STIPULATED INJUNCTION

S. JAMES OTERO, District Judge.

WHEREAS:

A. On June 13, 2013, Plaintiff Brenda Belderol ("Belderol") filed a complaint against Global Tel*Link Corporation ("GTL") and Does 1 through 20, inclusive, in the Superior Court for the State of California in and for the County of Ventura, alleging claims for breach of contract, quantum meruit, gender discrimination, retaliation, wrongful termination, and violation of California Labor Code §§203, 226 and 2751. GTL timely removed this action on July 26, 2013. On GTL's motion, the court subsequently dismissed Belderol's claim for violation of Labor Code §2751.

B. On August 30, 2013, GTL filed a counterclaim against Belderol for breach of contract, misappropriation of trade secrets, breach of fiduciary duty, breach of the duty of loyalty, and violation of California Business and Professions Code §17200, et. seq. In support of its counterclaim GTL alleged, among other things, that Belderol and her husband, Robert Wilson ("Wilson"), had established a separate business entity called Fidelis Professional Services a/k/a GSA Cabling Services ("Fidelis"). GTL's counterclaim sought, among other things, injunctive relief.

C. The parties have agreed to a settlement agreement and mutual release of claims and have, as a term of such agreement, agreed to the entry of this Stipulated Injunction by the Court.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the parties, through their respective counsel of record, and good cause appearing, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that Belderol, Wilson and Fidelis (collectively, the "California Parties"), and each of their agents, affiliates, employees, servants, assigns, and all those acting in concert or participation with them, SHALL, effective immediately,

1. Be restrained and enjoined from:

a. Disclosing or using for any purpose any of GTL's confidential, 2 proprietary and/or trade secret information, including but not limited to the files listed on the Link File Analysis report attached as Exhibit "A;" and

b. Maintaining in their possession any confidential, proprietary and/or trade secret information obtained from or belonging to GTL.

2. Return to GTL all information, documents and files in their possession, custody or control obtained from or belonging to GTL, including any copies and data electronically-stored in any format whatsoever.

This injunction shall remain in effect until the second anniversary of the date it is signed and entered into as an Order of the Court (the "Effective Date"), at which point it shall expire. Expiration of this injunction two years after its Effective Date will not cause the confidential, protected nature of GTL's confidential, proprietary and/or trade secret information to expire at that time, nor will it entitle the California Parties to use or disclose such information in contravention of applicable law or in violation of any agreements between any one of them and GTL, including but not limited to the Awareness and Acceptable Use Policy signed and entered into between GTL and Belderol during Belderol's employment. Further, expiration of this injunction will not impact GTL's continuing right and ability to protect its confidential, proprietary and/or trade secret information to the fullest extent under law, including but not limited to its right to file legal action against the California Parties or any one of them for any alleged wrongful conduct occurring after the second anniversary of the injunction's Effective Date.

This injunction does not apply to any information that is or becomes publicly known, provided such information does not become publicly known by virtue of any act by any of the California Parties.

IT IS SO STIPULATED AND AGREED:

IT IS SO ORDERED: