Cornell's favor, I cannot hold that it appears beyond doubt that the plaintiff can prove no set of facts that would prove the existence of conscious-shocking behavior by the defendants. 15 . Section 12131(2) of Title II of the ADA defines “qualified individual with a disability” as an “individual with a disability who, with or without reasonable modifications ... meets the essential eligibility requirements for the receipt of services or the participation in programs or activities provided by a public entity.” 16 . The Third Circuit has held that the ADA grants standing to entities like Cornell that have a close association with disabled persons to assert disability discrimination claims under the ADA. See Addiction Specialists, Inc. v. Twp. of Hampton, 411 F.3d 399, 408 (3d Cir.2005) (<HOLDING>); Innovative Health Sys., Inc. v. City of White
holding that neither the ada nor the rehabilitation act applies to prison employment holding that a proposed methadone treatment center has standing under both the ada and the rehabilitation act holding that the same standards apply to claims under the ada and under the rehabilitation act holding the ada and the rehabilitation act applicable holding that exemption under the ada does not preclude liability under the rehabilitation act