Fill and Sign the Trade Secrets Form

IN THE CIRCUIT COURT OF_________ COUNTY, ____________ NAME OF PLAINTIFF )       ) ) V. ) NO. ) ) NAME OF DEFENDANT )       ) 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 _____________________, and having its principal place of business in ____________________ County, ____________________. 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 _____________________, having its principal place of business in _____________________ County, ____________________, and which may be served with process by serving its registered agent, ______________________________; (b) ________________________, an adult resident citizen of the _____________ Judicial District of ______________ County, _____________________, who may be served with process at ______________________________________________________________. 3. The cause of action hereinafter stated occurred and accrued in _________________ County, ________________________. 4. ____________________________ is engaged in the business of wholesale of industrial pipe, valves and supplies to end users of such consumer goods. 5. In _____________, 20__, ________________, the President of ____________________, met with _________________________, a representative of _________________, at _____________ in _______________, ___________________. The meeting was conducted in order to discuss a potential purchase of __________________ business by _________________. - 1 - 6. In conjunction with the meeting, __________________________ left with ______________________________________ certain financial statements and other private sensitive documentation concerning condition and business of __________________________. 7. In ________________, 20____, ___________________________ received a telephone call from __________________________, another representative of ___________________, informing ____________________ that ____________________ was not interested in entering the business of wholesale of industrial pipe, valves, and supplies, and would not offer to purchase _____________________________________. 8. Shortly thereafter, in __________________, 20____, __________________________ began attempting to recruit _______________________, a key employee of _____________________, to go to work for _______________________, in the business of sales of industrial pipe, valves and supplies in __________________, ________________________. ________________________ 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 20_____, ___________________ asked _______________________ if he intended to continue in his employ with ____________________________ and was assured by _______________________________ that he intended to continue as an employee. 11. In __________, 20___, _________________________, resigned from his employment at ________________________________ and went to work for ___________________________, substantially performing the same duties he 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 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 employment with_____________________ and is liable for the actions of ___________________________ its employee, ___________________________, upon the doctrine of respondeat 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 employment with _________________________________ - 2 - 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 to breach his 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, _____________________________________ BY: _______________________________, Its Attorney - 3 -