CONFIDENTIAL — ATTORNEY WORK PRODUCT — PREPARED IN ANTICIPATION OF LITIGATION
Declaration of [DECLARANT NAME]
Regarding the Web Accessibility of DALTON_deep
I, , declare as follows:
- Background. I am [qualifications / basis of expertise in digital accessibility and WCAG].
I make this declaration based on my personal knowledge and the evaluation described below, and if called as a witness could testify competently to these facts.
- Methodology. The website was evaluated following the W3C Website Accessibility Conformance Evaluation
Methodology (WCAG-EM 1.0) using three independent, industry-recognized testing engines — axe-core (Deque),
HTML_CodeSniffer (via pa11y), and Google Lighthouse — run against the pages as rendered in Google Chrome on
20260702T235837Z (UTC). Findings on which multiple engines agreed were recorded at higher confidence.
- Evidence preservation. For each page, the rendered markup, the computed accessibility tree, full-page and
per-defect screenshots, and the raw engine output were captured and cryptographically sealed (SHA-256 + Merkle root
+ trusted timestamp), such that any later alteration is detectable. The integrity of that evidence is attested in the
accompanying Certificate of Evidence Integrity & Chain of Custody.
- Conformance findings. The evaluation identified 27 distinct standards-mapped
accessibility deficiencies across 6 page(s). Results by standard:
| Standard | Deficiencies | Criteria failed | Result |
|---|
| WCAG 2.1 Level AA | 27 | 3 |
Does not conform |
| WCAG 2.2 Level AA | 27 | 3 |
Does not conform |
| Section 508 (Revised — incorporates WCAG 2.0 A/AA) | 27 | 3 |
Does not conform |
- Nature of the barriers. The deficiencies include [e.g., links and controls without a
programmatically determinable name (WCAG 4.1.2), insufficient text contrast (1.4.3), non-text content without a text
alternative (1.1.1), controls below minimum target size (2.5.8)], each of which impedes users who rely on
assistive technology such as screen readers, keyboard-only navigation, or magnification.
- Limitations. Automated testing reliably evaluates only a subset of accessibility requirements; the figures
above are therefore a floor, not a ceiling. Criteria requiring human evaluation were assessed through recorded
keyboard-operability and screen-reader testing, described in the accompanying captures.
- Reproducibility. The evaluation is reproducible from the preserved evidence and recorded tool versions; the
sealed artifacts can be independently re-verified by any third party.
I declare under penalty of perjury under the laws of that the
foregoing is true and correct.
Executed on at .
Signature:
Printed name:
Counsel review required. This is a template. The declarant's qualifications, the characterization
of barriers, the applicable legal standard (e.g., ADA Title III, 28 C.F.R. Part 36; the DOJ 2024 Title II rule adopting
WCAG 2.1 AA; and controlling authority such as Robles v. Domino's, 9th Cir. 2019), and the standing/merits
analysis must be confirmed by counsel. This tool and declaration support, and do not replace, a qualified expert.