Fill and Sign the Complaint Mississippi 497314764 Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF VS. NO.             AND       DEFENDANTS COMPLAINT NOW COMES       , Plaintiff, ("       ") and files its Complaint against Defendants,       , ("       ") and       ("       ") and for cause of action would show unto the Court the following, to - wit: 1. Plaintiff,       , is a corporation organized and existing pursuant to the laws of the State of Mississippi, and having its principal place of business in       County, Mississippi. 2. The Defendants are: (a)       , a non - resident corporation organized and existing pursuant to the laws of the State of       and authorized to do business in the State of Mississippi, having its principal place of business in       County, Mississippi, and which may be served with process by serving its registered agent,       ; (b)       , an adult resident citizen of the       Judicial District of       County, Mississippi, who may be served with process at       . 3. The cause of action hereinafter stated occurred and accrued in       County, Mississippi. 4.       is engaged in the business of       to end users of such consumer goods. 5. In             ,       , the President of       , met with       , a representative of       , at       in       , Mississippi. The meeting was conducted in order to discuss a potential purchase of       business by       . 6. In conjunction with the meeting,       left with       certain financial statements and other private sensitive documentation concerning condition and business of       . 7. In             ,       received a telephone call from       , another representative of       , informing       that       was not interested in entering the business of       , and would not offer to purchase       . 8. Shortly thereafter, in             ,       began attempting to recruit       , a key employee of       , to go to work for       , in the business of sales of       in       , Mississippi.       continued to try to lure       from       for several months, continuing to offer       more money and benefits. 9. At all times material hereto,       was in a confidential relationship with       and owed       a fiduciary duty of good faith and fair dealing. 10. In early       ,       asked       if he/she intended to continue his/her employment with       and was assured by       that he/she intended to continue as an employee. 11. In       ,       ,       , resigned from his/her employment at       and went to work for       , substantially performing the same duties he/she had performed at       for       . 12.       and       have wrongfully misappropriated       trade secrets in the form of customer lists and bid computation procedures, all to the detriment of       's former employer,       , to whom he/she owed a fiduciary duty, and in favor of       's new employer,       , resulting in damage to       . 13. At all times,       's misappropriation of trade secrets has been conducted while in the course and scope of his/her employment with       and is liable for the actions of       its employee,       , upon the doctrine of respondent superior. 14. The customer list and bid computation methods of       constitute a confidential information of       as an employee and/or former employee,       had a high duty not to disclose such information to others to the detriment of       .       , while in the course and scope of his/her employment with       disclosed and utilized this confidential information to the detriment of       and the benefit of       , causing damage to       . 15. Due to the wrongful conduct of       and       ,       has been damaged and will continue to suffer damage to its business, in the sum of $       . 16. The actions of       in requiring the confidential financial information pertaining to the business of       under the pretext of purchasing the business of       , and then hiring the key employee of       and inducing him/her to breach his/her fiduciary duties owed to       were committed with willful and wanton disregard for the rights of       , and       is entitled to recover punitive damages from Defendant,       , in such sum as to be established by the Court upon a trial hereof. WHEREFORE, PREMISES CONSIDERED,       , sues and demands judgment against       and       , jointly and severally, in the sum of $       , and punitive damages against Defendant,       , in such sum as will be established by the Court upon a trial hereof, together with its costs. Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for