Tanya E. Moore, SBN 206683 K. Randolph Moore, SBN 106933 MOORE LAW FIRM, P.C., San Jose, California. Attorneys for Plaintiff ROBERT KALANI.
KRING & CHUNG, LLP, Shane Singh, Attorneys for Defendant, Starbucks Coffee Company.
JEFFER MANGELS BUTLER & MITCHELL LLP, Martin H. Orlick, Attorneys for Defendant, Brentina, LLC, a California limited liability Company.
STIPULATION CONTINUING LAST DATE TO MEET AND CONFER and TO FILE A NOTICE OF NEED FOR MEDIATION UNDER GENERAL ORDER 56; [PROPOSED] ORDER
LUCY H. KOH, District Judge.
Plaintiff, Robert Kalani ("Plaintiff"), and Defendants, Starbucks Coffee Company (erroneously sued herein as Starbucks Corporation, a Washington Corporation), and Brentina, LLC, a California limited liability company (collectively "Defendants, " and together with Plaintiff, "the Parties"), by and through their respective counsel, hereby stipulate as follows:
WHEREAS, this matter arises under Title III of the Americans with Disabilities Act of 1990, wherein Plaintiff alleges he encountered barriers to his full and equal access to the subject property, and is therefore procedurally governed by this Court's General Order 56;
WHEREAS, the Parties conducted a joint site inspection of the subject property on June 4, 2013, and therefore pursuant to the Court Scheduling Order and General Order 56, the Parties must meet and confer in person to discuss the barriers Plaintiff seeks to have removed from the subject property by July 2, 2013;
WHEREAS, since June 6, 2013, Plaintiff sought to coordinate such a date with Defendants, but it was not until June 17, 2013 that he received responses from Defendants;
WHEREAS, the first date the Parties are all able to participate in the in person meet and confer is July 19, 2013, which date is after the last date by which they are currently permitted to conduct the meet and confer;
WHEREAS, the last date to file a Notice of Need for Mediation should the Parties be unable to reach an agreement is 45 days after the site inspection took place, which date is July 16, 2013, a date prior to the date the Parties propose to meet and confer;
NOW, THEREFORE, the Parties hereby stipulate and agree as follows:
1. The in person meet and confer shall take place on July 19, 2013;
2. If a complete settlement is not reached prior, Plaintiff shall file his Notice of Need for ...