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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.

HOWARD MICHAEL CAPLAN,

Plaintiff,

vs.

MR. LIQUORS CORP., a Florida Profit 

Corporation d/b/a MR. LIQUORS CIGARS 

& LOUNGE and PEPE'S BAR & LIQUOR 

STORE #2, INC., a Florida Profit 

Corporation,

Defendants.

_______________________________/

COMPLAINT

Plaintiff, HOWARD MICHAEL CAPLAN (hereinafter “Plaintiff”), through the undersigned 

counsel, hereby files this complaint and sues MR. LIQUORS CORP. d/b/a MR. LIQUORS 

CIGARS & LOUNGE (“MR. LIQUORS”) and PEPE'S BAR & LIQUOR STORE #2, INC.

(“PBLS”) (hereinafter, collectively referred to as “Defendants”) for declaratory and injunctive 

relief; for discrimination based on disability; and for the resultant attorney's fees, expenses, and 

costs (including, but not limited to, court costs and expert fees), pursuant to 42 U.S.C. §12181 et. 

seq., ("AMERICANS WITH DISABILITIES ACT OF 1990," or "ADA") and alleges:

JURISDICTION 

1. This Court is vested with original jurisdiction over this action pursuant to 28 U.S.C. §1331 

and §1343 for Plaintiff’s claims arising under Title 42 U.S.C. §12181 et. seq., based on 

Defendants’ violations of Title III of the Americans with Disabilities Act of 1990, (hereinafter 

referred to as the "ADA"). See also 28 U.S.C. §2201 and §2202.

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VENUE

2. The venue of all events giving rise to this lawsuit is located in Miami-Dade County, 

Florida. Pursuant to 28 U.S.C. §1391(B) and rule 3.1 of Local Rules of the United States District 

Court for the Southern District of Florida, this is the designated court for this suit.

PARTIES

3. Plaintiff, HOWARD MICHAEL CAPLAN, is a resident of the State of Florida. At the time 

of Plaintiff’s visit to Mr. Liquors Cigar and Lounge (“Subject Facility”), Plaintiff suffered from a 

“qualified disability” under the ADA, which substantially limits Plaintiff’s major life activities, 

including but not limited to walking, and requires the use of a mobility aid. Plaintiff personally 

visited Mr. Liquors Cigar and Lounge, but was denied full and equal access, and full and equal 

enjoyment of the facilities, services, goods, and amenities within Mr. Liquors Cigar and Lounge, 

which is the subject of this lawsuit. The Subject Facility is a liquor store, and Plaintiff wanted to 

purchase liquor but was unable to due to the discriminatory barriers enumerated in Paragraph 15 

of this Complaint.

4. In the alternative, Plaintiff, HOWARD MICHAEL CAPLAN, is an advocate of the rights 

of similarly situated disabled persons and is a “tester” for the purpose of asserting his civil rights 

and monitoring, ensuring and determining whether places of public accommodation are in 

compliance with the ADA. 

5. Defendants, MR. LIQUORS and PBLS, are authorized to conduct business and are in fact 

conducting business within the State of Florida. The Subject Facility is located at 6700 W Flagler 

Street, Miami, FL 33144. Upon information and belief, MR. LIQUORS is the lessee and/or 

operator of the Real Property and therefore held accountable of the violations of the ADA in the 

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Subject Facility which is the matter of this suit. Upon information and belief, PBLS is the owner 

and lessor of the Real Property where the Subject Facility is located and therefore held accountable 

for the violations of the ADA in the Subject Facility which is the matter of this suit.

CLAIMS: VIOLATIONS OF THE AMERICANS WITH DISABILITIES ACT

6. Plaintiff adopts and re-alleges the allegations stated in paragraphs 1 through 5 of this 

complaint, as are further explained herein.

7. 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 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 Defendants had ten (10) or fewer employees and gross receipts of 

$500,000 or less. See 42 U.S.C. §12181; 28 C.F.R. §36.508(a).

8. As stated in 42 U.S.C. §12101(a) (1)-(3), (5) and (9), Congress found, among other things, 

that:

i. some 43,000,000 Americans have one or more physical or mental disability, and this 

number shall increase as the population continues to grow and age;

ii. 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;

iii. 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;

iv. 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 regulation 

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to lesser services, programs, benefits, or other opportunities; and,

v. 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 this country is justifiably famous and costs the United States 

billions of dollars in unnecessary expenses resulting from dependency and nonproductivity.

9. As stated in 42 U.S.C. §12101(b)(1)(2) and (4), Congress explicitly stated that the purpose 

of the ADA was to:

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

discrimination against individuals with disabilities;

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

against individuals with disabilities; and,

iii. 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.

10. Pursuant to 42 U.S.C. §12181(7), and 28 CFR §36.104, Title III, no individual may be 

discriminated against on the basis of disability with regards to the full and equal enjoyment of the 

goods, services, facilities, or accommodations of any place of public accommodation by any 

person who owns, leases (or leases to), or operates a place of public accommodation. Mr. Liquors 

Cigar and Lounge is a place of public accommodation by the fact it is an establishment that 

provides goods/services to the general public, and therefore, must comply with the ADA. The 

Subject Facility is open to the public, its operations affect commerce, and it is a sales 

establishment. See 42 U.S.C. Sec. 12181 (7) and 28 C.F.R. 36.104. Therefore, the Subject Facility 

is a public accommodation that must comply with the ADA.

11. The Defendants have discriminated, and continue 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 at Mr. Liquors Cigar and 

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Lounge located at 6700 W Flagler Street, Miami, FL 33144, as prohibited by 42 U.S.C. §12182, 

and 42 U.S.C. §12101 et. seq.; by failing to make reasonable modifications in policies, practices, 

or procedures pursuant to 42 U.S.C. §12182(b)(2)(A)(ii); and by failing to remove architectural 

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

12. Plaintiff has visited the Subject Facility, and has been denied full, safe, and equal access to 

the facility and therefore suffered an injury in fact.

13. Plaintiff shall suffer a future injury as Plaintiff intends to return and enjoy the goods and/or 

services at the Subject Facility within the next six months. The Subject Facility is in close 

proximity to Plaintiff’s residence and is in an area frequently travelled by Plaintiff. Furthermore, 

Plaintiff will also return to monitor compliance with the ADA. However, Plaintiff is precluded 

from doing so by the Defendants' failure and refusal to provide people with disabilities with full 

and equal access to their facility. Therefore, Plaintiff continues to suffer from discrimination and 

injury due to the architectural barriers, which are in violation of the ADA.

14. 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. The ADA Accessibility guidelines (hereinafter referred to as 

“ADAAG”), 28 C.F.R. Part 36, may cause violators to obtain civil penalties of up to $55,000 for 

the first violation and $110,000 for any subsequent violation. 

15. The Defendants are in violation of 42 U.S.C. §12181 et. seq., and 28 C.F.R. 36.302 et. seq., 

and are discriminating against Plaintiff with the following specific violations which Plaintiff 

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personally encountered and/or has knowledge of:

a) The customer parking facility in the rear of the liquor store does not provide a compliant 

accessible parking space. 2012 ADA Standards 502.1 

b) The parking facility has nine (9) marked standard spaces and one (1) non-compliant 

accessible parking space. 2012 ADA Standards 208.2 

c) The parking facility does not have the minimum number of compliant accessible parking 

spaces required. One (1) compliant accessible parking space with adjacent access aisle is 

required. 2012 ADA Standards 208.2 

d) The parking facility does not provide directional and informational signage to a compliant 

accessible parking space. 2012 ADA Standards 216.5 

e) The non-compliant parking space access aisle is not level. Parking spaces and access aisles 

serving them must comply with Section 302. Access aisles must be at the same level as the 

parking spaces they serve. Changes in level are not permitted. Slopes not steeper than 1:48 

are permitted to allow water runoff. 2012 ADA Standards 502.4 

f) The accessible parking space identification striping is faded. Each such parking space must 

be striped in a manner that is consistent with the standards of FDOT for other spaces and 

prominently outlined with blue paint, and must be repainted when necessary, to be clearly 

distinguishable as a parking space designated for persons who have disabilities. 2012 ADA 

Standards 502.6.1 

g) There are areas of the asphalt ground surface in the parking lot that are rough and uneven. 

Floor and ground surfaces must be stable, firm, and slip resistant. A stable surface is one 

that remains unchanged by contaminants or applied force, so that when the contaminant or 

force is removed, the surface returns to its original condition. A firm surface resists 

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deformation by either indentations or particles moving on its surface. A slip-resistant 

surface provides sufficient frictional counterforce to the forces exerted in walking to permit 

safe ambulation. 2012 ADA Standards 302.1 

h) The non-compliant accessible parking space sign is missing. Each accessible parking space 

must be posted with a permanent above-grade sign of a color and design approved by the 

Department of Transportation, which is placed on or at least 60 inches above the finished 

floor or ground surface measured to the bottom of the sign and which bears the international 

symbol of accessibility and the caption “PARKING BY ACCESSIBLE PERMIT ONLY” 

and must indicate the penalty for illegal use of the space. 2012 ADA Standards 502.6 

i) Existing facility does not provide a compliant accessible route to the liquor store from any 

site arrival point. 2012 ADA Standards 206.2, 208, 401.1 

j) There is currently no existing accessible route to help persons with disabilities enter the 

facility or safely maneuver through the parking area. At least one accessible route must be 

provided within the site from accessible parking spaces and accessible passenger loading 

zones; public streets and sidewalks; and public transportation stops to the accessible 

building or facility entrance they serve. 2012 ADA Standards 206.2.1 

k) The asphalt ground surface slopes up to the main entrance door. The main entrance door 

requires a 60” x 60” level landing to allow persons with mobility issues to safely enter the 

building. Changes in level are not permitted. Such changes in level are prohibited in 

required clear floor and ground spaces, turning spaces, and in similar spaces where people 

using wheelchairs and other mobility devices must park their mobility aids such as in 

wheelchair spaces, or maneuver to use elements such as at doors, fixtures, and telephones. 

The exception permits slopes not steeper than 1:48. 2010 ADA Standards 404.2.4.4 

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l) Maneuvering clearances must extend the full width of the doorway and the required latch 

side or hinge side clearance. 2012 Standards 404.2. 

m) The facility does not provide compliant directional and informational signage to an 

accessible route which would lead to an accessible entrance. Where not all entrances 

comply, compliant entrances must be identified by the International Symbol of 

Accessibility. Directional signs that indicate the location of the nearest compliant entrance 

must be provided at entrances that do not comply. 2012 ADA Standards 216.6

16. Upon information and belief there are other current violations of the ADA at Mr. Liquors 

Cigar and Lounge. Only upon full inspection can all violations be identified. Accordingly, a 

complete list of violations will require an on-site inspection by Plaintiff’s representatives pursuant 

to Rule 34b of the Federal Rules of Civil Procedure.

17. Upon information and belief, Plaintiff alleges that removal of the discriminatory barriers 

and violations is readily achievable and technically feasible. 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.

18. Pursuant to the ADA, 42 U.S.C. §12101 et. seq., and 28 C.F.R. §36.304, the Defendants 

were required to make the establishment a place of public accommodation, accessible to persons 

with disabilities by January 28, 1992. As of this date the Defendants have failed to comply with 

this mandate.

19. Plaintiff has been obligated to retain the undersigned counsel for the filing and prosecution 

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of this action. Plaintiff is entitled to have its reasonable attorney's fees, costs and expenses paid by 

the Defendants, pursuant to 42 U.S.C. §12205.

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

injunctive relief, including an Order to alter the subject facilities to make them readily accessible 

and useable by individuals with disabilities to the extent required by the ADA, closing the Subject 

Facility until the requisite modifications are completed, entering an Order directed at maintenance 

and future compliance, and entering an Order for Defendants to make reasonable modifications in 

policies, practices, or procedures.

COUNT I- DECLARATORY RELIEF

21. The Defendants’ Facility has architectural barriers which Plaintiff personally encountered 

and/or has knowledge of.

22. Defendants have failed to make reasonable modifications in policies, practices, or procedures 

to ensure full and equal enjoyment of goods, services, facilities, privileges, advantages and/or 

accommodations at the Defendants’ Facility to Plaintiff, and similarly situated individuals with 

disabilities.

23. Defendants have discriminated, and continue 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 at the Subject Facility, as prohibited by 

42 U.S.C. §12182, and 42 U.S.C. §12101 et. seq.; by failing to make reasonable modifications in 

policies, practices, or procedures pursuant to 42 U.S.C. §12182(b)(2)(A)(ii); and by failing to 

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

24. Unless declared that the Subject Facility owned, operated and/or controlled by the 

Defendants is in violation of the ADA, Defendants shall continue 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 at the Subject Facility.

25. Plaintiff has been obligated to retain the undersigned counsel for the filing and prosecution 

of this action. Plaintiff is entitled to have its reasonable attorney's fees, costs and expenses paid by 

the Defendants, pursuant to 42 U.S.C. §12205.

WHEREFORE, Plaintiff demands judgment against the Defendants and requests that this 

Honorable Court declare that the Subject Facility owned, operated and/or controlled by the 

Defendants is in violation of Title III of the ADA, and award reasonable attorney's fees, all costs 

(including, but not limited to court costs and expert fees) and other expenses of suit, to Plaintiff.

COUNT II- INJUNCTIVE RELIEF TO REMOVE ARCHITECTURAL BARRIERS

26. The Defendants’ Facility has architectural barriers which Plaintiff personally encountered 

and/or has knowledge of.

27. Upon information and belief, Plaintiff alleges that removal of the discriminatory barriers 

and violations is readily achievable and technically feasible. 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. 

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28. Unless enjoined by the Court, Defendants shall continue 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 at the Subject Facility by failing 

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

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

injunctive relief, including an Order to alter the subject facilities to make them readily accessible 

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

Subject Facility until the requisite modifications are completed.

30. Plaintiff has been obligated to retain the undersigned counsel for the filing and prosecution 

of this action. Plaintiff is entitled to have its reasonable attorney's fees, costs and expenses paid by 

the Defendants, pursuant to 42 U.S.C. §12205.

WHEREFORE, Plaintiff demands judgment against the Defendants and requests that this 

Honorable Court enter an Order requiring Defendants to alter the Subject Facility and remove 

architectural barriers to make the Subject Facility accessible to and usable by individuals with 

disabilities to the full extent required by Title III of the ADA, and award reasonable attorney's fees, 

all costs (including, but not limited to court costs and expert fees) and other expenses of suit, to 

Plaintiff.

COUNT III- INJUNCTIVE RELIEF TO MODIFY POLICIES, PRACTICES AND 

PROCEDURES

31. The Defendants’ Facility has architectural barriers which Plaintiff personally encountered 

and/or has knowledge of.

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32. Defendants have failed to make reasonable modifications in policies, practices, or 

procedures to ensure full and equal enjoyment of goods, services, facilities, privileges, advantages 

and/or accommodations at the Defendants’ Facility to Plaintiff, and similarly situated individuals 

with disabilities.

33. Unless enjoined by the Court, Defendants shall continue 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 at the Subject Facility by failing 

to make reasonable modifications in policies, practices, or procedures pursuant to 42 U.S.C. 

§12182(b)(2)(A)(ii).

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

injunctive relief, including an Order for Defendants to make reasonable modifications in policies, 

practices, or procedures.

35. Plaintiff has been obligated to retain the undersigned counsel for the filing and prosecution 

of this action. Plaintiff is entitled to have its reasonable attorney's fees, costs and expenses paid by 

the Defendants, pursuant to 42 U.S.C. §12205.

WHEREFORE, Plaintiff demands judgment against the Defendants and requests that this 

Honorable Court enter an Order requiring Defendants to evaluate, neutralize and modify their 

policies, practices and procedures as are necessary to make the Subject Facility accessible to and 

usable by individuals with disabilities to the full extent required by Title III of the ADA, and award 

reasonable attorney's fees, all costs (including, but not limited to court costs and expert fees) and 

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other expenses of suit, to Plaintiff.

COUNT IV- INJUNCTIVE RELIEF TO MAINTAIN COMPLIANCE

36. The Defendants’ Facility has architectural barriers which Plaintiff personally encountered 

and/or has knowledge of.

37. Upon information and belief, Plaintiff alleges that removal of the discriminatory barriers 

and violations is readily achievable and technically feasible. 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.

38. Unless enjoined by the Court, Defendants shall continue 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 at the Subject Facility by failing 

to maintain compliance with the ADA by allowing physical alterations to revert back into 

noncompliance, and by failing to enforce any modifications in policies, practices, or procedures.

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

injunctive relief, including an Order directed at maintenance and future compliance, and entering 

an Order for Defendants to maintain reasonable modifications in policies, practices, or procedures.

40. Plaintiff has been obligated to retain the undersigned counsel for the filing and prosecution 

of this action. Plaintiff is entitled to have its reasonable attorney's fees, costs and expenses paid by 

the Defendants, pursuant to 42 U.S.C. §12205.

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WHEREFORE, Plaintiff demands judgment against the Defendants and requests that this 

Honorable Court enter an Order requiring Defendants to maintain the alterations and modifications 

required to keep the Subject Facility accessible to and usable by individuals with disabilities and 

in compliance with Title III of the ADA, and award reasonable attorney's fees, all costs (including, 

but not limited to court costs and expert fees) and other expenses of suit, to Plaintiff.

Dated this December 09, 2022.

Respectfully submitted by:

Ronald E. Stern

Ronald E. Stern, Esq.

Florida Bar No. 10089

THE ADVOCACY LAW FIRM, P.A.

1250 East Hallandale Beach Boulevard, Suite 503

Hallandale Beach, Florida 33009

Telephone: (954) 639-7016

Facsimile: (954) 639-7198

E-Mail: ronsternlaw@gmail.com

Attorney for Plaintiff, HOWARD MICHAEL CAPLAN

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.

HOWARD MICHAEL CAPLAN,

Plaintiff,

vs.

MR. LIQUORS CORP., a Florida Profit 

Corporation d/b/a MR. LIQUORS CIGARS 

& LOUNGE and PEPE'S BAR & LIQUOR 

STORE #2, INC., a Florida Profit 

Corporation,

Defendants.

_______________________________/

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on December 09, 2022, I electronically filed the Complaint 

along with a Summons for each Defendant with the Clerk of Court using CM/ECF. I also certify 

that the aforementioned documents are being served on all counsel of record, corporations, or pro 

se parties identified on the attached Service List in the manner specified via Service of Process by 

an authorized Process Server, and that all future pleadings, motions and documents will be served 

either via transmission of Notices of Electronic Filing generated by CM/ECF or via U.S. Mail for 

those counsel or parties who are not authorized to receive electronically Notices of Electronic 

Filing.

Ronald E. Stern

Ronald E. Stern, Esq.

Florida Bar No. 10089

THE ADVOCACY LAW FIRM, P.A.

1250 East Hallandale Beach Boulevard, Suite 503

Hallandale Beach, Florida 33009

Telephone: (954) 639-7016

Facsimile: (954) 639-7198

E-Mail: ronsternlaw@gmail.com

Attorney for Plaintiff, HOWARD MICHAEL CAPLAN

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SERVICE LIST:

HOWARD MICHAEL CAPLAN vs. MR. LIQUORS CORP., a Florida Profit Corporation d/b/a 

MR. LIQUORS CIGARS & LOUNGE and PEPE'S BAR & LIQUOR STORE #2, INC., a 

Florida Profit Corporation

United States District Court Southern District of Florida

CASE NO.

MR. LIQUORS CORP. d/b/a MR. LIQUORS CIGARS & LOUNGE

REGISTERED AGENT:

DIAZ, CRISTAL

6700 W FLAGLER ST.

MIAMI, FL 33144

VIA PROCESS SERVER 

PEPE'S BAR & LIQUOR STORE #2, INC.

REGISTERED AGENT:

SEGURA, JOSEPH H.

3232 CORAL WAY APT 1610

MIAMI, FL 33145

VIA PROCESS SERVER 

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