STIPULATED PRELIMINARY INJUNCTION 

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BRENEMAN LAW FIRM 

1080 BROADACRES BUILDING 

1601 SECOND AVENUE 

SEATLLE, WA 98101 

(206) 224-1650 

FAX: (206) 224-7011

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HONORABLE ROBERT S. LASNIK 

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF WASHINGTON 

AT SEATTLE 

RBC DAIN RAUSCHER, INC., a 

Minnesota Corporation 

 Plaintiff, 

 v. 

STEVEN L. ALVORD, a Washington 

individual, and D.A. DAVIDSON & CO., a 

Montana Corporation, 

 Defendants. 

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C06-0481L 

STIPULATED PRELIMINARY 

INJUNCTION 

 This matter comes before the Court on plaintiff’s “Verified Complaint” (Dkt. # 1) and the ex 

parte “Motion for Temporary Restraining Order, Order to Appear and Show Cause Why Preliminary 

Injunction Should not Issue, Preliminary Injunction” (Dkt. # 2). 

 On April 6, 2006, the Court issued a Temporary Restraining Order (“TRO”) (Dkt. # 8). This 

matter is scheduled for an expedited hearing before the National Association of Securities Dealers 

(“NASD”) in NASD Arbitration Number 06-01781 on April 24, 2006 at 9 a.m. (“Expedited 

Hearing”). As such, the parties have agreed to stipulate to a Preliminary Injunction in this matter 

pending an Order of the NASD Arbitration Panel. 

Case 2:06-cv-00481-RSL Document 29 Filed 04/19/06 Page 1 of 3
STIPULATED PRELIMINARY INJUNCTION 

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BRENEMAN LAW FIRM 

1080 BROADACRES BUILDING 

1601 SECOND AVENUE 

SEATLLE, WA 98101 

(206) 224-1650 

FAX: (206) 224-7011

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 IT IS HEREBY ORDERED AND DECREED THAT, BASED ON THE STIPULATION 

OF THE PARTIES THROUGH THEIR COUNSEL OF RECORD: 

1. The security in the amount of $25,000.00 previously posted by plaintiff pursuant to the 

TRO be continued as security for the issuance of the Preliminary Injunction. 

2. Defendants are enjoined and restrained, directly or indirectly, and whether alone or in 

concert with others, including any officer, agent, representative, and/or employee of Alvord’s new 

employer, D.A. Davidson & Company, until the Expedited Hearing by the NASD in NASD 

Arbitration Number 06-01781, and thereafter until further Order of the NASD Panel or further Order 

of the Court from: 

a. initiating any further contact or communication with any client of RBC Dain (“RBC 

Dain clients”) whom Alvord served or whose name became known to Alvord while in the 

employ of RBC Dain either for the purpose of advising said clients of his new affiliation or 

for the purpose of inviting, encouraging, or requesting the transfer of any accounts or business 

from RBC Dain (excluding members of Alvord’s immediate family); 

b. using, disclosing, or transmitting, for any purpose, information derived from the 

records of RBC Dain concerning its customers, including for purposes of soliciting or 

accepting business or account transfers from any RBC Dain customer formerly serviced by 

Alvord. 

3. Defendants, and anyone acting in concert or participation with defendants who receives 

actual notice of this Order, including any agent, employee, officer, or representative of D.A. 

Davidson & Company, are further ordered to return to RBC Dain’s Bellingham, Washington, office 

any and all records, documents, and/or information pertaining to RBC Dain clients, whether in 

original, copied, computerized, handwritten, or any other form, and to purge any such information 

Case 2:06-cv-00481-RSL Document 29 Filed 04/19/06 Page 2 of 3
STIPULATED PRELIMINARY INJUNCTION 

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BRENEMAN LAW FIRM 

1080 BROADACRES BUILDING 

1601 SECOND AVENUE 

SEATLLE, WA 98101 

(206) 224-1650 

FAX: (206) 224-7011

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that is not capable of being physically relinquished to RBC Dain from their possession, custody, or 

control within twenty four (24) hours of service of this Order upon defendants or their legal counsel. 

4. This Order shall remain in full force and effect until such time as 1) the Court issues a 

further Order, or 2) the NASD Panel issues its Order regarding a permanent injunction. 

 

DATED this 19th day of April, 2006, at 2:30 pm. 

 Robert S. Lasnik 

 United States District Judge

A

Stipulated and Agreed to by: 

BRENEMAN LAW FIRM 

By /s/ 

Scott C. Breneman, WSBA # 18486 

1601 2nd Avenue, Suite 1080 

Seattle, WA 98101 

CHORPENNING, GOOD & PANDORA 

CO., LPA 

Eliott R. Good (Pro Hac Vice) 

Michael J. Zaretsky (Application for Leave to 

Appear Pro Hac to be submitted) 

585 South Front Street, Suite 250 

Columbus, Ohio 43215 

Tel: 614-469-1301 

Fax: 614-469-0122 

Ergood@cgmlpa.com 

mzaretsky@cgkesqs.com 

Attorneys for Plaintiff RBC Dain Rauscher, Inc. 

FOSTER & PEPPER PLLC 

By _________/s/____________________ 

Samuel T. Bull, Esq. 

Jeremy R. Larson, Esq. 

1111 Third Avenue, Suite 3400 

Seattle, Washington 98101-3299 

Attorneys for Respondents Steven L. Alvord, 

and D.A. Davidson & Co. 

Case 2:06-cv-00481-RSL Document 29 Filed 04/19/06 Page 3 of 3