Larry Dominick, Town President Office of the President _ ,4949 West Cermak Rd., 3rd Floor Cicero, IL 60804 October 12, 2018 RE: _ Notice of ADA Violations Pertaining to the Town of Cicero Dear President Larry Dominick, represent Ms. Laura Gonzales in relation to her need for accessible parking in the Town of Cicero. Ms. Gonzales is a resident of Cook County, Ilinois. Ms. Gonzales resides approximately seven (7) miles away from the Town of Cicero. Ms. Gonzales is a qualified individual with a disability under Title I of the ADA, 42 U.S.C. § 12131 et seg., and the Rehabilitation Act, 29 U.S.C. § 794, et seq. Ms. Gonzales has paraplegia from a spinal cord injury stemming from a car accident. Due to her disability, Ms. Gonzales is substantially impaired in multiple major life activities and requires a wheelchair for mobility. Further, Ms. Gonzales utilizes a van for her transportation and requires parking that is ADA van accessible. It is our understanding that the Town of Cicero owns the public, on-street parking available on and around Cermak Road between South Lombard Avenue and South Laramie Avenue. It is further our understanding that the Town of Cicero is the political entity which is responsible for operating, providing, and maintaining the public, on-street parking on and around Cermak Road between South Lombard Avenue and South Laramie Avenue. It is well established that on-street parking spaces must be ADA accessible. Ms. Gonzales routinely visits the Town of Cicero and the Cermak Road business district. While in the Cermak Road business district, Ms. Gonzales has tried to park in the ADA accessible-designated parking spaces, but has had great difficulty due to the Town’s failure to provide or otherwise maintain compliant ADA accessible parking spaces amongst the public, on- street parking. The Town's failure to provide or maintain compliant ADA accessible parking hinders Ms. Gonzales’ ability to access the services and utilize the programs offered in the Cermak Road business district. Specifically, Ms. Gonzales has experienced serious difficulty parking because of the following ADA barriers that are the responsibility of the Town of Cicero: ‘A. There are no access aisles serving any designated accessible parking spaces; B. There is no sufficient accessible route connecting any designated accessible parking space to a pedestrian circulation path on or around the Property; C. Without any accessible route connecting any of the designated accessible parking spaces to a pedestrian circulation path, wheelchair users must navigate behind parked cars and alongsideor against vehicular traffic on Cermak Road, a busy six-lane road, to reach a curb cut and access the pedestrian circulation path; D, There are no designated accessible parking spaces that are specifically designated for vans; E, The markings for the designated accessible parking spaces, including the signage and painted lines, are faded or non-existent, making designated accessible parking spaces hard to distinguish from the non-designated parking spaces, and as a result, non- disabled drivers have a pattem or practice of parking in the accessible spots without any consequence or repercussions; and F. Other current mobility-related barriers and violations of the Americans with Disabilities Act to be identified after a complete inspection of the accessible-designated parking on or around the Property. By and through this letter, Ms. Gonzales provides the Town of Cicero with Notice of the ADA barriers and her need for accommodation. By and through this letter, Ms. Gonzales affirmatively requests that the Town of Cicero correct, rectify, modify, and/or remedy the ADA. barriers. The Town of Cicero has already had over twenty-eight years to correct these ADA barriers. Therefore, the barriers should be corrected without hesitation. Ms. Gonzales expects that the ADA barriers will be removed within thirty (30) days. Please provide my office with evidence that the ADA barriers have been removed within thirty (30) days. Unfortunately, neither myself or Ms. Gonzales can provide you with legal or ‘engineering advice on what steps should be taken to correct, rectify, modify, and/or remedy the ADA barriers. Further, by and through this letter, please be advised that you are requested to engage in a “Litigation Hold.” I request that you take steps to preserve all existing and newly-created documents, including emails, text messages, photographs, measurements, etc. that pertain to the public, on-street parking available on and around Cermak Road between South Lombard Avenue and South Laramie Avenue, your communications about this letter, and your attempts to bring these on-street parking spaces into compliance with the ADA.