Keypoint Government Solutions Inc v. Pierron

Filing 8

AGREED TEMPORARY RESTRAINING ORDER - Preliminary Injunction Hearing April 24, 2017 at 9:30 am in Courtroom 2 before Judge Thomas M. Rose. Signed by Judge Thomas M. Rose on 17-108. (ep)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION
KEYPOINT GOVERNMENT
SOLUTIONS, INC.

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Plaintiff,
v.
DANIEL J. PIERRON
Defendant.

Case No. 3:17-cv-00108
Judge Thomas M. Rose

AGREED TEMPORARY RESTRAINING ORDER
This matter is before the Court on Plaintiff KeyPoint Government Solutions, Inc.’s
("KeyPoint" and "Plaintiff"), Motion for a Temporary Restraining Order against Defendant
Daniel Pierron. Pursuant to the agreement of the Parties, the Court hereby enters a
Temporary Restraining Order with the terms set forth below.
IT IS ORDERED that Defendant Daniel Pierron (“Pierron” and “Defendant”) and
any third-party to whom Defendant has disclosed or shared Plaintiff’s or its clients’
information SHALL:
1.

Immediately, and no later than 48 hours after this Order, identify for
KeyPoint and its counsel all KeyPoint and client information and
data (including all confidential information and trade secrets of
KeyPoint and its clients) Pierron maintained, transferred, or
transmitted by any means without authorization during or after his
employment with KeyPoint;

2.

Immediately, and no later than 72 hours of this Order, and pursuant
to a protocol agreed to by KeyPoint and Pierron, return to KeyPoint
all KeyPoint and client information and data (including all
memoranda, notes, lists, records, e- mails, computer files, and other
documents and information, and all copies and versions thereof);

3.

Preserve and protect in their present state from destruction,
modification, or alteration all information, data, and documents
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relating to KeyPoint and its clients in any form (including any
information and data stored on any computers or electronic devices
over which Pierron has possession, custody, or control), including,
as well, the preservation and protection of all emails in any account
over which he has access, and any information, documents, or data
that may be relevant or discoverable in this case; and
4.

Immediately produce, pursuant to a protocol agreed to by KeyPoint
and Pierron, all personal, and/or home computers, servers,
electronic storage devices, mobile devices, and e-mail accounts on
which there has been any of KeyPoint’s or its clients’ information or
data, or which Pierron has used to access, view, or disseminate any
of KeyPoint’s or its clients’ information or data, and that are in his
possession, custody, or control, to an authorized third-party
computer forensics expert as designated by KeyPoint to review
those computers, electronic storage devices, and e-mail accounts.

5.

Without deleting or modifying any information on the computer,
Pierron may copy all family photographs and music from his
personal computer to an external hard drive prior to producing the
computer for imaging. Pierron shall produce the external hard drive
to the authorized third-party computer forensics expert to review the
external hard drive to ensure that no KeyPoint information was
copied or transferred to it.

IT IS FURTHER ORDERED that Pierron and any third-party to whom
Defendant has disclosed or shared Plaintiff’s or its clients’ information SHALL NOT use
or disclose to any third party, including his current employer, any material (including all
documents and data) relating to KeyPoint and its clients, including KeyPoint’s or its
clients’ confidential material and trade secrets.
IT IS ALSO ORDERERD that this matter is set for a Preliminary Injunction
hearing for the 24th day of April, 2017 at 9:30 AM.
This Order shall be promptly filed in the Clerk’s office and entered in the record. It
shall continue in full force and effect until converted to a preliminary injunction, or until
otherwise modified by the Court.

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IT IS SO ORDERED.

April 13, 2017
Date

*/Thomas M. Rose______________
Thomas M. Rose, U.S. District Judge

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