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e. On September 9, 2025 and on many occasions prior to and after that date, Ms. <br />Leffmann encountered a portion of the sidewalk on Bancroft Avenue between <br />140th Avenue and 141st Avenue (1516 140th Avenue) that was inaccessible <br />and caused her difficulty and discomfort because a section of the concrete <br />sidewalk is cracked, improperly patched with asphalt, with landscaping <br />encroaching into the PROW. The sidewalk is also uneven and angled to the <br />right. A person with a mobility disability would have to attempt to maneuver <br />their way around these barriers in order to reach the nearby bus stop. <br />f. On September 9, 2025 and on many occasions prior to and after that date, Ms. <br />Leffrnann encountered a portion of the sidewalk on Bancroft Avenue between <br />138th Avenue and 139th Avenue (13890 Bancroft Avenue) which requires a <br />45-degree turn to or from the path of travel to a driveway. At that location, the <br />sidewalk is uplifted, causing a change in elevation of more than one-half inch. <br />At that location, there is also a hole in the concrete sidewalk that not only <br />causes her difficulty and discomfort but also caused her to fall on September 10, <br />2025. After falling, she required help from people in the neighborhood which <br />caused her great distress, anguish and embarrassment because she needed the <br />help of strangers around her. <br />g. On September 9, 2025 and on many occasions prior to and after that date, Ms. <br />Leffmann encounters portions of both sidewalks at 138th Avenue and Bancroft <br />Avenue (in front of 1503 138th Avenue) that was inaccessible and that caused <br />her difficulty and discomfort because sections of the concrete sidewalk in the <br />path of travel at those locations were cracked, improperly patched and uplifted, <br />causing a change in elevation of more than one-half inch. At that location, there <br />is a stop sign on the sidewalk which causes the width of the sidewalk to be <br />narrower than three feet. <br />h. On September 9, 2025 and on many occasions prior to and after that date, Ms. <br />11 <br />