has the website been revised since it was first

created?

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

Value Inn’s website is unaware of how many times

the website has been revised since it was first

created.

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9. State when the subject hotel was constructed.

RESPONSE: It is believed the subject hotel, America’s Best

Value Inn, was constructed sometime in 1985.

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 provides a listing of amenities.

11. State whether any such modifications, revisions, alterations set forth above include

or involve compatibility with 28 C.F.R. Section 36.302(e)(1). If the answer is yes, describe such

efforts with specificity.

RESPONSE: None.

12. Do you intend to challenge the hourly rates of $425 charged by Philip Michael

Cullen, III? If the answer to either is yes, state the hourly rates charged by each of the attorneys

retained by defendant in this action.

RESPONSE: Undetermined at this time as Philip Michael Cullen,

III failed to provide an invoice of total amount of

hours worked. Further, the Defendant, America’s

Best Value Inn, reserves the right to challenge an

award of attorney’s fees and costs.

13. State how many guestrooms the hotel has and state what kinds of accommodations

are offered (i.e. bed type, number of beds, view, balcony, etc.).

RESPONSE: The subject hotel, America’s Best Value Inn has a

total of 74 rooms which consists of 26 King/Single

beds and 48 Double bed rooms.

14. Identify each of the designated accessible guest rooms at the hotel and state what

kinds of sleeping and bathing accommodations each offers: (i.e. bed type, number of beds, view,

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balcony, one room/two room, roll-in shower, tub, etc.)

RESPONSE: America’s Best Value Inn has 1 accessible guest

room with a king size bed with roll-in shower, 2

accessible guest rooms with king size beds with

accessible bathtub; 2 accessible guest rooms with

queen size beds with accessible bathtubs. 

15. Identify all other places of public accommodation owned or operated by Defendant

or any entity in which more than 10% of ownership interest is commonly owned by the same

parties.

RESPONSE: Quality Inn

2175 Highway 71

Marianna, Florida 32448

Days Inn

2185 Highway 71

Marianna, Florida 32448

16. State whether the defendant is the owner, operator, lessor or lessee of the subject

hotel.

RESPONSE: Mr. Paresh M. Gocool, on behalf of the Defendant,

Arpan, LLC is the owner of the subject hotel,

America’s Best Value Inn.

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

RESPONSE: The Defendant, Arpan, LLC, relies on its

compliance with the provisions of the Americans

with Disabilities Act.

18. State whether any lawsuit was filed alleging that the website did not comply with

the requirements of the American With Disabilities Act, 42 U.S.C. Section 12181, et seq., was

incompatible with the screen reader software, or failed to comply with 28 C.F.R. Section

36.302(e)(1).

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RESPONSE: Only this lawsuit.

19. If the answer to Interrogatory number 19 is yes:

a. Identify the court and civil action number in which the case was filed.

RESPONSE: Not applicable.

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