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1 SUSAN K. HATMAKER 172543
DANIELLE N. KJAR 291481
2 HATMAKER LAW GROUP
A Professional Corporation
3
7522 N. Colonial Avenue, Suite 105
4 Fresno, California 93711
Telephone: (559) 374-0077
5 Facsimile: (559) 374-0078
6 RECEIVED VIA E-FILE
Attorneys for Plaintiff
OLAM AMERICAS, INC. 12/21/2017 8:47 AM
7 FRESNO COUNTY SUPERIOR COURT
By: C. Cogburn, Deputy
8 SUPERIOR COURT OF CALIFORNIA
9 COUNTY OF FRESNO
10 ***
11
OLAM AMERICAS, INC., ) Case No. 17CECG04157
12 )
Plaintiffs, )
13 ) [PROPOSED] TEMPORARY
vs. ) RESTRAINING ORDER AND ORDER
14 ) TO SHOW CAUSE RE PRELIMINARY
15 WILLIAM LEE ROBINSON; and DOES 1 ) INJUNCTION
through 10, inclusive, )
16 ) (Code Civ. Proc. §§ 525 et seq.; Cal. Rules of
Defendants. ) Court, rule 3.1150 and Cal. Rules of Court,
17 ) rules 3.1200 to 3.1207)
)
18
)
19 ) Date: December 21, 2017
) Time: 3:30 p.m.
20 ) Dept.: 502
)
21 ) Complaint Filed: December 5, 2017
) Trial Date: None Set
22
23
24 On reading the complaint of plaintiff on file in the above-entitled action and the
25 accompanying declaration(s), it appears to the satisfaction of the court that this is a proper case
26 for granting an order to show cause for a preliminary injunction and a temporary restraining
27 order, and that, unless the temporary restraining order prayed for be granted, great or irreparable
28 injury will result to plaintiff before the matter can be heard on notice.
Hatmaker Law Group
7522 N. COLONIAL AVENUE
SUITE 105 1
FRESNO, CA 93711
[PROPOSED] TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION
1 IT IS ORDERED that, pending the hearing and determination of the order to show
2 cause:
3 A. For a temporary restraining order enjoining and restraining Defendant WILLIAM
4 LEE ROBINSON (“Defendant”) and his employees, agents, and persons acting
5 with him, or on his behalf, from:
6 (1) Disclosing, sharing, copying, possessing or divulging any of the
confidential, proprietary of OLAM to any business or individual,
7 including usernames and passwords;
8
(2) Accessing Olam’s, including its agents’, subsidiaries’, and employees’,
9 computers, networks, servers and computer systems and using, copying,
taking, erasing, deleting or overwriting any data or information;
10
(3) Destroying, deleting, erasing, or corrupting any property, data, codes,
11
software, or technical information taken, obtained, copied, or deleted from
12 OLAM; and/or
13 (4) Returning all Olam data, information, documents, property, or other Olam
confidential and proprietary information taken or accessed by Defendant.
14
15 IT IS FURTHER ORDERED that the above-named defendants, and each of them,
16 appear in Department ____________________ of this court, located at 1130 O Street, Fresno,
17 California on ____________________ (date), at _________________ (time), or as soon
18 thereafter as the matter may be heard, then and there to show cause, if any they have, why they
19 and their agents, servants, employees, and representatives, and all persons acting in concert or
20 participating with them, should not be enjoined and restrained during the pendency of this action
21 from engaging in, committing, or performing, directly or indirectly, any and all of the following
22 acts: as specifically outline above in A.
23 IT IS FURTHER ORDERED that:
24 A. Plaintiff shall serve this order to show cause on Defendant in the following time
25 and manner: via email to _____________ and regular mail to __________________________
26 _______________________________________________________________________.
27 B. Proof of service must be delivered to the court hearing the OSC on:
28 _______________________________________________________________________.
Hatmaker Law Group
7522 N. COLONIAL AVENUE
SUITE 105 2
FRESNO, CA 93711
[PROPOSED] TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION
1 C. The parties shall adhere to the following briefing schedule:
2 _______________________________________________________________________.
3 _______________________________________________________________________.
4 IT IS FURTHER ORDERED that copies of the complaint, declaration(s), and this order
5 to show cause and temporary restraining order be served the parties against whom this order is
6 made not later than ___________ (date).
7
Dated: ____________________. __________________________________
8 JUDGE OF THE SUPERIOR COURT
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Hatmaker Law Group
7522 N. COLONIAL AVENUE
SUITE 105 3
FRESNO, CA 93711
[PROPOSED] TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION
Preview
1 SUSAN K. HATMAKER 172543 DANIELLE N. KJAR 291481 2 HATMAKER LAW GROUP A Professional Corporation 3 7522 N. Colonial Avenue, Suite 105 4 Fresno, California 93711 Telephone: (559) 374-0077 5 Facsimile: (559) 374-0078 6 RECEIVED VIA E-FILE Attorneys for Plaintiff OLAM AMERICAS, INC. 12/21/2017 8:47 AM 7 FRESNO COUNTY SUPERIOR COURT By: C. Cogburn, Deputy 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF FRESNO 10 *** 11 OLAM AMERICAS, INC., ) Case No. 17CECG04157 12 ) Plaintiffs, ) 13 ) [PROPOSED] TEMPORARY vs. ) RESTRAINING ORDER AND ORDER 14 ) TO SHOW CAUSE RE PRELIMINARY 15 WILLIAM LEE ROBINSON; and DOES 1 ) INJUNCTION through 10, inclusive, ) 16 ) (Code Civ. Proc. §§ 525 et seq.; Cal. Rules of Defendants. ) Court, rule 3.1150 and Cal. Rules of Court, 17 ) rules 3.1200 to 3.1207) ) 18 ) 19 ) Date: December 21, 2017 ) Time: 3:30 p.m. 20 ) Dept.: 502 ) 21 ) Complaint Filed: December 5, 2017 ) Trial Date: None Set 22 23 24 On reading the complaint of plaintiff on file in the above-entitled action and the 25 accompanying declaration(s), it appears to the satisfaction of the court that this is a proper case 26 for granting an order to show cause for a preliminary injunction and a temporary restraining 27 order, and that, unless the temporary restraining order prayed for be granted, great or irreparable 28 injury will result to plaintiff before the matter can be heard on notice. Hatmaker Law Group 7522 N. COLONIAL AVENUE SUITE 105 1 FRESNO, CA 93711 [PROPOSED] TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION 1 IT IS ORDERED that, pending the hearing and determination of the order to show 2 cause: 3 A. For a temporary restraining order enjoining and restraining Defendant WILLIAM 4 LEE ROBINSON (“Defendant”) and his employees, agents, and persons acting 5 with him, or on his behalf, from: 6 (1) Disclosing, sharing, copying, possessing or divulging any of the confidential, proprietary of OLAM to any business or individual, 7 including usernames and passwords; 8 (2) Accessing Olam’s, including its agents’, subsidiaries’, and employees’, 9 computers, networks, servers and computer systems and using, copying, taking, erasing, deleting or overwriting any data or information; 10 (3) Destroying, deleting, erasing, or corrupting any property, data, codes, 11 software, or technical information taken, obtained, copied, or deleted from 12 OLAM; and/or 13 (4) Returning all Olam data, information, documents, property, or other Olam confidential and proprietary information taken or accessed by Defendant. 14 15 IT IS FURTHER ORDERED that the above-named defendants, and each of them, 16 appear in Department ____________________ of this court, located at 1130 O Street, Fresno, 17 California on ____________________ (date), at _________________ (time), or as soon 18 thereafter as the matter may be heard, then and there to show cause, if any they have, why they 19 and their agents, servants, employees, and representatives, and all persons acting in concert or 20 participating with them, should not be enjoined and restrained during the pendency of this action 21 from engaging in, committing, or performing, directly or indirectly, any and all of the following 22 acts: as specifically outline above in A. 23 IT IS FURTHER ORDERED that: 24 A. Plaintiff shall serve this order to show cause on Defendant in the following time 25 and manner: via email to _____________ and regular mail to __________________________ 26 _______________________________________________________________________. 27 B. Proof of service must be delivered to the court hearing the OSC on: 28 _______________________________________________________________________. Hatmaker Law Group 7522 N. COLONIAL AVENUE SUITE 105 2 FRESNO, CA 93711 [PROPOSED] TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION 1 C. The parties shall adhere to the following briefing schedule: 2 _______________________________________________________________________. 3 _______________________________________________________________________. 4 IT IS FURTHER ORDERED that copies of the complaint, declaration(s), and this order 5 to show cause and temporary restraining order be served the parties against whom this order is 6 made not later than ___________ (date). 7 Dated: ____________________. __________________________________ 8 JUDGE OF THE SUPERIOR COURT 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Hatmaker Law Group 7522 N. COLONIAL AVENUE SUITE 105 3 FRESNO, CA 93711 [PROPOSED] TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION