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IN THE CIRCUIT COURT FOR MIDDLE EARTH
CENTRAL DISTRICT AT CARAS GALADON
Elf Gimpoliel on behalf of a class of persons )
Being comprised of disabled elves and peoples )
of Middle Earth, )
Plaintiffs )
)
Vs. ) Civ. No.
)112233-Y
The Realm of Lothlorien, )
Galadriel and Celeborn, individually )
Defendants )
COMPLAINT
Comes the Plaintiff, Gimpoliel, by and through counsel,
representing himself and all those similarity situated
and covered under the Elves and Beings with Disabilities
Act (EBDA) and for Plaintiffs’ complaint states as follows:
VENUE
1. Plaintiffs are elves and other beings covered under
the EBDA and reside in or have occasion to enter into
the area better known as the Realm of Lothlorien.
2. Class representative Gimpoliel is an elf residing
in Caras Galadon, Lothlorien.
3. Class representative Gimpoliel and class members
are disabled beings and elves within the definitions
set forth in the EBDA Section 2(c).
4. Plaintiffs assert proper venue in Caras Galadon the
capital of Lothlorien as the most egregious violations
of the EBDA are continuing in that city and it is the
residence of the class representative and those responsible
for the continuation of such violations, namely one
Galadriel and one Celeborn, elves and rulers of Lothlorien.
5. Plaintiffs claim is under Article IV, Section 2 of
the Code of Middle Earth better known as the EBDA. More
specifically Sections 2(b)(1) –2(e)(4) of the EBDA have
been violated by the named Defendants in this matter.
CLAIM
6. Plaintiffs note that the Realm of Lothlorien is designed
in such a manner as to deny access for elves and beings
with various disabilities. Further, the Realm of Lothlorien
and its representatives Galadriel and Celeborn make
no attempt currently or in the past to remedy the situations
denying access to disabled elves and other peoples of
Middle Earth. Thus, the Realm of Lothlorien and Galadriel
and Celeborn individually are in violation of the EBDA.
7. Defendants have developed a housing and meeting system
that requires great agility and physical stamina to
partake in. The central meeting tree of Caras Galadon,
for example, has in excess of 500 spiraling stairs sloping
upwards over 300 feet. No ramps or devices are available
for persons unable to traverse these stairs due to their
disability (such as but not limited to loss of a limb,
spinal injury or partial paralyzation). This failure
to provide access is a direct violation of EBDA Section
2(b)(1)(A) statingin part that, “[A]ll places of public
accommodation and housing shall be made fully accessible
to disabled elves and beings with mobility impairments.”
Further such violations are on-going and shall be presented
at trial on this matter.
8. Defendants Galadriel and Celeborn have been made
directly aware of these issues by notice in writing
by Plaintiff’s counsel as required under EBDA Section
2(d)(1). Galadriel and Celeborn have failed to take
corrective action as required within 90 days of such
notice claiming that elven magic will suffice as reasonable
accommodation. They are thus personally liable under
EBDA Section (e)(4)(F).
9. Having been denied access to counsel meetings and
comfortable housing, Plaintiffs have suffered damages
in an amount no less than 1000 gold coins each or 2,000,000
gold coins in the aggregate for the class.
RELIEF REQUESTED
Having now set forth their claim, Plaintiffs request
the following relief:
10. That the Realm of Lothlorien and the elves, Galadriel
and Celeborn be enjoined to install appropriate ramps,
raised platforms, elevators and other such devices as
necessary to effectuate compliance with the EBDA.
11. That Plaintiffs be given the sum of 1000 gold coins
each not to exceed 2,000,000 gold coins for the class.
12. That the court order and certify the Plaintiffs
as a class and notify other possible members of the
class of the pending action.
13. For further and other relief as may be necessary
and proper.
Respectfully,
FOR THE PLAINTIFFS BY COUNSEL
Sharque Findolas, Esq.
The large tan mallorn, #245-B
Caras Galadon, Lothlorien
BPR#1183