Berne v. The Regents of the University of California

Filing 15

ORDER re 14 Proposed Order, filed by Patricia Berne, The Regents of the University of California. Signed by Magistrate Judge Donna M. Ryu on 06/12/13. (dmrlc2, COURT STAFF) (Filed on 6/12/2013)

Case4:11-cv-00809-DMR Document14 Filed05/28/13 Page1 of 7

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PAUL L. REIN, Esq. (SBN 43053)
CELIA McGUINNESS, Esq. (SBN 159420)
LAW OFFICES OF PAUL L. REIN
200 Lakeside Drive, Suite A
Oakland, CA 94612
Telephone: [phone]
Facsimile: 510/832-4787
[e-mail]

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Attorneys for Plaintiff
PATRICIA BERNE
MICHAEL D. BRUNO (SBN 166805)
GORDON & REES LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant
THE REGENTS OF THE UNIVERSITY
OF CALIFORNIA

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[N THE IJNITED STATES DISTRICT COURT

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IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA

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PATRICIA BERNE,

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Plaintiff,

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vs.
THE REGENTS OF THE UNIVERSITY OF
CALIFORNIA; DOES 1 through 10, inclusive,

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Defendant.
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CASE NO. C1.1-00809 DMR
Civil Rights
CONSENT DECREE AND
[PROPOSED] ORDER
Pursuant to General Order 56

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CONSENT DECREE AND [PROPOSED] ORDER

Case4:11-cv-00809-DMR Document14 Filed05/28/13 Page2 of 7

1.

Plaintiff PATRICIA BERNE filed a Complaint in this action on February 22,

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2011 to obtain recoveiy of damages for her alleged discriminatory experiences, denial of access,

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and denial of her civil rights, and to enforce provisions of the Americans with Disabilities Act of

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1990 (“ADA”), 42 U.S.C. sections 12101 et seq., and California civil rights laws against

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Defendant The REGENTS OF THE UNIVERSITY OF CALIFORNIA relating to the condition

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of its public accommodations as of March 4, 2009, and continuing. Plaintiff has alleged that

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Defendants violated Title III of the ADA and sections 51, 52, 54, 54.1, 54.3 and 55 of the

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California Civil Code, and sections 19955 et seq. of the California Health & Safety Code by

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failing to provide fill and equal access to their facilities at Zellerbach Hall Auditorium, located

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on the

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ni versity f California campus at Berkeley, California.
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Defendant The REGENTS OF THE UNIVERSITY OF CALIFORNIA denies the

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liability for any of the allegations in Plaintiffs Complaint filed in this action. Plaintiff and

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defendant, hereinafter collectively, “the parties,” hereby enter into this Consent Decree and

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Order for the puiose of resolving this lawsuit without the need for protracted litigation and

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allegations in the Complaint and by entering into this Consent Decree and Order does not admit

without the admission of any liability.

C
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JURISDICTION:

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3.

The parties to this Consent Decree agree that the Court has jurisdiction of this

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matter pursuant to 28 U.S.C. section 1331 for alleged violations of the Americans with

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Disabilities Act of 1990, 42 U.S.C. sections 12101 et seq., and pursuant to supplemental

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jurisdiction for alleged violations of California Health & Safety Code sectionsl9955 et seq.; Title

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24, California Code of Regulations; and California Civil Code sections 51, 52, 54, 54.1, 54.3,

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and 55.

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4.

In order to avoid the costs, expense, and uncertainty of protracted litigation, the

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parties to this Consent Decree agree to entry of this Order to resolve all claims regarding

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injunctive relief, damages, and attorney fees, litigation expenses, and costs, raised in the

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Complaint filed with this Court. Accordingly, they agree to the entry of this Order without trial

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or further adjudication of any issues of fact or law concerning Plaintiffs claims for injunctive
-2CONSENT DECREE AND [PROPOSED) ORDER

Case4:11-cv-00809-DMR Document14 Filed05/28/13 Page3 of 7

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relief. Issues of damages, and attorney fees, litigation expenses, and costs have not been

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resolved and will be the subject of further negotiation andlor litigation.

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WHEREFORE, the parties to this Consent Decree hereby agree and stipulate to the
Court’s entry of this Consent Decree and Order, which provides as follows:

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SETTLEMENT OF INJENCTIVE RELIEF:

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5.

This Order shall be a full, complete, and final disposition and settlement of

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Plaintiff’s claims against Defendant for injunctive relief that have arisen out of the subject

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Complaint. The parties agree that there has been no admission or finding of liability or violation

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of the ADA andlor California civil rights laws, and this Consent Decree and Order should not be

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construed as such.

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6.

The parties agree and stipulate that the corrective work will be performed in

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compliance with the standards and specifications for disabled access as set forth in the California

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Code of Regulations, Title 24 2, and the Americans with Disabilities Act Accessibility

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Standards, unless other standards are specifically agreed to in this Consent Decree and Order.

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7.

Remedial Measures: Defendants agree to perform corrective work at the

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Zellerbach I-Tall Auditorium, where, Berkeley, California. The scope of the corrective work, and

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the schedule for it, agreed upon by the parties is delineated in Attachment A. As indicated,

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defendant represents some of the work has already been completed. Defendant shall provide a a

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status report to plaintiff’s counsel 180 days after this Consent Decree is signed by the Court.

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Thereafter, defendant will provide status reports every 180 days until the remedial measures are

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constructed.

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8.

Timing of Injunctive Relief: The parties shall complete the corrective work on

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the schedule delineated in Attachment A. In recognition of the comprehensive construction

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project known as the Lower Sproul Plaza Renovation, the parties acknowledge that completing

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the work set forth in Attachment A prior to December 31, 2013 may be unreasonably difficult or

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inefficient, and that the schedule may need to be redirected. In the event that such difficulties

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prevent Defendant from completing any of the agreed upon injunctive relief by the end of 2013,

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Defendant or its counsel will notify Plaintiff’s counsel in writing within 15 days of discovering
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Case4:11-cv-00809-DMR Document14 Filed05/28/13 Page4 of 7

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such a circumstance. This communication shall contain an explanation for the delay and propose

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an extension of time within which the work shall be completed. Plaintiffs counsel shall consider

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the reasons stated, as well as the proposed extension, and respond in writing. Within 15 days of

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plaintiffs writing, the parties shall confer by phone. If the parties are unable to reach an

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agreement through this process, Defendant shall be entitled to make a motion to the Court

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requesting an extension of this deadline. Nothing in this Consent Decree shall prevent plaintiffs

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counsel from demanding payment of reasonable attorney fees incurred in connection with a

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request from defendant for additional time to complete the remedial measures set forth in Exhibit

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A.

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DAMAGES:
9.

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The parties have not yet reached an agreement regarding Plaintiffs monetary

claims for damages.

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ATTORNEY FEES, LITIGATION EXPENSES AND COSTS:
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No agreement has been reached yet on these issues. They will be the subject of

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further negotiation and/or litigation. The parties jointly stipulate and request that the Court not

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dismiss the case as these significant issues remain unresolved.

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ENFORCEMENT:

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11.

If Defendant fails to perform the injunctive relief, or fails to perform in the time

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frame stated and the parties cannot come to a negotiated resolution through the mechanism set

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forth in paragraph 8, Defendants will pay all plaintiffs reasonable fees, litigation expenses and

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costs involved in enforcing this agreement.

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ENTIRE CONSENT ORDER:

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This Consent Decree and Order and Attachment A to this Consent Decree and

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Order, which is incorporated herein by reference as if fully set forth in this document, constitute

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the entire agreement between the signing parties on the matters of injunctive relief, issues of

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damages and attorney fees, litigation expenses, and costs are specifically excluded and shall be

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the subject of further negotiations andlor litigation.

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CONSENT ORDER BINDING ON PARTIES AND SUCCESSORS IN INTEREST:
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Case4:11-cv-00809-DMR Document14 Filed05/28/13 Page5 of 7

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13.

This Consent Decree and Order shall be binding on the parties and all successors

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in interest. The parties have a duty to so notify all such successors in interest of the existence

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and terms of this Consent Decree and Order during the period of the Court’s jurisdiction of this

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Consent Decree and Order.

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MUTUAL RELEASE AND WAIVER OF CIVIL CODE SECTION 1542 AS TO
INJUNCTIVE RELIEF ONLY:
14.

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Each of the parties to this Consent Decree understands and agrees that there is a

risk and possibility that, subsequent to the execution of this Consent Decree, any or all of them
will incur, suffer or experience some further loss or damage with respect to the lawsuit which are

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unknown or unanticipated at the time this Consent Decree is signed. Except for all obligations
required in this Consent Decree, the parties intend that this Consent Decree apply to all such
further loss with respect to the lawsuit, except those caused by the parties subsequent to the
execution of this Consent Decree. Therefore, except for all obligations required in this Consent

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Decree, this Consent Decree shall apply to and cover any and all claims, demands, actions and
causes of action by the parties to this Consent Decree with respect to the lawsuit, whether the
same are known, unknown or hereafter discovered or ascertained, and the provisions of Section
1542 of the California Civil Code are hereby expressly waived. Section 1542 provides as
follows:
A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE
CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST TN HIS OR HER FAVOR AT THE
TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST
HAVE MATERIALLY AFFECTED HIS SETTLEMENT WITH THE DEBTOR.

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15.

Except for all obligations required in this Consent Decree, each of the parties to

this Consent Decree, on behalf of each, their respective agents, representatives, predecessors,
successors, heirs, partners and assigns, releases and forever discharges each other Party and all
officers, directors, subsidiaries, joint venturers, partners, employees, agents, attorneys,
insurance carriers, heirs, predecessors, and representatives of each other Party, from all claims,
demands, actions, and causes of action of whatever kind or nature, presently known or unknown,
-5CONSENT DECREE AND [PROPOSED] ORDER

Case4:11-cv-00809-DMR Document14 Filed05/28/13 Page6 of 7

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arising out of or in any way connected with the lawsuit.

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TERM OF THE CONSENT DECREE AND ORDER:

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This Consent Decree and Order shall be in full force and effect for a period of

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forty-eight (48) months after the date of entry of this Consent Decree and Order, or until the

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injunctive relief contemplated by this Order is completed, whichever occurs later. The Court

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shall retain jurisdiction of this action to enforce provisions of this Order for forty-eight (48)

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months after the date of this Consent Decree, or until the injunctive relief contemplated by this

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Order is completed, whichever occurs later.
SEVERABILITY:

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1 i;y tenri of this Consert Decree and Order is determined by any court to be

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unenforceable, the othei terms of this Consent Decree and Order shall nonetheless remain in full

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force and effect.

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SIGNATORiES BIND PARTIES:

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18.

Signatories on the behalf of the parties represent that they are authorized to bind

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the parties to this Consent Decree and Order. This Consent Decree and Order may be signed in

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counterparts and a facsimile signature shall have the same force and effect as an original

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signature.

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Dated:

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PLMNTIFF PATRICIA BEE

,2013

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PATRICIA BERNE

DEFENDANT THE REGENTS OF THE
U1’HVERSITY OFALIFORN1.

2013

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Dated:

APPROVED AS TO FORM:
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-6CONSENT DECREE AND [PROPOSED] ORDER

Case4:11-cv-00809-DMR Document14 Filed05/28/13 Page7 of 7
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Dated:

PAUL L. REIN
CELIA McGUJNNESS
PAUL L. RE
LAW OFFICES

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By:___
Attorneys for Plaintiff
PATRICIA BERNE

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MICHAEL D. BRUNO
GORD N&REE LL

2013

DATED:

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Attorneys For Defe ant
THE REGENTS OF THE UNIVERSITY
OF CALIFORNIA
ORDER

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Pursuant to stipulation, and for good cause shown, IT IS SO ORDERED.

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Dated:

June 12
Honorable DONNA M. RYU
United States District Magistrate Judge

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UCRJIO573O8Il4O79352

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-7CONSENT DECREE AND [PROPOSED] ORDER

Case4:11-cv-00809-DMR Document14-1 Filed05/28/13 Page1 of 3

Berne v. UC Regents

Schedule of Remediation/Injunctive Relief at Zellerbach Hall at
The University of California, Berkeley
Defendant represents that the following work has been completed:
1.
Wheelchair Accessible Seats—Back Row: Installed six ADA-compliant
wheelchair accessible seats in back row, orchestra level;
2.
Wiring: Installed subfloor “snake” (slot) so sound wires for soundboard do not
protrude above aisle floor;
3.
ADA Compliant Workstation: Upgraded orchestra level soundboard
workstation to be ADA compliant;
4.
Path of Travel to Back Row Seating: Eliminated variations in level of back
corridor floor (which runs behind back row of seats on orchestra level);
5.
Lighting: Installed lighting along back corridor;
6.
New Ramp: Installed a new permanent exterior ramp at main entrance
providing ADA compliant path of travel to eight entrance doors and ticket office;
7.
Entrance: Eliminated door stops on strike plates of eight main exterior
entrance doors, replaced door closers and adjusted door pressure to be less than five
pounds and adjusted closing times to over five seconds (on all eight orchestra level
exterior entrance doors);
8.
Automatic Door Opener: Installed automatic door opener for ticket office
entrance;
9.
Guardrails: Installed guardrails under both lobby stairs leading to mezzanine
10.
Women’s Restroom: Reconfigured side-transfer stall in orchestra level
women’s restroom;
11.
Improvement for Sight-Impaired: Installed a “skirt” to eliminate potential
barrier of protruding drinking fountain in orchestra level lobby;
12.
Mezzanine Level Doors from Lobby to Auditorium: Adjusted door closers
from mezzanine lobby to mezzanine seats so that the door requires less than five
pounds pressure to operate and closes no faster than five seconds
13.
Parking: Restriped the lower garage disabled person parking spaces.
14.
Temporary Modular Aluminum Ramp from Lower to Upper Sproul Plaza:
Reconfigured the temporary ramp and agreed to retain this configuration until the
Lower Sproul Plaza renovation has addressed access from Lower Sproul Plaza.
15.
Public Entrance to Hall, Bank of Eight Exterior Doors on East Side:
Replaced all eight existing door closer hardware with new design, and subsequently
adjusted all doors to operate with a maximum five-pound push pressure and to close in
no faster than five seconds. Removed the door stops from the bottom of the doors and
agreed to maintain these conditions by checking the door pressure and closing speed not
less frequently than every six months.
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Case4:11-cv-00809-DMR Document14-1 Filed05/28/13 Page2 of 3

16.
Orchestra Level Doors from Lobby to Auditorium: Replaced all existing
door closer hardware with new design, and subsequently adjusted all doors to operate
with a maximum five-pound push pressure, to close in no faster than five seconds, and
agreed to maintain these conditions by checking the door pressure and closing speed not
less frequently than every six months.
17.
Elevator to the Mezzanine: Installed a tactile star on the elevator door jamb,
and agreed to implement a written policy to provide the interior dimensions of the
elevator to purchasers of wheelchair seating on the mezzanine. The dimensions will
also be stated on the Zellerbach ticketing website.
18. Women’s Restrooms at the Orchestra level: Modified the sink counter height.
19. Men’s and Women’s Restrooms on the Mezzanine Level: Installed accessible
toilet stall door hardware and adjusted the exterior door pressure to be ADAAG
compliant.
20. Drinking Fountains at Balcony Lobby Cafe : Installed two sets of wing-walls
on the two existing drinking fountains located on each side of the cafe.
21. Dining Area Seating: Installed two wheelchair-accessible tables and marked
them with the universal symbol of accessibility.

Work to be Completed By March 15, 2013:
1.
South Ramp from Bancroft Way: Install directional signage to the accessible
path of travel at major junctions where the accessible route of travel diverges from the
regular circulation path.

Work to be Completed By December 31, 2013:
1.
Mezzanine Entrances to Seating: Install one electric door opener at the
Mezzanine level.
2.
Men’s restrooms on the Orchestra level:
i.

Install 12" equilateral triangle sign at entrance to restroom

(1)

In the accessible toilet compartment:
ii.
iii.
iv.
v.
vi.
vii.
viii.

install pull hardware
adjust door operation so that it closes automatically
move the door to the stall approximately 11" laterally
reposition side grab bar
relocate the toilet paper dispenser to under the grab bar
replace the toilet with one that is 17" to 19" high
lower soap dispenser 3"
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Case4:11-cv-00809-DMR Document14-1 Filed05/28/13 Page3 of 3

3.
Accessible Path of Travel to Front Row Orchestra Seats: Construct an
accessible path of travel between the outer doors and the front seats in the lower
Orchestra section.
4.
Wheelchair Seats at Lower Orchestra Level: Reconfigure seating to provide
six wheel-chair accessible seats in the lower Orchestra section in substantial conformity
with Exhibit A (CAW Architects drawing, Sheet A2.07).
5.
Removable or Folding Armrests—Orchestra Section: Confirm that a total of
ten aisle seats, dispersed through the orchestra section, have removable or folding
armrests on the aisle side of the seat. Each seat shall be identified with the universal
symbol of accessibility.
6.
Signage at Ticket Office: Post signage at the ticket office and on the ticketing
website identifying the wheelchair accessible seats and the seats with adjustable
armrests

//14369230v.1

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Case4:11-cv-00809-DMR Document14-2 Filed05/28/13 Page1 of 1

HIGHLIGHTED SEAT COUNT: ROWS A,B,C,G & H
FLOOR MOUNTED FIXED CHAIRS
FIXED CHAIRS ON MOVABLE BASES

83
0

TOTAL FIXED CHAIRS

83

LOOSE CHAIRS

0

WHEELCHAIR POSITIONS
TOTAL SEAT COUNT

6
89

CHAIRS TO BE REMOVED
CHAIRS TO BE ADDED

-12
+17

TOTAL

+5

TOTAL FIXED CHAIRS:

88

GENERAL NOTES

SHEET NOTES

1. THIS (E) DRAWING HAS BEEN DEVELOPED FROM
"AS BUILT" DOCUMENTATION PROVIDED TO THE
ARCHITECT BY UNIVERSITY OF CALIFORNIA CAPITAL
PROJECTS, FROM FIELD MEASUREMENTS, AND
FROM MANUFACTURER'S SHOP DRAWINGS FROM
THE 2005 ZELLERBACH SEATING REPLACEMENT
PROJECT. AS SUCH, THIS DRAWING IS NOT
GUARANTEED TO BE ACCURATE OR TO SCALE.
FIELD VERIFY ALL DIMENSIONS AND CONDITIONS
PRIOR TO BEGINNING WORK AND NOTIFY
ARCHITECT OF ANY DISCREPANCIES. DO NOT
SCALE DRAWINGS.

NOTES NOT KEYED ON THE DRAWINGS ARE
APPLICABLE TO THE ENTIRE SHEET.

2. COUNTS AND DIMENSIONS FOR (E) FIXED CHAIRS
HAVE BEEN DEVELOPED FROM DATA PROVIDED IN
MANUFACTURER'S SHOP DRAWINGS FROM THE
2005 ZELLERBACH SEATING REPLACEMENT
PROJECT. MANUFACTURER SHALL PROVIDE FIELD
MEASURED SEATING LAYOUTS WITH FINAL SEAT
COUNTS.

S1. REVISE SEATING LAYOUT FOR ROWS A, B, C, G
AND H AS INDICATED USING (E) SEATING
COMPONENTS TO THE EXTENT POSSIBLE. UTILIZE (E)
COMPONENTS IN BEST CONDITION FIRST. IF
CONDITION OF ANY REQUIRED COMPONENT IS
SUBSTANDARD AS COMPARED TO QUALITY LEVEL
OF (E) STOCK, REFURBISH OR PROVIDE NEW
COMPONENT.
S2. ANY NEW COMPONENTS OR COMPONENTS
REQUIRING REPLACEMENT SHALL MATCH EXISTING.
S3. PROVIDE NUMBER AND LETTER PLATES FOR
ROW AND SEAT DESIGNATIONS TO MATCH
EXISTING AS REQUIRED.
S4. NEW AISLE AND CROSS-AISLE LIGHTING SHALL
MATCH EXISTING IN APPEARANCE, PLACEMENT,
AND COLOR TEMPERATURE AND SHALL MEET ALL
APPLICABLE CODE REQUIREMENTS. SEE
ELECTRICAL DRAWINGS.

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SIDE AISLE

18

N

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SIDE AISLE

S5. PROVIDE MOVEABLE BASES FOR FIXED CHAIRS
IN INDICATED AREAS.
S6. LOOSE CHAIRS (BY OWNER) CAN BE PROVIDED
IN WHEELCHAIR POSITIONS AND MANUEVERING
AREAS AS SHOWN IN DRAWING 2 IN THE EVENT
THESE ARE NOT NEEDED BY PATRONS IN
WHEELCHAIRS. LOOSE CHAIRS SHOULD BE
STACKABLE AND EQUIPPED WITH GANGING
DEVICES TO SECURE THEM TOGETHER AS
REQUIRED BY CODE. TO ENSURE SIGHTLINES,
LOOSE CHAIRS SHOULD BE PROVIDED WITH
DIFFERENT SEAT HEIGHTS, 18", 24", AND 30" AS
INDICATED.

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C o d y A n d e r s o n W a s n e y A r c h i t e c t s, I n c.
455 L a m b e r t A v e n u e • P a l o A l t o, CA 94306
6 5 0 . 3 2 8 . 1 8 1 8 • Fax 3 2 8 . 1 8 8 8
Copyright © 2010 by CODY ANDERSON WASNEY ARCHITECTS, INC.

STAMP

CENTER AISLE

L

M

CENTER AISLE

SEATING COMPONENTS
M

L

HIGHLIGHTED SEATS: ROWS A,B,C,G & H
ITEM

QTY

FIXED THEATRE CHAIRS

L

CONSULTANTS

20" CHAIR

10

21" CHAIR

57

22" CHAIR

8

23" CHAIR

K

K

COMPONENT SUMMARY:

M

8

TOTAL FIXED CHAIRS

K

83

OTHER SEATING COMPONENTS

M

END STANDARD PANEL/ARMREST

J

J

J

HH

END STANDARD PANEL/ADA ARMREST

36
0

I

I

I

67

ARMREST AISLE LIGHT

L

CENTER STANDARD/ARMREST

18

POSSIBLE WHEELCHAIR POSITIONS

6

REVISION

DATE

DESIGN DEVELOPMENT SET

01/14/2013

K
H

H

J

W

(RO

W

FIXED THEATRE CHAIR

G

G

)
'-4"±
+34

CHAIR WIDTH
20

F
F

27

AISLE END ARMREST &
STANDARD W/ END PANEL &
ROW DESIGNATION LABEL
SEAT NUMBER DESIGNATION
CENTER ARMREST & STANDARD

E

E

H

L.
G: E

SEATING LEGEND

G

F

(RO

I

"±)
3/4
4'-6
3
L. +
H: E

H

E

G
D

D

20

NO CHANGES TO (E)
SEATING ROW D AND ABOVE

27

D

CONCEALED AISLE LIGHT
INTEGRATED UNDER AISLE-END
ARMREST

F

D

"±)
1/2

+3

B
C

20
27
ADA APPROVED
ACCESSIBLE ARMREST
AT AISLE-END
STANDARD

JJ

27

PROJECT NAME

ACCESS IMPROVEMENT PROJECT FOR

20

ORCESTRA LEVEL REMOVABLE
CHAIR ZONE

WHEELCHAIR SPACE
W/ FIXED COMPANION
SEAT

ZELLERBACH HALL
UNIVERSITY OF CALIFORNIA, BERKELEY
BERKELEY, CA 94720

(EL. +33'-3"±)

EE

AC

B/
W
ROW LE RO
IB
ESS

NO
C
SE
ATI HANG
NG
E
RO S TO
WS
(E
D, E )
,F
(RO
WC
: +33
'-7 1/
2"±)

ROW B/
ACCESSIBLE ROW

FF

C:

B

A

(R

C

OW

3'-7

C

B

B

E

(ROW C: +33'-7
1/2"±)

C

C

(E)
TO
ES D, E, F
G
HAN WS
O C G RO
N
TIN
SEA

LEVEL 3: FRONT ORCHESTRA:

(EL
. +3
3'-3
"±

SEATING PLAN

)

AA

BB

CC

+
(EL.

)

DD

3"±
33'-

SHEET TITLE

PIT LIFT

STAGE PLATFORM
(EL. +36'-9"±)

PROJECT NO.

12030

DRAWN BY

M. DESING

CHECKED BY

C. WASNEY K. ABIKO
/

SHEET

LEVEL 3 FRONT ORCHESTRA: SEATING PLAN
SCALE: 1/4" = 1'-0"

1

TRUE
NORTH

N

A2.07