Litigation Defense. The teams deep expertise ranges from the negotiation of highly favorable, early resolutions, to the aggressive defense of these cases through all stages of litigation. Copyright 2021, The HARR LAW FIRM. Accessibility.com now offers an impartial listing of digital accessibility vendors. Through this illicit joint enterprise, Johnson and Dinin filed numerous frivolous claims, knowingly misrepresented the billable time expended to litigate these claims, made numerous other misrepresentations to the Court, and improperly shared attorneys fees in violation of the Rules Regulating the Florida Bar, all done without regard to the interests of those with disabilities. Furthermore, each of these lawsuits alleged that Victim-1 and Victim-2 had standing to sue under the ADA. Previously, these lawsuits were primarily focused in South Florida. Heres the news. Nonetheless, Im happy to act on a temporary basis as Virgil and see how far we can get. Seyfarth attorneys have handled numerous DOJ ADA Title III compliance investigations, including some of the most significant matters targeting industry leaders in the retail, hospitality, banking, and higher education industries. According to court records it has filed over 1500 ADA lawsuits since January. Dinin was counsel for the plaintiff in the first website accessibility lawsuit to ever to go trial (Gil v. Winn Dixie). The court found that Potter Handy was protected by the litigation privilege. In this case no fees were awarded; in fact, none were requested even though the plaintiff was represented by counsel. All Rights Reserved. Only qualified individuals with disabilities are protected under federal law by the ADA. It would allow awarding of attorney fees and punitive . According to PACER, Dinin was counsel of record in over 251 federal lawsuits in 2018 and 177 in 2019. Seyfarth attorneys know the unique challenges of litigating in the most plaintiff-friendly jurisdictions in the country, and routinely use that knowledge to their clients advantage. Explore the new content we've added to ADA.gov. Wilshire Law Firm had more plaintiffs including Darren Gresham and Brett DeSalvo. The Harr Law Firm provides a means to potentially defeat or limit frivolous ADA barrier-to-access lawsuits. Full Service, All Specialty Legal Referral ResourceThe Harr Law Firm, located in Daytona Beach, can provide legal assistance with other specialties such as Americans with Disability Act (ADA) lawsuits, product liability, employment law, personal injury, medical malpractice, nursing home abuse and more. The classic Creedence Clearwater Revival song asks what will have if someday never comes. Online File a complaint by submitting a report on the Department of Justice's Civil Rights Division website. . in Accessibility Litigation Trends, ADA - drive-by litigation, ADA - Hotels, ADA - serial litigation, ADA - Standing, ADA Attorney's Fees, ADA Internet Web, ADA Mootness, ADA Point of Sale, ADA Policies, ADA Web Access. California has a much higher standard for accessibility than most other states and countries; it has . With more than 800 attorneys nationwide, we have the resources and reach to provide you the best service possible. Morgan and Morgan is truly the best law firm! Weve helped over 300,000 families. They are filing these civil lawsuits using well known serial plaintiff's such as Luis Licea, Rusty Rendon and Dominick According to the 11th Circuit, this arrangement constituted a serious ethical transgression in violation of Florida Bar rules. Read the court order here: Court Order Dismissing District Attorney Lawsuit August 26, 2021, Newsletter This is a complimentary online event. Despite the prohibition against awarding monetary damages to the plaintiff, ADA lawsuits can still be lucrative for plaintiffs and their attorneys. If you believe youve experienced discrimination due to your disability, you shouldnt go through this alone. Dec. 15, 2022) andMurphy v. Regal Cinemas, Inc., 2022 WL 17821218 (S.D.N.Y. Dec. 16, 2022) mostly for the following striking statement: InTrujillo v. 4B Mkt. In Shayler v. 1310 PCH, LLC, here, the Ninth Circuit in a published decision decided on October 24, 2022, winds up approving a 65% downward multiplier to the total amount of fees and a $300 per hour blended billing rate for plaintiff's counsel because the nature of the work was turnkey. Copyright Insurance companies truly know that they will take it to court! The purpose of the law is to make sure that people with disabilities have the same rights and opportunities as everyone else. The Americans with Disabilities Act (ADA) is an important piece of civil rights legislation that became law in 1990. Always asked how I was doing and was prompt with responding to any of my questions or concerns. Judge Andrew Carter found the plaintiffs allegations inMatzura v. Macys Inc., 2022 WL 17718335 (S.D.N.Y. Ive linked to my quick profile write-ups of Wilshire (California) and Gottlieb (New York) above. Texas, Dec. 6, 2022) based on an almost identical pleading. Mail Fill out and send the paper ADA Complaint Form or a letter containing the same information, to: U.S. Department of Justice Civil Rights Division 950 Pennsylvania Avenue, NW The California ADA laws and the Federal United States American with Disabilities Act are one-sided. At Morgan & Morgan, our attorneys understand how devastating and unfair situations like yours can be and want to fight for the compensation and justice you deserve. Some businesses find themselves defending against investigations and enforcement actions brought by the US Department of Justice (DOJ) which can result in onerous remedial measures, large damage payments, and civil penalties. If the Ninth Circuit ever does the same my blogs will start getting much shorter. The problem is proving the claim is really moot. The case has potentially broad-reaching implications because Brian Whitaker, a prolific ADA plaintiff, has filed more than a thousand lawsuits in the Bay Area against small business owners. An employee with a history of impairment If an employee has a record or history of a substantially limiting impairment, then the employee may be considered an individual with a disability. By Richard Hunt Case Summary. SeeEEOC-Fact-Sheet-Disability-Discrimination-ADA. Although it is possible for a plaintiff and their attorney to recover legal fees and perhaps secure a settlement, it can be impossible to determine how much plaintiffs benefit monetarily from ADA lawsuits; but, the plaintiffs named in such lawsuits should benefit from injunctions forcing compliance with the ADA. Seyfarth's ADA Title III team has extensive experience litigating single plaintiff and class-action lawsuits in New York, California, and Florida, and is very familiar with each jurisdiction's peculiarities. Most notable in this group is the state of California. On March 1, 2023, Leslie Briggs, Evan Watson, and Henry A. Meyer III (collectively, "Plaintiffs"), represented by Frederic Dorwart, David Wayne Leimbach, and Paul DeMuro of Frederic Dorwart Lawyers PLLC; and Nick Southerland and Brian S. Wilkerson of Oklahoma Disability Law Center, Inc., filed a class action civil rights . Were a family law firm and treat every client as a member of the family, handling their cases personally. In ADA lawsuits started by the Department of Justice, the defendant is not responsible for paying the Departments legal fees if they lose, but they may be responsible for paying compensatory relief and civil penalties in cases of public importance and repeated abuse. If the goods and chattels are delivered by the sheriff or other officer to the defendant upon the making of a claim thereto and the giving of a redelivery bond or cash deposit pursuant to law, the sheriff or other officer shall promptly make a return of the facts to the court, annexing the claim of the defendant to the writ of replevin, and return the same forthwith . Under Californias Unruh Act and the New York State Civil Rights Law, plaintiffs can obtain statutory damages without having to prove that they suffered actual damages. Please be aware that we do not provide legal advice over the internet or in emails, nor will we agree to represent a party through an email. The ADA Title III team defends businesses against many hundreds of lawsuits and claims filed across the country each year. Our team of experts is committed to your success. Accessibility Defense, Helping Business Avoid and Defend ADA and FHA Lawsuits. Moreover, it includes people who may not be practically disabled but technically have a limiting disability. Critics will point to the growing number of ADA lawsuits being filed as evidence of abuse of the system, but the merits of each lawsuit are different. Secured the dismissal of three nationwide class action lawsuits brought in New York against three major hotel companies involving thousands of hotels and their compliance with the ADAs reservations rules on their websites. They are a great team! Join our community and get updates on legal reform and other exclusive content. The plaintiff asked for an order requiring the defendant to remediate parking and other architectural barriers but did not ask that the court impose any deadline on the work. The settlement put an end of a year of intensive and expensive litigation by the restauranteurs prior counsel. If you have any issues relating to alleged disability discrimination in the workplace and seek legal advice, please contact one of our labor and employment lawyers to discuss the issue in a free consultation. Daytona Beach, Florida 32114. June 17, 2022 In the case of prolific plaintiff Alexander Johnson, it was a nice cash supplement to his disability income, apparently. [email protected], I defend businesses nationwide in ADA and FHA accessibility lawsuits and consult with businesses and other attorneys concerning how to promptly and effectively deal with ADA and FHA demands, minimize litigation risk, and obtain meaningful compliance with the ADA and FHA. The case is pending. Florida Judge Sanctions Serial ADA Plaintiff Alexander Johnson and Attorney Scott Dinin, Ninth Circuit Says Restaurant Does Not Discriminate Against the Blind By Providing Only Drive-Through Service, California Governor Takes Action to Combat Emotional Support Animal Fraud, A Second California State Court Judge Says the ADA Covers Online-Only Businesses, Long Overdue Report Shows Deficient Accessibility for Many Federal Websites, ADA Title III Federal Lawsuits Numbers Are Down But Likely To Rebound in 2023, Eye Surgery Centers to Pay $1M in Damages and Penalties to Resolve Alleged ADA Violations, Plaintiffs Set a New Record for Website Accessibility Lawsuit Filings in 2022, California Peculiarities Employment Law Blog, Management Writes: Practical Labor Law Updates, Workplace Safety and Environmental Law Alert Blog. Mootness is the best and strongest defense to a Title III ADA claim because, as described in the entry above, if the facility is made accessible the case must be dismissed and the plaintiff gets no attorneys fees. Morgan & Morganwants to hear from you. This web site offers general information about our practice and its content is not intended to be, and should not be construed as, legal advice. DOJ Investigations. Disability Awareness: Progress Since the ADA and Challenges Ahead. Judge Boyle granted leave to amend, so the case isnt over, but in past cases Segovia and his lawyers have not been able to substantively improve their complaint. Garland, Texas 75044 ADA Law Firms | ADA Plaintiff Attorneys (Click on Law Firm to see samples of their lawsuits and demand letters) California Center for Disability Access / Potter Handy LLP | Amanda Seabock, Mark Potter, Chris Carson, Denise Price, Russell Handy The Manning Law Firm | Joseph Manning, Craig Cote, Phyl Grace So. "We are attorneys. The best way to avoid ADA lawsuits is for businesses and other public accommodations to comply with the law. Christian Sanchez Cohen & Mizrahi LLP Lawsuits, Cost Website Accessibility WCAG 2.1 AA Audit ADA Compliance, Southern District of Florida Miami Division. Wernz claims under ADA attorney fees are awarded to the plaintiff, and that it is proper for plaintiffs to share attorney's fees. Because the team handles so many cases covering so many different topics, it can leverage its institutional knowledge to formulate the most effective defense strategy for its clients. With additional litigators admitted to practice in virtually every jurisdiction in the country, we have the resources to defend our clients against lawsuits and investigations on a . Thank you so much Morgan & Morgan! If the policy had been adopted after the lawsuit was filed or there had been more than one uncaptioned video the result would likely have been different. Seyfarths ADA Title III attorneys monitor and analyze new court decisions and developments on a daily basis to develop CLE programs and write for the ADA Title III News & Insights Blog. The result has been a 17% increase in civil claims in recent years. N.H. November 8, 2017) (denying a motion to dismiss sought against ADA claims) ("[Plaintiffs] rely on Title III of the ADA as governing the defendant's potential liability and invoke . Collectively handled more than a thousand facilities accessibility controversies involving alleged violations of Title III of the ADA. An appeals court has ruled that the Florida federal judge who penalized a serial lawsuit-filer and his attorney for filing frivolous Americans with Disabilities Act (ADA) claims was right to do so, according to a report in Legal Newsline. For those keeping score motions to dismiss almost identical complaints filed in the Northern and Western Districts of Texas have reached very different results. The term major life activity is broadly defined to include basic tasks (such as walking, reading, bending, and communicating), as well as major bodily functions (like functions of the immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and reproductive functions). Contact us today foradditional information about our Colorado A attorneys. Providing quality ADA Defense, Business & Real Estate Services throughout the United States for over 40 years. If an ADA plaintiff does not have a bona fide intent to do business with the defendant, then there is no standing because there is no harm to the plaintiff. Common plaintiffs include: Cynthia Hopson and Meryl Pomponio. This is a civil right that we. In Costello v. Flatman, LLC,1 the plaintiff alleged an ADA violation because he was wheelchair-bound and unable to access a Subway restaurant. There is virtually no aspect of the ADA that team members have not encountered. An employee who the employer regards as disabled If an employee is perceived by the employer as being substantially limited in one or more major life activities (even if the employer is wrong), then the employee is considered an individual with a disability under the ADA. Defend your rights. OurexperiencedADA discrimination attorneys are passionate about fairness and fighting for the rights of victims like you. Title I of the Americans With Disabilities Act (ADA) prohibits employers from discriminating against employees or applicants on the basis of disability in any aspect of employment, including hiring, compensation, promotion, discharge and other terms and conditions of employment. Title I of the Americans With Disabilities Act (ADA) prohibits employers from discriminating against employees or applicants on the basis of disability in any aspect of employment, including hiring, compensation, promotion, discharge and other terms and conditions of employment. Know your judge. InHull v. Little, 2022 WL 17818065 (9th Cir. Uniformed Service Discrimination (USERRA), Employment Contracts Severance Agreements, Patents, Trademarks & Intellectual Property, USERRA Uniformed Service Discrimination. The district court gave the plaintiff what he asked for in terms of remediation but included no deadline. andQuick Hits Vernal Equinox editionfor a very brief history of gift card accessibility litigation. (a) Judgment for Damages. Gilbert v. Bonfare Markets, Inc., 2022 WL 17968629 (E.D. A US company has sued one of its former employees over allegations she "quiet quit" her job despite still raking in her $400,000 salary - a move that has prompted the ex . There are also instances where a plaintiff will file a lawsuit under the ADA and the defendant will quickly settle the suit with a cash payment. Serial ADA litigation is going strong because outcomes depend on the judge assigned rather than the law or the facts. Data is skewed because there are many law firms who are more focused on sending out demand letters (which do not become public record). The original five titles of ADA wereamended in 2008 with the passage of the Americans with Disabilities Act Amendments Act (ADAAA), which made substantial changes to the definition of "disability.". All rights reserved. There are, however, some cases dealing addressing important substantive issues, and few in which Courts seem ready to turn the ADA and FHA into laws to help people instead of laws to make lawyers rich. Drafted comprehensive ADA policies for almost every major hotel brand in the United States, in addition to a number of retailers and financial institutions. of the Deaf v. Fla., 2020 WL 6575040 (11th Cir. SUPERIOR COURT OF CALIFORNIA IN AND FOR THE COUNTY OF LOS ANGELES, ORANGE COUNTY, VENTURA, SAN BERNARDINO . Its hard to imagine a cheaper settlement given the Unruh Acts statutory damage provision. Has your employer failed to make accommodations that would allow you to do your job? Our Colorado ADA lawyers build strong attorney-client relationships to support you in all matters related to claims of employment discrimination related to disabilities. . Accordingly, ADA Title III team members are also very familiar with laws such as the Rehabilitation Act, the Air Carrier Access Act, and the Twenty-First Century Communications and Video Accessibility Act. 214-279-6124 fax What Is the ADA Employment Law Claims Process? We know how to win. With additional litigators admitted to practice in virtually every jurisdiction in the country, we have the resources to defend our clients against lawsuits and investigations on a nationwide basis and provide consistent and efficient service in national engagements. Defend Your Rights!Florida businesses and property owners must fight back. InSegovia v. Shahrukh & Shahzeb Inc., 2022 WL 17566267 (N.D. Tex. In fact, we are ADA Title III counsel to the market leaders of these industries which seek our counsel when they have critical and cutting edge ADA Title III challenges to solve. Seyfarths ADA Title III team has extensive experience handling DOJ investigations, state and local agency investigations, lawsuits brought under the FHA and other disability access laws concerning assistance/service animals, reasonable accommodations for individuals with disabilities, and the failure to design and construct multifamily housing in accordance with accessibility requirements. By Richard Hunt The essential duties of the job are those tasks that are fundamental to the position. A qualified worker with a disability is someone who is able to perform the essential duties of the job, with or without a reasonable accommodation by the employer. Winn Dixies appeal of the pro-plaintiff judgment in that case is awaiting a decision from the Eleventh Circuit, and it is unclear what impact, if any, the Sanctions Order will have on the award of fees and costs in that closely watched case. When a defendant defaults the Court can enter judgment for exactly what the plaintiff includes in the prayer for relief in their complaint, but nothing more. App. Dec. 30, 2022) it was about $3700 in fees and costs plus $4000 in damages and an injuction to fix what had to be fixed regardless. Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, 2023 The Karlin Law Firm LLP All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, Center for Disability Access / Potter Handy LLP, Shopping Centers, Strip Centers And Retail Stores, Restaurant and Food Service ADA Compliance, Apartments and the ADA law and Apartment Advertising, Industrial Buildings and Tenants not doing business with the Public, Motel and Hotel Swimming Pools and Spas ADA, Truncated Domes and the Blind and Visually Impaired, Law Offices of Hakimi and Shahriari | Anoush Hakimi & Peter Shahriari, Beverly Hill Trial Attorneys | Azar Mouzari, Law Office of Peter Kristofer Strojnik | Peter K. Strojnik, Law Office of Morse Mehrban | Morse Mehrban, Law Office of Ross Cornell | Ross Cornell, Law Office of Michael Taibi | Michael Taibi, Law Office of Brian C. Andrews | Brian C. Andrews, Law Office of Richard MacBride | Richard MacBride, Robert Wendt | Beverly Hills Trial Attorneys (ADA Website Lawsuits), Andrew Baracco | Beverly Hills Trial Attorneys (ADA Website Lawsuits), Pamela Hill | Beverly Hills Trial Attorneys (ADA Website Lawsuits), Aderiyike Lawal | Beverly Hills Trial Attorneys (ADA Website Lawsuits), United African Asian Abilities Club | Lightning Law (ADA Apartment Lawsuits), James Lee | Lightning Law (ADA Apartment Lawsuits), Jessie James IV | Lightning Law (ADA Apartment Lawsuits), Anna Marie Wiggins | Lightning Law (ADA Apartment Lawsuits), Estela J. Ramos | Pro-per (ADA Website Lawsuits), Jeff Fitzpatrick | Pro-per (ADA Website Lawsuits), Brenda Ordaz | Pro-per (ADA Website Lawsuits), Vanessa Orellena | Pro-per (ADA Website Lawsuits), John Paul Hutchines | Pro-per (ADA Website Lawsuits), Virdiana Quevedo | Pro-per (ADA Website Lawsuits), Juliana Garcia | Pro-per (ADA Website Lawsuits), Amber Ortiz | Pro-per (ADA Website Lawsuits), Garnik Blkhoyan | Pro-per (ADA Website Lawsuits), Nazik Blkhoyan | Pro-per (ADA Website Lawsuits), Fernando Gastelum | Pro-per(ADA Physical Lawsuits), Peter Strojnik Sr. | Pro-Per (ADA Physical Lawsuits), Theresa Brooke | Law Offices of Peter Strojnik (ADA Physical Lawsuits), Christopher Soldan | Calhoun & Associates (ADA Physical Lawsuits), Kayla Ryan | Calhoun & Associates (ADA Physical Lawsuits), Jonathan Turner | Law Office of Michelle Uzeta, Eric Cleveland | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), Ed Hull | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), Lasandra Price | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), Robbie Hurtado | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), Dee Anne Evans | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), Michelle Bartick | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), George Jones | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), Teresa Hicks | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), Todd Williamson | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), John Irizawa | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), Amber Machowski | The Law Offices of Hakimi and Shahriari (ADA Physical Lawsuits), Daniel Cervantes | Wilshire Law Firm (ADA Website Lawsuits), Flor Jimenez | Wilshire Law Firm (ADA Website Lawsuits), Crystal Redrick | Wilshire Law Firm (ADA Website Lawsuits), Christopher Lucero | Wilshire Law Firm (ADA Website Lawsuits), Portia Mason | | Wilshire Law Firm (ADA Website Lawsuits), Vivian Salazar | Wilshire Law Firm (ADA Website Lawsuits), Thuy Thanh Alonzo | Wilshire Law Firm (ADA Website Lawsuits), Bryan Estrada | Law Office of Ross Cornell (ADA Physical Lawsuits), Bryan Willams | Law Office of Ross Cornell (ADA Physical Lawsuits), Jose Casillas | Custodio & Dubey (ADA Website Lawsuits), Perla Mageno | The Manning Law Firm (ADA Website Lawsuits), Sheila Biglang-Awa Castro aka Sheila Biglang |, Edward Davis | Law Office of Olga Nazimova (ADA Website Lawsuits), Ronald Chism | Law Office of Olga Nazimova (ADA Website Lawsuits), Richard Sepulveda | Law Offices of Richard MacBride (ADA Physical Lawsuits), Richard Cooks | Law Office of Alisa Adams / Linnekens Law (ADA Website Lawsuits), Pursuit of Respect | Fishback Law Group (ADA Website Lawsuits), Santiago Hernandez | Law Office of Arthur Shushanyan / Linnekens Law (ADA Website Lawsuits), Michael Sandoval | Apex Law (ADA Website Lawsuits), John Ho | Ascension Law Group (ADA Physical Lawsuits), Ngoc Lam Che | Ascension Law Group (ADA Physical Lawsuits), Hoang Minh Le | Ascension Law Group (ADA Physical Lawsuits), Quy Trounng | Ascension Law Group (ADA Physical Lawsuits), Michael C. Keo | Ascension Law Group (ADA Physical Lawsuits), Stephen Turner | Ascension Law Group (ADA Physical Lawsuits), Adam Ghadiri | Law Office of Joseph Bakhos (ADA Physical Lawsuits), Richard Gambord | Moore Law Firm (ADA Physical Lawsuits), Darren Gilbert | Moore Law Firm (ADA Physical Lawsuits), Hendrick Block | Moore Law Firm (ADA Physical Lawsuits), Gerardo Hernandez | Moore Law Firm (ADA Physical Lawsuits), Jenisa Angeles | Stein Saks (ADA Website Lawsuits), Marina Iskhakova | Stein Saks (ADA Website Lawsuits), Warren Zinnamon | Stein Saks (ADA Website Lawsuits), Marta Hanyzkiewicz | Stein Saks (ADA Website Lawsuits), Victor Lopez | Gottlieb & Associates (ADA Website Lawsuits), Lawrence Young | Gottlieb & Associates (ADA Website Lawsuits), Donna Hedges | Gottlieb & Associates (ADA Website Lawsuits), Denise Crumwell | Gottlieb & Associates (ADA Website Lawsuits), Henry Tucker | Gottlieb & Associates (ADA Website Lawsuits), Sylinia Jackson | Gottlieb & Associates (ADA Website Lawsuits), Yelitza Picon | Gottlieb & Associates (ADA Website Lawsuits), Evelina Calcano | Gottlieb & Associates (ADA Website Lawsuits), Lynnette Tatum-Rios | Lipsky Lowe, LLP (ADA Website Lawsuits), Kareem Nisbett | Lipsky Lowe, LLP (ADA Website Lawsuits), Brian Fischler | Lipsky Lowe, LLP (ADA Website Lawsuits), Thomas J. Olsen | Lipsky Lowe, LLP (ADA Website Lawsuits), Veronica Maddy | Mars Khiamov Law PLLC (ADA Website Lawsuits), Andrew Toro | Mars Khiamov Law PLLC (ADA Website Lawsuits), Jenny Hwang | Mars Khiamov Law PLLC (ADA Website Lawsuits), Damon Jones | Mars Khiamov Law PLLC (ADA Website Lawsuits), Miriam Cruz | Mars Khiamov Law PLLC (ADA Website Lawsuits).

Delta Sigma Theta Graduate Membership Intake Process, Alfred Dunner Plus Size Tops At Jcpenney, Jeffrey Dean Morgan Looks Like Robert Downey Jr, Who Played John Carter's Wife In Er, Articles A