Between 2001 to present, at all times Plaintiffs were/are a client or customer of Defendants.  Defendants operate several medical facilities, including, inpatient and outpatient medical facilities throughout San Diego County.  Plaintiffs received medical services at one or more Kaiser facilities in San Diego.  Plaintiffs, on numerous occasions, received pharmacy written instructions, written medical instructions, printed media delivered in person to patients or clients and printed media delivered by other means to patients or clients from Kaiser.  Plaintiff Irving-Ramirez repeatedly requested this information be delivered to her in large print timely.  Plaintiff Deer repeatedly requested this information be delivered to her in audiocassette form timely.  Defendants continued to deliver Plaintiffs pharmacy written instructions, written medical instructions, printed media delivered in person to patients or clients and printed media delivered by other means to patients or clients in standard print, or Defendants delivered to Plaintiffs pharmacy written instructions, written medical instructions, printed media delivered in person to patients or clients and printed media delivered by other means to patients or clients which failed to provide meaningful access to the words contained therein.  Read Complaint By Clicking Here.