Blondie2 -- while you are correct that your client doesn't have employees, he does have tenants. I know you can buy a policy that covers Tenant Discrimination -- call your broker and see if that policy would Defend your client against an ADA claim.
I have been told, but do not know this first hand, that while an EPLI policy with 3rd party coverage will Defend an ADA claim, it will not pay the remediation. In other words, if your client has to re-configure the bathrooms to comply, the insurance company doesn't pay for that. If anyone has different info, it would be great if they would post!
"It's a typical day, on the road to Utopia.."