Moralez v. Hayward Medical Market, Inc. et al

Filing 15

ORDER GRANTING STIPULATION AS MODIFIED by Judge William Alsup granting 14 Stipulation. Case Management Conference set for 12/7/2017 11:00 AM in Courtroom 12, 19th Floor, San Francisco.(whalc1, COURT STAFF) (Filed on 11/6/2017)

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Tanya E. Moore, SBN 206683
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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HAYWARD MEDICAL MARKET, INC., et )
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al.,
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Defendants.
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No. 3:17-cv-04466-WHA
STIPULATION TO EXTEND DEADLINE
TO COMPLETE JOINT SITE
INSPECTION REQUIRED BY GENERAL
ORDER 56 AND TO CONTINUE CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER AS MODIFIED

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WHEREAS, on August 7, 2017, the Court issued its Scheduling Order for Cases

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Asserting Denial of Right of Access under Americans with Disabilities Act Title II & III (Dkt.

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4), requiring that Plaintiff, Francisca Moralez (“Plaintiff”), and Defendants, Hayward Medical

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Market, Inc. and Rajneesh Salwan, Trustee of the Rajneesh Salwan Separate Property Trust

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(“Trustee”) (Hayward Medical Market, Inc. and Trustee are collectively “Defendants,” and

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together with Plaintiff, “the Parties”), conduct a joint site inspection of the subject property no

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later than November 17, 2017;

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WHEREAS, due to scheduling conflicts and Trustee’s present endeavors to include

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insurance defense counsel in the matter, the Parties are unable to conduct the joint site

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inspection by the deadline, but have agreed to conduct it on December 13, 2017 at 11:00 a.m.;

STIPULATION TO CONTINUE DEADLINE FOR JOINT SITE INSPECTION; [PROPOSED] ORDER
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WHEREAS, a Case Management Conference has been set for November 9, 2017 at
11:00 a.m. (Dkt. 10);

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NOW, THEREFORE, the Parties stipulate to extend the deadline to conduct the joint

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site inspection to December 13, 2017, with all dates triggered by that deadline continued

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accordingly.

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The Parties additionally respectfully request a continuance the Case Management

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Conference to a date on or after January 18, 2018 at the Court’s convenience so that Trustee can

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obtain the participation of its insurance defense counsel prior to the Conference.

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IT IS SO STIPULATED.

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Dated: November 2, 2017

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MISSION LAW FIRM, A.P.C.
/s/ Tanya E. Moore
Tanya E. Moore
Attorneys for Plaintiff,
Francisca Moralez

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Dated: November 2, 2017

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LAW OFFICES OF CHRISTIAN B. GREEN
/s/ John T. Hill
John T. Hill
Attorneys for Defendant,
Hayward Medical Market, Inc.

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Dated: November 2, 2017

WESTON LAW GROUP

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/s/ Ian Bennett-Goldberg
Jonathan Black
Ian Bennett-Goldberg
Attorneys for Defendant,
Rajneesh Salwan, Trustee of the Rajneesh Salwan
Separate Property Trust

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

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Concurrence in the filing of this document has been obtained from each of the individual(s)
whose electronic signature is attributed above.

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/s/ Tanya E. Moore
Tanya E. Moore
Attorneys for Plaintiff
Francisca Moralez

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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 December 13, 2017, with all dates triggered by that deadline

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continued accordingly.

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IT IS FURTHER ORDERED that the Case Management Conference is continued to
2017
December 7
_____________, 2018, at 11:00 a.m. in Courtroom 8, 19th Floor, 450 Golden Gate Avenue,

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San Francisco, before Judge William Alsup. A joint case management statement is due one

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week prior to the Case Management Conference.

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IT IS SO ORDERED.

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Dated: November 6, 2017.
HON. WILLIAM ALSUP
United States District Judge

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