IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA
TAYLOR PRICE,Plaintiff,v.Civil Action No. 09-cv-1709-RMCKIMBERLY, INC.d/b/a MR. SMITH’S OF GEORGETOWN&MR. SMITH’S MANAGEMENTCOMPANY, INC.d/b/a MR. SMITH’S OF GEORGETOWN,Defendants.
ANSWER
Defendants Kimberly, Inc. and Mr. Smith’s Management Company, Inc. (collectively,“Mr. Smith’s” or “Defendants”) by their attorneys, state as follows:
NATURE OF ACTION
1.
Defendants deny knowledge or information sufficient to form a belief as to thetruth of the allegations contained in Paragraph 1 of the Complaint, and therefore, deny suchallegations. Defendants admit the allegation to the extent that this is an action for violations of Title III of the Americans with Disabilities Act (“ADA”), 42 U.S.C. §§ 12101
et seq
. and theDistrict of Columbia Human Rights Act (“DCHRA”), D.C. Code §§ 2-1401.01
et seq.
Case 1:09-cv-01709-RMC Document 3 Filed 11/09/2009 Page 1 of 13
2
JURISDICTION AND VENUE
2.
Defendants neither admit nor deny the allegations contained in Paragraph 2 of theComplaint on the basis that no factual allegations are asserted. To the extent that a response isrequired, Defendants deny the allegations in Paragraph 2 to the extent they conflict with the law.3.
Defendants neither admit nor deny the allegations contained in Paragraph 3 of theComplaint on the basis that no factual allegations are asserted. To the extent that a response isrequired, Defendants deny the allegations in Paragraph 3 to the extent they conflict with the law4.
Defendants deny the allegations contained in Paragraph 4. Defendants neither admit nor deny the other allegations contained in Paragraph 4 of the Complaint on the basis thatno factual allegations are asserted. To the extent that a response is required, Defendants denythose allegations to the extent they conflict with the law.5.
Defendants neither admit nor deny the allegations contained in Paragraph 5 of theComplaint on the basis that no factual allegations are asserted. To the extent that a response isrequired, Defendants deny the allegations to the extent they conflict with the law.
THE PARTIESPlaintiff Taylor Price
6.
Defendants deny knowledge or information sufficient to form a belief as to thetruth of the allegations contained in Paragraph 6 of the Complaint, and therefore, deny suchallegations.
Case 1:09-cv-01709-RMC Document 3 Filed 11/09/2009 Page 2 of 13
37.
Defendants deny knowledge or information sufficient to form a belief as to thetruth of the allegations contained in Paragraph 7 of the Complaint, and therefore, deny suchallegations.8.
Defendants deny knowledge or information sufficient to form a belief as to thetruth of the allegations contained in Paragraph 8 of the Complaint, and therefore, deny suchallegations.9.
Defendants deny knowledge or information sufficient to form a belief as to thetruth of the allegations contained in Paragraph 9 of the Complaint, and therefore, deny suchallegations. Defendants neither admit nor deny the allegations contained in Paragraph 9 of theComplaint to the extent that no factual allegations are asserted. To the extent that a response isrequired to such allegations, Defendants deny the allegations to the extent they conflict with thelaw.
Defendant Kimberly, Inc.
10.
Defendants admit the allegations contained in Paragraph 10 of the Complaint thatDefendant Kimberly, Inc. is a corporation organized under the laws of the District of Columbiaand has an address at 3104 M Street, N.W., Washington, D.C. 20007. Kimberly, Inc. owns andoperates a bar under the trade name “Mr. Smith’s of Georgetown.”11.
Defendants neither admit nor deny the allegations contained in Paragraph 11 of the Complaint on the basis that no factual allegations are asserted. To the extent that a responseis required, Defendants deny the allegations to the extent they conflict with the law.
Case 1:09-cv-01709-RMC Document 3 Filed 11/09/2009 Page 3 of 13
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