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MARC L. JACUZZI, State
SARAH E. LUCAS, State
Bar No.
Bar No.
173220
148713
FILED
SAN MATEO COUNTY
JOSEPH L. J.APPEL, State Bar No. 276946
SIMPSON, GARRITY, INNES 8'c JACUZZI, P.C.
2175 N. California Blvd., Suite 710 MAY I 2016
Walnut Creek, CA 94596
4 Tel: CI rk rior CoUrt
925.322.8889
Fax:
Attorneys
925.332.8890
for Plaintiff
By
~ &ungihK
IMPACT PAPER Ec INK, LTD.
6
DAVIDR. GRIFFITH, State Bar No. 170172
GRIFFITH Ec HORN, LLP
1530 Humboldt Road, Suite 3
Chico, CA 95928
Tel: 530.812.1000
Fax: 530.809.1093
Attorneys for Defendants
ALANSAJADI and PACIFIC BUSINESS SUPPLIES
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
IN AND FOR TIIE COUNTY OF SAN MATEO
13
14
IIviPACT PAPER Ec INK LTD., Case No. CIV531938
15
Plaintiff, STIPULATED JUDGMENT
16
V.
17
ALANSAJADI; PACIFIC BUS1NESS
18 SUPPLIES and DOES 1through 10, inclusive,
19 Defendant. Complaint Filed: December 30, 2014
Trial Date: May 9, 2016
20
21
22
23
24
25
26
27
28
I 20394-2
0035417LDocx II
STIPULATED JUDGMEN
I'ase No. CIV53 I 938
1 Plaintiff Impact Paper E Ink LTD ("Plaintiff") and Defendants Alan Sajadi and Pacific
2 Business Supplies ("Defendants" ) hereby stipulate and agree to the following
STIPULATION
4 WHEREAS, Plaintiff filed this action against Defendants alleging claims for
5 misappropriation of trade secrets, unfair competition, intentional interference with prospective
I
6 economic advantage, conversion, breach of contract, and injunctive relief;
7 WI-IEREAS, the parties entered into a written settlement agreemcnt in February 2016
8 ("Agreement" ), and Sajadi has breached the Agreement by using Impact's Confidential
9 Information to solicit customers, or otherwise violated paragraphs 1 or 6 of the Agreement, and
10 thereby misappropriated Impact's trade secrets, engaged in unfair competition, intentionally
11 interfered with prospective economic advantage, illegally converted Impact's property,. and
12 breached his contract obligations with Impact:
13 IT IS I-IEREBY STIPULATED AND AGREED by and between Plaintiff and Defendant
14 that the Court may enter judgment on all causes of action as follows:
15 Plaintiff has judgment against Defendant for a permanent injunction prohibiting Sajadi
16 from directly or indirectly, as a result of using the Confidential Information of Impact, as defined
17 by Paragraph 2 of the Agreement, solicit, contact, pursue, engage, or conduct business with any of
18 the customers listed in E~xhibit A to the Agreement.
20
21 IV,
22 6'i
23 QI,
24
25
26
27 39,
28 IV
(20394-2 0035417 I.DOCX
I } -1- Case No. CIV531938
STIPULAl ED JUDGMENT
The parties acknowledge rhat they havehad the opportunity to consult with counsel
2 concerning this stipulation,that they understand its terms,and that they enter into it freely and
3 voluntarily.
4 Dated; Z/z J
1
2016 IlvtPACT PAPER & INK LTD
St Christensen
Dated' 7 l,. 201 6 IMPAC TD
10 Ry:
lj'plr'id Sklar
!1
17
Dated: 7, 2016 SIMPSON, TY. 6'& JACUZZI, P.C.
By:
M'" jacuzzi, 8981
14 Attorneys for Plaiiiti
1MPACT PAPER . LTD.
15'6'ated:
2/2 3 .2016 PACIFIC BUSINESS SUPPLIES
17 / I
Bty:~ ~ '9tpa
P 4d. yt 8'r
20
Dated: ALAN SAJADI, an Individual
21
22
A an SaJa
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MARC L. JACUZZI, State SARAH E. LUCAS, State Bar No. Bar No. 173220 148713 FILED SAN MATEO COUNTY JOSEPH L. J.APPEL, State Bar No. 276946 SIMPSON, GARRITY, INNES 8'c JACUZZI, P.C. 2175 N. California Blvd., Suite 710 MAY I 2016 Walnut Creek, CA 94596 4 Tel: CI rk rior CoUrt 925.322.8889 Fax: Attorneys 925.332.8890 for Plaintiff By ~ &ungihK IMPACT PAPER Ec INK, LTD. 6 DAVIDR. GRIFFITH, State Bar No. 170172 GRIFFITH Ec HORN, LLP 1530 Humboldt Road, Suite 3 Chico, CA 95928 Tel: 530.812.1000 Fax: 530.809.1093 Attorneys for Defendants ALANSAJADI and PACIFIC BUSINESS SUPPLIES 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 IN AND FOR TIIE COUNTY OF SAN MATEO 13 14 IIviPACT PAPER Ec INK LTD., Case No. CIV531938 15 Plaintiff, STIPULATED JUDGMENT 16 V. 17 ALANSAJADI; PACIFIC BUS1NESS 18 SUPPLIES and DOES 1through 10, inclusive, 19 Defendant. Complaint Filed: December 30, 2014 Trial Date: May 9, 2016 20 21 22 23 24 25 26 27 28 I 20394-2 0035417LDocx II STIPULATED JUDGMEN I'ase No. CIV53 I 938 1 Plaintiff Impact Paper E Ink LTD ("Plaintiff") and Defendants Alan Sajadi and Pacific 2 Business Supplies ("Defendants" ) hereby stipulate and agree to the following STIPULATION 4 WHEREAS, Plaintiff filed this action against Defendants alleging claims for 5 misappropriation of trade secrets, unfair competition, intentional interference with prospective I 6 economic advantage, conversion, breach of contract, and injunctive relief; 7 WI-IEREAS, the parties entered into a written settlement agreemcnt in February 2016 8 ("Agreement" ), and Sajadi has breached the Agreement by using Impact's Confidential 9 Information to solicit customers, or otherwise violated paragraphs 1 or 6 of the Agreement, and 10 thereby misappropriated Impact's trade secrets, engaged in unfair competition, intentionally 11 interfered with prospective economic advantage, illegally converted Impact's property,. and 12 breached his contract obligations with Impact: 13 IT IS I-IEREBY STIPULATED AND AGREED by and between Plaintiff and Defendant 14 that the Court may enter judgment on all causes of action as follows: 15 Plaintiff has judgment against Defendant for a permanent injunction prohibiting Sajadi 16 from directly or indirectly, as a result of using the Confidential Information of Impact, as defined 17 by Paragraph 2 of the Agreement, solicit, contact, pursue, engage, or conduct business with any of 18 the customers listed in E~xhibit A to the Agreement. 20 21 IV, 22 6'i 23 QI, 24 25 26 27 39, 28 IV (20394-2 0035417 I.DOCX I } -1- Case No. CIV531938 STIPULAl ED JUDGMENT The parties acknowledge rhat they havehad the opportunity to consult with counsel 2 concerning this stipulation,that they understand its terms,and that they enter into it freely and 3 voluntarily. 4 Dated; Z/z J 1 2016 IlvtPACT PAPER & INK LTD St Christensen Dated' 7 l,. 201 6 IMPAC TD 10 Ry: lj'plr'id Sklar !1 17 Dated: 7, 2016 SIMPSON, TY. 6'& JACUZZI, P.C. By: M'" jacuzzi, 8981 14 Attorneys for Plaiiiti 1MPACT PAPER . LTD. 15'6'ated: 2/2 3 .2016 PACIFIC BUSINESS SUPPLIES 17 / I Bty:~ ~ '9tpa P 4d. yt 8'r 20 Dated: ALAN SAJADI, an Individual 21 22 A an SaJa