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HomeMy WebLinkAbout14-7109s E C T I 0 N s E C T I 0 N Supreme Courfof Pennsylvania Cour .:of,Co n n Pleas OC i1 CoWtt She tCounty LA For Prothonotary Use Only: Petition Declaration of Taking 12 Complaint * Writ of Summons * 1lilr. t „7/ Docket No: fit 7/ 041 ' C • The information collected on this forret is used solely for court administration purposes. .This forret does not suppletnent or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: Petition Declaration of Taking 12 Complaint * Writ of Summons * Transfer from Another Jurisdiction $ Lead Plaintiff's Name: Shoemaker's Insurance Agency, Inc. Lead Defendant's Name: David B. Wolf Dollar Amount Requested: * within arbitration limits Are money damages requested? Yes l No (check one) outside arbitration limits Is this a Class Action Suit? * Yes El No Is this an MDJAppeal? IIS Yes No Name of Plaintiff/Appellant's Attorney: David W. DeLuce Esq., Anthony T. Lucido, Esq., Johnson Duffle Law Offices a Self -Represented (l'ro Se] Litigant) X Check here if you have no attorney (are Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) O Intentional El Malicious Prosecution O Motor Vehicle 0 Nuisance O Premises Liability I© Product Liability (does not include mass tort) O Slander/Libel/ Defamation O Other: MASS TORT O Asbestos O Tobacco O Toxic Tort - DES 0 Toxic Tort - Implant 0 Toxic Waste • Other: PROFESSIONAL LIABLITY El Dental O Legal O Medical O Other Professional: CONTRACT (do not include Judgments) O Buyer Plaintiff O Debt Collection: Credit Card • Debt Collection: Other O Employment Dispute: Discrimination i' Employment Dispute: Other 0 Other: REAL PROPERTY El Ejectment O Eminent Domain/Condemnation 0 Ground Rent O Landlord/Tenant Dispute O Mortgage Foreclosure: Residential 0 Mortgage Foreclosure: Commercial O Partition O Quiet Title i.- _i Other: CIVIL APPEALS Administrative Agencies 0 Board of Assessment 0 Board of Elections • Dept. of Transportation • Statutory Appeal: Other O Zoning Board 0 Other: MISCELLANEOUS • Common Law/Statutory Arbitration O Declaratory Judgment O Mandamus Non -Domestic Relations Restraining Order ▪ Quo Warranto 0 Replevin El Other: Updated 1/1/2011 JOHNSON, DUFFIE, STEWART & WEIDNER By: David W. DeLuce I.D. No. 41687 By: Anthony T. Lucido I.D. No. 76583 By: Brian W. Carter I.D. No. 204934 301 Market Street, P.O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Shoemaker's Insurance Agency, Inc., Plaintiff v. David B. Wolf, Defendant F,_ `FD—OE I C;j HE PRO i3,..3 6 F • r nt. ' f,~ CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. /1/' 7'1' ea/ CIVIL ACTION — LAW INJUNCTIVE RELIEF AND DAMAGES REQUESTED NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these pages by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Ps --.7s- pi, 4 4'"4 �'��' Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 (800) 990-9108 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en Ia Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en Ia demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 (800) 990-9108 JOHNSON, DUFFIE, STEWART & WEIDNER By:. David W. DeLuce I.D. No. 41687 By: Anthony T. Lucido I.D. No. 76583 301 Market Street, P.O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Shoemaker's Insurance Agency, Inc. Plaintiff v. David B. Wolf, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION — LAW INJUNCTIVE RELIEF AND DAMAGES REQUESTED COMPLAINT AND NOW, comes the Plaintiff, Shoemaker's Insurance Agency, Inc. ("Shoemaker") by and through its attorneys, Johnson, Duffie, Stewart & Weidner, P.C., and files this Complaint against David B. Wolf ("Wolf) for violation of the Pennsylvania Uniform Trade Secrets Act, breach of contract, tortious interference with contractual relations, and for injunctive relief, and in support thereof alleges as follows: 1. Plaintiff is Shoemaker's Insurance Agency, Inc. ("Shoemaker"), a licensed insurance agency organized under the laws of the Commonwealth of Pennsylvania and contracted as a captive agent representing Nationwide Mutual Insurance and its affiliated companies, with a principal place of business at 115 Fairfield Street, Newville, Pennsylvania and a separate office located in Mount Holley Springs, Pennsylvania. 2. Plaintiff Shoemaker is an Independent Contractor Exclusive Agent representing Nationwide Mutual Insurance Company and its affiliated and subsidiary companies ("Nationwide"). As an exclusive agent, Shoemaker services Nationwide policyholders and is responsible for protecting Nationwide property in its custody, care and control. 3. David B. Wolf ("Wolf") is an adult individual, who is believed to have a residence at 1550 Harney Road, Littlestown, Pennsylvania, 17340. Wolfs Employment with Shoemaker 4. On or about April 19, 2004, Shoemaker hired Wolf as a licensed insurance agent, primarily to sell Nationwide policies of insurance and to market and generate commercial insurance clients in the Central and South Central Pennsylvania market. 5. At the time of his hiring, Wolf had no book of business. 6. When Wolf was hired, he signed a contract with Shoemaker, setting forth, inter alia, Wolf's duties and obligations as an employee. That Agreement, dated 4/19/04, is attached hereto as Exhibit "A." 7. The Agreement signed by Wolf specifically provided that he was an exclusive agent for Shoemaker and Nationwide Insurance, and that he would not directly or indirectly place insurance with another company, nor would he act as an agent or representative of another company. 8. The Agreement further provided that, upon termination of the Agreement, Wolf could not solicit or service Shoemaker policyholders following the end of his employment. 9. On May 25, 2010, the Agreement between Shoemaker and Wolf was renewed, and it contained the same binding exclusive representation and non -solicitation provisions. The updated Associate Agent Contract, dated 5/25/2010, is attached hereto as Exhibit "B." 2 10. In addition to the above contracts, during his employment Wolf was provided with a copy of the Nationwide Agency Administrative Handbook ("Handbook"), which all employees were required to follow. 11. Wolf was instructed and understood that as a Shoemaker employee and Nationwide agent, he was required to abide by all terms and conditions of the Handbook. 12. In particular, Wolf understood, based on the express provisions of the Handbook relating to "Ownership and Control of In-Force Business" that he, as the employee and agent, had no ownership of the book of business, had no right to assign or transfer the book of business, and that all policyholder information remained within the exclusive ownership and control of Shoemaker and Nationwide. See relevant Handbook excerpt relating to Policy Ownership, attached hereto as Exhibit "C." 13. As an employee of Shoemaker, Wolf also had a common law duty of loyalty and fiduciary responsibility to always act in good faith to further the interests of his employer, and to do nothing to undermine, sabotage or damage Shoemaker's business interests and client relationships. 14. Wolf worked for Shoemaker from April of 2004 until he suddenly resigned on Monday, November 17, 2014. 15. Wolf gave no prior warning of his intention to resign, provided no explanation, but merely announced to Shoemaker President, Andrew L. Shoemaker, that he was quitting, effective immediately. 16. As Plaintiff has discovered following Wolf's departure, it turns out that the reason Wolf provided no notice of his intentions, was because he had already illicitly and secretly transferred to himself — via both email and in hard copy format — private, confidential policy holder information constituting trade secrets of the company, for the purpose of soliciting 3 existing Shoemaker customers and convincing them to transfer their business to different insurance companies that Wolf was representing. Wolfs Intentional and Improper Misappropriation of Shoemaker Trade Secrets In the Form of Detailed, Confidential Policyholder Information 17. Upon information and belief, Wolf is now an insurance agent with a company called Advantage Insurance Group, Inc. 18. Upon information and belief, in the months and weeks prior to his departure from Shoemaker, Wolf — with full knowledge that he was acting wrongfully and in violation of both his employment Agreements and his common law obligations of employee loyalty — covertly transferred to himself confidential policy holder information for hundreds of Shoemaker customers and/or Nationwide policyholders, including all details regarding those customers' respective policy amounts, premiums, policy renewal dates and in-place coverage. 19. Upon information and belief, Wolf intended to use this confidential policyholder information — and has in fact used it — to take Shoemaker's customers and convince them to transfer their policies to insurance companies that Wolf now represents, either individually or through his new employer, Advantage Insurance Group, Inc. 20. Upon information and belief, even before Wolf left the employ of Shoemaker, he was already actively soliciting existing customers to transfer their policies to different insurers, while misrepresenting to those customers that he was acting on behalf of the Shoemaker agency. 21. Thus, while Wolf was still being paid by Shoemaker, Plaintiff has reason to believe, based on its post -termination investigation of Wolf's activities, that he was out in the market seeking to divert business away from Shoemaker while never disclosing to existing 4 Shoemaker customers and/or Nationwide policyholders that he was furthering his own interests to the financial detriment of Shoemaker. 22. The weekend before Wolf announced his resignation, he downloaded 48 megabytes of policyholder information — including existing premium, policy renewal and in-force coverage information — to his personal email account. 23. Prior to that clandestine data dump of all the information he would need to proposition existing Shoemaker customers and/or Nationwide policyholders with lower premium offers, Wolf also took eight file drawers of Shoemaker customer and/or Nationwide policyholder information from Shoemaker's Mount Holley office. 24. Shoemaker reported the theft of the file drawers and the confidential information they contained to the police; eventually, after the authorities contacted him, Wolf returned the customer/policyholder files, although presumably not before making copies for himself. 25. Plaintiff's investigation has now confirmed that Wolf, both before and after his departure, has contacted multiple Shoemaker customers and/or Nationwide policyholders and convinced them to transfer policies to competing insurance companies. 26. Wolf has used the misappropriated policyholder information he took from Shoemaker to contact existing policyholders and, more importantly, to learn exactly what premium amounts to quote that would be less than the customer's existing policy. 27. The detailed and confidential policyholder information taken by Wolf, constitutes trade secrets within the meaning of Pennsylvania's Uniform Trade Secrets Act. 12 Pa.C.S. §5301 et. seq. 28. Wolf knew or should have known that his conduct, in taking policyholder information and using that to undermine Shoemaker's and Nationwide's existing business relationships, was wrongful and constituted a misappropriation of property that was not his. 5 29. Wolf's actions — as evidenced by his subterfuge in downloading policyholder information to his personal email the very weekend before his sudden resignation — are willful and malicious, and are plainly indicative of someone acting recklessly indifferent to the rights of his former employer, Shoemaker. 29. Plaintiff Shoemaker is entitled to both compensatory and punitive damages against Wolf, along with immediate injunctive relief to prevent Wolf from continuing to use misappropriated trade secrets to pilfer clients and to permanently damage Shoemaker's business interests. COUNT I MISAPPROPRIATION OF TRADE SECRETS IN VIOLATION OF THE PENNSYLVANIA UNIFORM TRADE SECRET ACT, 12 PA.C.S.A. §5301 SHOEMAKER'S INSURANCE AGENCY, INC. V. DAVID B. WOLF 30. Shoemaker incorporates the averments of paragraphs 1 through 29 above as if the same were set forth herein at length. 31. Wolf acquired the Trade Secrets and proprietary information of Shoemaker customers and/or Nationwide policyholders — specifically, the detailed and confidential policyholder information that he emailed to himself -- through his employment, and the circumstances of his employment with Shoemaker gave rise to a duty to maintain the secrecy and limit the use of such information. 32. Wolf acquired the Trade Secrets and proprietary information of Shoemaker customers and/or Nationwide policyholders through his employment and owed and continues to owe a duty to Shoemaker to keep this information secret and, in particular, not to use this policyholder information to undermine, damage and sabotage Shoemaker's and Nationwide's existing business relationships. 6 33. Wolf's active solicitation and contact, via direct or indirect means, with Shoemaker's current customers is not authorized 34. Nationwide Insurance, the insurance carrier with which Shoemaker has an exclusive agency agreement, wrote a cease and desist letter to Wolf on December 2, 2014, demanding that he stop soliciting Shoemaker clients, violating the terms of his employment contract, and interfering with policyholders and their contracts of insurance. Upon information and belief, Wolf has ignored that warning and continues brazenly to use misappropriated policyholder information to harm Shoemaker's business. The cease and desist letter is attached hereto as Exhibit '�D." 35. The conduct of Wolf as described above consistitutes willful and malicious misappropriation of Shoemaker's Trade Secrets and proprietary information in violation of the Pennsylvania Uniform Trade Secrets Act, 12 Pa.C.S.A. §5301 et seq., and as specifically defined in 12 Pa.C.S.A. § 5302. 36. Shoemaker will be irreparably harmed by Wolf's continued and prospective misappropriation of policy holder Trade Secret information through: loss of customer contracts; loss of revenue; and loss of business reputation. 37. Shoemaker Tacks an adequate remedy at law and, unless enjoined by this Court, Wolf will continue to cause irreparable injury to Shoemaker as a result of his knowing and wrongful acts complained of herein. 38. In view of the foregoing, Wolf must be enjoined by this Court from his ongoing and future possession, misappropriation and wrongful use of policyholder information pursuant to the Uniform Trade Secrets Act, 12 Pa.C.S. § 5303(a), which constitutes Trade Secrets of Shoemaker. 7 WHEREFORE, Shoemaker demands: a. judgment in its favor; b. a finding that David B. Wolf willfully and maliciously misappropriated Trade Secrets of Shoemaker, c. injunctive relief (pursuant to 12 Pa.C.S.A. § 5303), an award of compensatory damages and exemplary damages (pursuant to 12 Pa.C.S.A. § 5304), and attorneys' fees and costs (pursuant to 12 Pa. C.S.A. §5305); and d. any other relief this Court deems just and appropriate. COUNT II TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS SHOEMAKER'S INSURANCE AGENCY, INC. v. DAVID B. WOLF 39. Shoemaker incorporates the averments of paragraphs 1 through 38 as if the same were set forth herein at length. 40. Shoemaker maintains, by virtue of the insurance policies written on behalf of Nationwide and other carriers, relationships with policy holders. 41. These insurance contracts, and their renewals, involve relationships cultivated with customers over a span of many years, and are based upon mutual trust, professional expertise and outstanding performance of the insurance services Shoemaker provides for its policyholders. 42. Customer contacts and the business reputation of Shoemaker are vital to the continued success of Shoemaker's operations, its growth, and its financial viability in a highly competitive insurance marketplace. 43. Shoemaker believes, and therefore avers, that Wolf has and will continue to contact Nationwide policyholders and customers of Shoemaker, and has used detailed 8 policyholder Trade Secret information to cause these customers not to renew their insurance contracts with Nationwide, and to sever business ties with Shoemaker. 44. Shoemaker's current relationships with policyholders are based upon longstanding business dealings, professional service, and mutual trust developed over the years through Shoemaker's hard earned reputation for integrity, customer loyalty and expertise in the insurance industry. 45. Wolf's misappropriation will affect those customer relationships and has already resulted in customers terminating their existing insurance policies, or refusing to use Shoemaker in the future for their insurance needs. 46. Wolf's conduct is intentional, wrongful, tortious, and without privilege. 47. Wolf's conduct, in wrongfully taking protected Trade Secrets in the form of confidential Nationwide policyholder information not available to anyone in the marketplace, was done in an effort to retaliate against and damage the business interests and reputation of Shoemaker. WHEREFORE, Plaintiff, Shoemaker's Insurance Agency, Inc., demands judgment in its favor and requests an award of compensatory damages, punitive damages and any other relief this Court deems just and appropriate. COUNT III BREACH OF CONTRACT SHOEMAKER'S INSURANCE AGENCY, INC. v. DAVID B. WOLF 48. Shoemaker incorporates the averments of paragraphs 1 through 47 as if the same were set forth herein at length. 49. Wolf signed written employment agreements with Shoemaker setting forth his contractual duties, obligations and responsibilities to Shoemaker and its policyholders. 9 50. The contracts required Wolf, during his employment, to exclusively represent both Shoemaker and Nationwide, and to not directly or indirectly place insurance through or for any other company or agency. 51. Upon information and belief, Shoemaker believes that Wolf breached his duty of exclusive representation by approaching policyholders while still employed by Shoemaker in an effort to convince them to enter into policies of insurance with different companies, all the while failing to disclose to the policyholder that Wolf was not acting in furtherance of Shoemaker's interests, but rather, to its detriment. 52. Wolf's contract precluded him from soliciting or servicing any Shoemaker policy holders, or interfering with their existing policies, for a period of three years following his termination of employment. 53. Wolf has knowingly breached the non-solicitation and non-compete provisions of the contract by actively soliciting and servicing existing Shoemaker customers and/or Nationwide policyholders on behalf of himself or his new employer, and by directly interfering with existing policies by enticing customers to renew policies with competing insurance companies. 54. As a result of Wolf's breach of his contractual obligations, Shoemaker has sustained monetary damages, in the form of lost premium revenue, lost bonus opportunities, declining market share, future lost profits and other compensatory losses. 10 WHEREFORE, Plaintiff, Shoemaker's Insurance Agency, Inc., demands judgment in its favor and requests an award of compensatory damages, and any other relief this Court deems just and appropriate. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. David W. DeLuce, Esquire I.D. No. 41687 Anthony Lucido, Esquire I.D. No. 76583 301 Market Street — P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Plaintiff Shoemaker's Insurance Agency, Inc. By: Date: December 9, 2014 :668330 11 EXHIBIT A This contract is between Shoemaker's Insur ce Agency, Inc. An ew L. Sh emaker V.P. a Nationwide agent (hereinafter "agent , and [} at/ :3 LVO l' CSR/Marketing Assistant (hereinafter "asso late"). The parties agree that this contract will become effective on y ! ' - 0 2. Appointment. The Agent agrees to Insurance Companies for appointme comply with the terms of this contra Agreement. certify the associate to the Nationwide t as an agent and the Associate will t and the Agency Associate Agent Expenses . Associate will pay all expenses in connection with his or her effort for agent. Any expenses charged to the Agent must have the Agent's prior approval. 3. Licenses. Associate will be res any required license. Associate agr he/she has the required license auth onsible for securing and keeping in effect es not to solicit any lines of insurance unless rizing Associate to do so. 4. Errors and omissions Insurance. Agent will secure E&O protection for Associate. 5. Exclusive Representation. Assoc employment hereunder faithfully an Associate further agrees that during Licensed as an agent, solicitor. Rep Company other that those Nationwi Appointed him or her and will not Whatsoever with or through any ins Insurance Companies which have a Or broker thereof, unless authorized 6. 7. Compensation. See Addend ate agrees to devote the entire time during diligently to the services if the Agent. 's/her employment he/she will not be sentative, or broker for any insurance e Insurance Companies, which have ectly or indirectly place and insurance ance company other that those Nationwide • ointed him/her or the agent, representative, and directed to do so by the Agent. (A)- Semi-annual Review The remuneration specified shall be u e sole remuneration due Associate from the Agent for all services rendered. Fiduciary Responsibilities. All funds coming into the possession of the Associate shall be promptly paid to the Agent without delay. However, should they not be paid to the Agent, they shall nevertheless, be considered funds of the Agent and the Agent shall have a first lien on all compensation due or which may become due the Associate to the extent of such funds due to Agent. Agent may deduct said funds from Associate. 8. No Competition. Associate agrees that he/she will not, either directly or indirectly by ad for himself or as agent for another or through others as agent, engage in or be licensed as an agent, solicitor, representative or broker or in any way be connected with the sale, advertising or solicitation of fire, casualty, health or life insurance in the area described below for a period of one year from the date of voluntary or involuntary termination of employment with the agent, or, should the Agent find it necessary by legal action to enjoin Associate from competing with the Agent, one year after the date uch injunction is obtained in the following area: Within Twenty-five mile of the p ' cipal place of business located at 115 Fairfield Street Newville, PA 17241. 9. Policyholder Solicitiation. In any ju appearing in paragraph 8 is held to be i decision, the Associate agrees that upoi thereafter refrain from further solicitati Agent and from interfering in any way policies and policyholders in the geographical area described in paragraph 8 or such other period being the longest permitted by law less than one year. Further, Associate acknowledges he has no right to policyholder lists, expiration dates, or marketing techniques. isdiction where a convenent similar to that ivalid either by statute or by judicial termination of this contract he/she shall n or servicing of policyholders of the or a period of one year with existing 10. Termination. Associate's employment hereunder shall terminate upon the death of the Associate and said employmen may be terminated at will by the Agent or by the Associate by mailing or delive g to the other written notice of termination. Upon termination of the Associate's e any compensation shall absolutely eas firm, or corporation claiming under or whatsoever against the Agent for any compensation which, in the usual coax become certain and due and payable tc such termination. nployment, compensation or the right to and neither the Associate or any person, through them shall have any claim ;ompensation of any nature, except only fc e of business, had fully accrues and t he Associate prior to the effective date o 11. Legal Action. The Associate shall be able to the Agent for all expenses, loss ort damage suffered by the Agent on acco nt of any violation of or refusal or failor to comply with the terms of this contract. The Agent shall have the right to institute legal proceedings to enjoin the Associate from doing any act in violation of this contract or to enforce the specific performance of all the agreements on the part of the Associate. The rights and remedies reserved by the Agent hereunder shall be construed and held to be cummulative and not exclusive of anyother right or remedy available to the Agent. It is agreed that no action, suit, proce under this contract unless it is comm years after the cause of action for w in this paragraph are prohibited by th issued, then these limitations shall b minimum period of limitation perm' Prior contracts superseded. The ex supersede and take the place of any p delivery of this contract shall not aff due the Agent under the provisions o shall the execution of this contract nu into between Associate and the Agen that contract. 13. Severability. If any clause or part o reason, then such invalidity shall not parts thereof not invalid shall remain CSR/Marketing Assistant'' Date �1�1u-aLj ding at law or in equity shall be brought need and process is served within three ch suit is brought. If the limitations set forth stutes of the state which this agreement is deemed amended to agree with the ed by such statutes. cution and delivery of this contract shall or contract, provided that the execution and t Associate's obligation to pay any money any other agreement, written or oral, nor fy and negotiated compensation entered on cases written prior to the execution of this agreement shall be held invalid for any ect any part of this Agreement and the full force and effect. gent Date EXHIBIT B i U 7'ttis= Gittrlfract 7s : by .aiti ,Agent,' locateri • a f ref fenced; attachmer 'T'EI MINATION 5 (emsCedes A c'. i) 0 r Pero sJ 5,/I'l) 614 9,1c,-( d a s A'SSOcla Two -P :e 4'ger :C•c ritTa . • �eet�ieits �rAdfew 1146 r n'.•/Awn- 16:5 -d a:Natisirtiwiiiei strrarrce .�-.4k ' (/ 5'o2 Nal/ ,.;/e ereiii46—r:-.,:406 ale;.) 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Genefat, Variable;Ljte; . a':Is an nde)D nderit contras tor,: Assgc1ate.; place ,arid i ipnner at:soiioting:l*irancs, servicing potiaytroiders, acid G proYisians vhTs Contra.cc?i ipiea rate`.vviili .Mat on vicle•s;tiigh f .pust:omerseit�"' me• erwse cgrTying otic tile,': Gat standards and lts" quetatyr: JCENS'E5 :Assdolate.wi l'secnreand kee 3n edea an ie: wrec};Itdenses=.to sent iitatfd! wide • Insurance -:Coat' antes;:and wiEIE'not solicit;insurance _with;reference�toan':: e;.of insurani for which; .. P Y'b'P . . A'ssooiate is riot tfcerisedby the appropriate Department •of lnsuraince Associate r;iusi av •he a valid: o;iecei,e comrriissiori'o TinsUCancs saki:: 'Sa00.44 .11Sj1NS,{)i7ANGE Agent`. from compensation (cctn otly " 0 anitiraey) poi .Bq igL'l EXt LLISIVE•"REPRESENTATION:: 'Assb`ciate.:witi not, • representative. ar broker for any insurance '.company Companies .Which: have appointed him/her; and' will``. not d. 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'' " cprlipontii:1 11044COcc4OPPrilY-1.0P0f11110040bii...?ilirg4'i.165/0.--i*fol;i404r.§Tg,pf.biSqitf*,.;:400,101St:.pcsqrLiod:a41;..1 become certarn ari due Arip".pafp*-;-.9 . * -„. • irti)..f..0iM*.00*1*.ie0i....01ffi.0frii:'.0§6t4::0r.1600601i6.*,54041k00ifOft-ti40664111'•••0f.'.1ii#::04#:a .• he theto • • y sbrought ep(his • :PO4:d.f;:ihf0*.K-10::f0§511[POrlPO4.'.0P0:"P:t:40:02#4*1?Ct-W101n:#1.ts0.'.:,M-X'*ii404#§:f.':'-thkf-g..i400'10T. • • —.0041V iiW4f1ty7t 11411:ipoNtio6fiy other pari afnva1rt shall Contract and Ibe pr1s• fhereot not.•• „.. . Asspdate Narne A.C2-TR./141 At.5i3drAtiebigtatiti'e , .• ' . • . ..... • • *. • Ai6idr6§s. • • • ta10*. 'Adaltp:0 EXHIBIT C Agency Administration Handbook Policy Ownership Ownership and The interest of the policyholders, agents, employees, and the Control of In -Force public are best served through policyholder ownership and control Business of the business. Such control helps to develop and maintain Nationwide's financial soundness and provide high quality insurance service at the lowest possible cost. Therefore, the policyholders, through Nationwide, shall maintain ownership and control of the business and all policyholder information and such ownership rights shall not be vested with either agents or employees. Nationwide retains the right to continue to provide insurance services to any and all customers. Nationwide has the exclusive right to assign the business. Agents have no ownership of the book of business and have no transferable interest that they can sell to another agent or entity. However, the agent is responsible for protecting the confidentiality and security of customer information at all times. Part of this responsibility includes drafting and implementing an information security policy, which details procedures for protecting customer information. It is entirely up to Nationwide to reassign cancelled agent business, with no financial considerations payable to the cancelled agent from any source other than those provided by the agent's security compensation benefits. Any cancelled agent that interferes with a transfer of a book of business by influencing policyholders to lapse, cancel, or replace a contract in force with Nationwide is subject to the loss of agent's security compensation. It is a violation of an agent's contract to interfere with the assignment of a book of business to another agent. Agents who interfere with the assignment of a book of business may have their contract with Nationwide cancelled. Unassigned Unassigned policies shall be assigned, at the sole discretion of Policies — Casualty Nationwide, at such times and in such quantities as to produce the and Fire maximum benefit to policyholders, Nationwide, and agents. It is Nationwide's policy to assign an active agent to each customer as soon as practical after a change in agent status causes a policy to be unassigned. The following criteria will be considered when making an 09 -Policy Ownership 1 7/26/07 Agency Administration Handbook Policy Ownership con't Unassigned assignment: Policies — Casualty and Fire con't Unassigned Policies - Life Inter -Regional Transfer of Policyholders Solicitation of Nationwide Policyholders 09 -Policy Ownership • The existence of any other active agent on. policies in the customer's name; • Any expressed desire for a particular agent on the part of the policyholder; • Location of the agent in relationship to the policyholder's residence or insured property; • Ability and willingness of the agent to service the customer. Such policies will be processed and recorded under the approved Nationwide procedure. Unassigned life policies are transferred to active agents for service but not for compensation. Exceptions are when a rider is added to the original policy or the selling of an additional insurance offer, term or permanent conversion derived from an orphan policy. Any of these transactions will make the placing agent eligible for a commissionable interest in the orphan policy from which the sale was generated. Nationwide's intent to transfer policyholders, as determined by the transferring region, as expeditiously as possible and to render all services necessary to complete the transfer as smoothly as possible. See Family Property Portfolio (IRT) for full details. The agent's mission is to write new policies of insurance. Solicitation of one Nationwide agent's business by another Nationwide agent is inconsistent with this mission. Agents may not solicit or induce policyholders to request policy transfers from another active agent, whether such policyholders were originally written by the active agent or assigned to them. Activity of this nature will be considered a violation of the Agent's Agreement and may result in cancellation. An active agent realizes that other Nationwide agents may solicit or sell additional insurance to his/her policyholders. Sales management, however, must not encourage or promote the solicitation of one active agent's policyholders by another agent. 2 7/02/07 EXHIBIT D December 2, 2014 Mr. Dave Wolf 1550 HARNEY RD LITTLESTOWN, PA 17340 Re: Agency Associate Agent/Office Staff Agreement Dear Mr. Wolf: ..Nationwidire Certified Mail Return Receipt Reauested Our Office represents Nationwide Mutual insurance Company (Nationwide) and its affiliated companies on legal matters. it has come to Nationwide's attention that your employment with Andrew Shoemaker Insurance Agency, Inc. ("Agency") ended November 16, 2014. Further, Nationwide has received information that you have solicited Nationwide customers in violation of yourAGENCY ASSOCIATE AGENT/Office Staff Agreement ("Independent Contractor Agent Only") that you signed on April 19, 2004, while employed by the Agency, and you may have taken proprietary and confidential customer information when you left the.Agency. Nationwide hereby demands and insists that you immediately cease and desist from soliciting Nationwide policyholders, using Nationwide's confidential information and/or otherwise interfering with existing Nationwide policyholders. Further, Nationwide demands that you return any and all 'Nationwide confidential and proprietary information in your possession, including but not limited to, customer lists, customer files and any other customer information including electronic data. This information should be returned to the Shoemaker Agency immediately. If you have any questions or concerns regarding the -return of Nationwide's confidential information, please. contact Sales Manager Brad Guise at (7 17)480-1621. Regards. kent . Simmons Assistant General Counsel Office of General Counsel Nationwide Mutual Insurance Company One Nationwide Plaza, MS: 1-35-402 Columbus, Ohio 43215 Cc: Brad Guise Nicole Schlosser Page 1 of 1 VERIFICATION 1, ANDREW SHOEMAKER, President of Shoemaker's Insurance Agency, Inc., verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE: r2 -q47 Andrew Sho- aker, President JOHNSON, DUFFIE, STEWART & WEIDNER By: David W. DeLuce I.D. No. 41687 By: Anthony T. Lucido I.D. No. 76583 301 Market Street, P.O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Shoemaker's Insurance Agency, Inc. Plaintiff v. David B. Wolf, Defendant F!LED-OFFICF THE PROTHONOTAin 2011i DEC -9 Ph 1.4:03 CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 7/09 eat -41 CIVIL ACTION - LAW INJUNCTIVE RELIEF AND DAMAGES REQUESTED PLAINTIFF'S EMERGENCY MOTION FOR SPECIAL. AND PRELIMINARY INJUNCTIONS AND NOW, comes the Plaintiff, Shoemaker's Insurance Agency, Inc., by and through its attorneys, Johnson, Duffie, Stewart & Weidner, P.C., and moves this Honorable Court for Special and Preliminary Injunctions pursuant to Pa.R.C.P. 1531 and 12 Pa.C.S.A. § 5303(a), and in support thereof avers the following: 1. The Plaintiff, Shoemaker's Insurance Agency, Inc. (hereinafter "Shoemaker"), has filed a Complaint with Exhibits which is incorporated herein by reference. 2. As set forth in the Complaint, Defendant has violated the Pennsylvania Uniform Trade Secrets Act, 12 Pa.C.S.A. § 5301 et. seq. (hereinafter the "Act"), by willfully and maliciously misappropriating Shoemaker's trade secrets, as that term is defined by 12 Pa.C.S.A. § 5302. 3. Specifically, and as set forth in detail in the Complaint, Defendant was an employee and insurance agent for Plaintiff, who surreptitiously took confidential, policyholder information - including key policy renewal, premium and coverage information - and has used that information to improperly solicit Plaintiff's existing customers to convince them to transfer their policies of insurance 1 to different companies now represented by Defendant. 4. Plaintiff's investigation of Defendant's activities both prior to and subsequent to his sudden resignation on November 17, 2014, has revealed that Defendant has already used these trade secrets to entice longstanding clients of Plaintiff to transfer their insurance policies. 5. Upon information and belief, based on the facts gathered to date from existing policyholders, Defendant is continuing to use the information he misappropriated to target Plaintiff's customers — primarily business people with commercial insurance policies — in an effort to take those customers for himself and his new employer. 6. As a result of these violations of the Act, Shoemaker will suffer immediate and irreparable harm to its business interests, should Defendant be permitted to continue to wrongfully use this information to contact Shoemaker's current customers in an effort to tortiously interfere with these contractual relationships. 7. Shoemaker will suffer immediate harm if Defendant is not enjoined from misappropriating its trade secrets in an effort to tortiously interfere with the existing and prospective contractual relationships with Shoemaker's customers. 8. Shoemaker will suffer immediate and irreparable harm to its continued relationship with its customers if Defendant is not enjoined from misappropriating trade secrets in an effort to tortiously interfere with these existing business relationships. 9. The harm suffered by Shoemaker cannot be adequately compensated by damages. 10. The granting of this Special Injunction will return the parties to the status quo existing prior to Defendant's willful, malicious and ongoing violations of the Act by allowing Shoemaker to protect proprietary, Nationwide policyholder information and trade secrets as set forth in its employment contracts with Defendant. 11. Shoemaker's right to relief is clear in that Defendant's conduct is in direct violation of the Pennsylvania Uniform Trade Secrets Act, which permits injunctive relief against any actual or threatened misappropriation. 12 Pa.C.S.A. § 5303(a). 12. The harm that might result to Defendant from the entry of a Special Injunction will be substantially less than the harm that would be done to Shoemaker should Defendant continue to misappropriate trade secrets in an effort to tortiously interfere with Shoemaker's current and prospective contractual relations with its existing customers. 13. By reason of all the foregoing, Shoemaker will suffer immediate and irreparable harm and is therefore without an adequate remedy at law. Shoemaker's right to a Special injunction is clear. WHEREFORE, Plaintiff Shoemaker's Insurance Agency, Inc., respectfully requests that this Honorable Court issue special and preliminary injunctions until final hearing, in order to: A. Enjoin and restrain Defendant from using misappropriated policyholder information in violation of the Pennsylvania Uniform Trade Secrets Act, 12 Pa.C.S.A. § 5301 et. seq., to solicit Plaintiffs customers with the intention of damaging Plaintiff's business interests and customer relationships; B. Enjoin Defendant from contacting, either directly or indirectly through any new employer, any of Shoemaker's current customers contained in the policyholder information misappropriated by Defendant; C. Schedule this matter for a hearing on the merits; and D. Granting such other equitable relief as this Honorable Court deems just and proper. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. By: Date: December 9, 2014 :668331 David W. DeLuce, Esquire I.D. No. 41687 Anthony Lucido, Esquire I.D. No. 76583 301 Market Street — P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Plaintiff SHOEMAKER'S INSURANCE AGENCY, INC. Plaintiff v. DAVID B. WOLF, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. /x/'7/6% 4,J CIVIL ACTION — LAW INJUNCTIVE RELIEF AND DAMAGES REQUESTED // ORDER OF COURT /7 day o/>.p , i_ -e -e2 , 2014, upon review of the Complaint and Emergency Motion for Special and Preliminary Injunctions field by Plaintiff, Shoemaker's Insurance Agency, Inc., it is hereby ORDERED that a hearing on the Emergency Motion for Special and Preliminary Injunctions shall be held on 4 i Pi. /S , 2014 in Courtroom No. t at (,30 �.m. An+hong l Lueido, "1aiid B. WI f BY THE COURT: Mai led aje rrIP cn r-CDcz -�zCrn 4:) SHOEMAKER INSURANCE AGENCY, INC. 'Plaintiff v. DAVID B. WOLF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 14-7109 CIVIL CIVIL ACTION -LAW ENTRY OF APPEARANCE Please enter my appearance as counsel for David B. Wolf, Defendant, in the above matter. By: Date: 12/15/14 Respectfully submitted, STROKOFF & COWDEN, P.C. Elliot A. Strokoff I.D. No. 16677 132 State Street Harrisburg, PA 171.1 c-, (717) 233-5353 r- riFri ..▪ .S.) (fi -71 SHOEMAKER'S INSURANCE : IN THE COURT OF COMMON PLEAS OF AGENCY, INC., PLAINTIFF c V. rri Fri 7.7 c -a : CUMBERLAND COUNTY, PENNSYLVANIA DAVID B. WOLF, -<' r>-+ DEFENDANT : 14-7109 CIVIL TERM: -0 ORDER OF COURT ''- ry_ c AND NOW, this /3 day of December, 2014, following a hearing on Plaintiffs emergency motion for special and preliminary injunctive relief, we find that Plaintiff has or will suffer immediate and irreparable harm to its continued relationship with its customers if Defendant is not enjoined from using the misappropriated policyholder information, which constitutes trade secrets under the Pennsylvania Uniform Trade Secrets Act, 12 Pa.C.S. § 5301 et seq. We further find that Plaintiff's right to relief is clear and that any harm that might result to the Defendant from the injunctive relief we grant will be substantially less than any harm that would be done to Plaintiff. Therefore, we ORDER AND DIRECT as follows: 1. Defendant and any brokerage firm, agency or company with whom he is associated is enjoined and restrained from using the Plaintiff's policyholder information in violation of the Pennsylvania Uniform Trade Secrets Act for a period of one year. 2. Defendant and any brokerage firm, agency or company with whom he is associated is specifically enjoined from using the aforesaid policyholder information to solicit or contact Plaintiffs customers. 3. Within three (3) days of this order, Defendant shall return the misappropriated files to Plaintiff, including all hard copies and any electronic versions of the same. 4. This court will schedule a hearing on the merits upon request of either party. By the Court, Albert H. Masland; Andrew T. Lucido, Esquire For Plaintiff Elliot A. Strokoff, Esquire For Defendant :sal Cores li a., 1x.117/1 y .`=°/9 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY .„ b. tr.,„mbr ' ' 1 i1C 4.�it� 1. VIlb 30-1 Li Clir•13Eyr1N�Y11�aPt1 �j�i -1 OFFC4, OFTI-E,} µRIFF Shoemaker's Insurance Agency, Inc. vs. David E Wolf Case Number 2014-7109 SHERIFF'S RETURN OF SERVICE 12/09/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David E Wolf, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Adams, Pennsylvania to serve the within Complaint & Summons according to law. 12/22/2014 06:15 PM - The requested Complaint & Summons served by the Sheriff of Adams County upon David E Wolf, personally, at 1550 Harney Road, Littlestown, PA 17340. James Muller, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.49 SO ANSWERS, December 31, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Te cosoft, inc. James W. Muller Sheriff Len J. Supenski Chief Deputy a SHERIFF'S OFFICE OF ADAMS COUNTY Bernard A. Yannetti, Jr. Solicitor Kevin E. Miller Lieutenant SHOEMAKER'S INSURANCE AGENCY, INC. vs, DAVID B. WOLF Case Number 2014-7109 SHERIFF'S RETURN OF SERVICE 12/22/2014 06:15 PM - Deputy Jason Brady, being duly sworn according to law, deposes and says, the Complaint & Summons was served upon DAVID B. WOLF at 1550 HARNEY ROAD, LITTLESTOWN, PA 17340 by handing a true and attested copy to the Defendant and made known the contents thereof. SHERIFF COST: $45.40 December 30, 2014 DATE 12/16/2014 12/16/2014 12/16/2014 12/16/2014 12/30/2014 12/30/2014 CATEGORY Advance Fee Notary Fee Docket & Return Service Mileage Refund MEMO SO ANSWERS, JAMES W. MULLER, SHERIFF Advance Fee CHK # 48812 DEBIT $0.00 $5.00 $9.00 $9.00 $22.40 3795 $104.60 CREDIT $150.00 $0.00 $0.00 $0.00 $0.00 $0.00 BALANCE: CO $150.00 $150.00 $0.00 ONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Erica L. Newman, Notary Public Gettysburg Boro, Adams County My Commission Expires April 7, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES Affirmed and subscribed to before me this 30TH day of DECEMBER NOTARY 2014 ‘.(:;) CountySuitt, Sherilf, Telensoft, 0,0 Pr( a -le ti0I QuLblic,