Moralez v. California Check Cashing Stores, LLC et al
Filing
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STIPULATION AND ORDER re 22 THIRD STIPULATION WITH PROPOSED ORDER extending deadline to complete joint site inspection filed by California Check Cashing Stores, LLC. No further extensions will be granted. Signed by Judge Jon S. Tigar on March 2, 2018. (jstlc3, COURT STAFF) (Filed on 3/2/2018)
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ANTHONY J. DECRISTOFORO, SBN 166171
anthony.decristoforo@ogletree.com
PAUL M. SMITH, SBN 306644
paul.smith@ogletree.com
OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
Esquire Plaza
1215 K Street 17th Floor
Sacramento, CA 95814
Telephone:
916.840.3150
Facsimile:
916.840.3159
Attorneys for Defendants CALIFORNIA
CHECK CASHING STORES, LLC
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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FRANCISCA MORALEZ
Plaintiff,
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Case No. 3:17-CV-06141-JST
v.
CALIFORNIA CHECK CASHING STORES,
LLC dba CALIFORNIA CHECK CASHING;
GENIRBERG FAMILY, LLC, dba THE
GENIRBERG FAMILY LIMITED
PARTNERSHIP,
THIRD STIPULATION TO EXTEND
DEADLINE TO COMPLETE JOINT SITE
INSPECTION REQUIRED BY GENERAL
ORDER 56; [PROPOSED] ORDER
Complaint Filed: October 26, 2017
Trial Date:
None Set
Defendants.
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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:
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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
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of the Americans with Disabilities Act (“ADA”) and parallel California law. Plaintiff seeks
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33160490_1.docx
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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 access
matters.
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Case No. 4:17-CV-06141-JST
THIRD STIPULATION TO EXTEND DEADLINE TO COMPLETE JOINT SITE INSPECTION REQUIRED BY GENERAL ORDER 56;
[PROPOSED] ORDER
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The Court has ordered that the Parties conduct a joint site inspection of the subject
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property on or before February 8, 2018 (Dkt. 4); thereafter, the Parties requested an extension
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and were given until February 13, 2018 (Dkt. 19); thereafter, the Parties requested a second
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extension and were given until March 2, 2018 (Dkt. 21).
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3.
The Parties are engaging in settlement discussions and wish to avoid incurring
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additional attorney’s fees and costs incident to attending the joint site inspection while
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settlement efforts are being exhausted. The Plaintiff and the landlord defendant (Genirberg
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Family, LLC) have tentatively reached a resolution.
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4.
The Parties have agreed to conduct the joint site inspection on March 16, 2018 at
10:30 a.m. unless a settlement is reached prior to that date.
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Accordingly, the Parties stipulate to extend the deadline to conduct the joint site
inspection to March 16, 2018.
IT IS SO STIPULATED.
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DATED: March 1, 2018
MISSION LAW FIRM, A.P.C.
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By: /s/ Zachary M. Best
Zachary M. Best
Attorney for Plaintiff,
Francisca Moralez
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DATED: March 1, 2018
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OGLETREE, DEAKINS, NASH, SMOAK
& STEWART, P.C.
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By: /s/ Anthony J. DeCristoforo
Anthony J. DeCristoforo
Attorneys for Defendants CALIFORNIA
CHECK CASHING STORES, LLC
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33160490_1.docx
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DATED: March 1, 2018
FERBER LAW
By: /s/ James B. Wickersham
James B. Wickersham
Attorneys for Defendant,
Genirberg Family, LLC, dba The Genirberg
Family Limited Partnership
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Case No. 4:17-CV-06141-JST
THIRD STIPULATION TO EXTEND DEADLINE TO COMPLETE JOINT SITE INSPECTION REQUIRED BY GENERAL ORDER 56;
[PROPOSED] ORDER
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ATTESTATION
Concurrence in the filing of this document has been obtained from each of the individual(s)
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whose electronic signature is attributed above.
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DATED: March 1, 2018
OGLETREE, DEAKINS, NASH, SMOAK
& STEWART, P.C.
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By: /s/ Anthony J. DeCristoforo
Anthony J. DeCristoforo
Attorneys for Defendants CALIFORNIA
CHECK CASHING STORES, LLC
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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 March 16, 2018, with all dates triggered by that deadline continued
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accordingly.
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No further extensions will be granted.
IT IS SO ORDERED.
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March 2, 2018
Dated: ________________
United States District Judge
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33160490.1
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33160490_1.docx
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Case No. 4:17-CV-06141-JST
THIRD STIPULATION TO EXTEND DEADLINE TO COMPLETE JOINT SITE INSPECTION REQUIRED BY GENERAL ORDER 56;
[PROPOSED] ORDER
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