National Federation of the Blind et al v. Target Corporation

Filing 20

MOTION for Preliminary Injunction filed by National Federation of the Blind, Bruce Frank Sexton, the National Federation of the Blind of California. Motion Hearing set for 6/12/2006 02:00 PM in Courtroom 15, 18th Floor, San Francisco. (Attachments: # 1 Affidavit of Dr. James W. Thatcher# 2 Affidavit of Marc Maurer# 3 Affidavit of Anne Taylor# 4 Affidavit of Bruce F. Sexton# 5 Affidavit of Bob Ayala# 6 Affidavit of Tim Elder# 7 Affidavit of Steve Jacobson# 8 Affidavit of Robert Stigile# 9 Affidavit of Tina Thomas# 10 Affidavit of Terri Uttermohlen# 11 Affidavit of Ken Volonte# 12 Proposed Order Granting Plaintiffs' Motion for Preliminary Injunction)(Paradis, Laurence) (Filed on 5/8/2006)

National Federation of the Blind et al v. Target Corporation

Doc. 20 Att. 9

Case 3:06-cv-01802-MHP

Document 20-10

Filed 05/08/2006

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12
DISABILITY RIGHTS ADVOCATES 2001 CENTER STREET, THIRD FLOOR BERKELEY, CALIFORNIA 94704-1204 510.665.8644

LAURENCE W. PARADIS (California Bar No. 122336) [e-mail] MAZEN M. BASRAWI (California Bar No. 235475) [e-mail] DISABILITY RIGHTS ADVOCATES 2001 Center Street, Third Floor Berkeley, California 94704 Telephone: [phone] Facsimile: [phone] TTY: [phone] TODD M. SCHNEIDER (California Bar No. 158253) [e-mail] JOSHUA KONECKY (California Bar No. 182897) [e-mail] SCHNEIDER & WALLACE 180 Montgomery Street, Suite 2000 San Francisco, CA 94104 Telephone: [phone] Fax: [phone] TTY: [phone] DANIEL F. GOLDSTEIN (pro hac vice) [e-mail] BROWN, GOLDSTEIN & LEVY, LLP 120 E. Baltimore St., Suite 1700 Baltimore, MD 21202 Telephone: [phone] Fax: [phone] UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION NATIONAL FEDERATION OF THE BLIND, the NATIONAL FEDERATION OF THE BLIND OF CALIFORNIA, on behalf of their members, and Bruce F. Sexton, on behalf of himself and all others similarly situated, Plaintiffs, v. TARGET CORPORATION, Defendant. Case No.: C 06-01802 MHP CLASS ACTION DECLARATION OF TINA THOMAS IN SUPPORT OF PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION Hearing Date: June 12, 2006 Time: 2:00 p.m. Judge: The Honorable Marilyn Hall Patel

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Dockets.Justia.com

Case 3:06-cv-01802-MHP

Document 20-10

Filed 05/08/2006

Page 2 of 3

1 2 3 4 5 6 7 8 9 10
DISABILITY RIGHTS ADVOCATES 2001 Center Street, Third Floor Berkeley, CA 94704-1204 [phone]

I, Tina Thomas, declare as follows: 1. The facts in this declaration are based upon my personal knowledge. If called to testify,

I could testify competently to the facts described in this declaration. Background 2. 3. 4. 5. I am 37 years old. I have been legally blind since birth. I reside in Los Angeles, California. I have been a member of the National Federation of the Blind and the National

Federation of the Blind of California since 1987. Internet Use 6. I have used the screen reading software "JAWS" to access computers and, especially, the

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

internet for 10 years. 7. I use the internet every day for a variety of functions and activities in my daily life,

including "surfing" the internet and online shopping. 8. 9. I also use the internet for my work as a special education teacher in a K-12 school. I frequently shop online rather than going to a physical store because it is difficult and

time consuming to take a bus or arrange for a paratransit ride, and I find it much easier to complete purchases online. 10. I shop online for many things, including music, movies, coffee, prescriptions and

vitamins. 11. Using my screen reader to access the internet has significantly improved my own view of

my independence to conduct personal business without the help of others. Experience with Target Retail Stores 12. Shopping at Target's physical location near my home requires me to take a bus or arrange

for a paratransit ride, and it is much easier for me to shop online. Harms Experienced Because of the Inaccessibility of Target.com 13. I would like to shop at Target.com because traveling to the physical retail location

necessitates a significant expense of time, energy, and money.
National Federation of the Blind, et al. v. Target Corporation, et al. Case No.: C 06-01802 MHP Declaration of Tina Thomas in support of Plaintiffs' Motion for Preliminary Injunction

1

Case 3:06-cv-01802-MHP

Document 20-10

Filed 05/08/2006

Page 3 of 3