STIPULATION AND [PROPOSED] ORDER REGARDING CONTACT AND COMMUNICATIONS BETWEEN COLIN DYNE, ROBERT WEIR, AND THE PARTIES TO THIS ACTION

MICHAEL R. WILNER, Magistrate Judge.

Plaintiff Alpha GRP, Inc. d/b/a Red Bull Global Rally Cross ("Plaintiff or "Alpha GRP") and Colin Dyne ("Dyne"), Plaintiffs former Chief Executive Officer and a witness affiliated with Plaintiff who is represented individually for purposes of this stipulation by Plaintiffs counsel of record, and Defendant Subaru of America, Inc. ("Defendant" or "Subaru") and its former employee and witness identified by Subaru Robert Weir ("Weir") who is represented individually for purposes of this stipulation by Defendant's counsel of record (each a "Party" and collectively the "Parties"), hereby stipulate to the entry of the following order:

Dyne and Weir shall avoid all contact, directly or indirectly (including by any electronic means), with each other. Messrs. Dyne and Weir will also avoid all contact with the other person's family or current employer.

This order will not prohibit:

(a) any communication or contact made in the presence of counsel; and

(b) any communication or contact between persons affiliated with the Parties that is made with the mutual consent of both persons. Mutual consent is established only if the person initiating the communication or contact acknowledges this stipulation and obtains the express permission from the other person to continue with the communication or contact.

IT IS SO STIPULATED THROUGH COUNSEL OF RECORD.

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.