Adam Ghadiri

Disability: difficulty walking

Represented by: the Potter Handy Firm ("Center for Disability Access")

Number of lawsuits filed: hundreds

Targets: all retails

Serial filer Adam Ghadiri lives in Coto de Caza, California. He uses a walker to move about. He learned how profitable the ADA can be as a paralegal. Mr. Ghadiri, at times, represents himself in lawsuits, however he is also represented by the Potter Handy Firm. In his spare time he counsels others on how to profit from ADA suits. 

Mr. Ghadiri filed suit in the Central District against a carpet store in Long Beach. His deposition testimony reveals his tactics.

Examination by attorney Ara Sahelian:

22· · · · Q.· · Do you drive through the gates to get to your 

23· ·house.?

24· · · · A.· · Yes.

25· · · · Q.· · When did you move to Coto de Caza? 

·1· · · · A.· · Last July.

Adam Ghadiri Deposition, Pages 46, 47

·3· · · · Q.· · Would you say your principle source of income

·4· ·is the filing of ADA cases?

·5· · · · A.· · Yes.

·6· · · · Q.· · And that you for all intents and purposes have

·7· ·no other source of income?

·8· · · · A.· · No.

·9· · · · Q.· · I'm sorry?

10· · · · A.· · No, I don't.

11· · · · Q.· · You do not have any other sources of income?

12· · · · A.· · I don't, no.

13· · · · Q.· · If you stopped filing ADA cases, how would you

14· ·be able to survive?

15· · · · A.· · I don't know.

Id. Page 106

When it comes to drafting lawsuits, many of which he has filed pro se, he delegates the task to non-attorneys, and does not bother reading them. 

·5· · · · Q.· · What part of this Complaint did you write 

·6· ·yourself?

·7· · · · A.· · I don't think this one I write any of it. 

...

13· · · · Q.· · Do you remember reading it?

14· · · · A.· · I did not read it.· I'm -- I'm try to just 

15· ·now.

16· · · · Q.· · Do you remember reading it at all before you 

17· ·filed it?

18· · · · A.· · No.

19· · · · Q.· · Did you read it at all before you signed it?

20· · · · A.· · No.

21· · · · Q.· · Who put it in front of you for you to sign?

22· · · · A.· · Whoever typed it.

Id. Page 62

22· · · · Q.· · Okay.· And you did not read this Complaint 

23· ·before you signed it; correct?

24· · · · A.· · Correct.

25· · · · Q.· · I'm going to direct your attention to --.· And

·1· ·one last attempt.· No attorneys contributed to this 

·2· ·Complaint; correct?

·3· · · · A.· · No.

·4· · · · Q.· · Is that a -- is that correct?

·5· · · · A.· · Correct.

Id. Pages 66-67

·2· · · · Q.· · I would like you to go to paragraph 11 of the 

·3· ·Complaint.· I would like you to direct your attention to 

·4· ·the second sentence that starts with, "Plaintiff would 

·5· ·like to patronize."· And I would like you to please read 

·6· ·that entire sentence.

·7· · · · A.· · Well, again it talks about restroom, and I say

·8· ·earlier is a typo.

·9· · · · MR. PRICE:· Just answer the question he's asking.

10· · · · Q.· · BY MR. SAHELIAN:· I'm asking you to read the

11· ·second sentence, not the first.

12· · · · A.· · "Plaintiff would like to patronize this

13· ·establishment again but cannot do so until the defendants

14· ·remove these barriers."

15· · · · Q.· · What does the word patronize mean to you?

16· · · · A.· · I didn't type it.· I really don't know.· I not

17· ·type that.· This is the one they put it in, and I did not

18· ·check it.

19· · · · Q.· · What does it mean to you that you cannot do so

20· ·until defendants remove these barriers?

21· · · · A.· · I don't know what that mean.· I did not wrote

22· ·this.· Office did it, and I sign it.· I should have read

23· ·it.

Id. Pages 94, 15-18

It's not clear whether Ghadiri is a "drive-by" ADA plaintiff. Ghadiri did not remember when he actually visited the store, or how he got there. He presumes he drove from Coto de Caza to the Westwood area of Los Angeles, and on his way back towards Long Beach stumbled on the store (a 40 minute drive from his house, including an 8 minute drive from the 405 Fwy).  

15· · · · Q.· · BY MR. SAHELIAN:· So is it your testimony that 

16· ·you left your house on some unspecified morning and drove 

17· ·straight to Long Beach to shop for carpeting?

18· · · · A.· · No.

19· · · · Q.· · What is your testimony?

20· · · · A.· · I had other business to do in LA area.

21· · · · Q.· · Okay.· Do you remember what the other business 

22· ·was in LA?

23· · · · A.· · Yes.

24· · · · Q.· · What was it?

25· · · · A.· · I go to Westwood, is a Persian square.· I go

·1· ·there for shopping, see friends, and that is it.

Id. Page 80 - 81

....

22· · · · Q.· · Okay.· And you have no recollection of what 

23· ·that business was?

24· · · · A.· · I go eat, have nice Persian restaurants there, 

25· ·very delicious food.· They have some Persian markets.

·1· ·Every -- it's a Persian square.

·2· · · · Q.· · And so did you go to a restaurant that day 

·3· ·before your visit to Carpet and Linoleum City?· Did you 

·4· ·go to a restaurant in Westwood?

·5· · · · A.· · I don't remember.

Id, Pages 81 - 82  

·6· · · · Q.· · What do you understand from "difficulty,

·7· ·discomfort, and embarrassment" as it applies to your

·8· ·visit to the defendant's property?

·9· · · · A.· · Well, if a big chance I fall down when I was

10· ·walking across of his property, and it's a difficult I

11· ·walk at that time even three feet, 30 feet, so that's why

12· ·I put it here.· And if I -- if I would have fall down, is

13· ·embarrass.· And I did fall down a lot.· A lot of time.

14· ·Numerous of time.

Id, Page 98

....

11· · · · Q.· · BY MR. SAHELIAN:· Okay.· Now describe all the

12· ·discomfort that you experienced that day visiting

13· ·defendant's store.

14· · · · A.· · Wouldn't be able to park by the door or there

15· ·was no sign to I can go from front door or backdoor.· Was

16· ·no signage.· The backdoor was roll-up door.· There was

17· ·only place I could enter.· And at that time.· And I had

18· ·to walk cross of a walkway, and I was afraid to maybe I

19· ·fall down again.

20· · · · Q.· · Okay.· Did you have your walker with you?

21· · · · A.· · I don't remember.

22· · · · Q.· · Okay.· Now would you say there's less of a

23· ·chance for you to fall down if you're using your walker?

24· · · · A.· · Yes.

25· · · · Q.· · Okay.· So if there was a chance for you to

1· ·fall down on that day and you were, as you described,

·2· ·concerned about falling down, why would you not have

·3· ·brought your walker with you?

·4· · · · A.· · I didn't want to be embarrass.· I -- because I

·5· ·fall in a shopping center, middle of a driveway, and then

·6· ·people has to stop their car and come pick me up, it was

·7· ·embarrassing.· So as emotional feeling I have.· I still

·8· ·have it.· Even I walk with this walker, I kind of hurts

·9· ·me, my feeling.

10· · · · Q.· · You'll have to forgive me because I didn't

11· ·understand your answer.· Are you suggesting that you did

12· ·not bring your walker that day because it's embarrassing

13· ·for you to use a walker?

14· · · · A.· · If I fall down is embarrassing, yeah.

15· · · · Q.· · But you just said --

16· · · · A.· · I said I don't remember if I had my walker

17· ·with me or no.

18· · · · Q.· · But if you are prone to falling down, would

19· ·you not want to bring your walker with you?

20· · · · A.· · Being stubborn, I still don't want to believe

21· ·I have -- I'm disable.· I fight with it.'ll

Id. Pages 99 - 100

12· · · · Q.· · Okay.· So you mentioned in your Complaint that

13· ·you were embarrassed on that day of the incident.· What

14· ·part of -- what happened on that day caused you

15· ·embarrassment?

16· · · · MR. PRICE:· Again, I'm going to object.· This calls

17· ·for interpretation of a legal term.· I understand he will

18· ·still answer, but the same objection as before.

19· · · · THE WITNESS:· Well, generally being a handicap is

20· ·not happiness.· Everybody knows that.· And being

21· ·discriminating, so makes me embarrass.· Because again, I

22· ·had the experience of falling down and hurting myself.

23· ·So I was try to be a stubborn and not to use walker, and

24· ·I don't remember at that day I had walker with me or no.

Id, Page 101 

·3· · · · Q.· · Okay.· Now you say you were shopping for

·4· ·carpeting in October of 2018; correct?

·5· · · · A.· · Yes.

·6· · · · Q.· · Okay.· What was the carpeting going to be used

·7· ·for?

·8· · · · A.· · For my house.

·9· · · · Q.· · I see.· Which part of your house?

10· · · · A.· · Outdoor.

11· · · · MR. PRICE:· Take your hand down.

12· · · · THE WITNESS:· Outdoor.· In a walking area.

13· · · · Q.· · BY MR. SAHELIAN:· Could you repeat that,

14· ·please?

15· · · · A.· · Outdoor for sidewalk area.

16· · · · Q.· · Outdoor for sidewalk area.

17· · · · A.· · Yes, from sidewalk to entering into the house.

Adam Ghadiri Depo, Page 77

15· · · · Q.· · BY MR. SAHELIAN:· So is it your testimony that 

16· ·you left your house on some unspecified morning and drove 

17· ·straight to Long Beach to shop for carpeting?

18· · · · A.· · No.

19· · · · Q.· · What is your testimony?

20· · · · A.· · I had other business to do in LA area.

21· · · · Q.· · Okay.· Do you remember what the other business 

22· ·was in LA?

23· · · · A.· · Yes.

24· · · · Q.· · What was it?

25· · · · A.· · I go to Westwood, is a Persian square.· I go

·1· ·there for shopping, see friends, and that is it.

Id, Pages 80 - 81

....

22· · · · Q.· · Okay.· And you have no recollection of what 

23· ·that business was?

24· · · · A.· · I go eat, have nice Persian restaurants there, 

25· ·very delicious food.· They have some Persian markets.

·1· ·Every -- it's a Persian square.

·2· · · · Q.· · And so did you go to a restaurant that day 

·3· ·before your visit to Carpet and Linoleum City?· Did you 

·4· ·go to a restaurant in Westwood?

·5· · · · A.· · I don't remember.

Id. Pages 81 - 82  

Since his initial visit, Ghadiri has made no concrete plans to re-visit the store. Buying carpeting is no longer a "priority" for him. The law requires that a plaintiff suffer an injury, and that he have a concrete plan to return to the store. 

·5· · · · Q.· · As we sit here today, have you bought the

·6· ·outdoor carpeting you were looking for?

·7· · · · A.· · No, I bought it indoor carpet.

·8· · · · MR. SAHELIAN:· Could you please read my question.

·9· · · · · · · (The record was read as follows:

10· · · · · · · · "As we sit here today, have you bought the

11· · · · · · outdoor carpeting you were looking for?")

12· · · · THE WITNESS:· No.

13· · · · Q.· · BY MR. SAHELIAN:· Why not?

14· · · · A.· · Change my mind.· Because I did operation, and

15· ·I'm using this often.· And I was for two months -- three

16· ·weeks in hospital, one month inside the house recovering,

17· ·so I was -- I wasn't go -- for two months, I didn't go

18· ·out too much.

19· · · · Q.· · When do you plan to buy this outdoor

20· ·carpeting?

21· · · · A.· · Maybe near futures.· Pretty soon I have to buy

22· ·it.

23· · · · Q.· · And what steps have you taken to look for

24· ·outdoor carpeting since?

25· · · · A.· · Is not priority for my need right now, so I

·1· ·didn't take any steps.

Id. Pages 86 - 87