STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

SUSAN ILLSTON, District Judge.

Pursuant to Local Rules 16-2(e) and 7-12, Plaintiffs Costaneira Transport, Inc., KR Express, Inc., Hiram Mendes, and Kim Raney (collectively, "Plaintiffs") and Defendant FedEx Ground Package System, Inc. ("Defendant"), by and through their respective attorneys of record have met and conferred and agreed to the following stipulation:

(1) Plaintiffs filed their First Amended Complaint in this action on November 19, 2014.

(2) Defendant filed its Motion to Dismiss Plaintiffs' First Amended Complaint pursuant to Federal Rule of Civil Procedure ("FRCP") 12(b)(6) on December 2, 2014. The hearing on Defendant's Motion to Dismiss is scheduled for January 16, 2015 at 9:00 a.m.

(3) The Initial Case Management Conference in this matter is currently scheduled for January 16, 2015 at 2:30 p.m.

(4) Because Defendant's pending Motion to Dismiss may impact some or all of the claims asserted in the First Amended Complaint, in the interest of efficiency the parties jointly request that the initial Case Management Conference (and associated deadlines for initial disclosures and preparation of a Joint Case Management Conference Statement) be continued to a date after the Court's ruling on Defendant's Motion to Dismiss, as determined by the Court.

IT IS SO STIPULATED.

CERTIFICATION OF COMPLIANCE WITH N.D. L.R. 5.1(i)(3)

I hereby certify that pursuant to N.D. Cal. L.R. 5.1(i)(3), I have obtained authorization from the above signatories to file the above-referenced document, and that the above signatories concur in the filing's content.

I certify under penalty of perjury under the laws of the United States that the foregoing is true and correct.

PURSUANT TO STIPULATION, IT IS SO ORDERED:

(1) The Case Management Conference is continued to 2/13/15, 2015, commencing at 2:30 p.m. in Courtroom 10, 19th Floor in San Francisco; and

(2) A Joint Case Management Statement will be filed 7 days prior to the Conference.