CONFIDENTIAL — ATTORNEY WORK PRODUCT — PREPARED IN ANTICIPATION OF LITIGATION

Declaration of [DECLARANT NAME]

Regarding the Web Accessibility of OTHERS_dalton_glasshouse_beachfront_arroyo_neu

I,  , declare as follows:

  1. 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.
  2. 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 20260702T210032Z (UTC). Findings on which multiple engines agreed were recorded at higher confidence.
  3. 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.
  4. Conformance findings. The evaluation identified 22 distinct standards-mapped accessibility deficiencies across 5 page(s). Results by standard:
    StandardDeficienciesCriteria failedResult
    WCAG 2.1 Level AA226 Does not conform
    WCAG 2.2 Level AA226 Does not conform
    Section 508 (Revised — incorporates WCAG 2.0 A/AA)226 Does not conform
  5. 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.
  6. 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.
  7. 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.