STIPULATION TO CONTINUE DATES FOR DEFENDANTS' MOTION TO DISMISS AND OTHER DATES; ORDER

JOHN A. MENDEZ, District Judge.

IT IS HEREBY STIPULATED, by and between Defendants C.H. ROBINSON WORLDWIDE, INC. and C.H. ROBINSON COMPANY, INC. (collectively, "C.H. Robinson" or "Defendants"), and Plaintiff PATRICK COLIN ("Plaintiff"), by and through their attorneys, as follows:

WHEREAS, Plaintiff filed this action in Yolo County Superior Court on June 30, 2014. Plaintiff asserted causes of action against Defendants for declaratory relief and unfair competition, relating to several employment agreements that Plaintiff signed while employed by Defendants;

WHEREAS, Defendants removed this action to this Court on August 1, 2014;

WHEREAS, Defendants filed an action against Plaintiff and Patrick Colin, Jr. in Hennepin County District Court in Minnesota. Defendants asserted causes of action against Plaintiff for violation of Minnesota's Trade Secrets Act, breach of contract, breach of the duty of loyalty, and injunctive relief (the "Minnesota Action"), arising out of Plaintiff's former employment with Defendants;

WHEREAS, Defendants filed a motion to dismiss this action for forum non conveniens, or in the alternative, to transfer venue, on August 8, 2014;

WHEREAS, the Minnesota Action was removed to the United States District Court, District of Minnesota on August 12, 2014;

WHEREAS, the parties previously stipulated to, and the Court ordered continuance of various dates to allow the parties to mediate this matter;

WHEREAS, the parties participated in a mediation that resolved this case, and have agreed to dismissal of this action upon completion of certain actions scheduled to take place within the next month;

WHEREAS, the parties wish to stay the action and continue certain dates in this action to avoid the cost and expense of litigation so that the parties can complete the actions agreed upon for dismissal of this action;

IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff and Defendants, through their respective undersigned counsel, that:

1) the date of the hearing on Defendants' Motion to Dismiss for Forum Non Conveniens, or in the alternative, to Transfer Venue ("Motion to Dismiss"), should be continued from October 15, 2014 until November 5, 2014 at 9:30 a.m., or as soon thereafter as the matter may be heard.

2) Plaintiff's opposition to Defendants' Motion to Dismiss, if any, will be filed and served on October 17, 2014;

3) Defendants' reply brief in support of the Motion to Dismiss will be filed and served on October 24, 2014;

4) the Order Requiring Joint Status Report should be modified to state the following: "No later than November 21, 2014, the parties shall confer as required by Fed. R. Civ. P. 26(f) and shall prepare and submit to the Court a joint status report that includes the Rule 26(f) discovery plan."

IT IS SO STIPULATED.

ORDER

Based on Plaintiff PATRICK COLIN's and Defendants C.H. ROBINSON WORLDWIDE, INC. and C.H. ROBINSON COMPANY, INC.'s Stipulation to Continue Dates for Defendants' Motion to Dismiss and Other Dates, the Court orders the following:

1) The date of the hearing on Defendants' Motion to Dismiss for Forum Non Conveniens, or in the alternative, to Transfer Venue ("Motion to Dismiss"), should be continued from October 15, 2014 to November 5, 2014 at 9:30 a.m.;

2) Plaintiff's opposition to Defendants' Motion to Dismiss, if any, will be filed and served on October 17, 2014;

3) Defendants' reply brief in support of the Motion to Dismiss will be filed and served on October 24, 2014;

4) the Order Requiring Joint Status Report should be modified to state the following: "No later than November 21, 2014, the parties shall confer as required by Fed. R. Civ. P. 26(f) and shall prepare and submit to the Court a joint status report that includes the Rule 26(f) discovery plan."

IT IS SO ORDERED.