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POST-DISTRIBUTION ACCOUNTING - CASE NO. 5:16-CV-07013-LHK (SVK)

834406.3

Guy B. Wallace (SBN 176151)

gwallace@schneiderwallace.com

Mark T. Johnson (SBN 76904)

mjohnson@schneiderwallace.com

SCHNEIDER WALLACE

 COTTRELL KONECKY LLP

2000 Powell Street, Suite 1400

Emeryville, CA 94608

(415) 421-7100; (415) 421-7105 (Fax)

Linda M. Dardarian (SBN 131001)

ldardarian@gbdhlegal.com

Andrew P. Lee (SBN 245903)

alee@gbdhlegal.com

Katharine L. Fisher (SBN 305413)

kfisher@gbdhlegal.com

GOLDSTEIN, BORGEN, DARDARIAN & HO

155 Grand Avenue, Suite 900 

Oakland, CA 94612

(510) 763-9800; (510) 835-1417 (Fax)

Adam B. Wolf (SBN 215914)

awolf@pwcklegal.com 

Catherine Cabalo (SBN 248198)

ccabalo@pwcklegal.com

PEIFFER WOLF CARR & KANE

4 Embarcadero Center, 14th Floor

San Francisco, CA 94111

(415) 766-3592; (415) 402-0058 (Fax)

Attorneys for Plaintiffs and the Certified Classes

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN JOSE DIVISION

ABDUL NEVAREZ and PRISCILLA NEVAREZ, 

on behalf of themselves and all others similarly 

situated, and SEBASTIAN DEFRANCESCO, 

Plaintiffs,

vs.

FORTY NINERS FOOTBALL COMPANY, LLC, 

a Delaware limited liability company, et al.,

Defendants.

CLASS ACTION

Case No.: 5:16-cv-07013-LHK (SVK)

POST-DISTRIBUTION ACCOUNTING

Dept: Courtroom 8

Before: Hon. Lucy H. Koh

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 1 of 15
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POST-DISTRIBUTION ACCOUNTING - CASE NO. 5:16-CV-07013-LHK (SVK)

834406.3

Pursuant to paragraph 13 of the Court’s July 23, 2020 Order Granting Final Approval of Class 

Action Settlement (ECF No. 416) (“Final Approval Order”), and in accordance with the Northern 

District of California’s Procedural Guidance for Class Action Settlements updated November 1, 2018 

and December 5, 2018 (“Settlement Guidance”), the Parties in the above-captioned matter hereby 

submit the following chart summarizing the Post-Distribution Accounting of the Class Action 

Settlement. Unless otherwise noted, the information in the chart is based on the Declaration of Alex 

Thomas Re: Current Status of Settlement Claims Audit and Distribution of Payments, filed 

concurrently herewith. 

Total settlement fund $24,003,158.09

Total number of class members Approximately 5,779 “known” class members identified in 

Forty Niners Defendants’ records 

Total number of class members to 

whom notice was sent and not 

returned as undeliverable 

5,233

Number and percentage of claim 

forms submitted

5,240 claim forms submitted (after de-duplication), 7.9% of

which corresponded to known class members. 3,140 total 

claims approved as valid by Settlement Administrator. 

Number and percentage of opt-outs 1 opt-out (0.02% of known class list)

Number and percentage of objections 0 objections (0% of known class list)

Average recovery per claimant $7,640.49

Median recovery per claimant $4,000

Largest amount paid $79,729.71

Smallest amount paid $4,000

Methods of notice to Class Members • U.S. mail;

• e-mail; 

• provision to membership and/or service 

organizations for individuals with mobility 

disabilities;

• posting to the settlement website by settlement 

administrator KCC; and 

• posting by Defendants throughout Levi’s Stadium 

and to websites controlled by Defendants. 

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 2 of 15
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POST-DISTRIBUTION ACCOUNTING - CASE NO. 5:16-CV-07013-LHK (SVK)

834406.3

See generally ECF No. 392, Order Granting Preliminary 

Approval at ¶ 13. 

Methods of payment to Class 

Members

Check mailed via U.S. Mail

Number and value of checks not 

cashed to date 

2,901 checks totaling $22,625,336.41 have not yet been 

cashed since mailed on July 23, 2021. Class Members 

have until July 23, 2022 to cash settlement checks. 

Amounts distributed to cy pres 

recipients to date 

N/A. See Settlement Agreement (ECF No. 375-2) at p. 41, 

§ VIII.B (payment to cy pres not to be determined until 400 

days has elapsed from mailing of damages award). 

Administrative costs to date $253,636.91 paid directly by Defendants.

Attorneys’ fees and costs $13,457,152.40 paid directly by Defendants.

Benefits conferred on the classes by 

the injunctive relief obtained 

As described in the Long-Form notice1 and in greater detail 

in Section III of the Settlement Agreement (ECF No. 375-

2)2, and as modified by Stipulation and Order Regarding 

Extension of Time for Injunctive Relief Stadium 

Remediation Deadlines (ECF No. 439), by October 23, 

2023, Defendants have agreed to modify Levi’s Stadium, 

its main parking lot, and the pedestrian right of way 

connecting the parking lots to the Stadium so that 

individuals with mobility disabilities who use wheelchairs, 

scooters, or other mobility aids will have full and equal 

access to all features and services of the Stadium. 

Defendants will also make improvements to Stadium 

ticketing shuttle services. This work will include, but is not 

limited to, the following:

• ensuring there are at least 282 accessible parking 

spaces in the main parking lot adjacent to Levi’s 

Stadium;

• creating accessible paths of travel to and from the 

entrances of Levi’s Stadium, including the removal 

1

 The Court-approved Long-Form Notice (ECF No. 390-3) is available on the settlement website, here: 

http://www.levisstadiumclassactionsettlement.com/media/2806055/v4_f2n_notice_032520_final.pdf. 

2 The Settlement Agreement is available on the settlement website maintained by Settlement 

Administrator KCC, here: 

http://www.levisstadiumclassactionsettlement.com/media/2691589/ecf_375-2_ex._1.pdf. Exhibits to 

the Settlement Agreement are available on the Case Documents page of the settlement website, here: 

http://www.levisstadiumclassactionsettlement.com/case-documents.aspx. 

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 3 of 15
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POST-DISTRIBUTION ACCOUNTING - CASE NO. 5:16-CV-07013-LHK (SVK)

834406.3

of alleged physical barriers;

• creating accessible paths of travel within the 

Stadium, including paths to, from, and through 

accessible seating locations, concession stands, 

clubs, shops, restaurants, breastfeeding stations, the 

auditorium, and other amenities; 

• providing additional signage in the Stadium and 

surrounding area that directs patrons toward 

accessible paths of travel, such as ramps, elevators, 

and accessible entrances;

• providing accessible bars, tables, concession 

counters, drinking fountains, ticketing windows, 

etc. that people can use while seated in a wheelchair 

or scooter; 

• providing the required amount of designated 

accessible seating for wheelchair and scooter users 

that complies with applicable federal and state 

access standards;

• leveling accessible seating sections so that the 

ground surface is not overly sloped and ensuring 

that companion seats have armrests and cup 

holders; 

• ensuring that all Stadium suites and luxury boxes 

include accessible seating locations and dining 

surfaces;

• modifying restrooms to make them fully accessible 

to people with mobility disabilities by installing 

accessible stall door hardware, ensuring that toilet 

paper dispensers are within reach range, and 

lowering mirrors, among other improvements; 

• making sure that the golf carts, vans, and shuttles 

that provide transportation from the parking lots to 

the Stadium are accessible to individuals with 

mobility disabilities;

• bringing stairs into compliance with applicable 

federal and state access requirements; 

• changing how tickets for accessible seating are sold 

and exchanged to ensure that individuals with 

mobility disabilities have the same access to 

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834406.3

ticketing services as the general public; and

• providing additional disability access training to 

Levi’s Stadium employees, as well as to vendors 

and other relevant third parties. 

Attached hereto as Exhibit A is Defendants’ Progress 

Report #2 dated July 23, 2021, describing the status of 

Defendants’ efforts to implement injunctive-relief terms of 

the Settlement Agreement to date. Licensed architect, 

certified access specialist (CASp) and general contractor, 

Steven E. Schraibman valued the injunctive relief secured 

at $12,194,758. See ECF No. 408-5 (Declaration of Steven 

E. Schraibman in Support of Plaintiffs’ Motion for 

Reasonable Attorneys’ Fees, Costs and Expenses) at ¶ 27. 

Dated: August 2, 2021 Respectfully submitted,

GOLDSTEIN, BORGEN, DARDARIAN & HO

/s/ Katharine Fisher

Katharine Fisher

Attorneys for Plaintiffs and the Certified Classes

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 5 of 15
Exhibit A 

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 6 of 15
Abdul Nevarez, et al v. Forty Niners Football Company LLC, et al, 

United States District Court for the Northern District of California, 

Case No. 5:16-cv-07013 LHK (SVK) 

Progress Report 

Report #2 

Report Dated July 23, 2021 for Period Beginning 

January 23, 2021 (since last Progress Report) 

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 7 of 15
2

I. INTRODUCTION 

SUMMARY 

This report fulfills the requirements outlined in Section X(B) of the Settlement Agreement 

[ECF 375-2] (the “Agreement”) in Nevarez v. Forty Niners Football Company LLC, “Reporting 

Requirements,” which requires the Defendants to report every six months in writing on the 

status of the efforts to implement the terms of the Agreement. 

REPORTING REQUIREMENTS 

The report shall summarize the following: 

a. All compliance efforts that have been made since the last report with respect to each of 

the substantive terms of the Agreement (“Compliance Efforts”); 

b. All parts of Levi’s Stadium, its parking lots and the Pedestrian Rights of Way leading 

from its parking lots to Levi’s Stadium that have been modified and in what manner, all 

Access Work that has been performed, all elements of Levi’s Stadium, its parking lots 

and the Pedestrian Rights of Way leading from the parking lots to the Stadium that have 

been brought into compliance with the 2010 ADA Standards and the 2019 CBC, and all 

Conditions identified in Exhibit A to the Agreement that have been remediated or 

removed and the manner in which this was done (“Modifications”); 

c. The status of any scheduled Access Work on the Stadium, its parking lots and the 

Pedestrian Rights of Way leading from the Stadium’s parking lots to the Stadium; 

d. The reason(s) why any previously scheduled Access Work on the Stadium, its parking 

lots and the Pedestrian Rights of Way leading from the Stadium’s parking lots to the 

Stadium has not been completed (“Status of Access Work”); 

e. The reason(s) why any previously scheduled Access Work on the Stadium, its parking 

lots and the Pedestrian Rights of Way leading from the Stadium’s parking lots to the 

Stadium has not been completed (“Previously Scheduled Access Work Not Performed”); 

f. Anticipated delay(s) completing Access Work in the future and the reason(s) for the 

anticipated delay(s) (“Anticipated Delays”); 

g. All grievances or complaints received by Defendants regarding disability access or 

ticketing services related to accessible tickets since the last report, including copies of 

same, and the response to the grievances or complaints (“Grievances”); and 

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 8 of 15
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h. The monies spent since the last report performing the Access Work specified in Section 

III including, but not limited to, a detailed itemization of the monies expended to 

remediate or remove Conditions identified in Exhibits A-J (“Monies Spent”).

I. REPORTING REQUIREMENTS 

a. COMPLIANCE EFFORTS: 

● Retained Independent Settlement Administrator: 

Defendants previously retained an independent Settlement Administrator and timely 

provided the Settlement Administrator with the most current and complete class list. The 

Settlement Administrator distributed settlement notice and claims forms, received and 

tracked claims forms, traced class members, obtained supplemental information from 

claimants, received and forwarded opt-out statements, and verified the validity of the 

claims. The Settlement Administrator also established a website containing the 

settlement agreement and exhibits, class notice, claims forms, and other relevant 

information apprising class members of their opt-out rights and other rights under the 

Agreement. Defendants provided these documents to the Settlement Administrator in 

the format required by the Agreement. The Settlement Administrator also established a 

toll-free number for class members’ inquiries regarding the settlement. Since the last 

report, Defendants have responded to requests for information from the Settlement 

Administrator to aid in its efforts to verify the validity of claims. Pursuant to Court order, 

the Settlement Administrator completed review of the claims for validity by March 31, 

2021 and were scheduled to distribute the damages awards on July 15, 2021. On July 

20, 2021, the Settlement Administrator advised that it had not distributed the damages 

fund but would do so on or before July 23, 2021. Defendants are prepared to work 

cooperatively with Class Counsel to file the post-distribution accounting with the Court by 

the court-ordered deadline of August 1, 2021. 

● Continued Retention of and Coordination With Mutually Agreed Upon Disability 

Consultant: 

Defendants previously retained Gary Waters as the mutually agreed-upon Disability 

Consultant. Since the last report, Mr. Waters has provided further guidance on the 

informational signs and site maps of the Stadium’s Accessible features and the Access 

Guide. He also has reviewed drawings, plans and projects for ADA compliance. 

● Maintained Grievance Procedure: 

Defendants maintained their written policy and procedure for Class members to submit 

complaints or grievances regarding the accessibility of the Stadium, its parking facilities, 

pedestrian rights of way, and ticketing and transportation services, and trained personnel 

regarding use of same. The ADA Coordinator continued to track submitted grievances 

and oversee the Grievance Procedure. 

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 9 of 15
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● Developed ADA Map and Guide: 

With the assistance of Gary Waters, Defendants prepared an ADA Map and Guide, 

which includes updated maps of accessible paths of travel and other accessibility 

features, as well as additions to the A-Z Guide listing facility resources and features. 

Updated ADA Guide and A-Z Guide are posted to the Levi’s Stadium website. ADA Map 

and Guide will also be available in print version on game day. 

● Developed New Ticketing Policy to Better Accommodate Accessible and Companion 

Seating: 

Defendants’ ticketing policy complies with the requirements of the Agreement, and 

Defendants have made available the exchange of tickets, when available, through 

electronic means that do not require the ticketholder or his/her representative to 

exchange tickets in person. Training sessions were provided to all personnel who sell or 

exchange tickets for Accessible seating to guests of Levi’s Stadium regarding the 

Stadium’s policies and procedures for ensuring that persons with disabilities are 

provided with full and equal access to the Stadium’s facilities and services, and in 

particular, that persons with Mobility Disabilities and their nondisabled companions are 

provided with prompt, effective, and courteous ticketing services for Accessible seating. 

● Parking Lot Design Developer: 

BKF Engineers produced and submitted a Permit Detail Design Package to the City of 

Santa Clara Building Department for review and approval. Gary Waters reviewed the 

design package and provided a letter of conformance for the design that was included in 

the design submission to the City on May 10, 2021. The permit application was paid on 

July 7, 2021. Permit review by the City is anticipated to take 4+ months. The project 

will go to public bid and award after the City approval and work is anticipated to occur in 

Quarter 1 and 2 of 2022. 

 Remediation in the Pedestrian Rights of Way: 

Bellecci began the design engineering and construction contract preparation for the work 

in September 2020. The PROW work has been split up into four design, bid, and 

construction packages. Packages 1 and 2 have been prepared through a 65% 

milestone level of design completion, Package 3 has been completed through a 35% 

milestone level of design completion, and Package 4 has begun design. Each milestone 

submittal is routed to various City departments and divisions for review and comments to 

reduce conflicts and ensure consistency with various public infrastructures and services 

provided by the City per the City’s typical design development process. Bellecci has also 

applied for outside agency permits and approvals required to complete certain elements 

of the work from the San Francisco Public Utilities Commission, the California Public 

Utilities Commission, Valley Transportation Authority, and the Santa Clara Valley Water 

District and is pursuing these approvals. Bellecci’s subconsultant also completed an 

independent CASp review of the Package 1 design engineering and is preparing an 

independent CASp review of the Package 2 design engineering, and will similarly do as 

such for Packages 3 and 4 once they reach the 65% milestone level of completion. 

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 10 of 15
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Bellecci’s subconsultant also completed the CEQA analysis required for the work and 

determined a Categorical Exemption is applicable which is anticipated to be filed by the 

City. The public works construction contract bidding process of Packages 1 and 2 is 

expected to occur through September and October 2021 and Packages 3 and 4 in 

February and March 2022, with construction to begin after bids are accepted and 

contracts awarded by the City Council. Some elements of the PROW work are 

anticipated to be affected by other activities occurring in the area such as private 

development projects and other City capital improvement projects and are planned to be 

addressed through those other activities and not the four construction packages being 

prepared by Bellecci.

● Accessible Courtesy Carts/Shuttles: In researching the procurement of side-facing 

seated carts/shuttles, Defendants have concluded these vehicles are not stocked items. 

Defendants are confirming appropriate specifications with its Disability Consultant. 

b. MODIFICATIONS: 

With regard to modifications related to Access Work, please see Schedule 1. With 

regard to any other modifications made since the Effective Date, please see the following list: 

● North Field Cache Creek Club (Completed): 

Project converted 1,400 SF of tenant warehouse space to new club space. Club is 

located on the 100 level service tunnel across from Visitor Locker Room with access to 

the field. Plans were reviewed and approved by Gary Waters of Pacific Access 

Consulting prior to permit application. Gary Waters performed a post-construction 

inspection and identified three punch list items. Two of the three items have been 

resolved and the third has materials on order. All work will be complete prior to use of 

the space. 

● Food and Beverage Concession Upgrade Project (Completed): 

Projects replaced the Point of Sale units at all concessions in the Stadium, upgrades 

kitchen service equipment to include mechanical, electrical and plumbing connections, 

and replaces concession signage on the 300 and 700 level concourse. Plans were 

reviewed and approved by Gary Waters of Pacific Access Consulting prior to permit 

application. 

● Other Miscellaneous Projects: 

Other modifications include upgrades to broadcast cameras, sponsor signage, and 

maintenance repair projects at the Stadium. 

● Parking Lot: 

Non Access Work modifications related to the Great America Parking Lot remediation 

are set forth in Section c, below. 

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c. STATUS OF ACCESS WORK: 

Defendants provide the following detail regarding status of Access Work: 

● Great America Parking Lot Remediation: 

Parking Lot and Path of Travel Design in the Main (Great America) Parking Lot through 

the canopies and to the Gate A, B and C Bridges design is complete and was submitted 

to the City of Santa Clara for permit review on May 10, 2021. The Stadium Manager paid 

the initial permit application fee to the City of Santa Clara of $30,382.93. This design 

package identifies 282 ADA Parking Stalls with an 8-ft wide accessible walkway to the 

Stadium. Project also removes and replaces the current fence line at the ticketing 

canopies. These drawings will provide details of accessibility improvements in the Great 

America Parking lot. Defendants anticipate to bid and award the construction contract for 

this scope of work once the design is approved by the City. Work is anticipated to take 

place in Quarter 1 and Quarter 2 of 2022. 

● Scoping and Preconstruction Activities: 

Scoping and preconstruction activities started with the Board approval of the TDJV InKind Agreement for remediation of barriers work: accessible path of travel connecting 

Stadium gates and Stadium, Stadium ramps slopes, designated accessible seating 

areas, drinking fountains, suite modifications, and restroom improvements. The 

contractor is scoping and preconstruction activities for the following remediation of 

barriers work will start: handrail extensions, removal of obstructions, modifications of 

countertops, accessible paths of travel, stadium box office improvements, interior 

circulation, signage, and concession improvements. 

● Kiosk, Platform, and Bollard Removal: 

Defendants removed the kiosk in Section 125, the elevated exterior Bud Light counter 

and platform, and the bollard at the ramp identified in the Agreement. 

 

 

● Suite Signage: 

Suite signage has been contracted and will be installed prior to the first event. The 

signage is added to inform and notify guests of how to request the removal of chairs to 

provide accessible seating for suite guests. 

● Pedestrian Rights of Way: 

Bellecci began the design engineering and construction contract preparation for the work 

in September 2020. The PROW work has been split up into four design, bid, and 

construction packages. Packages 1 and 2 have been prepared through a 65% 

milestone level of design completion, Package 3 has been completed through a 35% 

milestone level of design completion, and Package 4 has begun design. Each milestone 

submittal is routed to various City departments and divisions for review and comments to 

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 12 of 15
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reduce conflicts and ensure consistency with various public infrastructures and services 

provided by the City per the City’s typical design development process. Bellecci has also 

applied for outside agency permits and approvals required to complete certain elements 

of the work from the San Francisco Public Utilities Commission, the California Public 

Utilities Commission, Valley Transportation Authority, and the Santa Clara Valley Water 

District and is pursuing these approvals. Bellecci’s subconsultant also completed an 

independent CASp review of the Package 1 design engineering and is preparing an 

independent CASp review of the Package 2 design engineering, and will similarly do as 

such for Packages 3 and 4 once they reach the 65% milestone level of completion. 

Bellecci’s subconsultant also completed the CEQA analysis required for the work and 

determined a Categorical Exemption is applicable which is anticipated to be filed by the 

City. The public works construction contract bidding process of Packages 1 and 2 is 

expected to occur through September and October 2021 and Packages 3 and 4 in 

February and March 2022, with construction to begin after bids are accepted and 

contracts awarded by the City Council.

d. PREVIOUSLY SCHEDULED ACCESS WORK NOT PERFORMED:

There is no Access Work that was “previously scheduled” but that has not been 

completed. There is Access Work that, pursuant to the Agreement, was to be completed before 

the date of this report that has not yet been completed. That Access Work was the subject of a 

stipulation and order signed by the Court extending the deadlines to complete such work. 

e. ANTICIPATED DELAYS: 

The COVID-19 pandemic presented significant challenges related to completion of 

construction-related Access Work: Minimal staff and no fans / guests have been permitted to 

enter the Stadium since the original shelter in place order was issued by the Santa Clara County 

Health Officer on March 16, 2020. Santa Clara County issued an additional order on November 

28, 2020 restricting all contact sports requiring the San Francisco 49ers to relocate operations 

to Phoenix, Arizona. In addition, the COVID-19 pandemic has affected supply chains and travel 

of design and construction specialists, as well as City operations, which are necessary for both 

approval of Stadium construction, but also remediation in the Pedestrians Rights of Way. Public 

entities, such as the City of Santa Clara, have been disproportionately affected by the pandemic 

with huge increases in expenses, large reductions in revenue from industries, and strained 

supply of public resources including human resources. Further, the Stadium was used as a 

mass COVID-19 vaccination site until late June 2021. 

In addition, when agreeing to the schedule as set forth in the Settlement Agreement, it 

was the intent of Defendants to complete most of the construction-related Access Work during 

the months of January through April each year during the Compliance Period and Defendants 

will be unable to perform any construction-related Access Work during these months in 2021. 

Further, Defendants’ Third Party Complaint against TDJV is still pending. Defendants 

and TDJV engaged in settlement negotiations for many months and the parties executed a 

Case 5:16-cv-07013-LHK Document 444 Filed 08/02/21 Page 13 of 15
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settlement agreement on July 1, 2021. The settlement provides that TDJV perform a significant 

amount of the construction-related Access Work. The settlement is not final until the Court has 

issued an order regarding TDJV’s motion for determination of good faith settlement, which the 

Court has set for hearing on November 18, 2021. In addition, the City of Santa Clara and the 

Santa Clara Stadium Authority approved in open session an amendment to the original Design 

Build Agreement to allow TDJV to perform the work consistent with Santa Clara ordinances and 

state law related to public works projects. 

Finally, to the extent construction-related Access Work is not performed by TDJV, such 

work must comply with applicable local and state laws related to public works projects, and the 

procurement process related to such compliance also has been affected by the pandemic. 

As a result, the parties agreed, and the Court ordered, an extension of time for injunctive 

relief for the Forty Niners Defendants on April 14, 2021. Those deadlines are identified in the 

Court’s Order, ECF 439. The parties are continuing to meet and confer about a potential 

extension of time related to Defendant The City of Santa Clara’s remediation to the PROW, and 

Defendant will file a motion in the unlikely event that the parties cannot reach an agreement 

regarding those deadlines. 

f. GRIEVANCES: 

No grievances or complaints were reported during this time period regarding disability 

access or ticketing services related to accessible tickets. A handful of inquiries were made 

regarding future availability of accessible seating and parking. 

g. MONIES SPENT:

In addition to monies spent for equitable relief including, but not limited to, training, 

internal retention of employees, legal counsel, and claims administration, Defendants spent the 

amounts related to Access Work on Exhibit A to this Report. 

 

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EXHIBIT A 

Vendor Amount 

Since Last 

Report

Total Amount Since Effective 

Date

Work 

Gary 

Waters 

Architectural 

Corp DBA 

Pacific 

Access 

Consulting

Amounts 

have been 

incurred. 

Awaiting 

invoice. 

$5,483 Review of informational signs 

and site maps of the Stadium’s 

Accessible features and the 

Access Guide

BKF 

Engineers

$0 $145,725 Design Services for parking lot 

remediation

Imprintz $0 $10,757 Design, layout, and installation 

of ADA directory signage

Inprintz $2135.70 $2135.70 ADA Suite Signage

KCC $189,271.32 $189,271.32 Claims Administration 

City of 

Santa Clara 

$30,382.93 $30,382.93 Great America Parking Lot 

Permit Application 

Lithographix $10,339.85 $10,339.85 Revisions and updates to sign 

directories. 

Kevin 

McGuire & 

Associates

$97,736.98 $97,736.98 Preparation of ADA Training 

Materials; Conducted ADA 

Training 

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