UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

 CASE NO.:

HOWARD COHAN,

Plaintiff,

vs. INJUNCTIVE RELIEF SOUGHT

STATION MANAGEMENT TEAM, LLC,

a Florida Limited Liability Company,

d/b/a SHELL

Defendant(s).

____________________________________/

COMPLAINT

Plaintiff, HOWARD COHAN (“Plaintiff”), by and through the undersigned counsel, 

hereby files this Complaint and sues STATION MANAGEMENT TEAM, LLC, a Florida Limited 

Liability Company d/b/a SHELL (“Defendant”), for declaratory and injunctive relief, attorneys’ 

fees, expenses and costs (including, but not limited to, court costs and expert fees) pursuant to 42 

U.S.C. § 12182 et. seq., and the 2010 Americans with Disabilities Act (“ADA”) and alleges as 

follows:

JURISDICTION AND VENUE

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

of the Settlement Agreement and Release (copy attached as Exhibit A) reached in the case of 

HOWARD COHAN v. STATION MANAGEMENT TEAM, LLC, 9:19-CV-80897-RKA (S.D. 

Fla.) (dismissed by order upon settlement) which arose out of Plaintiff’s claim of discrimination

caused by certain barriers encountered by Plaintiff on Defendant’s property that prevented Plaintiff 

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from the full and equal enjoyment of a place of public accommodation in violation of Title III of 

the Americans with Disabilities Act.

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

§§ 1331, 343 for Plaintiff’s claims arising under Title 42 U.S.C. § 12182 et. seq., based on 

Defendant’s violations of Title III of the ADA. See also, 28 U.S.C. §§ 2201, 2202, as well as the 

2010 ADA Standards.

3. Venue is proper in this Court, West Palm Beach Division, 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 Palm Beach County, 

Florida.

PARTIES

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

residing in Palm Beach County, Florida.

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

the Real Property, which is subject to this suit, and is located at 5010 W. Atlantic Ave., Delray 

Beach, Florida 33484, (“Premises”), and is the owner of the improvements where Premises is 

located.

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

State of Florida.

7. 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 

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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 Plaintiff’s major life activities. As such, 

Plaintiff suffered from a “qualified disability” under the ADA. 42 U.S.C § 12101, et seq.

8. On April 23, 2019, Plaintiff visited Defendant’s Premises. At the time of Plaintiff’s 

visit to the Premises on April 23, 2019, Plaintiff required the use of fully accessible restrooms; 

fully accessible paths of travel throughout the facility; a fully accessible parking area, and fully 

accessible service areas. Plaintiff personally visited the Premises, but 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”.

9. Defendant’s Premises is a public accommodation as defined by Title III of the ADA 

and as such is governed by the ADA.

10. On or about July 9, 2019, Plaintiff filed a lawsuit against Defendant seeking to force 

Defendant to comply with the ADA and applicable regulations thereto. See HOWARD COHAN 

v. STATION MANAGEMENT TEAM, LLC, 9:19-CV-80897-RKA (S.D. Fla.).

11. On or about October 7, 2019, Plaintiff’s suit was dismissed upon stipulation and 

notice to the U.S. District Court that the parties had settled. 

12. In connection with said dismissal, Plaintiff and Defendant entered into a Settlement 

Agreement and Release (Exhibit A) on or about September 4, 2019.

13. The Settlement Agreement and Release required Defendant to complete all 

modifications to the Premises by on or about July 4, 2020.

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14. Defendant has failed to complete the required modification(s) to the Premises as 

required by the ADA and the Settlement Agreement and Release and Defendant has failed to give 

notice of any reasons or documentation for non-compliance. 

15. Plaintiff again personally visited Defendant’s Premises on December 2, 2021, (and 

prior to instituting this action). 

16. Plaintiff required the use of fully accessible restrooms; fully accessible paths of 

travel throughout the facility; a fully accessible parking area, and fully accessible service areas.

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”. 

17. 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.

18. 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.

19. 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.

20. 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.

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21. 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 Premises to verify its compliance or non-compliance 

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

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 Plaintiff’s 

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.

22. 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.

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COUNT I 

VIOLATIONS OF THE AMERICANS WITH DISABILITIES ACT

23. Plaintiff adopts and re-alleges the allegations stated in paragraphs 1 through 22 

above as if fully stated herein.

24. On July 26, 1990, Congress enacted the Americans With Disabilities Act (“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(s) have ten (10) or fewer employees and 

gross receipts of $500,000.00 or less. See 42 U.S.C. § 12182; 28 C.F.R. § 36.508(a).

25. 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, 

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segregation, and regulation 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 

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

the United States billions of dollars in unnecessary expenses resulting from 

dependency and non-productivity.

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

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

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

discrimination against individuals with disabilities;

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

against individuals with disabilities; and

c. 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.

U.S.C. § 12101(b)(1)(2) and (4).

27. Pursuant to 42 U.S.C. § 12182(7), 28 C.F.R. § 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. 

28. 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 

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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).

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

facilities and therefore suffered an injury in fact.

30. Plaintiff would like to return and enjoy the goods and/or services at Premises on a 

spontaneous, full and equal basis. However, Plaintiff is precluded from doing so by the 

Defendant’s failure and refusal to provide disabled persons with full and equal access to its 

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

architectural barriers that are in violation of the ADA.

31. 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 C.F.R. § 36 and its successor the 2010 ADA Standards ADA 

Accessibility guidelines (hereinafter referred to as “ADAAG”), 28 C.F.R. § 36, under which said 

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

for any subsequent violation.

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

U.S.C. § 12182 et. seq. and the 2010 American Disabilities Act Standards et. seq., and is 

discriminating against Plaintiff as a result of, inter alia, the following specific violations:

Unisex Restroom

a. Failure 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, 603, 703, 703.1, 703.2, 

703.5 and 703.7.2.1. 

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

obstructing elements in this space in violation of 2010 ADAAG §§4.22.3, 603, 

603.2.3, 604, 604.3 and 604.3.1. 

c. Failure to provide sufficient clear floor space around a water closet without any 

obstructing elements in this space in violation of 2010 ADAAG §§4.22.3, 603, 

603.2.3, 604, 604.3 and 604.3.1. (trash can and toilet cleaner)

d. Failure to provide the proper spacing between a grab bar and an object projecting 

out of the wall in violation of 2010 ADAAG §§ 609, 609.1 and 609.3. (toilet paper 

dispenser)

e. Failure to provide the proper spacing between a grab bar and an object projecting 

out of the wall in violation of 2010 ADAAG §§ 609, 609.1 and 609.3. (soap 

dispenser)

f. Failure to provide operable parts that are functional or are in the proper reach ranges 

as required for a person with a disability in violation of 2010 ADAAG §§ 309, 

309.1, 309.3, 309.4 and 308. (door handle)

g. Failure to provide operable parts that are functional or are in the proper reach ranges 

as required for a person with a disability in violation of 2010 ADAAG §§ 309, 

309.1, 309.3, 309.4 and 308. 

h. Failure to provide the proper insulation or protection for plumbing or other sharp 

or abrasive objects under a sink or countertop in violation of 2010 ADAAG §§ 606 

and 606.5. 

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i. Failure to provide grab bars at 33 inches minimum and 36 inches maximum above 

the finished floor measured to the top of the gripping surface in violation of 2010 

ADAAG §§ 609, 609.4 and 609.7. (rear)

j. Providing grab bars of improper horizontal length or spacing as required along the 

side wall in violation of 2010 ADAAG §§ 604, 604.5, 604.5.1 and 604.5.2. 

k. Failure to provide mirror(s) located above lavatories or countertops at the proper 

height above the finished floor in violation of 2010 ADAAG §§ 603 and 603.3. 

l. Failure to provide proper knee clearance for a person with a disability under a 

counter or sink element in violation of 2010 ADAAG §§ 306, 306.1 306.3, 606 and 

606.2 

m. Failure to provide the correct opening width for a forward approach into a lavatory 

(sink) in violation of 2010 ADAAG §§ 305, 305.7.1, 404, 605.3 and 606.2 

Service Counter

n. Providing counter heights exceeding 36 inches making it impossible to service a 

person with a disability in violation of 2010 ADAAG §§ 904, 904.4, 904.4.1, 

904.4.2, 305 and 306.

Store Aisles

o. Providing pathways and or aisles that are too narrow in violation of 2010 ADAAG 

§§ 403, 403.1 and 403.5.1.

Access Aisle of Parking Spot

p. Providing any access aisle for parking that contains a ramp, obstruction or incorrect 

curb cut preventing an accessible route of travel for person(s) with a disability in 

violation of 2010 ADAAG §§ 502, 502.1 and 502.7.

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33. To the best of Plaintiff’s belief and knowledge, Defendant has failed to eliminate 

the specific violations set forth in paragraph 32 herein.

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

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

same.

35. To date, the readily achievable barriers and other violations of the ADA still exist 

and have not been remedied or altered in such a way as to effectuate compliance with the 

provisions of the ADA.

36. 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 was 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. 

37. To the extent the Premises, or portions thereof, was 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.

38. Plaintiff has retained the 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.

39. All of the above violations are readily achievable to modify in order to bring 

Premises or the Facility/Property into compliance with the ADA.

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40. In instance(s) where the 2010 ADAAG standard does not apply, the 1991 ADAAG 

standard applies and all of the violations listed in paragraph 32 herein can be applied to the 1991 

ADAAG standards.

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

Plaintiff’s injunctive relief, including an order to alter the Subject Facility to make it readily 

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

closing the Subject Facility until the requisite modifications are completed.

WHEREFORE, Plaintiff demands judgment against Defendant and requests the following 

injunctive and declaratory relief:

1. That this Court declares that Premises owned, operated and/or controlled by 

Defendant is in violation of the ADA;

2. That this Court enter an Order requiring Defendant to alter 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. That this Court enter an Order directing the Defendant to evaluate and neutralize 

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

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

procedures to Premises;

4. That this Court award reasonable attorney’s fees, all costs (including, but not 

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

and,

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

and proper.

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COUNT II 

BREACH OF CONTRACT

39. Plaintiff adopts and re-alleges the allegations stated in paragraphs 1 through 22 

above as if fully stated herein.

40. On or about September 4, 2019, Plaintiff and Defendant entered into a Settlement 

Agreement and Release. (Exhibit A). Through this Settlement Agreement, Defendant agreed to 

make modifications to Defendant’s Premises as outlined in the agreement. The Settlement 

Agreement and Release required Defendant to complete all modifications to the Premises by on or 

about July 4, 2020.

41. Plaintiff has performed all conditions precedent to be performed by him under the 

Settlement Agreement.

42. Since July 4 2020, Defendant has failed to complete the modifications promised in 

the Settlement Agreement. Specifically, Defendant has failed to perform the following agreed 

upon modifications pursuant to the Settlement Agreement:

Unisex Restroom

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

as required for a person with a disability (missing opening latch) 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. Failure to provide operable parts that are functional or are in the proper reach ranges 

as required for a person with a disability (the flush button) 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. 

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d. Failure to provide sufficient clear floor space around a water closet without any 

obstructing elements in this space in violation of 2010 ADAAG §§4.22.3, 603, 

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. 

e. Failure to provide the proper insulation or protection for 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. 

g. Failure to provide the proper spacing between a grab bar and an object projecting 

out of the wall (the toilet paper dispenser) 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. 

h. Failure to provide grab bars at 33 inches minimum and 36 inches maximum above 

the finished floor measured to the top of the gripping surface in violation of 2010 

ADAAG §§ 604, 604.5, 609, and 609.4 and/o r§§4.17.6, 4.26, and 4.26.2 of the 

1991 ADA Standards. 

j. Failure 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, 603, 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.

Service Counter

k. Providing counter heights exceeding 36 inches making it impossible to service a 

person with a disability in violation of 2010 ADAAG §§ 904, 904.4, 904.4.1, 

904.4.2, 305 and 306 and/or §§4.32.4, 5.2, 5.3, and 5.4 of the 1991 ADA Standards.

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Access Aisle 

m. Providing any access aisle for parking that contains a ramp, obstruction or incorrect 

curb cut preventing an accessible route of travel for person(s) with a disability in 

violation of 2010 ADAAG §§ 502, 502.1 and 502.7 and/or §§4.6.6, 4..7, 4.7.6, 4.7.8 

and 4.8 of the 1991 ADA Standards.

Pathway from the Ramp to the Restroom:

n. Failing to provide a doorway or walkway with a minimum clear width for a person 

with a disability in violation of 2010 ADAAG §§403, 403.5, 403.5.1 and 404.2.3 

and/or §§4.13.5 and 4.13.6 of the 1991 ADA Standards.

43. Plaintiff has been damaged by the Defendant’s breach of the Settlement Agreement. 

Specifically, Plaintiff has had to retain the services of the undersigned attorney to pursue this action 

for breach of contract.

WHEREFORE, Plaintiff demands judgment against Defendant and requests the following 

injunctive and declaratory relief:

1. That this Court declares that Defendant has failed to comply with the Settlement 

Agreement and Release;

2. That this Court enter an Order requiring Defendant to alter 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. That this Court award reasonable attorney’s fees, all costs (including, but not 

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

and as provided in the Settlement Agreement and Release; and,

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

and proper.

Dated August 26, 2022.

Sconzo Law Office, P.A.

3825 PGA Boulevard, Suite 207

Palm Beach Gardens, FL 33410

Telephone: (561) 729-0940

Facsimile: (561) 491-9459

By: /s/ Gregory S. Sconzo 

GREGORY S. SCONZO, ESQUIRE

Florida Bar No.: 0105553

SAMANTHA L. SIMPSON, ESQ.

Florida Bar No.: 1010423

Primary Email: greg@sconzolawoffice.com

Primary Email: samantha@sconzolawoffice.com

Secondary Email: alexa@sconzolawoffice.com

Secondary Email: amanda@sconzolawoffice.com

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