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Matchpoint Solutions, A California v. Consulting

January 3, 2013

MATCHPOINT SOLUTIONS, A CALIFORNIA
CORPORATION, PLAINTIFF,
v.
CONSULTING, INC., A TEXAS CORPORATION, AND FRANCIS T. KHUONG, AN INDIVIDUAL,
DEFENDANTS.



The opinion of the court was delivered by: United States District Judge Samuel Conti Judge

HARMEET K. DHILLON (SBN: 207873) harmeet@dhillonsmith.com NITOJ P. SINGH (SBN: 265005) nsingh@dhillonsmith.com DHILLON & SMITH LLP 177 Post Street, Suite 700 San Francisco, California 94108 Telephone: (415) 433-1700 Facsimile: (415) 520-6593 Attorneys for Plaintiff MatchPoint Solutions

STIPULATED FINAL JUDGMENT AND [PROPOSED] ORDER FOR PERMANENT INJUNCTION INFORMATION MANAGEMENT 15

Plaintiff MatchPoint Solutions and defendants Information Management Consulting, Inc., and Francis T. Khuong (collectively, the "Parties"), by and through their respective 20 counsel, hereby enter into this Stipulation to entry of injunctive relief as follows: 21

WHEREAS, on May 15, 2012, Plaintiff, MatchPoint Solutions ("MatchPoint") filed a Complaint against Francis T. Khuong ("Khuong"), and Information Management Consulting, 23 Inc. ("IMC") (collectively, "Defendants") for inter alia breach of contract, intentional 24 interference with contracts and economic advantage, and prima facie tort; 25

WHEREAS, Defendants have been represented by the attorneys whose names appear 26 hereafter; and

WHEREAS, the parties have agreed to entry of this Stipulated Final Judgment and Order for Permanent Injunction ("Order") to resolve all matters in dispute in this Action without 3 trial or adjudication of any issue of law or fact herein; 4

5 follows: 6

THEREFORE, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED as FINDINGS

1. This Court has jurisdiction over the subject matter of this case and over the Parties. 9 2. Venue in this District is proper under 28 U.S.C. § 1391(b)(2). 3. The Complaint states claims upon which relief may be granted against 10 Defendants. 12 13 the jurisdictional facts. 14 15 contest the validity of this Order. 16

17 any settlement the parties may have reached in this Action.

4. Defendants make no admissions to eh allegations in the Complaint, other than 5. Defendants waive all rights to seek appellate review or otherwise challenge or

6. This Action and the relief awarded herein are in addition to, and not in lieu of,

[PROPOSED] ORDER

I. UNILATERAL STAY-AWAY ORDER BETWEEN MATCHPOINT AND ...


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