EXHIBIT A

Case 1:22-cv-24124-BB Document 18-1 Entered on FLSD Docket 02/06/2023 Page 1 of 5
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-cv-24124-BB

JAMES WATSON,

Plaintiff,

vs.

PADRINOOS RESTAURANTS, INC.

Defendant.

DECLARATION OF ROBERT KINGETT

I, Robert Kingett, being over the age of 18 years old, having been duly sworn, hereby

declare that if called upon, I could testify to the following facts based on personal knowledge:

l. I am over the age of 18 and of sound mind, and have personal knowledge of the

matters set forth herein.

2. I am totally blind and use NVDA screen reader software.

3. I use screen reader technology in my daily life.

4. I was hired by Padrino's Restaurants, Inc. ("Padrino") to review

www.padrinos.com ("Website") on February 1,2023 in response to Plaintiff s Inspection Report.

5. I have reviewed Plaintiffs Inspection Report and am aware of Plaintiffs

allegations regarding the alleged accessibility barriers that Plaintiff claims he encountered on or

about November 16, 2022.

6. A video was made of me reviewing the Website on February 1,2023.

7. Attached as Exhibit I to this Declaration is a true and accurate copy of that video.

Case 1:22-cv-24124-BB Document 18-1 Entered on FLSD Docket 02/06/2023 Page 2 of 5
8. During my review of the Website using a screen reader, I was able to navigate

through the headings on the Website to locate the "Private Dining Inquiry" form. I was able to

select "Inquire About an Event" at Padrino's Hallandale Beach location and select a new date on

the inquiry form. I used the date picker to select a new date and focus did not exit the popup and

move to the Event Time field until new dates were announced which I selected from.

Alternatively, I was also able to manually input a desired date in the inquiry form without issue.

(See Ex. I at2:51-5.08). This directly refutes Paragraph 1(i) of Plaintiff s Inspection Report. (DE

13, 13-1).

9. All of the menu links were announced and I was able to navigate through every

heading on the website and every available submenu. The Court can watch my screen reader

navigate through the headings on the homepage and expand the "menu" and "locations" submenus

for Defendant's Hallandale Beach, Dania Beach, Fort Lauderdale, Plantation, and Boca Raton

locations. (See Ex. 1 at 5: lI-7:06). This directly refutes Paragraph 1(ii) of Plaintiff s Inspection

Report. (DE 13, l3-1).

10. Defendant's Website no longer has a "Holiday Season" popup considering that the

holidays are over. However, I encountered no issue with any popups or dialogue boxes that I

encountered on the Website. My screen reader announced the "Order Now" link. (See Ex. I at

7:07-8:15). This directly refutes Paragraph l(iii) of Plaintiff s Inspection Report. (DE 13, 13-l).

11. Additionally, I reviewed the Defendant's "Accessibility" link which provided

Defendant's accessibility statement. The accessibility statement, which was read aloud by my

screen reader verbatim, provides me information about Defendant's accessibility policies and

provided me with altemative contact information. This information is beneficial for me such that

Case 1:22-cv-24124-BB Document 18-1 Entered on FLSD Docket 02/06/2023 Page 3 of 5
if I do come across any accessibility issues there's an alternative way for me to get information

from Defendant or to interact with the business.

12. I did not encounter any of the barriers alleged in the Plaintiff s Inspection Report

during my review.

13. The Website is very accessible andavisually impaired individual should be able to

use the Website if they actually know how to use a screen reader.

14. Pursuant to 28 U.S.C.S 1746,I declare under penalty of perjury that the foregoing

statements are true.

FURTHER DECLARANT SAYETH NAUGHT

Feb 3, 2023 Robert Kingett

Date

Case 1:22-cv-24124-BB Document 18-1 Entered on FLSD Docket 02/06/2023 Page 4 of 5
2023-02-03 DEC 32198 Declaration of Robert

Kingett for Def lnspection Report

FinalAudit Report 2023-02-03

"2023-02-03 DEC 32198 Declaration of Robert Kingett for Def ln

spection Report" History

fi Document created by Fiona Wolfe (FWolfe@ohaganmeyer.com)

2023-02-03-7:45:48 PM GMT- lP address: 38.106.198.82

B Document emailed to kingettspeaks@gmail.com for signature

2023-02-03 -7:47:17 PM GMT

fi Email viewed by kingettspeaks@gmail.com

2023-02-03 - 7:48:10 PM GMT- lP address: 69.245.221.243

4" Signer kingettspeaks@gmail.com entered name at signing as Robert Kingett

2023-02-03 - 7:49:24 PM GMT- lP address: 69.245.221.243

ft, Document e-signed by Robert Kingett (kingettspeaks@gmail.com)

Signature Date:2023-02-03 -7:49:26 PM GMT - Time Source: server- lP address: 69.245.221.243

Q Agreement completed

2023-02-03 - 7 :49:26 PM GMT

Created:

By:

Status:

Transaction lD:

2023-02-03

Fiona Wolfe (FWolfe@ohaganmeyer.com)

Signed

CBJCH BCAABAAJSSAI LmY3OJgV9JAmyPyiasHAFfXQSVn

@ nAoH Acrobrt Slgn

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