STIPULATION GRANTING PLAINTIFF LEAVE TO FILE FIRST AMENDED COMPLAINT; 

[PROPOSED] ORDER

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Zachary M. Best, SBN 166035 

MISSION LAW FIRM, A.P.C. 

332 North Second Street 

San Jose, California 95112 

Telephone (408) 298-2000 

Facsimile (408) 298-6046 

E-mail: service@mission.legal 

Attorney for Plaintiff 

Francisca Moralez

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

FRANCISCA MORALEZ,

Plaintiff,

vs.

LUZ PATRICIA NAVARRO dba CINCO DE 

MAYO RESTAURANT, et al.,

Defendants.

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No. 3:17-cv-00676-JST

STIPULATION GRANTING PLAINTIFF 

LEAVE TO FILE FIRST AMENDED 

COMPLAINT; [PROPOSED] ORDER

 IT IS HEREBY STIPULATED by and between Francisca Moralez (“Plaintiff”), and 

Defendants, Luz Patricia Navarro dba Cinco de Mayo Restaurant; Douglas W. Knight; 

Katherine K. Robbins, Trustee of the Katherine K. Robbins Trust; Julienne Lemoine; and 

James M. Lemoine (“Defendants,” and together with Plaintiff, “the Parties”), the parties 

hereto, through their respective attorneys of record, that Plaintiff may file a First Amended 

Complaint, a copy of which is attached hereto as Exhibit “A.” This amendment will not modify 

any date or deadline fixed by Court order, and is not prejudicial to Defendants, the product of 

undue delay, proposed in bad faith, or futile. 

IT IS FURTHER STIPULATED that Plaintiff will file her First Amended Complaint 

within five (5) calendar days of the Court’s Order permitting such filing, and that Defendants’ 
STIPULATION GRANTING PLAINTIFF LEAVE TO FILE FIRST AMENDED COMPLAINT; 

[PROPOSED] ORDER

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response thereto shall be filed within fourteen (14) days after the First Amended Complaint is 

filed. 

 IT IS SO STIPULATED.

Dated: March 8, 2018 MISSION LAW FIRM, A.P.C. 

 /s/ Zachary M. Best 

 Zachary M. Best 

 Attorneys for Plaintiff, 

 Francisca Moralez 

Dated: March 8, 2018 VAUGHAN & ASSOCIATES 

 /s/ Cris C. Vaughan 

 Cris C. Vaughan 

 Attorneys for Defendants 

 Luz Patricia Navarro dba Cinco de Mayo 

 Restaurant; Douglas W. Knight; Katherine K. 

 Robbins, Trustee of the Katherine K. Robbins 

 Trust; Julienne Lemoine; and James M. Lemoine 

ATTESTATION 

Concurrence in the filing of this document has been obtained from each of the individual(s) 

whose electronic signature is attributed above. 

 /s/ Zachary M. Best 

 Zachary M. Best 

 Attorneys for Plaintiff 

 Francisca Moralez 
STIPULATION GRANTING PLAINTIFF LEAVE TO FILE FIRST AMENDED COMPLAINT; 

[PROPOSED] ORDER

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ORDER 

 The Parties having so stipulated and good cause appearing, 

IT IS HEREBY ORDERED that Plaintiff shall file her First Amended Complaint, a 

copy of which was filed with the Parties’ stipulation, within five (5) calendar days of the date 

this Order is filed. 

IT IS FURTHER ORDERED that Defendants’ response thereto shall be filed within 

fourteen (14) days after the First Amended Complaint is filed. 

IT IS SO ORDERED.

Dated: 

 HON. JON S. TIGAR 

 United States District Judge 

March 12, 2018