On September 8, 2017, Complainants filed their initial complaint. Complainants filed an amended complaint on August 13, 2018. We hereby amend the present Complaint to add Maria Aparicio as an individual complainant:
Organizational Complainant Make the Road New York, and Individual Complainants Iris Vega, Victor Sanchez, Aura Cruz, and Maria Aparicio, through their attorney Make the Road New York, respectfully allege the following
1. This Complaint is brought by Make the Road New York as an organization complainant, S21 and by five limited English proficient (“LEP“) New Yorkers, on behalf of themselves and all others similarly situated, against the New York City Police Department (“NYPD“) for their pattern and practice of denying interpretation services to Complainants and other persons of foreign–born origin, which deprives them of critical access to NYPD services and unlawfully discriminates against them on the basis of their national origin.
2. Respondent failed to offer and provide interpretation services to Complainants seeking assistance from the police, directly violating New York City‘s Language Access Executive Order (Executive Order 120), NYPD written policy and procedures as outlined in the NYPD Patrol Guide, and the New York City Human Rights Law (“NYCHRL“). Interpretation services were denied when Complainants attempted to report crimes and had made repeated requests for interpretation services. The NYPD‘s refusal to provide interpretation deprived LEP Complainants of the opportunity to communicate effectively with the police and to receive protection and assistance from the NYPD.
3. As a public accommodation under the NYCHRL, the NYPD is liable for their pattern and practice of failing to provide services and protections to LEP immigrant New Yorkers.