Moralez v. California Check Cashing Stores, LLC et al

Filing 29

STIPULATION AND ORDER re 28 JOINT STIPULATION TO EXTEND DEADLINE TO COMPLETE COURT ORDERED MEDIATION REQUIRED BY GENERAL ORDER 56; filed by California Check Cashing Stores, LLC. Signed by Judge Jon S. Tigar on July 12, 2018. (wsn, COURT STAFF) (Filed on 7/12/2018)

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ANTHONY J. DECRISTOFORO SBN 166171
[e-mail]
PAUL M. SMITH, SBN 306644
[e-mail]
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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v.

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CALIFORNIA CHECK CASHING STORES,
LLC dba CALIFORNIA CHECK CASHING;
GENIRBERG FAMILY, LLC, dba THE
GENIRBERG FAMILY LIMITED
PARTNERSHIP,
Defendants.

Case No. 3:17-CV-06141-JST
JOINT STIPULATION TO EXTEND
DEADLINE TO COMPLETE COURT
ORDERED MEDIATION REQUIRED BY
GENERAL ORDER 56; [PROPOSED]
ORDER
Complaint Filed: October 26, 2017
Trial Date:
None Set

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

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Stores, LLC (“Defendant,” and together with Plaintiff, “the Parties”),1 by and through their

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respective counsel, hereby stipulate as follows:
1.

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

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access to its public accommodation on account of her disabilities in violation of Title III of the

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

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relief under federal and California law, as well as damages under California law. This matter

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therefore proceeds under this district’s General Order 56 which governs ADA access matters.

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34795901_1.docx

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A Stipulation for Dismissal of the other Defendant, Genirberg Family, LLC, dba The Genirberg Family Limited
Partnership, was filed on March 27, 2018. (Dkt. 24.)

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Case No. 4:17-CV-06141-JST

JOINT STIPULATION TO EXTEND DEADLINE TO COMPLETE COURT ORDERED MEDIATION REQUIRED BY GENERAL ORDER 56; [PROPOSED] ORDER

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Pursuant to this district’s General Order 56, the Parties conducted a joint site

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inspection of the subject property on March 16, 2018. The case was then referred to mediation on

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April 13, 2018. This Court ordered the Parties to conduct mediation on or before July 12, 2018

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(Dkt. 25), assigning the matter to Mediator Kari Levine on May 23, 2018. Dkt. 26.

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3.

Despite their best efforts to find a mutually convenient date for mediation prior to

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the July 12, 2018 deadline, there were no dates prior to that date on which all of the parties and

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their respective counsel of record were available.

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calendars, and have circulated many potential dates for the mediation. The first date on which all
of the parties, their counsel and the mediator are available for mediation is September 11, 2018.

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The parties and mediator have performed an exhaustive review of their respective

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Accordingly, the Parties stipulate to extend the deadline to conduct mediation to

September 11, 2018.

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IT IS SO STIPULATED.

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DATED: July 11, 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: July 11, 2018

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

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By: /s/ Anthony J. DeCristoforo
Anthony J. DeCristoforo
Paul M. Smith
Attorneys for Defendant CALIFORNIA
CHECK CASHING STORES, LLC

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34795901_1.docx

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Case No. 4:17-CV-06141-JST

JOINT STIPULATION TO EXTEND DEADLINE TO COMPLETE COURT ORDERED MEDIATION 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: July 11, 2018

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

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By: /s/ Anthony J. DeCristoforo
Anthony J. DeCristoforo
Paul M. Smith
Attorneys for Defendants CALIFORNIA
CHECK CASHING STORES, LLC

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34795901_1.docx

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Case No. 4:17-CV-06141-JST

JOINT STIPULATION TO EXTEND DEADLINE TO COMPLETE COURT ORDERED MEDIATION REQUIRED BY GENERAL ORDER 56; [PROPOSED] ORDER

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PROPOSED] ORDER
The Parties having so stipulated and good cause appearing,
IT IS HEREBY ORDERED that the deadline for the Parties to conduct mediation is
extended to September 11, 2018, with all dates triggered by that deadline continued accordingly.

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IT IS SO ORDERED.

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July 12, 2018
Dated: ________________
United States District Judge

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34795901.1

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34795901_1.docx

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Case No. 4:17-CV-06141-JST

JOINT STIPULATION TO EXTEND DEADLINE TO COMPLETE COURT ORDERED MEDIATION REQUIRED BY GENERAL ORDER 56; [PROPOSED] ORDER