RECEIVED

AUG 2S 2O2O P

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DIVISION OF ILLINOIS

DEANDRE BRADLEY

Vs

111th Food Market dlbla Express Food Mart ll,

20-cv-051 16

Judge Steven G. Seeger

Magistrate Beth W. Jantz

COMPLAINT FOR MONETARY RELIEF

PARTIES

Deandre Bradley is the pro-se plaintiff who is a 29 year old wheelchair bound male who

is located at 103 west 112th street Chicago 1L,60628.

Defendant 11lth Food Market d/b/a Express Food Mart ll is located 11058 south

Wentworth Ave Chicago 1L,60628 is being sued in its individualand or officialcapacities

pursuant to title 3 of the americans with disabilities act.

JURISDICTION

This court has jurisdiction over the plaintiffs claims pursuant to 42 USC sec.12101 et

seq

STATEMENT OF FACTS

1.Pro-se plaintiff Deandre Bradley at all times relevant to this complaint is a wheelchair

bound individual who qualifies under the Americans with Disabilities Act as a person

with a disability.

2.On May 25,2O2A the plaintifi attended Roseland hospita! to have staples removed

from this abdomen. While waiting the plaintiff pushed his wheelchair to the defendants

store Express Food Mart ll.

3.When the plaintiff anived in the parking lot, the plaintiff located a ramp that would

allow him access to the side walk. The ramp was small ill-maintenanced and there was

a car parked too close to the ramp.

Case: 1:20-cv-05116 Document #: 1 Filed: 08/28/20 Page 1 of 4 PageID #:1
4.Not looking for something to complain about the plaintiff used the ramp to the best of

his ability and was able to gain access to the store.

S.The plaintiff went back to the hospital and the staples were removed ,the plaintiff

returned to the defendants store for medicalsupplies and tobacco products on the same

day.

6.This time when the plaintiff arrived in the parking lot there was a car parked right on

top of the wheelchair ramp.The plaintiff asked the car to move and the man in the car

was unaware that he was parked over or on the ramp and stated a fact.

7.This individual stated in a very aggressive threatening manner that there are no lines

painted on the ground and there are no signs posted anywhere.

8.To avoid any confrontation the plaintiff saw a employee and stopped him and

explained that he had no access to the store because the ramp was unavailable

because customers are not being instructed on where they can and can't park ,therc

requesting that this employee shop for the plaintiff and was told that they don't do shop

for customers.

9.A lady who was nearby saw and heard the plaintiff ,then approacfied the plaintiff and

tried to help but her time was limited so she purchased tobacco products and almost got

into a verbal altercation with the man who was parked over the ramp in the plaintiffs

defense.

10.Due to the above stated reasons the plaintiff was intentionally discriminated against

by this company and respectfrrlly request compensation.

11.The plaintiff also tried to resolve this issue prior to any court but the defendants are

refusing to.

12.Since this incident the defendants did take appropriate action, the entire parking lot

has been remodeled and is now up to code.This is more proof into plaintiffs claims.

13.The plaintiff was not able to obtain medical supplies to treat his wound which

eventually ended up becoming infected as antibiotics had to be prescribed to treat the

plaintiff.

RELIEF

Case: 1:20-cv-05116 Document #: 1 Filed: 08/28/20 Page 2 of 4 PageID #:2
The plaintiff Deandre Bradley is entitled to be compensated for the intentional

discrimination inflicted upon him by this priviate company.

The law provides that pursuant to title 3 of the americans with disabilities act certain

accommodations must be made available.

The humiliation caused by this companies reckless failure to provide simple

maintenance to a parking lot ,the disrespect and ignorance of an employee to refuse to

help a customer in a wheelchair is a problem.

Plaintiff is requesting Compensatory damages in the amount of $65,000.00.

Respectfully submitted

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