For a failure to train claim under Title II of the ADA and the RA, Court's utilize the Monell framework for § 1983 claims. See Bauer v. City of Pleasanton, 2021 U.S. Dist. LEXIS 103627, *53-*54 (C.D. Cal. June 2, 2021) (assuming that a failure to train claim is cognizable and granting summary judgment for the same reasons that a § 1983 Monell claim failed); O'Doan v. Sanford, 2019 U.S. Dist. LEXIS 52810, *6-*7 (D. Nev. Mar. 26, 2019); Lerma v. City of Nogales, 2014 U.S. Dist. LEXIS 139613, *49-*50 (D. Ariz. May 19, 2014); Green v. Tri-Country Metropolitan Transp. Dist. of Or., 909 F.Supp.2d 1211, 1220-21 (D. Or. 2012). As a Monell related theory, the plaintiff must demonstrate inter alia that a municipality's failure to train caused 21 an injury.