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ADA Plaintiff – United African Asian Abilities Club

Karlin Law Firm LLP has defended numerous apartment owners from abusive lawsuits filed under the name, United African Asian Abilities Cub, by their attorney, lawyer David Wakefield. Often these lawsuits first start with a letter, sent by Anna Wiggins (aka Anna Marie Wiggins), that the ADA plaintiff group claims they sent to the owner or manager of the apartments. Here is a sample letter by Anna Wiggins asking for a reasonable accommodation on behalf of the United African Asian Abilities Club. These letters often ask questions and ask for a REASONABLE ACCOMMODATION. By and large, we find these letters are a “set up” and the particular person or disabled person they claim they represent has no real intent to rent an apartment at the apartment building being set up. Rather, it is their hope and expectation that the management or owner will not know how to properly, or timely, respond to the letter. The text of the sample letter is also set forth below.

In our experience, the owner or manager should not waste a day and contact one of the few knowledgeable law firms that know this obscure area of the law. Often if the inquiry or letter is not responded to in a few days, this group will file a lawsuit claiming, in part, the reasonable accommodation request was not timely responded to, and the failure to timely respond was in itself a violation that allows them to file the ADA lawsuit.

This group, typically represented by ADA attorney David Wakefield, appears to target mostly apartment owners. A review of sample complaints suggests that the main focus in on (a) access for disabled people who attempt to, or who are considering obtaining a rental application, and/or (b) failure to provide a timely response to a request for a reasonable accommodation from a would-be ADA plaintiff who is a potential tenant.

We expect to post a few sample lawsuits filed by this group in the near future. Contact us for more information.


Text of the sample Reasonable Accommodation Letter from United African Asian Abilities Club:

Florida: 5335 Falling Water Dr. Orlando, FL 32818
California: 515 P St., #207 Sacramento, CA 95814
P: 619-866-4576 * F: (916) 330-3339


To: Jane Doe, Manager

Great American Apartments

123 Main Street

Anytown, California


Dear Manager:

The UAAAC is composed of members with disabilities. Our members have difficulties finding apartments that comply with the Fair Housing Act. This letter requests information from you.

This letter requests reasonable accommodations that are not obvious and do not relate to providing effective communication. We are sending this letter to the manager because the United States Housing and Urban Development Department recommends that the letter be directed to the manager.

Many of the apartment common areas are not accessible. Can you provide reasonable accommodations to the facilities to provide physical or service accessibility? One of our members, who uses a wheelchair, had difficulty accessing the rental services at your apartments due to physical barriers. Can you accommodate our member by removing these barriers or alternatively, provide alternative means to access those services?

Additionally, we seek information with respect to the following. How do you engage in the interactive process to a request? What is your process to allow our members that use a mobility device to put a ramp into a unit and to install grab bars in the unit? Do you provide TTY or are other texting services available at the office where rental services are provided? We have a member that has a visual disability. Do you provide large print for the lease and tenant notices? We noticed on the Internet pictures that the common areas for the apartments are not accessible. If a member moves there, can the member pay to make them accessible?

Please have your management answer the above questions by emailing usaac1[email protected].

Respectfully yours,

Anna Wiggins (aka Anna Marie Wiggins)


Our law firm has developed policies and procedure manual to assist in responding to requests for reasonable accommodation, including a response letter and email to a request from the United African Asian Abilities Club. Contact us ASAP. It is highly important that such a letter receive an immediate reply. Any delay in response will be used as evidence that you failed to timely and properly reply, which in and of itself is a violation.