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

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.
STIPULATION TO CONTINUE DEADLINE FOR JOINT SITE INSPECTION; [PROPOSED] ORDER

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2. The Court has ordered that the Parties conduct a joint site inspection of the 

subject property on or before May 25, 2017 (Dkt. 4). 

3. Counsel for Defendants is unavailable to conduct the joint site inspection prior to 

the May 25, 2017 deadline.

4. The Parties and their counsel have agreed to conduct the joint site inspection on 

June 20, 2017 at 11:00 a.m.

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

inspection, to June 20, 2017. 

IT IS SO STIPULATED.

Dated: April 26, 2017 MISSION LAW FIRM, A.P.C.

/s/ Zachary M. Best 

Zachary M. Best

Attorneys for Plaintiff,

Jose Trujillo

Dated: April 26, 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
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 June 20, 2017, with all dates triggered by that deadline continued 

accordingly.

IT IS SO ORDERED.

Dated: 

United States District Judge 

April 26, 2017