STIPULATION AND ORDER REGARDING PERMANENT INJUNCTION

JOHN A. MENDEZ, District Judge.

This stipulation is entered into by and between BRETT ROSSELLI and NICOLE BRUSO ("Defendants" or "Cross-Claimants") and SGI RESORT PROPERTIES, LLC and THE SCHOMAC GROUP, INC. ("Plaintiffs" or "Cross-Defendants"), through their respective counsel of record, as follows:

WHEREAS, Defendants are former employees of Plaintiffs;

WHEREAS, on December 21, 2015, Plaintiffs filed a Complaint in the instant action seeking damages and injunctive relief and asserting causes of action for (1) Defamation/Slander Per Se; (2) Trade Libel; (3) Misappropriation of Trade Secrets; (4) Conversion; (5) Interference with Prospective Economic Advantage; and (6) Violation of the California Unfair Competition Law and the Common Law Unfair Competition.

WHEREAS, on December 31, 2015, Plaintiffs filed an Ex Parte Application for a Temporary Restraining Order and Order to Show Cause Re Preliminary Injunction ("Ex Parte Application");

WHEREAS, on January 6, 2016, Defendants filed a Non-Opposition to Plaintiff's Ex Parte Application;

WHEREAS, on January 12, 2016, the Court granted Plaintiffs' Preliminary Injunction;

WHEREAS, the parties now seek to enter a Permanent Injunction containing substantially the same terms as the Preliminary Injunction.

NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE, through their respective counsel of record, that Brett Rosselli and Nicole Bruso and their agents, representatives, and all persons acting in concert or participating with them; and SGI Resort Properties, LLC and The Schomac Group, Inc. and their agents, representatives, and all persons acting in concert or participating with them are all permanently restrained and enjoined from engaging in or performing directly or indirectly any and all of the following acts:

1. Publishing by Defendants, whether verbal or written to any third-party any disparaging and/or otherwise defamatory, false statements regarding the business reputation of Plaintiffs, their business at issue in this litigation, Nakoma Golf Resort & Spa ("Nakoma") SGI Resort Properties, Inc. and the Schomac Group (collectively, "SGI" or "Plaintiffs"); SGI's employees and management; Ryan Schoff, Michael Schoff and Dan Gallagher (collectively with SGI, "SGI Parties").

2. Publishing by Plaintiffs, or any of the SGI Parties, whether verbal or written to any third-party any disparaging and/or otherwise defamatory, false statements regarding the business reputation of Defendants, their business and any of Defendants' employees and management.

3. Utilizing, disseminating, using, copying, transmitting, or publishing by Defendants any of Nakoma's or SGI's "Confidential Business Information" and/or trade secrets, including without limitation, pricing information, cost of materials information, strategic and marketing plans, financial management information, operating policies, vendor files with information including vendor contact information, vendor ordering needs and requirements, and other business procedures customized for its operation as a popular golf resort and spa and special event hosting location.

4. Inducement or incitement by either Plaintiffs or Defendants of claims of discrimination, harassment retaliation, wrongful and/or constructive discharge or termination, claims for unpaid wages, including overtime, violations of California's Labor Code and the Industrial Welfare Commission wage orders, unlawful business practices, or any other claims, based in tort or contract, against either SGI or the SGI Parties or any other managers, supervisors, or employees of SGI by any other person; or against Brett Rosselli or Nicole Bruso, or any of Defendants' employees or management, as applicable.

5. Interference by either Plaintiffs or Defendants with the existing or prospective business relationships and contracts of the other by any means, including, but not limited to, initiating contact of any kind with:

h. Any third party vendor to Plaintiffs or Defendants, both current and former as well as any prospective third party vendor to Plaintiffs and Defendants.

IT IS SO STIPULATED.

IT IS SO ORDERED.