STIPULATED [PROPOSED] PRELIMINARY INJUNCTION

PHILIP S. GUTIERREZ, District Judge.

This matter having come before the Court upon the stipulation of the Plaintiff ADP, LLC's ("ADP") and Defendant DeShawn Hearn, the Parties having agreed to this Stipulated Preliminary Injunction, the Court having reviewed this Stipulated Preliminary Injunction and being otherwise advised:

IT IS ORDERED THAT Defendant is and shall be:

1. ENJOINED from engaging in any actual and/or threatened misappropriation of ADP's trade secrets pursuant to California Civil Code § 3426.2(a);

2. ENJOINED from using or disclosing at any time in the future, ADP's confidential, proprietary, or business information or property received prior to Defendant's employment termination from ADP;

3. ENJOINED from using any document or information obtained prior to Defendant's employment termination from ADP to interfere in any way with any current contract, client relationship, prospective client relationship, or marketing partner relationship of ADP;

4. ENJOINED from breaching any loyalty obligation to ADP, including, but not limited to, appropriating any business opportunity of ADP known as of Defendant's employment termination, engaging in deceptive acts or statements with regard to ADP's abilities, experiences, and personnel, misappropriating ADP's Proprietary Information and retaining the Downloaded Files, and from otherwise attempting to gain unfair advantage against ADP;

5. REQUIRED to return all ADP confidential information and property to ADP, including, but not limited to, the Downloaded Files, requests for proposal, requests for bid, client correspondence, meeting minutes, notes, marketing data, prospect meeting data, proposals, faxes, pricing contracts, contracts awarded, marketing brochures, recommendations, including, but not limited to, vendor recommendations, marketing database, marketing plans, costs, client lists, prospect lists, marketing partner information, client contact information, prospect client contact information, competitive bid information, strategic planning information, alliance relationships, employee lists, client information, internal strengths and weakness information, marketing plans, business plans, project costs and all other confidential, proprietary or trade secret information, confidential client and vendor information and confidential and proprietary marketing partner information, in any form including electronic and hard copy form;

6. REQUIRING Defendant to deliver, on or before December 6, 2019, the USB Device, as that term is defined in ADP's Application, and any other device to which the USB Device has been connected since October 9, 2019, including but not limited to Defendant's personal laptop computer, to ADP so that ADP can perform a forensic evaluation of the device(s) to determine the extent of Defendant's misappropriation and whether any of ADP's Proprietary Information has been removed from the USB Device and/or copied to other devices;

7. ENJOINED from destroying or disposing of the Downloaded Files and/or any paper documents in his possession, custody, or control, or deleting anything from any computers to which he has access, including smartphones, PDAs or any other electronic storage devices, including e-mail, databases, and any other electronically stored data that relate to, evidence, or concern any of the issues involved in this litigation; and

8. ADP is not required to post a bond.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.