Moralez v. Navarro et al

Filing 22

STIPULATION AND ORDER re 21 STIPULATION WITH PROPOSED ORDER re 4 Initial Case Management Scheduling Order - ADA Case extending deadline to complete joint site inspection filed by Francisca Moralez. Signed by Judge Jon S. Tigar on April 26, 2017. (wsn, COURT STAFF) (Filed on 4/26/2017)

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Zachary M. Best, SBN 166035
MISSION LAW FIRM, A.P.C.
332 North Second Street
San Jose, California 95112
Telephone [phone]
Facsimile [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
Francisca Moralez

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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FRANCISCA MORALEZ,

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Plaintiff,
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vs.
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LUZ PATRICIA NAVARRO dba CINCO DE )
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MAYO RESTAURANT, et al.,
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Defendants.
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No. 3:17-cv-00676-JST
STIPULATION TO EXTEND DEADLINE
TO COMPLETE JOINT SITE
INSPECTION REQUIRED BY GENERAL
ORDER 56; [PROPOSED] ORDER

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Plaintiff, Francisca Moralez (“Plaintiff”), and Defendants, Luz Patricia Navarro dba

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Cinco de Mayo Restaurant; Douglas W. Knight; Katherine K. Robbins, Trustee of the

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Katherine K. Robbins Trust dated February 2, 2001; Julienne Lemoine; and James M. Lemoine

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(collectively “Defendants,” and together with Plaintiff, “the Parties”), by and through their

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respective counsel, hereby stipulate as follows:

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1.

This action arises out of Plaintiff’s claims that Defendants denied her full and

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equal access to their public accommodation on account of her disability in violation of Title III

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of the Americans with Disabilities Act (“ADA”) and parallel California law. Plaintiff seeks

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injunctive relief under federal and California law, as well as damages under California law.

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This matter therefore proceeds under this district’s General Order 56 which governs ADA

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access matters.

STIPULATION TO CONTINUE DEADLINE FOR JOINT SITE INSPECTION; [PROPOSED] ORDER
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2.

The Court has ordered that the Parties conduct a joint site inspection of the

subject property on or before May 25, 2017 (Dkt. 4).
3.

Counsel for Defendants is unavailable to conduct the joint site inspection prior to

the May 25, 2017 deadline.
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The Parties and their counsel have agreed to conduct the joint site inspection on

June 20, 2017 at 11:00 a.m.
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Accordingly, the Parties stipulate to extend the deadline to conduct the joint site

inspection, to June 20, 2017.

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IT IS SO STIPULATED.

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Dated: April 26, 2017

MISSION LAW FIRM, A.P.C.

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/s/ Zachary M. Best
Zachary M. Best
Attorneys for Plaintiff,
Jose Trujillo

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Dated: April 26, 2017

VAUGHAN & ASSOCIATES

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/s/ Cris C. Vaughan
Cris C. Vaughan
Attorneys for Defendants
Luz Patricia Navarro dba Cinco de Mayo
Restaurant; Douglas W. Knight; Katherine K.
Robbins, Trustee of the Katherine K. Robbins
Trust dated February 2, 2001; Julienne Lemoine;
and James M. Lemoine

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STIPULATION TO CONTINUE DEADLINE FOR JOINT SITE INSPECTION; [PROPOSED] ORDER
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ORDER

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The Parties having so stipulated and good cause appearing,

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IT IS HEREBY ORDERED that the deadline for the Parties to complete the joint site

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inspection is extended to June 20, 2017, with all dates triggered by that deadline continued

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accordingly.

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IT IS SO ORDERED.

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Dated: April 26, 2017
United States District Judge

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STIPULATION TO CONTINUE DEADLINE FOR JOINT SITE INSPECTION; [PROPOSED] ORDER
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