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(30112.00001) #774325.2 

 JOINT STIPULATION TO CONTINUE INSPECTION CASE 4:17-CV-00636 

MARK A. DELGADO, #215618

mdelgado@donahue.com 

DONAHUE FITZGERALD LLP 

Attorneys at Law 

1999 Harrison Street, 25th Floor 

Oakland, California 94612-3520 

Telephone: (510) 451-3300 

Facsimile: (510) 451-1527 

Attorneys for Defendants 

HI-SUK T. DONG and SANJU 

DONG 

ZACHARY M. BEST, #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 

ALBERT DYTCH 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO 

ALBERT DYTCH, 

Plaintiff, 

v. 

HI-SUK T. DONG, individually and dba 

MUA OAKLAND BAR & 

RESTAURANT; SANJU DONG, an 

individual and dba MUA OAKLAND BAR 

& RESTAURANT; 

Defendants. 

Case No. 4:17-CV-00636 WHA

STIPULATION AND [PROPOSED] 

ORDER CONTINUING DEADLINE TO 

CONDUCT JOINT INSPECTION OF 

PREMISES 

On February 10, 2017, the Court filed and entered its Scheduling Order for Cases 

Asserting Denial of Right of Access Under Americans with Disabilities Act Title II & III 

(“Order”). Pursuant to the Order, the parties’ deadline to hold a joint inspection of premises in 

accordance with General Order No. 56 is currently May 24, 2017. 

WHEREAS, the parties have been, and continue to be, engaged in discussions regarding 

availability for a joint site inspection; and 

Order re:
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(30112.00001) #774325.2 -2-

 JOINT STIPULATION TO CONTINUE INSPECTION CASE NO. 4:16-CV-05413 

WHEREAS, both Defendants are unavailable to attend an inspection in the month of April 

due to international travel for a family engagement; and 

WHEREAS, Counsel for Defendants is not available to attend an inspection from May 5th

through May 20, 2017, due to preplanned international travel; and 

WHEREAS, Defendants' certified access specialist is unavailable to attend an inspection 

from May 1st through May 28, 2017, due to preplanned travel; and 

WHEREAS, the parties have agreed on a site inspection date of June 2, 2017, at 3:00 

p.m.; and 

WHEREAS, the parties and their counsel have agreed to extend the deadline to conduct 

the Joint Site Inspection to June 12, 2017. 

THEREFORE, the parties hereby request that the Court continue the deadline to complete 

inspection of the premises in this matter to June 12, 2017. 

IT IS SO STIPULATED. 

Dated: April 17, 2017 DONAHUE FITZGERALD LLP 

By: /s/ Mark A. Delgado 

Mark A. Delgado 

Attorneys for Defendants 

HI-SUK T. DONG and SANJU DONG 

Dated: April 17, 2017 MISSION LAW FIRM, A.P.C. 

By: /s/ Zachary M. Best 

Zachary M. Best 

Attorneys for Plaintiff 

ALBERT DYTCH 

 

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(30112.00001) #774325.2 -3-

 JOINT STIPULATION TO CONTINUE INSPECTION CASE NO. 4:16-CV-05413 

ORDER 

 Pursuant to the Stipulation of the parties, and for good cause, the Court hereby continues 

the deadline to complete inspection of premises to June 12, 2017. 

 IT IS SO ORDERED. 

Dated: __________________ _________________________________________ 

 HONORABLE WILLIAM H. ALSUP 

 UNITED STATES DISTRICT JUDGE 

April 18, 2017. Order re: