§ 1981 by denying the full and equal 17 right to contract to Plaintiff and the Class on the basis of alienage; 18 c. [...] The claims of the named Plaintiff are typical of the claims of the Class. [...] Plaintiff 24 and all Class Members sustained injuries and damages arising out of and caused by Defendant’s 25 common course of conduct and common policies in violation of federal laws, regulations, and 26 statutes as alleged here. [...] Each member of the proposed Class has been damaged and is entitled 18 to recovery by reason of Defendant’s unlawful policies and practices of discriminating on the basis 19 of immigration status and denying full and equal access to Defendant’s services. [...] Plaintiff and Class Members have the right to make and enforce contracts in the 16 United States and are entitled to the full and equal benefits of the law.
- Pages
- 9
- Published in
- United States of America
