SECOND STIPULATION TO CONTINUE DEADLINE FOR JOINT SITE INSPECTION; 

[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

Attorneys 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

SECOND STIPULATION TO EXTEND 

DEADLINE TO COMPLETE JOINT SITE 

INSPECTION REQUIRED BY GENERAL 

ORDER 56; [PROPOSED] ORDER

Plaintiff, 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 dated February 2, 2001; Julienne Lemoine; and James M. Lemoine

(collectively “Defendants,” and together with Plaintiff, “the Parties”), by and through their 

respective counsel, hereby stipulate as follows:

1. This action arises out of Plaintiff’s claims that Defendants denied her full and 

equal access to their public accommodation on account of her disability in violation of Title III 

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

injunctive relief under federal and California law, as well as damages under California law. 

This matter therefore proceeds under this district’s General Order 56 which governs ADA 

access matters.
SECOND STIPULATION TO CONTINUE DEADLINE FOR JOINT SITE INSPECTION; 

[PROPOSED] ORDER

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2. The Parties previously stipulated, and the Court has ordered, that the Parties 

conduct a joint site inspection of the subject property on or before June 20, 2017 (Dkt. 22). 

3. The Parties have been working together cooperatively to seek an informal 

resolution of this matter. To this end, the Parties are circulating a draft settlement agreement, 

and are in the process of approving and/or revising the language of the agreement and coming 

to an agreement on the monetary terms of settlement.

4. The Parties wish additional time to finalize settlement without the need to 

conduct the joint site inspection, in order to minimize the additional expenditure of attorneys’ 

fees and costs.

5. The Parties have agreed to conduct the joint site inspection on July 12, 2017 at 

12:00 p.m. unless a settlement is reached prior to that date. 

6. Accordingly, the Parties stipulate to extend the deadline to conduct the joint site 

inspection to July 12, 2017. 

IT IS SO STIPULATED.

Dated: June 20, 2017 MISSION LAW FIRM, A.P.C.

/s/ Zachary M. Best 

Zachary M. Best

Attorneys for Plaintiff,

Jose Trujillo

Dated: June 20, 2017 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 dated February 2, 2001; Julienne Lemoine; 

and James M. Lemoine
SECOND STIPULATION TO CONTINUE DEADLINE FOR JOINT SITE INSPECTION; 

[PROPOSED] ORDER

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ORDER

The Parties having so stipulated and good cause appearing,

IT IS HEREBY ORDERED that the deadline for the Parties to complete the joint site 

inspection is extended to July 12, 2017, with all dates triggered by that deadline continued 

accordingly.

IT IS SO ORDERED.

Dated: 

United States District Judge 

The Court is unlikely to grant any further extensions. June 21, 2017