STIPULATION AND ORDER REGARDING EXPEDITED DISCOVERY

KIMBERLY J. MUELLER, District Judge.

This stipulation is entered into by and between to Plaintiff PEO Experts CA, Inc., dba Bixby Zane Insurance Services ("BZ" or "Plaintiff") and Defendants Ryan Wakefield ("Wakefield"), Michael Engstrom ("Engstrom"), Christopher Longo ("Longo"), Jennifer Engstrom ("Jennifer"), Michael Engstrom, Inc., B&C Loc, Inc., PEO Advisors of CA, Inc., and Freedom Risk Insurance Services (collectively, "Defendants"), through their respective counsel of record, as follows:

WHEREAS, on February 24, 2017, the Honorable Judge Kimberly J. Mueller ordered Parties to meet and confer regarding expedited discovery in the instant matter.

WHEREAS, as a result of such meet and confer process, the Parties stipulated to the matters and dates as described herein.

NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE, through their respective counsel of record, to the following:

Each and every Defendant must make available for mirroring all electronic devices that currently hold or have held in the past Plaintiff's claimed confidential Trade Secret Information. The subject mirroring process is to commence on March 6, 2017 and is to be completed within a 12 hour period, excluding logistical interference. Defendants' respective personal cellular devices will not be subject to the mirroring process provided Defendants confirm that such personal cellular devices contain no separate or different information than that contained on all other respective electronic device subject to mirroring. Parties agree to execute a Stipulated Protective Order as to the confidentiality of the information, the details of which parties are in the process of meeting and conferring. Parties agree to further meet and confer to mutually agree on the consultant to image the information, with the cost of the consultant to be borne by Plaintiff.

Plaintiff is permitted to serve the Requests for Production of Documents, a total of fifteen (15) Requests, attached to its Motion for Expedited Discovery, with verified responses due from Defendants by March 7, 2017.

Defendants Engstrom, Longo, Jennifer, B&C Loc, Inc., and PEO Advisors of CA, Inc. are permitted to serve the same number of Requests for Production of Documents as Plaintiff, or fifteen (15) Requests, due from Plaintiff 12 days after electronic service to counsel.

Defendants Wakefield and Freedom Risk Insurance Services are permitted to serve the same number of Requests for Production of Documents as Plaintiff, or fifteen (15) Requests, due from Plaintiff 12 days after electronic service to counsel.

Plaintiff is permitted to take four (4) hours each of the depositions of Defendants Engstrom, Longo, Jennifer, and Wakefield.

Defendants are permitted to collectively take four (4) hours each of the deposition of Jason Crawford, Brad Worley, and William Lee.

Counsel for the respective parties have determined their availability for the above depositions on the following dates: March 16, 2017, March 17, 2017, March 20, 2017, March 23, 2017, and April 5, 2017. Given the time constraints, required travel, and each deponent's availability, Parties are continuing to meet and confer on the exact date and time for each respective deposition on these dates.

Parties agree that the depositions of Engstrom, Longo, Jennifer, Wakefield, Crawford, Worley, and Lee will take place in Sacramento, California, unless travel arrangements necessitate otherwise, in which case, Parties will further meet and confer.

Parties agree to the expedited deposition of Javier De Haro. However, Plaintiff does not represent De Haro and he will need to be subpoenaed. Therefore, Plaintiff cannot state that he will be available during the expedited discovery period and do not agree to delay the period for his deposition.

Lastly, Parties jointly request that the Court continue the Preliminary Injunction Hearing date from April 14, 2017 to a date during the week of April 24, 2017 in accordance with Court's availability, in order to allow Parties sufficient time in filing opposition and reply papers after completion of the expedited discovery.

The court notes the parties continue to meet and confer to identify specific dates for depositions; the court expects the parties to identify dates that allow for completion of the discovery here allowed in time for proper briefing of the plaintiff's motion for a preliminary injunction.

The parties shall file their proposed discovery protective order by the close of business on Friday, March 3, 2017.

The preliminary injunction hearing previously set for April 14, 2017 at 10:00 a.m. is continued to April 27, 2017 at 10:00 a.m.

IT IS SO ORDERED.