Moralez v. California Check Cashing Stores, LLC et al

Filing 19

STIPULATION AND ORDER re 18 STIPULATION WITH PROPOSED ORDER extending deadline to complete joint site inspection filed by Francisca Moralez. Signed by Judge Jon S. Tigar on January 30, 2018. (wsn, COURT STAFF) (Filed on 1/30/2018)

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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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FRANCISCA MORALEZ,

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Plaintiff,
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vs.
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CALIFORNIA CHECK CASHING STORES, )
LLC dba CALIFORNIA CHECK CASHING, )
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et al.,
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Defendants.
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No. 3:17-cv-06141-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, California Check Cashing
Stores, LLC dba California Check Cashing; and Genirberg Family, LLC, dba The Genirberg
Family Limited Partnership (“Defendants,” and together with Plaintiff, “the Parties”), by and
through their respective counsel, hereby stipulate as follows:
1.

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

equal access to their public accommodation on account of her disabilities in violation of Title
III of the Americans with Disabilities Act (“ADA”) and parallel California law. Plaintiff seeks
injunctive relief under federal and California law, as well as damages under California law.
This matter therefore proceeds under this district’s General Order 56 which governs ADA

STIPULATION TO EXTEND DEADLINE TO COMPLETE JOINT SITE INSPECTION REQUIRED BY
GENERAL ORDER 56; [PROPOSED] ORDER
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access matters.

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2.

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

subject property on or before February 8, 2018 (Dkt. 4).
3.

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

to the February 8, 2018 deadline.
4.

The Parties have agreed to conduct the joint site inspection on February 13, 2018

at 10:00 a.m. unless a settlement is reached prior to that date.
5.

Accordingly, the Parties stipulate to extend the deadline to conduct the joint site

inspection to February 13, 2018.

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IT IS SO STIPULATED.

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Dated: January 29, 2018

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

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Dated: January 29, 2018

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/s/ Anthony J. Decristoforo
Anthony J. Decristoforo
Attorneys for Defendant,
California Check Cashing Stores, LLC
dba California Check Cashing

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OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P .C.

Dated: January 29, 2018

FERBER LAW

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/s/ James B. Wickersham
James B. Wickersham
Attorneys for Defendant,
Genirberg Family, LLC, dba The Genirberg
Family Limited Partnership

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STIPULATION TO EXTEND DEADLINE TO COMPLETE JOINT SITE INSPECTION REQUIRED BY
GENERAL ORDER 56; [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/ Zachary M. Best
Zachary M. Best
Attorney for Plaintiff,
Francisca Moralez

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[PROPOSED] 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 February 13, 2018, 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: January 30, 2018
United States District Judge

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STIPULATION TO EXTEND DEADLINE TO COMPLETE JOINT SITE INSPECTION REQUIRED BY
GENERAL ORDER 56; [PROPOSED] ORDER
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