ENGIE Insight Services Inc. v. Stannard

Filing 13

STIPULATED PRELIMINARY INJUNCTION. Signed by Judge Rosanna Malouf Peterson. (Attachments: # 1 Appendix A)(VR, Courtroom Deputy)

Case 2:20-cv-00234-RMP

ECF No. 13

filed 06/26/20

PageID.157 Page 1 of 3

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FILED IN THE
U.S. DISTRICT COURT
EASTERN DISTRICT OF WASHINGTON

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Jun 26, 2020

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SEAN F. MCAVOY, CLERK

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF WASHINGTON

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ENGIE INSIGHT SERVICES, INC.,
doing business as Engie Impact,
formerly doing business as Ecova,
Inc.,
Plaintiff,

NO: 2:20-CV-234-RMP
STIPULATED PRELIMINARY
INJUNCTION

v.
CINDY MARIE STANNARD,
Defendant.
STIPULATED PRELIMINARY INJUNCTION
WHEREAS, on June 23, 2020, Plaintiff ENGIE Insight Services Inc., d/b/a

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ENGIE Impact (“ENGIE Impact”) filed a Motion for Temporary Restraining Order

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and Preliminary Injunction (the “TRO Motion”);

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WHEREAS, on June 25, 2020, Defendant turned over to a courier hired by

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ENGIE Impact the following company-issued devices (the “Company Devices”),

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the return of which was part of the requested relief sought by the TRO Motion: (a)

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STIPULATED PRELIMINARY INJUNCTION ~ 1

Case 2:20-cv-00234-RMP

ECF No. 13

filed 06/26/20

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ThinkPad laptop with tag SPO170519-L; (2) black iPhone XR; and (3) iPad with

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tag 190971;

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WHEREAS, the TRO Motion is currently scheduled for a telephonic hearing
on June 29, 2020, at 10:00 a.m.; and
WHEREAS, the parties now wish to stipulate to the issuance of a Stipulated
Preliminary Injunction as set forth herein and agree to request the Court so order:

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THEREFORE, the parties stipulate and agree as follows:

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1.

Scope of Application. This Stipulated Preliminary Injunction applies

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to Defendant Cindy Marie Stannard and any persons or entities in active concert or

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participation with her who receive notice of this Stipulated Preliminary Injunction

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after its entry by the Court.

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2.

Duration. This Stipulated Preliminary Injunction shall remain in

effect until such time as the Court modifies or dissolves it.
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Non-Disclosure. Stannard shall comply with the non-disclosure

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obligations in the Confidentiality, Non-Solicitation, and Invention Assignment

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Agreement (hereafter the “NDA”) attached hereto as Appendix A. Specifically,

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Stannard, and any person in active concert or participation with her, are enjoined

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from disclosing any “Confidential Information,” as that term is defined in

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Paragraph 1 of the NDA, to others or from using the Confidential Information for

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her own benefit or for the benefit of others.

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STIPULATED PRELIMINARY INJUNCTION ~ 2

Case 2:20-cv-00234-RMP

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4.

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Preservation of Information/Accounting. Stannard is directed to

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preserve, but not access, any Confidential Information of ENGIE Impact that was

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not on the Company Devices and that remains in her possession, custody, or

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control. Within five business days of this Order, Stannard shall provide ENGIE

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Impact with a written accounting of this Confidential Information, if any, or

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provide a written statement that no Confidential Information remains in her

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possession, custody, or control.

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5.

Cooperation. If Stannard reports that ENGIE Impact Confidential

Information remains in her possession, custody, or control under Paragraph 4 of

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this Order, she is to cooperate with ENGIE Impact in taking any other appropriate

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and reasonable steps to allow ENGIE Impact to recover the Confidential

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Information in a manner that preserves the Confidential Information while

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removing it from Stannard’s continued possession, custody, and control.

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6.

Further Injunctive Relief. If necessary, this Stipulated Preliminary

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Injunction may be enforced by seeking relief from this Court by way of a motion for

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contempt for breach.

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IT IS SO ORDERED. The District Court Clerk is directed to enter this

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Order and provide copies to counsel.

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DATED June 26, 2020.

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s/ Rosanna Malouf Peterson
ROSANNA MALOUF PETERSON
United States District Judge

STIPULATED PRELIMINARY INJUNCTION ~ 3