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STIP & ORDER RE: INJUNCTIVE RELIEF 

DEADLINES (CITY) 

NO. 4:16-CV-07013-HSG 

MARIA M. LAMPASONA, SBN 259675

lampasona@rankinlaw.com

DAMON M. THURSTON, SBN 186861

thurston@rankinlaw.com

RANKIN, SHUEY, MINTZ, 

LAMPASONA & HARPER

475 14th Street, Suite 650 

Oakland, CA 94612

Telephone Number: (510) 433-2600

Facsimile Numbers: (510) 433-2699 and (510) 452-3006

Attorneys for Defendants FORTY NINERS FOOTBALL 

COMPANY LLC, FORTY NINERS SC STADIUM 

COMPANY LLC, FORTY NINERS STADIUM 

MANAGEMENT COMPANY LLC, CITY OF SANTA 

CLARA and SANTA CLARA STADIUM AUTHORITY

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN JOSE DIVISION

ABDUL NEVAREZ, PRISCILLA 

NEVAREZ, and SEBASTIAN 

DEFRANCESCO, on behalf of 

themselves and all others similarly 

situated, 

Plaintiffs,

v.

FORTY NINERS FOOTBALL 

COMPANY, LLC, a Delaware limited 

liability company; FORTY NINERS SC 

STADIUM COMPANY, LLC, a 

Delaware limited liability company; 

NATIONAL FOOTBALL LEAGUE; 

CITY OF SANTA CLARA; SANTA 

CLARA STADIUM AUTHORITY; 

TICKETMASTER ENTERTAINMENT, 

INC.; FORTY NINERS STADIUM 

MANAGEMENT COMPANY LLC; and 

DOES 1-10, Inclusive,

Defendants.

Case No. 4:16-cv-07013-HSG 

STIPULATION AND ORDER REGARDING 

EXTENSION OF TIME FOR INJUNCTIVE 

RELIEF FOR CITY OF SANTA CLARA 

PEDESTRIAN RIGHTS OF WAY 

REMEDIATION 

/ / /

/ / /

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STIP & ORDER RE: INJUNCTIVE RELIEF 

DEADLINES (CITY) 

NO. 4:16-CV-07013-HSG 

THIS STIPULATION is hereby entered into by and between Plaintiffs Abdul Nevarez, 

Priscilla Nevarez, and Plaintiff Sebastian DeFrancesco on behalf of themselves and all others 

similarly situated (collectively, “Plaintiffs”), and Defendants Forty Niners Football Company 

LLC, Forty Niners SC Stadium Company LLC, Forty Niners Stadium Management Company 

LLC (collectively, the “Forty Niners”), the City of Santa Clara, and the Santa Clara Stadium 

Authority (collectively, “Santa Clara,” and with Plaintiffs and the Forty Niners, the “Parties”), by 

and through their respective counsel of record, as follows:

WHEREAS, on July 23, 2020, this Court issued an order granting final approval of the 

settlement in this case [ECF 416] in which the Court directed the parties to implement the 

settlement according to its terms and provisions;

WHEREAS, the settlement agreement [ECF 375-2] specifies certain injunctive relief to 

be undertaken by the Defendants in connection with remediation of alleged access barriers at 

Levi’s Stadium, its parking lots, and certain pedestrian rights of way; 

WHEREAS, the COVID-19 pandemic has had a significant impact on all aspects of 

normal business across all spectrums, including construction, material sourcing, public entity 

planning and review, and employee absenteeism, and other construction and permitting 

challenges arose; 

WHEREAS, Santa Clara has not previously requested an extension of time to perform 

remediation in the pedestrian rights of way; and

WHEREAS, prior to entering into this stipulation, Santa Clara and Plaintiffs’ counsel met 

and conferred regarding this requested extension, and the parties agreed that Plaintiffs will not 

agree to a further extension and Santa Clara does not expect to request an additional extension.

NOW, THEREFORE, IT IS HEREBY STIPULATED as follows:

Subject to the Court’s approval, the Parties agree the deadline related to remediation work 

to be performed by Santa Clara in the pedestrian rights of way as identified on Exhibit I [ECF 

375-14] is extended to January 24, 2024.

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STIP & ORDER RE: INJUNCTIVE RELIEF 

DEADLINES (CITY) 

NO. 4:16-CV-07013-HSG 

IT IS SO STIPULATED.

Dated: May 30, 2023 Respectfully submitted,

PEIFFER WOLF CARR KANE & CONWAY 

/s/ Catherine M. Cabalo

Catherine M. Cabalo

Attorneys for Plaintiffs and the Certified Classes

Dated: May 30, 2023 RANKIN, SHUEY, RANUCCI, MINTZ, 

LAMPASONA & REYNOLDS

/s/ Maria M. Lampasona

Maria M. Lampasona

Attorneys for Defendants

FORTY NINERS FOOTBALL COMPANY LLC, 

FORTY NINERS SC STADIUM COMPANY LLC, 

FORTY NINERS STADIUM MANAGEMENT 

COMPANY LLC CITY OF SANTA CLARA, 

SANTA CLARA STADIUM AUTHORITY

SIGNATURE ATTESTATION

The e-filing attorney hereby attests that concurrence in the content of the document and 

authorization to file the document has been obtained from each of the other signatories indicated 

by a conformed signature (/s/) within this e-file document.

Dated: May 30, 2023 /s/ Maria Lampasona

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STIP & ORDER RE: INJUNCTIVE RELIEF 

DEADLINES (CITY) 

NO. 4:16-CV-07013-HSG 

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: 6/5/2023

Hon. Haywood S. Gilliam, Jr. 

United States District Judge

Case 4:16-cv-07013-HSG Document 483 Filed 06/05/23 Page 4 of 4