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Alejandra Perez
Disability: visually impaired
Represented by: Law Offices of Morse Mehrban
Number of lawsuits filed: dozens
Targets: small restaurants, bakeries and coffee shops for purported website violations
Ms. Perez is a visually impaired college student. She likes to cruise the internet, and randomly picks restaurants - some located as far away as 60 to 80 miles from her residence - to inspect their menus. She sues restaurants, the menus of which she finds to be "inaccessible."
Ms. Perez prefers suing small restaurants for their allegedly inaccessible menus. As an example, she sued The Village Inn on Balboa Island. Excerpts from her deposition, below, reveal her mindset.
Is Ms. Perez an advocate for the disabled or is she a profiteer? You be the judge. Examination by Attorney Ara Sahelian:
__________________
9 Q. What do you do for a living, Ms. Perez?
10 A. I'm a full-time student. I just graduated from
11 high school and I'm going to CSUN this coming semester
12 in the fall. And I will also be getting an internship
13 very soon at the Braille Institute.
14 Q. Very well. Where do you live?
15 A. In Arleta.
16 Q. Spell that.
17 A. A-R-L-E-T-A.
...
11 Have you had your deposition taken ever?
12 A. No.
13 Q. Do you know why you are here?
14 A. Yes.
15 Q. What is the reason?
16 A. I'm here to get compensation for the -- my
17 violations being -- I'm not sure how to say this, but I
18 know that my -- when I was going on the websites, it
19 wasn't accessible to me and I'm here to make a
20 difference and -- yeah.
...
24 Q. All right. Can you tell me how many lawsuits
25 you've filed so far?
1 A. Seventeen.
2 Q. And has Mr. Mehrban been your attorney on
3 all 17?
4 A. Yes.
...
3 Q. How often do you order food online?
4 A. A week or like --
5 Q. In a week.
6 A. Um, about three times to four times a week,
7 yeah.
8 Q. And you use your credit card for placing those
9 orders?
10 A. Yes.
...
7 Q. So tell me: Where were you when you went
8 online to look into The Village Inn on Balboa Island.
9 A. We were at my house.
10 Q. And what were you looking to do by going on the
11 website?
12 A. Again, look at restaurants. On what website?
13 Q. On The Village Inn on Balboa Island's website?
14 A. I was looking for, like, the menus and stuff.
15 Q. Menus and stuff; okay.
16 So what were you looking to see on the menu?
17 A. Food.
18 Q. (Inaudible.)
19 Did you hear my question?
20 A. I said, "Food."
21 Q. What specific type of food were you looking
22 for?
23 A. None specific.
24 Q. Did you end up going there?
25 A. I didn't.
1 Q. Why not?
2 A. I didn't find anything, like -- that I, like,
3 actually like there, because when I would look at
4 restaurants, a lot of the restaurants in Balboa Island,
5 their websites are really messed up.
6 Q. I'm asking you specifically with respect to
7 The Village Inn on Balboa Island. You said you haven't
8 gone back there or you haven't been there.
9 And what is the reason for that?
10 A. I just didn't find -- I couldn't find anything
11 that, like, would help me go there. I didn't see a use
12 to go there.
13 Q. I don't understand. You'll have to explain
14 that again.
15 What is the reason you did not go to dine at
16 The Village Inn on Balboa Island?
17 A. Because I didn't know what the food was. I
18 couldn't read it, so...
19 Q. You weren't able to read the menu at all?
20 A. Huh-uh.
21 Q. Did you try going on Yelp?
22 A. I didn't use Yelp because Yelp is inaccessible.
23 Q. You'll have to speak slower.
24 A. I don't use Yelp because it's not accessible.
25 Q. Have you sued Yelp?
1 A. No.
2 Q. Any reason why?
3 A. I haven't thought about it because it's a
4 big -- it's an app, like -- I don't know.
5 Q. How about some of the other sites that provide
6 menus?
7 A. Like what?
8 Q. Well, you tell me. You're the one that orders
9 food.
10 Have you ever been on Grubhub, for instance?
11 A. Yes, but I don't order from there.
12 Q. Why not?
13 A. It's not accessible either. The most
14 accessible ones that even aren't super accessible, but I
15 can still manage to work with it is Uber Eats and
16 DoorDash.
17 Q. Have you thought of suing Grubhub?
18 A. No.
19 Q. Why not?
20 A. No specific reason. I just haven't thought
21 about it.
22 Q. Well, you did mention at the beginning of our
23 conversation that your mission is to make these websites
24 accessible, did you not?
25 A. I did.
1 Q. Don't you think you would make -- in your mind,
2 do you think you would make an impact on society as a
3 whole if you sued some of these websites, such as
4 DoorDash and Uber Eats?
5 A. Yeah.
6 Q. So what's holding you back?
7 A. Nothing. It's a good idea.
...
