SECOND STIPULATION TO EXTEND TIME FOR DEFENDANTS TO RESPOND TO PLAINTIFF'S COMPLAINT

THELTON E. HENDERSON, District Judge.

IT IS HEREBY STIPULATED AND AGREED by and between plaintiff Francisca Moralez ("Plaintiff") and defendants Joe's Union L.P.; The Riviera LLC; James A. Maciel, Jr.; Gregory A. Maciel; Barry Maciel; Peter R. Johnson; Gail A. Gavello; Charlene Marie Ozawa; and Georgia Vierra ("Defendants") (collectively, the "Parties"), by and through their respective attorneys of record, as follows:

WHEREAS, on November 1, 2016, Plaintiff filed her Complaint in the United States District Court, Northern District of California, Case Number 3:16-cv-06345, alleging three causes of action, including violations of the Americans With Disabilities Act of 1990; Unruh Act; and Denial of Full and Equal Access to Public Facilities;

WHEREAS, the Parties previously stipulated to a 30-day extension of the deadline for Defendants to file and serve their responsive pleading, which extended such deadline to December 28, 2016, while the Parties explored early resolution of the matter before Defendants spent the necessary time and resources preparing and filing a responsive pleading;

WHEREAS, the Parties are currently in the end-stages of settlement negotiations that, if successful, will resolve this matter in its entirety;

WHEREAS, Plaintiff and Defendants have stipulated to a second 30-day extension of the deadline for Defendants to file and serve their responsive pleading, which extends such deadline to January 30, 2017, to allow the Parties to continue to negotiate for resolution of the matter in its entirety and prepare and execute settlement documents;

WHEREAS, this extension will not alter the date of any event or deadline already fixed by Court order and is made pursuant to Local Rule 6-1(a); and

WHEREAS, the Parties agree that this Stipulation and the extension of time for Defendants to respond to the Complaint shall be without prejudice to any claims, defenses or rights that any party may have regarding the Complaint or any other matter in this action.

THEREFORE, the Parties hereby stipulate that the deadline for Defendants to file and serve their responsive pleading to Plaintiff's Complaint shall be continued to January 30, 2017.

IT IS SO STIPULATED.

Certification Pursuant to Local Rule 5-1(i)(3)

Pursuant to Local Rule 5-1(i)(3), I, Amber L. Roller, do attest that all signatories listed, and on whose behalf the filing is submitted, concur in the filing's content and have authorized the filing.