Moralez v. California Check Cashing Stores, LLC et al

Filing 21

STIPULATION AND ORDER re 20 STIPULATION WITH PROPOSED ORDER extending deadline to complete joint site inspection (second) filed by Francisca Moralez. Signed by Judge Jon S. Tigar on February 14, 2018. (wsn, COURT STAFF) (Filed on 2/14/2018)

1
2
3
4
5

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

6
7

UNITED STATES DISTRICT COURT

8

NORTHERN DISTRICT OF CALIFORNIA

9
10
11
12
13
14
15
16
17
18

FRANCISCA MORALEZ,

)
)
Plaintiff,
)
)
vs.
)
)
CALIFORNIA CHECK CASHING STORES, )
LLC dba CALIFORNIA CHECK CASHING, )
)
et al.,
)
)
Defendants.
)
)
)
)
)
)

No. 3:17-cv-06141-JST
SECOND STIPULATION TO EXTEND
DEADLINE TO COMPLETE JOINT SITE
INSPECTION REQUIRED BY GENERAL
ORDER 56; [PROPOSED] ORDER

19
20
21
22
23
24
25
26
27
28
SECOND STIPULATION TO EXTEND DEADLINE TO COMPLETE JOINT SITE INSPECTION
REQUIRED BY GENERAL ORDER 56; [PROPOSED] ORDER
Page 1

1

Plaintiff, Francisca Moralez (“Plaintiff”), and Defendants, California Check Cashing

2

Stores, LLC dba California Check Cashing; and Genirberg Family, LLC, dba The Genirberg

3

Family Limited Partnership (“Defendants,” and together with Plaintiff, “the Parties”), by and

4

through their respective counsel, hereby stipulate as follows:

5

1.

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

6

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

7

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

8

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

9

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

10

access matters.

11

2.

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

12

subject property on or before February 8, 2018 (Dkt. 4); thereafter, the Parties requested an

13

extension and were given until February 13, 2018 (Dkt. 19).

14

3.

The Parties are engaging in settlement discussions and wish to avoid incurring

15

additional attorney’s fees and costs incident to attending the joint site inspection while

16

settlement efforts are being exhausted. The Parties appear to be near settlement.

17
18
19
20

4.

The Parties have agreed to conduct the joint site inspection on March 2, 2018 at

10:30 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 March 2, 2018.

21
22

IT IS SO STIPULATED.

23
24
25
26
27

Dated: February 12, 2018

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

28
SECOND STIPULATION TO EXTEND DEADLINE TO COMPLETE JOINT SITE INSPECTION
REQUIRED BY GENERAL ORDER 56; [PROPOSED] ORDER
Page 2

1

Dated: February 12, 2018

2

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P .C.
/s/ Anthony J. Decristoforo
Anthony J. Decristoforo
Attorneys for Defendant,
California Check Cashing Stores, LLC
dba California Check Cashing

3
4
5
6
7

Dated: February 12, 2018

8

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

9
10
11

ATTESTATION

12
13

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

14
/s/ Zachary M. Best
Zachary M. Best
Attorney for Plaintiff,
Francisca Moralez

15
16
17
18

[PROPOSED] ORDER

19
20

The Parties having so stipulated and good cause appearing,

21

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

22

inspection is extended to March 2, 2018, with all dates triggered by that deadline continued

23

accordingly.

24
25
26
27

IT IS SO ORDERED.
Dated: February 14, 2018
United States District Judge

28
SECOND STIPULATION TO EXTEND DEADLINE TO COMPLETE JOINT SITE INSPECTION
REQUIRED BY GENERAL ORDER 56; [PROPOSED] ORDER
Page 3