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and stop signs; <br />e. Narrow sidewalks, including sidewalks that are encroached upon by driveway <br />aprons and landscaping so that portions of the required level width of the path <br />of travel is too narrow; <br />f. Sidewalks with broken or uplifted portions that have been improperly patched <br />with asphalt or other temporary material causing the surface to be uneven; <br />g. Sidewalks with excessive cross slopes; and <br />h. Crosswalks that have broken or crumbled asphalt, gaps in the surface, raised or <br />sunken surfaces and other barriers. <br />4. These conditions in the City's "PROW" have denied full and equal access to Ms. <br />Leffmann and have made it difficult and undignified for her to travel throughout the City in <br />her wheelchair. As a result of these barriers, and the City's failure to remove them, Ms. <br />Leffmann has been denied the right that non -disabled persons have to travel the City <br />sidewalks freely without the risk of injury and without physical difficulties or discomfort. <br />Further, these conditions have forced Ms. Leffmann to suffer constant unreasonable jostling, <br />bumping and rattling of her chair and have caused her to have difficulty controlling the <br />direction of the chair which is causing Ms. Leffmann back pain and deteriorating the. <br />condition of her wheelchair. Frequently, in order to avoid barriers on the sidewalk, Ms. <br />Leffmann has had to use driveways to enter into the street where the road surface may be <br />more smooth and wider, risking injury and even death from cars or other vehicles. resulting <br />in her falling out of her wheelchair and dependent on people passing by for assistance. <br />5. Ms. Leffrnann encounters barriers of the type described above whenever she travels <br />between her residence n San Leandro to the gym or to run errands such as <br />visiting the grocery store, regardless of the route she takes. Likewise, Ms. Leffmann has <br />encountered such barriers along alternate routes she has taken to and from her home and in <br />other parts of the City. Ms. Leffmann feels trapped in her home and cannot even walk her <br />dog in the neighborhood because she encounters barriers in every direction she travels. Since <br />2 <br />