Plaintiff desires to attend the aqua classes at the Sunrise, Florida location. Plaintiff previously  explained to Defendant’s personnel at the front desk that her PCA is required in order to assist  her in getting dressed prior to and after the aqua class in the locker room.    Plaintiff is partially paralyzed in her left side and cannot get into and out of a swimsuit without  the assistance of her PCA. Plaintiff explained in detail that her PCA would be coming into the  locker room to assist with dressing, and would in no way be availing herself of the services  offered at the gym.    On or about Wednesday, July 30, 2014, the Defendant’s front desk at the Sunrise, Florida  location would not let Plaintiff’s PCA onto the premises to assist Plaintiff in changing clothes.     Plaintiff immediately brought this issue to the attention of the manager, Maurice, and  explained that her PCA would have to be allowed into and out of the locker room to assist  with changing in and out of Plaintiff’s bathing suit.    The manager of the location (Maurice) instructed Plaintiff that either the PCA would have to  buy a gym membership, or Plaintiff would be required to pay a personal trainer to assist when  inside the gym. Plaintiff replied that a personal trainer does not assist with dressing and  undressing disabled individuals in the locker room.    Plaintiff insisted that it was discriminatory to disallow the PCA from entering the premises to  assist Plaintiff with changing clothes, which Plaintiff cannot undertake on her own due to  disability. Defendant’s manager then stated “have a nice day” and walked away without any  further communication.   Accordingly, so as to continue to make use of the Sunrise, Florida, 24 HOUR FITNESS  location, and so as to be assured that her PCA will be granted entry to change Plaintiff’s  clothing within the locker room (without being stopped, impeded, or harassed), Plaintiff has  been left with no choice but to file this lawsuit seeking an injunction, and mandating that the  gym comply with its legal obligations as it relates to policies and procedures applicable to  disabled gym members such as Plaintiff.   Plaintiff brings this action on her own behalf and as a class action pursuant to Federal Rule of  Civil Procedure 23, on behalf of the following class of individuals:   All members of any 24 HOUR FITNESS gym nationwide, who by  virtue of physical disability, require the assistance of a Personal  Care Attendant while on gym property (the “Class”).    The Class includes all individuals who have been forced to pay membership fees for their  PCA in order to secure entry for the PCA onto gym property.    Plaintiff has personal knowledge that there exist other 24 HOUR FITNESS members who  have been told or forced to buy memberships for their PCAs, so the PCAs can provide  disability-related assistance within the gym premises.    The members of the Class are so numerous that joinder of all Class members is not practical;  the exact size of the Class can be determined only through discovery.    Plaintiff can adequately protect the interest of the members of the Class and has retained  competent counsel experienced in ADA and class action litigation. Plaintiff has no interest  that is contrary to or in conflict with the interests of the members of the Class.   A class action is superior to other methods of adjudicating this controversy. The expense and  burden of individual litigation over this issue makes it virtually impossible for the Class  members to individually seek redress for all violations across the country, and it would be  highly inefficient for the Defendant, the Class, and the Court system, for all Class members  to individually seek redress for the issue raised herein.    Common questions of law and fact exist as to all members of the Class and predominate over  questions solely affecting any individual Class member. Among such questions of law and  fact is whether or not Defendant has violated one or more statutory obligations by failing to  accommodate disabled gym members in need of assistance (relating to a function of daily  living) from a PCA.     Plaintiff knows of no difficulty that would be encountered in the management of this litigation  that would preclude its maintenance as a class action.   The names and addresses of disabled individuals who have been excluded from fair and equal  access is obtainable through traditional channels used to identify members of any class; notice  can be delivered to all such individuals by U.S. Mail or electronic mail using techniques and  in a form of notice similar to those customarily used in class action litigation.  The subject 24 HOUR FITNESS location in Sunrise, Florida, is a place of public  accommodation as defined by the ADA. 42 U.S.C. § 12181.     Plaintiff has been a long term member of the 24 HOUR FITNESS gym, and was a bona fide  visitor to the subject Sunrise, Florida location on July 30, 2014, and intends to continue  visiting the Sunrise, Florida location and making use of aqua classes into the foreseeable  future, and thus desires to use the goods, services, facilities, privileges, advantages and/or  accommodations offered at the Sunrise, Florida gym.    In light of her disabilities, Plaintiff will be unable to fully, properly, safely, and equally access  the subject facility and/or the goods, services, facilities, privileges, advantages and/or  accommodations therein, unless and until Defendant is required to modify its policies and  procedures so as to comply with the Americans with Disabilities Act, or if such policies and  procedures already exist, is required by injunction to enforce those policies and procedures at  the Sunrise, Florida location, and at every location used by any member of the Class.    Defendant has discriminated against Plaintiff and all others with similar disabilities by  denying full and equal access and enjoyment of the goods, services, facilities, privileges,  advantages and/or accommodations at the subject gym.   Defendant will continue to discriminate against Plaintiff and all others similarly situated  requiring the assistance of a PCA in the locker room (or elsewhere), unless and until it is  compelled by this Court to remove barriers to access by either implementing appropriate  policies and procedures or enforcing policies and procedures that are not being followed by  the Sunrise, Florida location and its management.   This Court is vested with authority to grant injunctive relief sought by Plaintiff herein  including entry of an order requiring creation, implementation, and/or enforcement of  applicable policies, practices, and procedures necessary to provide full and equal access to  Plaintiff and all those similarly situated.   As a corollary to the injunctive relief sought herein, Plaintiff seeks disgorgement of profits  garnered through enjoined and unlawful misconduct. Both the Eleventh Circuit Court of  Appeal and the U.S. Supreme Court have been clear that a Court sitting in equity has at its  disposal a full range equitable remedies, including the power to disgorge funds previously  garnered through enjoined activities.    This Court’s equitable jurisdiction has been invoked through Plaintiff’s filing of a claim for  violation of the ADA (which provides for injunctive relief). As an adjunct to this Court’s  authority to award an injunction in this case, the Court is fully vested with jurisdiction to  disgorge Defendant of all funds collected as direct result of its own discriminatory and  enjoined misconduct.    Plaintiff has been a member of the 24 HOUR FITNESS gym for years, and for years has made  use of the Miramar, Florida location, with the assistance of her personal care attendant  (“PCA”), without any issue.    VIOLATION OF THE AMERICANS WITH DISABILITIES ACT  