EN
Translate:
EN
EN
Translate:
EN
Disability: paraplegic
Represented by: the Manning Firm, Atty. Joseph Manning
Number of lawsuits filed: hundreds
Targets: convenience stores
Ms. Cabrera is a paraplegic confined to a wheelchair. She does not drive. She uses public transportation to travel to the various parts of town. She then finds a convenience store, the parking lot of which may be worn exposing minor bumps and cracks, and sues alleging that riding over small cracks and bumps causes her difficulty and discomfort (keeping in mind that her wheelchair tires measure four to five inches in width, and the cracks to which she refers are one-half inch wide).
Is Ms. Cabrera an advocate for the disabled or is she a profiteer? You be the judge. Examination by attorney Ara Sahelian:
____________
14 Q. Can you tell me, Ms. Cabrera, every aspect of
15 your visit? Let me rephrase that.
16 Can you please tell me what difficulty you
14:14 17 experienced with respect to your visit to the liquor
18 store in question here?
19 A. Yes. There was no ADA entrance. Um, I
20 believe about that slope that we were talking about a
21 little. And that the floors were cracked. That was it.
14:15 22 Q. All right. How much does your wheelchair
23 weigh, Ms. Cabrera?
24 A. Roughly around 350 to 380 pounds.
25 Q. All right. And I am sorry, I'm having to ask
1 this for technical reasons. What do you weigh?
2 A. 230.
14:15 3 Q. All right. So you said the wheelchair was
4 380? Is that what you said?
5 A. Yeah, roughly.
6 Q. Okay. Along with 230, that would make the
7 combined weight of you and your wheelchair 600 pounds;
8 correct?
9 A. Yes.
14:16 10 Q. Do you think that a crack in the asphalt is
11 going to cause you difficulty or discomfort?
12 A. Yes.
13 Q. How wide does the crack have to be to cause
14 you difficulty and discomfort?
15 A. I don't know, I wouldn't -- I've never
16 measured a crack.
17 Q. All right. Would it have to be a quarter inch
18 or half an inch?
19 MR. HASHEMI: Calls for speculation. Lacks
20 foundation.
21 Q. BY MR. SAHELIAN: So if you're riding along a
14:17 22 -- an asphalt parking lot, how wide would a crack have to
23 be to cause you difficulty?
24 A. Like a quarter of an inch or a half an inch.
25 Q. Half an inch. And how deep would it have to
1 be?
2 A. Like an inch as well.
14:17 3 Q. All right. So an inch deep and quarter to
4 half an inch in width; correct?
5 A. Yes.
6 Q. And that could cause you difficulty; correct?
7 A. Yes.
8 Q. All right. And how often do you come across
9 that riding along sidewalks?
10 A. Quite often.
11 Q. Does that stop you from riding along
14:17 12 sidewalks?
13 A. No, but it's uncomfortable.
14 Q. All right. And do you end up having to go to
15 see a doctor because you went over a half inch crack?
16 A. No.
17 MR. HASHEMI: Objection, argumentative, and lacks
18 foundation, vague.
14:18 19 THE WITNESS: But I get diaper rashes. And the
20 diaper rash when I go through cracks like that irritates
21 it. So it's quite discomforting for me.
22 Q. BY MR. SAHELIAN: All right. Do you take
23 Advil or a painkiller because you've had to go over half
24 inch cracks?
25 A. I have.