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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