D.W. et al v. Vasona Management, Inc. et al

Filing 32

STIPULATION AND ORDER re 31 STIPULATION WITH PROPOSED ORDER FOR LEAVE TO FILE SECOND AMENDED COMPLAINT filed by Shamon Blue, D.W. Signed by Judge Jon S. Tigar on March 22, 2019. (wsn, COURT STAFF) (Filed on 3/22/2019)

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ALLACCESS LAW GROUP
Irene Karbelashvili, State Bar Number 232223
[e-mail]
Irakli Karbelashvili, State Bar Number 302971
[e-mail]
19 North Second Street, Suite 205
San Jose, CA 95113
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for D.W. and SHAMON BLUE, Plaintiffs

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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D.W., a minor, et al.
Plaintiffs,

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Case No. 4:18-cv-00195-JST
STIPULATION AND [PROPOSED]
ORDER FOR LEAVE TO FILE SECOND
AMENDED COMPLAINT

vs.

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VASONA MANAGEMENT, INC., a
California corporation et al.
Defendants

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STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE SECOND AMENDED
COMPLAINT
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IT IS HEREBY STIPULATED, BY AND BETWEEN PLAINTIFFS D.W. and

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SHAMON BLUE (collectively, “Plaintiffs”) and Defendants VASONA MANAGEMENT, INC.,

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a California corporation and CATALINA CREST, LLC, a California limited liability company

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(collectively, “Defendants”), through their counsel of record, that Plaintiffs may file a Second

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Amended Complaint in order to add additional alleged accessibility barriers identified by

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Plaintiffs’ expert at the General Order 56 inspection and subsequent alleged incidents of

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discrimination.

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A True and correct copy of the proposed Second Amended Complaint with the
substantive changes highlighted is attached hereto as Exhibit “A”.

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Respectfully submitted,

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Dated: March 19, 2019

/s/ Irakli Karbelashvili
By Irakli Karbelashvili, Attorney for Plaintiffs
D.W. and SHAMON BLUE

Dated: March 21, 2019

/s/ Ronnie Shou
By Ronnie Shou, Attorney for Defendants
VASONA MANAGEMENT, INC., a California
corporation and CATALINA CREST, LLC

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Filer’s Attestation

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I, Irakli Karbelashvili, attest that I received concurrence from Defendants’ counsel in
the filing of this document.
/s/ Irakli Karbelashvili
By Irakli Karbelashvili

_____

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STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE SECOND AMENDED
COMPLAINT
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[PROPOSED] ORDER
Based upon the foregoing Stipulation and good cause appearing, IT IS SO ORDERED.
Plaintiffs shall file the Second Amended Complaint as a separate docket entry.

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IT IS SO ORDERED.

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Dated: March 22, 2019

__________________________
United States District Judge

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STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE SECOND AMENDED
COMPLAINT
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