Moralez v. Navarro et al

Filing 46

STIPULATION AND ORDER re 44 STIPULATION WITH PROPOSED ORDER to file First Amended Complaint filed by Francisca Moralez. Signed by Judge Jon S. Tigar on March 12, 2018. (wsn, COURT STAFF) (Filed on 3/12/2018)

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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]
Attorney for Plaintiff
Francisca Moralez

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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)
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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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FRANCISCA MORALEZ,

No. 3:17-cv-00676-JST
STIPULATION GRANTING PLAINTIFF
LEAVE TO FILE FIRST AMENDED
COMPLAINT; [PROPOSED] ORDER

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IT IS HEREBY STIPULATED by and between Francisca Moralez (“Plaintiff”), and

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Defendants, Luz Patricia Navarro dba Cinco de Mayo Restaurant; Douglas W. Knight;

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Katherine K. Robbins, Trustee of the Katherine K. Robbins Trust; Julienne Lemoine; and

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James M. Lemoine (“Defendants,” and together with Plaintiff, “the Parties”), the parties

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hereto, through their respective attorneys of record, that Plaintiff may file a First Amended

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Complaint, a copy of which is attached hereto as Exhibit “A.” This amendment will not modify

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any date or deadline fixed by Court order, and is not prejudicial to Defendants, the product of

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undue delay, proposed in bad faith, or futile.

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IT IS FURTHER STIPULATED that Plaintiff will file her First Amended Complaint

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within five (5) calendar days of the Court’s Order permitting such filing, and that Defendants’
STIPULATION GRANTING PLAINTIFF LEAVE TO FILE FIRST AMENDED COMPLAINT;
[PROPOSED] ORDER
Page 1

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response thereto shall be filed within fourteen (14) days after the First Amended Complaint is

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filed.

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IT IS SO STIPULATED.
Dated: March 8, 2018

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MISSION LAW FIRM, A.P.C.
/s/ Zachary M. Best
Zachary M. Best
Attorneys for Plaintiff,
Francisca Moralez

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Dated: March 8, 2018

VAUGHAN & ASSOCIATES
/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; Julienne Lemoine; and James M. Lemoine
ATTESTATION

Concurrence in the filing of this document has been obtained from each of the individual(s)
whose electronic signature is attributed above.
/s/ Zachary M. Best
Zachary M. Best
Attorneys for Plaintiff
Francisca Moralez

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STIPULATION GRANTING PLAINTIFF LEAVE TO FILE FIRST AMENDED COMPLAINT;
[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 Plaintiff shall file her First Amended Complaint, a

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copy of which was filed with the Parties’ stipulation, within five (5) calendar days of the date
this Order is filed.
IT IS FURTHER ORDERED that Defendants’ response thereto shall be filed within

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fourteen (14) days after the First Amended Complaint is filed.

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IT IS SO ORDERED.
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Dated:

March 12, 2018
HON. JON S. TIGAR
United States District Judge

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STIPULATION GRANTING PLAINTIFF LEAVE TO FILE FIRST AMENDED COMPLAINT;
[PROPOSED] ORDER
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