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1

STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

MARIA M. LAMPASONA, SBN 259675

lampasona@rankinlaw.com

DAMON M. THURSTON, SBN 186861

thurston@rankinlaw.com

RANKIN, SHUEY, RANUCCI, MINTZ, 

LAMPASONA & REYNOLDS 

2030 Franklin Street, Sixth Floor

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 and PRISCILLA 

NEVAREZ, et al., 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 

CLASS ACTION 

STIPULATION AND ORDER 

REGARDING EXTENSION OF TIME FOR 

INJUNCTIVE RELIEF STADIUM 

REMEDIATION DEADLINES 

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

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, at the time the Parties negotiated the settlement, the Forty Niners agreed to 

the original remediation schedule as it related to construction-related remediation efforts at Levi’s 

Stadium and its adjacent parking lot based, in part, on the expectation that the Forty Niners could 

meet the deadlines therein by performing the majority of the stadium remediation work in the first

half of each year leading up to the end of the compliance period as most remediation could not be 

undertaken during the second half of each year because construction would interfere with access 

during events at the stadium (e.g., reconstructing the parking lot where all accessible parking is 

located, remediating slopes in multiple bowl seating areas, reconstructing bars throughout the 

stadium, etc.); 

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, resulting in the Forty Niners’ requesting an extension of time to complete the 

remediation, to which Plaintiffs stipulated, and the Court granted [ECF 439];

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

WHEREAS, the above-mentioned circumstances have continued to present a situation 

where a second extension of time is necessary for the Forty Niners to perform remediation work 

at Levi’s Stadium; 

WHEREAS, this stipulation does not include an extension of time for Santa Clara to 

perform remediation in the pedestrian rights of way, as such stipulation or motion on behalf of 

Santa Clara will be submitted separately for the Court’s consideration; and

WHEREAS, prior to entering into this stipulation, the Forty Niners and Plaintiffs’ 

counsel met and conferred a number of times regarding this requested second extension, and the 

Parties agreed to the following conditions related to entering into this stipulation:

a. The Forty Niners will attend quarterly meetings with Class Counsel and

mutually agreed-upon access specialist Gary Waters to discuss remediation

progress, and Forty Niners’ counsel and Mr. Waters will confer with Class

Counsel in between the quarterly meetings upon Class Counsel’s request;

b. Prior to the quarterly meetings, the Forty Niners will provide a written

remediation update to use in conjunction with these quarterly meetings;

c. The Forty Niners will remediate hook placement, phone placement, and other

non-structural remediation in suites (not including furniture replacement due

to long lead times as acknowledged by Plaintiffs) in accordance with the

previously-agreed upon and approved schedule; and

d. The Forty Niners do not expect to request an additional extension, however,

nothing will prevent the Forty Niners from seeking an extension from the

Court, be it by stipulation or motion, should extraordinary and unanticipated

circumstances arise. Plaintiffs’ counsel have informed counsel for the Forty

Niners that they will not stipulate to any further extensions of the injunctive

relief deadlines.

NOW, THEREFORE, IT IS HEREBY STIPULATED as follows:

Subject to the Court’s approval, the Parties agree to extend the following deadlines related 

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

to remediation work to be performed at Levi’s Stadium and its adjacent parking lot as follows:

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

Item Orig.

Date

Current 

Date

Extension 

Date Per 

This Stip

NEW 

DATE

Progress Made

1 Parking Lots: 

provide 282 

handicapped 

parking spaces in 

the Main Lot 

Agreement, 

Section III.A.3.a. 

NOTE: Section 

references below 

are to the 

sections in the 

Agreement

1/23/21 7/23/22 7/23/23 The Construction Drawings 

Permit Submittal has been 

in review at the City of 

Santa Clara since May of 

21. BKF Engineers, the civil

engineering firm, continues

to work with the City of

Santa Clara to resolve all

permitting questions and

comments. Multiple

meetings have been held,

with the most recent

meeting occurring on

6/23/22; the 4threview and

comment session with the

City to date.

2 Handrail 

Extensions (III. 

A. 1. n)

1/23/21 7/23/22 7/23/23 The required handrail 

extension improvements are 

included in construction 

drawings performed by 

HOK Architects. The 

Contractor will submit this 

package for permit during 

the week of 7/5/22. 

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6

STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

3 Dignity Health 

First Aid (Level 

300/Main 

Concourse): 

removal of 

obstructions, 

creation of clear 

spaces, toilet 

paper dispensers 

per Exhibit A 

(III.A.1.o)

1/23/21 7/23/22 7/23/23 Six (6) of the twelve (12) 

items listed on Exhibit A 

have been addressed and 

closed by Gary Waters 

(CASp). 

Many other items have been 

addressed but have not yet 

been inspected and 

approved by Gary Waters. 

They are anticipated to be 

inspected by Gary Waters 

on 7/11/22. Five of the 

remaining six items are 

scheduled to be reviewed by 

Gary Waters on 7/11/22.

4 NRG Solar 

Terrace: provide 

accessible 

seating and 

companion 

seating at the 

NRG Solar 

Terrace bars and 

counters 

(III.A.1.q)

1/23/21 7/23/22 7/23/23 The required NRG Solar 

Terrace improvements are 

included in construction 

drawings performed by 

HOK Architects. The 

Contractor will submit this 

package for permit during 

the week of 7/5/22. 

5 Auditorium: 

provide 

accessible path 

of travel to the 

stage, accessible 

and companion 

seating in the 

back of the 

Auditorium 

(III.A.1.r)

1/23/21 7/23/22 7/23/23 The required Auditorium 

improvements are included 

in construction drawings 

performed by HOK 

Architects. The Contractor 

will submit this package for 

permit during the week of 

7/5/22.

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

6 Paths of Travel 

to the Stadium, 

per Exhibit A 

(III.A.1.a)

4/23/21 7/23/22 7/23/23 Many Path of Travel issues 

have been resolved, which 

include the majority of the 

door closing / opening 

issues, access to the 

platform at the Bud Light 

Deck, access to the raised 

platform at the Pepsi Deck. 

Other required Path of 

Travel improvements are 

included in construction 

drawings performed by 

HOK Architects. The 

Contractor will submit this 

package for permit during 

the week of 7/5/22. 

7 Entrances to the 

Stadium: provide 

an 8-foot path of 

travel connecting 

entrances to the 

Stadium, and a 

48-inch wide 

path of travel 

from the Main 

Parking Lot to 

Canopies, with 

signage, per 

Exhibit B 

(III.A.1.b)

4/23/21 7/23/22 7/23/23 Construction Drawing 

Permit Submittal is still in 

review at the City of Santa 

Clara. BKF Engineers 

continue to work with the 

City to resolve all 

permitting questions and 

comments. Multiple 

meetings have been held, 

with the most recent 

meeting occurring on 

8 Stadium Box 

Office: provide 

access to 

designated box 

office ticket 

window, remove 

foot bar at that 

window, provide 

signage 

designating 

accessible ticket 

window 

(III.A.1.c)

4/23/21 7/23/22 7/23/23 The required Stadium Box 

Office improvements are 

included in construction 

drawings performed by 

HOK Architects. The 

Contractor will submit this 

package for permit during 

the week of 7/5/22.

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

9 Signage: provide 

signage 

throughout the 

Stadium 

identifying 

accessible paths 

of travel, 

elevators. Forty 

Niners to 

provide a copy 

of the signage 

plan to 

Plaintiffs’ 

counsel at least 

30 days prior to 

implementation 

of the plan. At 

plaintiffs’ 

request, the 

parties will meet 

and confer 

concerning the 

plan. (III.A.1.d)

4/23/21 7/23/22 7/23/23 The required Signage 

improvements are included 

in construction drawings 

performed by HOK 

Architects. This design 

package is pending Gary 

Waters’ final letter of 

conformance. The 

Contractor is pricing this 

design package and will 

provide an updated cost and 

schedule in July, 22

following their 

Constructability and Pricing 

review. 

10 Interior 

Circulation: 

Create accessible 

interior path of 

travel from Gate 

A and Gate C to 

Gate F, 

remediate ramps 

per Exhibit D 

(III.A.1.e)

4/23/21 7/23/22 7/23/23 The Contractor surveyed the 

path of travel and 

established a plan to 

remediate the existing 

conditions. The Contractor 

is presenting the proposed 

Path of Travel and 

necessary remediation with 

the Gary Waters 7/11/22 to 

gain concurrence the plan 

and scope of work to 

remediate the existing 

conditions.

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

11 Restrooms: 

provide signage, 

remove video 

displays, ensure 

counters and 

mirrors and stall 

doors comply 

with specs in 

Exhibit A 

(III.A.1.i)

7/23/21 4/23/22 4/23/23 Approximately 250 items in 

the restrooms have been 

corrected and approved by 

Gary Waters. These items 

include removal of 

obstructions, correcting the 

accessible toilet 

compartments. The 

Architect completed this 

Construction Drawing 

package for many of the 

other items, which was 

submitted by the Contractor 

to the City of Santa Clara on 

5/12/22 for permit approval. 

The design package is still 

in permit review.

12 Drinking 

Fountains: bring 

up to current 

accessibility 

standards per 

Exhibit A 

(III.A.1.j)

7/23/21 4/23/22 4/23/23 The Contractor adjusted the 

existing drinking fountains, 

but the review and approval 

from Gary Waters is 

required before the work 

can be considered complete.

13 Concessions: 

remediate 

conditions 

identified in 

Exhibit A, 

ensure that 

owners/operators 

do so (III.A.1.k)

7/23/21 4/23/22 4/23/23 Many of the items have 

been completed, such as 

removal of concession 

queue lines that were 

stenciled with decals on the 

floor and trash can 

obstructions. Other items, 

such as counter heights and 

condiment stations, are 

included in the Architect’s 

design package.

The Architect completed 

this Construction Drawing 

package for many of the 

other items, which was 

submitted by the Contractor 

to the City of Santa Clara on 

5/12/22 for permit approval. 

The design package is still 

in permit review.

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

14 Counters and 

Bars: provide 

lowered, 

accessible 

sections in 

designated Clubs 

and Terraces per 

Exhibit G 

(III.A.1.h)

10/23/21 7/23/22 7/23/23 The required Counter and 

Bar improvements are 

included in construction 

drawings performed by 

HOK Architects. The 

Contractor will submit this 

package for permit during 

the week of 7/5/22.. 

16 Stadium 

Restaurants: 

Within 15 

months after the 

Effective Date, 

or 9 months after 

February 15, 21, 

whichever is 

later, the Forty 

Niners are to 

have completed 

the access work 

for the Stadium’s 

Restaurants 

specified in 

Exhibit A. The 

remedial work 

for Bourbon 

Steak (clearing a 

path of travel 

next to the 

kitchen to the 

elevator) is 

specified in the 

Agreement 

(III.A.2)

11/15/21 5/15/22 5/15/23 The Architect has 

completed this Construction 

Drawing package, but one 

issue in the package is still 

in review with Gary Waters 

before we gain his 

concurrence. The Contractor 

has been directed to review 

the package and provide a 

price proposal. 

Some of the items in this 

spaces, specifically 

associated with the Loft 

Spaces, have been closed.

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

17 Seating: 

remediate all 

non-compliant 

conditions in 

designated 

accessible 

seating areas 

throughout the 

Stadium, per 

Exhibit E 

(III.A.1.f)

5/15/22 2/15/23 2/15/24 The Architect has 

completed the design 

package for a significant 

amount of this design 

package. We anticipate that 

a majority is expected to be 

complete by early 23. The 

Contractor has evaluated the 

floor drain slopes and 

grades and will review and 

propose remediation efforts 

with a scheduled walk 

through with Gary Waters 

on 7/11/22. 

18 Drink rails 

(Phase 1): 

remediate 50% 

of the drink rails 

in the Stadium 

per Exhibit F 

(III.A.1.g) within 

15 months after 

the Effective 

Date or by 

February 15, 21, 

whichever is 

later, 

10/23/21 7/23/22 7/23/23 The required Drink Rail 

improvements are included 

in construction drawings 

performed by HOK 

Architects. The Contractor 

will submit this package for 

permit during the week of 

7/5/22.

19 Drink rails 

(Phase 2): the 

remaining 50% 

of the drink rails 

to be remediated 

by 15 months 

after February 

15, 22

5/15/22 7/23/23 7/23/24 The required Drink Rail 

improvements are included 

in construction drawings 

performed by HOK 

Architects. The Contractor 

will submit this package for 

permit during the week of 

7/5/22. 

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

20 Shops: by this 

date, the Forty 

Niners are to 

have ensured 

that the owners 

and operators of 

Stadium shops 

have completed 

the remediation 

work identified 

in Exhibit A 

(III.A.1.m)

1/23/22 7/23/22 7/23/23 The required Shops 

improvements are included 

in construction drawings 

performed by HOK 

Architects. The Contractor 

will submit this package for 

permit during the week of 

7/5/22. 

21 Stadium Stairs: 

within 24 

months after the 

Effective Date, 

or November 15, 

22, whichever is 

later, the Forty 

Niners are to 

have remediated 

the stairs at Gate 

A and Gate C, 

within the 

United Club and 

the interior stairs 

at Toyota Gate 

F, and 

throughout the 

outdoor seating 

areas within the 

Stadium to 

ensure that the 

nosings of the 

stair treads 

comply with 

ADAS section 

504.5, and that 

the slopes of the 

risers do not 

exceed 1:48 

(2.1%) 

(III.A.1.s)

11/15/22 5/15/23 5/15/24 The required Stadium Stair 

improvements are included 

in construction drawings 

performed by HOK 

Architects. The Contractor 

will submit this package for 

permit during the week of 

7/5/22. 

We have completed three of 

twelve items associated with 

stairs.

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

22 Stadium Suites 

and Boxes –

Phase 1 

(III.A.1.l) (50% 

of Suites and 

Boxes) 

1/23/22 7/23/22 7/23/24 A full renovation of the 

suites are planned for 2024

and 2025. Gary Waters 

supports the plan to address 

the remediation of the 

Suites scheduled for 

renovation to be completed 

as part of the larger 

renovation plan.

For all other work 

associated with the suites, 

the architect (HOK) has 

included the improvements 

as part of a permit submittal 

design package. The 

Contractor will submit this 

package for permit by week 

of 7/5/22.

23 Stadium Suites 

and Boxes –

Phase 2 

(III.A.1.l) (50% 

of Suites and 

Boxes)

1/23/22 10/23/23 10/23/25 A full renovation of the 

suites are planned for 2024

and 2025. Gary Waters is 

supporting the plan to 

address the remediation of 

the Suites schedule for 

renovation to be completed 

as part of the larger 

renovation plan.

For all other work 

associated with the suites, 

the architect (HOK) has 

included the improvements 

as part of a permit submittal 

design package. The 

Contractor will submit this 

package for permit by week 

of 7/5/22.

/ / /

/ / /

/ / /

/ / /

Case 4:16-cv-07013-HSG Document 479 Filed 07/26/22 Page 13 of 14
RANKIN, SHUEY, RANUCCI, MINTZ,

LAMPASONA & REYNOLDS

2 0 3 0 F r a n k l i n St r e e t, S ix t h F l o o r

O a k l a n d , C A 9 4 6 1 2

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STIP & ORDER RE: INJUNCTIVE 

RELIEF DEADLINES 

NO. 4:16-CV-07013-HSG 

IT IS SO STIPULATED.

Dated: July 25, 2022 Respectfully submitted,

PEIFFER WOLF CARR KANE & CONWAY 

/s/ Catherine M. Cabalo

Catherine M. Cabalo

Attorneys for Plaintiffs and the Certified Classes

Dated: July 25, 2022 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: July 25, 2022 /s/ Maria Lampasona

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: 7/26/2022

Hon. Haywood S. Gilliam, Jr. 

United States District Judge

Case 4:16-cv-07013-HSG Document 479 Filed 07/26/22 Page 14 of 14