Fill and Sign the Complaint for Injunctive Relief and Damages Form

- 1 - IN THE UNITED STATES DISTRICT COURT FOR THE _________________ DISTRICT OF _________________ ________________ DISTRICT )) ) Petitioner/Plaintiff, ))) NO. Vs. )) ) Respondent/Defendant ) ) COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES COMES NOW Plaintiff, _________, formerly doing business as _________ and _________,by and through its undersigned counsel, and files its Complaint for Injunctive Relief and Damages, showing the Court as follows: 1. This action is brought by _________ against Defendant _________ for his breach of his non-competition agreement, a copy of which is attached hereto as Exhibit "A": This action also is brought against _________, as _________'s former employee, for breach of contract, breach of duty of loyalty in performance of _________'s business in violation of the common law of _________, tortious interference with business relations, and violation of the _________ Uniform Trade Secrets Act. 2. ____________ is a corporation incorporated in the State of Delaware with its principal place of business in ____________. __________ supplies products, including paper, plastics, laundry chemicals, cleaning maintenance chemicals, and dry cleaning chemicals, to many types of customers, including large customers such as schools, municipalities, and health care institutions.
Supplies paper and plastic products for many products, such as school and home construction paper. 3. Is a business company owned by an individual. The company's business is that of selling paper and plastic products on the wholesale and retail level. 4. Is engaged in its business through a network of companies. The business is that of selling paper and plastic products on a retail level to customers with a need for products such as schools, municipalities, and health care facilities. 5. Is a corporation with over 30 million in gross receipts last year and has sold paper and plastic products directly to more than 80,000 customers, such as schools, municipalities, hospitals, and other users for over forty years. On June 30, 1999, one of its former employees, Thomas s. Hester (thomas s. Hethering ), who was formerly a vice president and assistant corporate counsel, allegedly entered into and entered into a noncompete with defendant, which the parties dispute, and which in the opinion of the court would result in a substantial and materially adverse restraint of trade and unfair competition. 6. Is a business with numerous owners that have owned the business for decades. 7. Is a company that has been in existence for over fifty years, with over 60 million in gross receipts revenue in 1998. The company has over 5,000 employees and over 10,000 customers. 8. Is a business that has had over a dozen bankruptcies; a company that has been in existence for four decades and has over 30 million in gross receipts revenue; and with over 25,000 employees and 100,000 customers. 9. Is a company whose gross receipts revenue in 1993 was over 25 million. 10. Is a national business that has over 25 million in gross receipts last year and has over 100,000 customers. 11. Is a company that has over 75 million in gross receipts revenue; and that has over 5,000 employees and over 10,000 employees' customers are required to purchase paper and plastic products. 12. Is an individual business that has over 25 million in gross receipts revenue in 1996 and sold paper and plastic products during 2001. 13. Is a corporation that had been in existence for over thirty years and had over 65 million in gross receipts revenue in 1998. 14. Is a corporation that had been in existence for over thirty years, that had over 35 million in gross receipts revenue in 1996, and had over 15,000 employees and customers. On September 27, 1999, defendant hester was accused.