Cargill, Incorporated v. Kuan

Filing 25

STIPULATED TEMPORARY RESTRAINING ORDER. By Judge Raymond P. Moore on 8/26/2014. (trlee, )

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Judge Raymond P. Moore
Civil Action No. 14-cv-2325-RM-MJW
CARGILL, INCORPORATED, a Delaware corporation,
Plaintiff,
v.
JASON KUAN
Defendant.
STIPULATED TEMPORARY RESTRAINING ORDER
The parties through between their respective counsel stipulate and agree as follows
to the Temporary Restraining Order regarding Cargill’s highly confidential and
proprietary business information and trade secrets.
1)

Mr. Kuan shall be immediately enjoined from disclosing, or disseminating,
any Cargill highly confidential and proprietary business information and
trade secrets, the contents of any documents containing such information,
or any Cargill trade secret to any party, whether verbally or otherwise,
specifically including JBS.

2)

Mr. Kuan shall return all copies of Cargill highly confidential and
proprietary business information and trade secrets in his possession or
control and allow an analysis of his electronic devices to ensure that all

Cargill highly confidential and proprietary business information and trade
secrets have been returned.
3)

Mr. Kuan shall be immediately enjoined from using any Cargill highly
confidential and proprietary business information and trade secrets, the
contents of documents containing such information, and other Cargill trade
secrets.

4)

Mr. Kuan hereby stipulates to the expedited discovery requested by Cargill
in Cargill’s Motion for Expedited Discovery (Dkt. No. 12).

The Parties agree that the Stipulated Temporary Restraining Order will remain in
effect during the pendency of this matter. In addition, at the conclusion of expedited
discovery, it will be necessary to conduct a preliminary injunction hearing on the issue
of whether Mr. Kuan should be restricted from involvement with JBS on matters related
to the business units similar to those in which he was involved at Cargill. The parties
request that a preliminary injunction hearing be set in approximately thirty (30) days.
This stipulated temporary restraining order is subject to revision at the request of
Cargill should Cargill learn new information regarding the scope of Cargill highly
confidential and proprietary business information and trade secrets retained by Jason
Kuan.

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ACCEPTED:

ACCEPTED:

By:s/W.V. Bernie Siebert
W.V. Bernie Siebert
Heather F. Vickles
Sherman & Howard
633 17th St #3000
Denver, CO 80202
[e-mail]
[e-mail]

By:s/ Tucker Trautman
Tucker K. Trautman
Case Collard
DORSEY & WHITNEY LLP
1400 Wewatta Street, Ste. 400
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff, Cargill,
Incorporated

Attorneys for Defendant Jason Kuan

SO ORDERED this 26th day of August, 2014 at 9:30 a.m.
BY THE COURT:

____________________________________
RAYMOND P. MOORE
United States District Judge

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