Bote v. Keene

STIPULATION TO TRANSFER VENUE; ORDER
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LANDON D. BAILEY (State Bar No. 240236)
BAILEY PLC
1200 Suncast Lane, Suite 7
El Dorado Hills, CA 95762
Telephone: (916) 713-2580
Email: landon@baileyplc.com
Attorneys for Plaintiff
Vasile Bote dba BAS Apiary
WANGER JONES HELSLEY PC
265 East River Park Circle, Suite 310
Fresno, California 93720
Telephone: (559) 233-4800
Facsimile: (559) 233-9330
Kurt F. Vote #160496
kvote@wjhattorneys.com
Attorneys for Defendant
Scott Keene dba Mountain Honey Farms
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
Case No. 2:25-cv-02207-WBS-JDP
STIPULATION TO TRANSFER VENUE
TO UNITED STATES DISTRICT COURT
OF NORTH DAKOTA PURSUANT TO 28
U.S.C. § 1404(a); ORDER
VASILE BOTE dba BAS APIARY;
Plaintiff,
v.
SCOTT KEENE dba MOUNTAIN HONEY
FARMS,
Defendant.
Case 1:25-cv-00284-DMT-CRH Document 14 Filed 12/10/25 Page 1 of 4

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STIPULATION TO TRANSFER VENUE; ORDER
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Plaintiff Vasile Bote dba BAS Apiary (“Plaintiff” or “Bote”) and Defendant Scott Keene
dba Mountain Honey Farms (“Defendant” or “Keene”) (the “Parties”), by and through their
respective counsel, jointly submit the following Stipulation to transfer venue of this matter to the
United States District Court, District of North Dakota.
STIPULATION
WHEREAS, Plaintiff Bote is, and at all relevant times was, an individual domiciled in the
State of California, residing in the city of Modesto, California who does business under the
fictitious business name BAS Apiary; and
WHEREAS, Defendant Keene is, and at all relevant times was an individual domiciled in
the State of Oregon, but with his principal place of business in North Dakota, who does business
under the fictitious business name Mountain Honey Farms; and
WHEREAS, Bote filed his Complaint in this Court on August 7, 2025 alleging six separate
causes of action arising from a beekeeping business relationship between Bote and Keene; and
WHEREAS, on November 25, 2025, Keene filed a Motion to Dismiss, or in the
Alternative, to Transfer Venue contending that the proper venue for this action is the United States
District Court, District of North Dakota; and
WHEREAS, the hearing on Keene’s Motion is currently scheduled before this Court on
January 20, 2026; and
WHEREAS, Bote disputes and disagrees with many of the contentions set forth in Keene’s
Motion, but does not dispute that this matter could have been properly filed in United States
District Court for the District of North Dakota; and
WHEREAS, rather than litigating the Parties’ dispute concerning venue, Bote is amenable
to agreeing to transferring this action to the United States District Court, District of North Dakota
for further proceedings; and
WHEREAS, the Parties, by and through their respective counsel of record, have met and
conferred in good faith, and have agreed to jointly request that this Court transfer this case to the
United States District Court, District of North Dakota.
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STIPULATION TO TRANSFER VENUE; ORDER
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NOW, THEREFORE, Plaintiff Bote and Defendant Keene hereby stipulate and agree as
follows:
1. This case may be transferred to the United States District Court, District of North
Dakota.
2. The Parties hereby request that this Court Order the transfer of venue.
3. The Parties further request that this Court vacate the hearing on Defendant’s
Motion presently set for January 20, 2026, as well as the Initial Scheduling Conference presently
set for April 6, 2026.
IT IS SO STIPULATED.
Dated: December 9, 2025 BAILEY PLC
By: /s/ Landon D. Bailey
Landon D. Bailey
Attorneys for Plaintiff
VASILE BOTE DBA BAS APIARY
Dated: December 9, 2025 WANGER JONES HELSLEY PC
By: /s/ Kurt F. Vote
Kurt F. Vote
Attorneys for Defendant
SCOTT KEENE DBA MOUNTAIN
HONEY FARMS
Case 1:25-cv-00284-DMT-CRH Document 14 Filed 12/10/25 Page 3 of 4

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ORDER
The Court, having reviewed and considered the Stipulation of the Parties, and good cause
appearing therefore, hereby ORDERS as follows:
1. The Stipulation of the Parties to transfer venue in this case to the United Stated
District Court, District of North Dakota is APPROVED.
2. This case is hereby TRANSFERRED to the United States District Court, District of
North Dakota pursuant to 28 U.S.C. § 1404(a).
3. Hearing on Defendant’s Motion presently set for January 20, 2026 is VACATED.
4. The Initial Scheduling Conference presently set for April 6, 2026 is VACATED.
5. The Clerk is hereby directed to transfer this case to the United States District Court,
District of North Dakota, forthwith.
Dated: December 10, 2025
Case 1:25-cv-00284-DMT-CRH Document 14 Filed 12/10/25 Page 4 of 4