Venue is proper in this district pursuant to 28 U.S.C. § 1391 because a substantial part of the acts giving rise to this action occurred in the Northern District of Florida. [See 28 U.S.C. § 1391(b).] III. PARTIES Plaintiff, Billy Ray Kidwell, is a 100% Service-Connected, Severely Disabled, Vietnam Combat Veteran, and resident of the State of Florida. Billy Kidwell has physical, and mental, impairments that substantially limit at least one, or more, of his major life activities. Plaintiff greatly exceeds all requirements, to be a “Qualified Disabled Person” as described in the ADA, entitled to the protections of the Americans with Disabilities Act. His address is: Billy Ray Kidwell, 5064 Silver Bell Drive, Port Charlotte, Florida 33948. Defendant, Florida Commission on Human Relations, is a Quasi-Legal State Agency, as described in Title II of the ADA. This Defendant’s Address is; Florida Commission on Human Relations, 4075 Esplanade Way, Room 110, Tallahassee, Florida 32399. Defendant, SeaWorld Entertainment, Inc., is a Public Accommodation within the meaning of 42 U.S.C. § 12181, and pursuant to Title III of the ADA. The address of this Defendant is: SeaWorld Entertainment, Inc., Suite 400, 9205 South Park Center Loop, Orlando, Florida 32819.
Venue is proper in this district pursuant to 28 U.S.C. § 1391 because a substantial part of the acts giving rise to this action occurred in the Northern District of Florida. [See 28 U.S.C. § 1391(b).] III. PARTIES Plaintiff, Billy Ray Kidwell, is a 100% Service-Connected, Severely Disabled, Vietnam Combat Veteran, and resident of the State of Florida. Billy Kidwell has physical, and mental, impairments that substantially limit at least one, or more, of his major life activities. Plaintiff greatly exceeds all requirements, to be a “Qualified Disabled Person” as described in the ADA, entitled to the protections of the Americans with Disabilities Act. His address is: Billy Ray Kidwell, 5064 Silver Bell Drive, Port Charlotte, Florida 33948. Defendant, Florida Commission on Human Relations, is a Quasi-Legal State Agency, as described in Title II of the ADA. This Defendant’s Address is; Florida Commission on Human Relations, 4075 Esplanade Way, Room 110, Tallahassee, Florida 32399. Defendant, SeaWorld Entertainment, Inc., is a Public Accommodation within the meaning of 42 U.S.C. § 12181, and pursuant to Title III of the ADA. The address of this Defendant is: SeaWorld Entertainment, Inc., Suite 400, 9205 South Park Center Loop, Orlando, Florida 32819.
ADA-Federal-Civil-Complaint.docx