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4. On June 6, 1994, Plaintiff and Defendant Hammaker
executed a written employment agreement (hereinafter "Employment
Agreement") by which Plaintiff agreed to employ Defendant Hammaker
as an employment representative in consideration of Plaintiff
paying Defendant Hammaker $360.00 per week. A copy of the
Employment Agreement is attached hereto as "Exhibit A."
5. At all times relevant and material to Plaintiff's cause
of action, Defendant Capital Area is a temporary help business, and
is a direct competitor of Plaintiff.
6. At all times relevant and material to Plaintiff's cause
of action, Defendant Hammaker has been engaged in performing
services as an employment representative.
7. Defendant Hammaker has the reputation of possessing
certain skills in the rendering of such services.
8. By paragraph seven (7) of the Employment Agreement,
Defendant Hammaker agreed that during the twelve (12) month period
immediately following her termination of employment with Plaintiff,
she would not, in any area within fifty (50) miles of any of
Plaintiff's businesses, engage, either directly or indirectly, in
competition with the business activity carried on by Plaintiff.
9. Defendant Hammaker terminated her employment with
Plaintiff on March 31, 1995.
10. In April, 1995, the exact date of which is unknown,
Defendant Hammaker obtained employment as an employment
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representative with Defendant Capital Area, a business located
within fifty (50) miles of Plaintiff's business and in competition
with Plaintiff.
11. Upon information and belief, Defendant Hammaker has,
since the date of her employment with Defendant Capital Area,
engaged in the temporary help business in competition with
Plaintiff and has or will solicit, divert or take away persons and
companies who are potential applicants and clients of Plaintiff.
12. 'fhe aforementioned actions of Defendant Hammaker
constitute breaches of the Employment Agreement.
WHBRBFORB, Plaintiff, Keystone Personnel & Keystone Temporary
Services, Inc., respectfully requests this Honorable Court to:
(a) permanently enjoin Defendant, Lori J. Hammaker, from
soliciting business from or rendering services to any person or
entity which violates the terms of the Employment Agreement for a
period of twelve (12) months from the date of the termination of
Defendant Hammaker's employment with Plaintiff;
(b) permanently enjoin Defendant, Capital Area Temporary
services, Inc., from soliciting, obtaining or using the services of
Defendant Hammaker for a period of twelve (12) months from the date
of the termination of Defendant Hammaker's employment with
Plaintiff;
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Exhibit A
'.'
EHl'J.OYHElll' AGRlmHEllT
2. HOllR:!..
EmplC)'ee shall he re'l"ired to ,wrk on 0 five day cslendor week
between the hOllrs o( r.'p{J-:;-:'OO "a"turn Standnrd Time thrbugh
Eastern Standnrd Time ot 0 localion tll be selected by Employer.
3 . 1'1 J.llli...Jlt~PIUJ5 AIIIJ PA TA .
It Ie lII111~1-6lood nnd at~rued l\ert!t.u tl1nt tIle tlnnles, addresses,
HIes, Job orders, (orms, reu'ld" ond other "alient business data of the
npplicants ond client cempanies of Emplo)'er (onstitute a valuable asset of
Emplo)'er and .re trode secrets of the Emplo)'t!\'. In the event that Emplo)'ee's
employment relntionohip ,.-lth Emplo)'H "hall be terminated, Io'hether voluntarily
or involuntarily. Emplo)'ee agrees that he or she will Ileop confidential cuch
information; that he er she will not .ttempt to benefit personally in any way
(rom the disclosure o( nn)' sllch information relnting to said cI ients; that he or
Gha will not sell, give or disclose Bny [;ut:h nnmes, Addresses or other salient
busines8 d.ta of Employer'r. clients to nny competitllr of Employer nnd, that he
or she will not mol<e eny efforl, directly or indirectly, on his or her own beholf
or on the behelf of any olher penon or b".iness entity to encollrege any of said
clients of Employer to wJthhold theh p31ronage from Employer. It is further
understood that no file.. reconls, oc l'I.ht!r sallent business data of Employer
shell be removed from thB ofHre. \If Emplo)'er ,dthout the e'pre.. prior consent
of Emp] ")'Ot' ,
I,. 'I'1lAIlllll~,
Empl'J)'H l:linll be ''''ponsilile for providing t.raining et He 0\-11\
expense to the benefit {\[ Ell\pll')'l:r in onler lhnt he or the moy improvo his or her
skills os I1n F.mployment H..pr..r.untutJv,' , The IImuuot of. said training, the
localhlIl ot snit,! Ilnining nnd th~ l'xl ('nl t1(" tdlCh lruining til1311 be at the
dis"r"I ion of Emplo)'"," ,
5, !,!!!:;JLlTl/'li,
Emp1,,)'r', "lwl1 I." '''I'I",,,~jbJ,, ro, providi"llull IncJJjlies
necessary for the tIel fOllllfll1lP of dllt if'S nil nn Empluyment Hepll'flentnt ivo.
6. !'IiOMTl9l!.
ElIlploY'H ",," rmployo" e'~"owledge Ihat Ihe Illst ninety (90)
tle)'9 of the EmpJo)'lnunt '''',1'''.'11''11' shall (Oll.tltule what ia hnown as 8
"probntionnry podod", At tho cllndu,;ion o( ~ald probat.ionary period, Employer
shnll have the right to retain 0'- dischnrge Emplo)'ou Idth or without cnuse.
Emplo)'er furthe,- nr.Srve6 the right to t.erminate any time then,after nn employee
not (ully complying with his or her job dl'r.cription and duties as directed, or
nny roasons listed undor pUlugrnph "leven (11), T!!rmlnntion,
7. HE5THIC'nVIi COVlillhtlT.
F.JI1plll)'ee lloen herl1hy t':qll'eflfdy covcnnnt I pl"om1r;0 Bnd ogree that
du,-inl! t.he lHm o( Ids or IIf'r I'rnl'lc)'mcnt nnd (or a poriod uf one (1) yenr
fol1U\voing the t.erminatiun of hir. or llt'r QmploYlllent, fur any rOOfion whatsoever,
he ur she shnll not, either nr. prinelpsl or 00 behalf of, 0,' in conjooction "ith,
any uther person, firm, pnrtnenhip. compnny or corporntion, either as agent,
employee, pnrtner, o((il'l'r, .Ilr!!ct.or, "ollGnl tant or nny other cap"c1ty, directly
or Jndirectly, "ithin n rnrll1l6 of fifty (50) miles from Emplo)'er's principal
office do nny of the following:
A, Emplo)'ee shnll not engnge in the employment agency or
temporary help busioess in cempetition with En~lo)'er.
D, Emplo)'ee ngre"s that he or r.he shall not solicit or
contnct nny of ElIIplu)'Cl"'s cIiBnts "ith whom he or she
dealt doring the employment relationship,
C, Iirnplo)'oo agr"e" t.hat he or "he shall not solicit, divert
or take ""ny pIltontinl applicnnts Dr client cDmpanies Df
Ernplo)'er ,dlhin snid fifty (50) mile radiu" Df
Emplo)'e,"r. prlndpal D((ice fur the period Df Dne (1)
)'ear from the tecmlnation of his Dr her employment
relationship,
o. COHPElISA'nO!!.
Ernpln)'er ngn~l'R to C('lopC'llflnte Emplo)'ec for t.he perforInonce of
F.mpluYlllent ReproculltolJve in th,' fulll1\lillg "'''n:It'r, the Emplo)'oe Ghall earn3G.{).oo
per "'Bek, plus ponuD if 'lllalifi"" ,
9. DEUEI'I1'S.
Emplo)'er our""s to ITD'Iide salarior! Emplo)'ee the f011D"lng
fringe benefitsl
A, Vat:nUon ia arrlll11111nted nt a rate of 03% per mDnth or 5
da}'a Cur e\'ery 6 mDnths, After 5 years, 3 weeks vacntion
is esrncu at a rote Df 1.25% per month, This is
cnlrlllotud frnm )'our anniversary dnte to YDur anniversary
doto, Vnrntinn limn. cnn nut be carried Dver from year
to yr'ar, It I11IJr.t be or.ed hy your nnniversary date
IMl'LO"yHElrr AGHEElmN1'
n. Employell "hall hll '''ltitled 10 the followlnll holiday.'
Chrlstmns, I-lem"rlnl !Joy, Fourth of Joly, Labor Day,
Thanllsllivinll nnd New Yllnr's !Jay.
,
C, l'aid del, len\-ll is nVllilnb1c onl)' for full-time, salnded
employees and .hnll be determined nt the discretion of
Employer ,
0, Dinner costs for nttendinll various busiuess meetings when
relsted to the industry to be pllid by Employer unless
otherwise stilted in advance, Seminar costs to be handled
in the 60me manner. convention costs will be on a
contest or bon\\s husil:i.
10. COIl'l'HOL.
Employer shall reserve tho right to direct and control the
assignment of applicants/temporary employees and client companies to Employee and
Employee agrees t.o Accept the responsibility assigned to him by Employer.
11. ~'E1lHINATlON.
Employee may volunt.nrily terminate t.he employment relationship
provided he or she notify Employer t.\.IO (2) \leolts in advance as t.o the date of his
or her termination.
A. Employer may t.enll!lInt.e the employment. relationship for
tIle fullowina rcasonOI
1. Violar ion of the code of ethics est.ablished by the
National A,"nciat.icn of Personnel Consultants or
National As"oelation of Temporary Services,
2, Violatllm of I ho liccnsinlllaws of t.he Conunonwealth
of Pennsylvania end/or foderal regulations
governing elnI)loym~nl ngcl1cies or tem!lOrary help
services.
], Any continued course of conduct which is
dlltrlmentaJ to Ihe Employer \.Ildch aftor notice by
Employer t.o Employee in continlled by Employee,
This conduct ran Inc]ude. but Is not limited to,
intoxic3tion nn the job, abusive language, inunoral
comluct I tardin(~6S find un{'xcused Ausences, refu~81
to follow Empl oYf'r I'"] leies or instructions in the
performanre of his llr her duties.
4. Any t I iii" dllril1ll the probationary period without
CBlItiO.
EMPLOYMENT AGREEMENT
12. ~.
This Agreement shall
Pennsylvania and shall be
be governed
construed in
by the laws of the
accordsnce therewith,
Commonwealth of
IN WITNESS "~EREOF, the parties hereto have executed this agreement
the day and year first above written.
KEYSTONE PERSONNEL AND KEYSTONE TEMPORARY
SERVICES
BY,
Sherry L.
President
EMPLOYMENT REPRESENTATIVE
BY, (.M,t~ 12 dJw.mt.aJ~A.)
S gnat e of Employee
WITNESS,
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KEYSTONB PERSONNEL , KEYSTONE
TEMPORARY SERVICES, INC.,
IN THB COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
plaintiff
v.
NO. (i I). .) <: j <'J )
IN EQUITY
LORI J. HAMMAKER and
CAPITAL AREA TEMPORARY
SERVICES, INC.,
Defendants
ORDER SETTING HEARING DATB
AND NOW, this
day of
1995, a
hearing on Plaintiff's Motion for Preliminary Injunction will be
held on
, 1995, at
_,m., in Court Room No.
, cumberland county Courthouse.
BY THE COURT:
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Defendants
I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
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KEYSTONE PERSONNEL , KEYSTONE
TEMPORARY SERVICES, INC.,
plaintiff
v.
LORI J. IlAMMAKER and
CAPITAL AREA TEMPORARY
SERVICES, INC.,
IN EQUITY
ORDER
AND NOW, this
day of
, 1995, after a
hearing on Plaintiff I s Motion for Preliminary Injunction, said
Motion is hereby GRANTED.
BY THE COURT:
J.
,r
KEYSTONB PERSONNBL , KEYSTONB
TEMPORARY SERVICBS, INC.,
Plaintiff
I IN TUB COURT or COMMON PLBAS
I CUMBERLAND COUNTY, PENNSYLVANIA
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: NO.' h.:)~,'.'>'.)
:
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:
v.
LORI J. HAMHAKER and
CAPITAL AREA TEMPORARY
SERVICES, INC.,
.
.
Defendants :
MOTION FOR PRELIMINARY INJUNCTION
c
1. This Motion is submitted pursuant to Pa. R.C.P. 1531.
2. Concurrent with the filing of this Motion, Plaintiff has
filed a Complaint seeking to permanently enjoin Defendant, Lori J.
Hammaker (hereinafter "Hammaker") from violating the terms of an
employment agreement.
3. In support of this Motion, Plaintiff relies upon, and
incorporates herein by reference, the verified Complaint and
exhibits thereto, a copy of which is attached hereto as
"Exhibit A."
4. The breaches of Defendant Hammaker of the employment
agreement have and will continue to cause immediate and irreparable
harm to the Plaintiff unless a preliminary injunction is granted.
5. Plaintiff has no adequate remedy at law.
WHEREFORE, the Plaintiff requests this Honorable Court to:
(a) preliminarily enjoin Defendant, Lori J. Hammaker,
from violating the terms of the employment agreement I
REAGER & ADLER. PC
A1l0~NIYS AND (OllNSIIOIIS Al lAW
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(!LURA A III NIION
lIH1M!\S 0. WilliAMS
S(JSAN II I ONIAtH
NIPl'r lO'
August 25, 1995
r.o. IIOk 197
ftARRIShURr.. ,."
11108.019,.
MONIC A IllIH( It! N
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OAI..o .ullllillt'd lull< 11.11
Honorable J. Wesley Oler, Jr.
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
Rei Keystone Personnel , Xeystone Temporary
Services, Inc. v. Lori J. Hammaker, at al.
No. 95-2882 \ Cumberland county
Dear Judge Oler:
Enclosed please find a Memorandum of Law in support of
plaintiff's motion for an injunction. A hearing on this matter is
scheduled to begin on Monday, August 28, 1995, at 9:00 a.m.
Thank you.
TAA/kde
Enclosure
pc: Sandra A. Girifalco, Esquire (w/enc.)
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Plaintiff
I IN THB COURT OF COKMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
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I NO. 95-2882 EQUITY TERM
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KEYSTONB PERSONNEL , KEYSTONB
TEMPORARY SERVICES, INC.,
v.
LORI J. HAMMAKER and
CAPITAL AREA TEMPORARY
SERVICES, INC.,
Defendants
MEMORANDUM OF LAW IN SUPPORT OF
PLAINTIFF'S MOTION FOR PERMANENT INJUNCTION
I. STATEMENT OF THE FACTS
The following facts are not in dispute.
On June 6, 1994,
Defendant Lori J. lIammaker came to work for Plaintiff as an
employment representative. As a condition of her employment, she
signed an employment agreement (hereinafter "the Agrpp.ment").
Paragraph 7 of the Agreement states:
BESTRICTIVE COVENANT.
Employee does hereby expressly covenant,
promise and agree that during the term of his
or her employment and for a period of one (1)
year following the termination of his or her
employment, for any reason whatsoever, he or
she shall not, either as principal or on
behalf of, or in conjunction with, any other
person, firm, partnership, company or
corporation, either as agent, employee,
partner, officer, director, consultant or any
other capacity, directly or indirectly, within
a radius of fifty (50) miles from Employer's
principal office do any of the following:
A. Employee shall not engage in the
employment agency or temporary help business
in competition with Employer.
B. Employee agrees that he or she shall
not solicit or contact any of Employer's
clients with whom he or she dealt with during
the employment relationship.
C. Employee agrees that he or she shall
not solicit, divert or take away potential
applicants or cl ient companies of Employer
within said fifty (50) mile radius of
Employer's principal office for the period of
one (1) year from the termination of his or
her employment relationship.
Prior to her employment by Keystone, Hammaker had never worked
as an employment representative and had never worked for an
employment agency in any capacity whatsoever.
Her prev ious
employment was varied.
It included working (a) for trucking
companies as an administrative assistant or a billing clerk; (b) as
a secretary; and (c) as a customer service representative for the
General Electric Co. Hammaker has computer and secretarial skills,
and has taken accounting courses at Harrisburg Area Community
College.
Hammaker was hired by Keystone to work out of its Harrisburg
and Lemoyne offices. She had access to the following confidential
information of Keystone.
(a) the employment and payroll histories for all of
Keystone's job applicants;
(b) Keystone's client lists, including contact names;
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(c) Keystone's rate sheets and fee schedules for permanent
placements; and
(d) Keystone's confidential sales strategies and client
bill ing rates.
On March 31, 1995, Hammaker terminated her employment with
Plaintiff. In her termination letter, she stated that she was
ending her employment with Keystone so that she could "stay home
with [her] children." On May 1, 1995, Hammaker went to work for
Defendant Capital Area Temporary Services. Capital Area is a
temporary help business and is a competitor of Plaintiff.
Hammaker is employed by Capital Area as an employment
representative, the same position she had when she worked for
Plaintiff. As an employment representative, Hammaker seeks out
potential job applicants in direct competition with Keystone. As
recently as August 15, 1995, Hammaker participated in a job fair in
which Keystone was also participating. At that fair, companies
that are long-time clients of Keystone were also participants.
Hammaker's exhibit booth on behalf of Capital Area Temporary
Services was set up not more than fifty (50') feet from Keystone IS.
On May 26, 1995, a Complaint and Motion for Preliminary
Injunction was filed by Plaintiff, and on July 25, 1995, Plaintiff
received the Answer of Defendants.
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There is ample case law for the proposition that reasonable
restrictions may be imposed on an employee after that employee
terminates his or her employment. In Kevstone Temporarv Services.
Inc. v. Johnson. Clarke and The Drexel Group. Inc., Judge Lewis of
the Dauphin county Court of Common Pleas held that the covenant at
issue in this lawsuit was "reasonable as to duration and geographic
extent, and reasonably necessary for the protection of Keystone
Temporary Services, Inc. without imposing undue hardShip..." A
copy of Judge Lewis I Order is attached to this Memorandum as
Exhibit A.
other courts have reached similar conclusions. In JUdqe
Associates. Inc. v. Belcher, 71 D&C 2d 112 (1975), the court
concluded that a restrictive covenant barring for one year the
former employee from working for a competitor wi thin a 60 mile
radius was reasonable.
In National Risk Manaqement. Inc. v. Branwell, 819 F.Supp. 417
(E.D. Pa. 1993), the court stated that a restrictive covenant is
valid under Pennsylvania law if it meets a four-part test: (1) the
covenant is ancillary to an employment contract; (2) the covenant
is supported by adequate consideration; (3) the covenant is
reasonably limited as to time and geographic scope; and (4) the
covenant is necessary to protect the employer. Defendants cannot
reasonably argue that requirements (1) through (3) have not been
met. They intend to claim, however, that the covenant is not
-5-
necessary to protect Keystone because the Defendants have taken
steps to make certain that Hammaker is not dealing with any
companies or job applicants who were clients of Keystone's when she
worked there. Defendants contend that while lIammaker may be
partially restrained from dealing with clients she worked with as
an employee of Keystone, it would be unreasonable to bar her
completely from working in the temporary help business in
accordance with the provisions of the restrictive covenant.
Initially, we note that the facts will show that Hammaker has
participated at events which include present and former clients of
Keystone. However, even if there is no direct evidence that
Hammaker has been dealing with Keystone I s clients, the covenant not
to compete still needs to be enforced in accordance with its terms.
The evidence will show that the temporary help business is
extremely competitive. Information regarding the pricing of
services is proprietary, since temporary help companies bid against
each other, in part, based upon price. Ilammaker knows how Keystone
prices its services. She knows the strategies and methods employed
by Keystone in preparing its proposals to clients. All of this
information is now available to Capital Area, a direct competitor
of Keystone, whose offices are virtually across the street from
Keystone.
Even if Hammaker has no dealings with any of the clients of
Keystone she dealt with while working for Keystone, her ability to
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use the information she does have to the detriment of Keystone is
substantial. Moreover, Keystone is seeking only to prevent
Hammaker from working wi thin 50 miles of Lemoyne until March 31,
1996. This allows Keystone the time it needs to revise its client
strategies and pricing methods so that Hammaker no longer can use
the information she obtained while working for Keystone to
Keystone's detriment. Simply enjoining lIammaker from dealing with
Keystone's clients and from revealing or using information she
obtained while working for Keystone wllile allowing her to continue
to work for Capital Area Temps will not protect Keystone. Such an
injunction is virtually unenforceable. For these reasons, the
restrictive covenant must be enforced in accordance with its
express terms.
B. ENFORCEMENT OF THE COVENANT NOT TO COMPETE
WOULD NOT IMPOSE AN UNDUE HARDSHIP ON
HAMMAKER.
The Pennsylvania courts have heI d that the hardship brought
about because of the enforcement or a covenant not to compete must
be reviewed with an eyo to what is reasonably necessary to protect
the interest of the empl oyet'. Jllg91JIlQlLgmL!:.Q,_.YLlnt. Env ironmwt
Corp., 427 Pat 439, 235 A.2d 612 (1%7). TheBe interests include
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alleges violations of the Minimum Wage Act and the Fair Labor
standards Act. Based upon these allegations, Defendants argue that
Plaintiff should not be able to enjoin Defendants from continuing
to violate the covenant not to compete because of the doctrine of
unclean hands.
Assuming for the sake of argument that Plaintiff has, in fact,
.
violated the aforementioned statute, it does not bar Plaintiff's
entitlement to injunctive relief. In Stouffel" v. stou!!.fi, 465 Pa.
558, 351 A.2d 236, 244 (1976), the Supreme Court stated:
The bar of unclean hands is applicable in
Pennsylvania only where the wrongdoing of the
plaintiff directlY affects the equitable
relationship subsisting between the parties
and is directly connected with the matter in
controversy. II
(emphasis added)
There is no averment in any of the pleadings filed by the
Defendants which claims that Hammaker left her employment with
Plaintiff because she was not being paid overtime or the minimum
wage. The evidence will show that this issue was raised for the
first time only il.lltl Plaintiff sought its injunctive relief.
Moreover, the evidence will show that the claims are baseless.
Since the alleged violations of law did not have any effect on
~'-'~-_._~~._..._-------_..".,._,-_.._~-_.>.
11 1"01- example, one who sigl1l3 a restrictive covenant under
duress may avoid its applicability using the doctrine of unclean
hands. WOl'hlwiWl.J\udit Ssr-v.h;es v. liJ.mlill, 402 "a.Supal" 584, 507
A.2d 772,777 (1991).
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Exhibit A
0&/101/1995 10: 30
7177[,15<159
hEVSTll I: PERSll.I:L I'IIGE 10
Jo..tx.M1 a. J~
KErSTONE TEHPORARr SERVICES, INC. I
I
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VS. I
I
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PEoor H. JOHNSON. SONORA CLARKE I
and THE DREXEL GROUP, INC. I
IN THE COURT or COHMON PLEAS
DAUPHIN COUNTr. PENNsrLVANIA
NO. 5182 EQUITr
ORDER
AND NOW, thia ~~~dey of July. 1994, fOllowinQ a
hearlnQ on tho Motion for Preliminary Injunction filad by
plaintiff, it is hereby ordered a. follow.,
la) Defendant Sondra Clarke .hall be enjoined from continued
violation of her employment contract with Key.tone Temporary
Services. Inc. a. well a, continued u.e of plaintiff'e li.te
and information and continued contact with plaintiff'e
cuetomer, and temporary employee, in conformance with the
employment contract alQned on Auguet 5, 1987. Thia court
conclude, that the covenant not to compete contained In aald
contract was ancillary to employment, reasonable as to
duration and geoQraphlc extent, and reaeonably necessary for
the protection of Keyat.one Temporary Servlcea, Inc. without
Impoalng undue hardship on Defendant.
Ibl Plaintlff'a Motion for preliminary Injunction to enjoin
all defendant. from continued contact with plaintiff's
cuatomer" appllcanta for fuil-tlme placement aa well ae
temporary employees of Keyatone. and continued uae of
plaintiff's confidential information and trade secrete i.
denied. Thi. court concludes that client lists of Keystone
T.mpora.y Services, Inc. are not trade .ecr.t. .ubject to
protection aQalnst user disclosure independent of an
employment contract. The llete In question are not
particular secrets of K.yatone Temporary Servics.. Inc. but
rath.r gonoral secrets of th. trade and of the general
temporary sorvlcoe/omploymont aQency bu.ln....
Additionally, t.hls court finds that the list of cllanta Ie
not oxclusive, can be eaeily compiled from a variety of
OG( 101/1995 111: 30
7111&1545tJ
H~\'~,lIl1' fHelH.\.
PIIGE 11
indlplndlnt lour~II, end WII dlvllopld, et 11est in pert, by
thl ImploYln.
01ltrlbut ion I
Jamel A. Johnlon, Elquire, 301 Hlrklt Street, P.O. Box 109.
Lemoyne, PA 17043-0109
Leonerd Tintner, Elquirl, 315 N. Front Strllt, P.O. Box 741,
HbQ., PA 17108-0741
~.,- ~tS - 19 ~y
I hweby certify that the foregoIng Is .
true and correct co 01 the original
flied,
(.
.
REAGER . ADLER. PC
ATTORNEYS AT LAW
USl MARkET STREET
CAMP HrLL, PA 11011
171.11 18s.1S83
oM
.
,
,
A. Employee shall not engage in the
employment agency or temporary help business
in competition with Employer.
B. Employee agrees that he or she shall
not solicit or contact any of Employer's
clients with whom he or she dealt with during
the employment relationship.
C. Employee agrees that he or she shall
not solicit, divert or take away potential
applicants or client companies of Employer
within said fifty (50) mile radius of
Employer's principal office for the period of
one (1) year from the termination of his or
her employment relationship.
Prior to her employment by Keystone, Hammaker had never worked
as an employment representative and had never worked for an
employment agency in any capacity whatsoever.
Her previous
employment was varied.
It included working (a) for trucking
companies as an administrative assistant or a billing clerk; (b) as
a secretary; and (c) as a customer service representative for the
General Electric Co. Hammaker has computer and secretarial skills,
and has taken accounting courses at Harrisburg Area Community
College.
Hammaker was hired by Keystone to work out of its Harrisburg
and Lemoyne offices. she had access to the following confidential
information of Keystone.
(a) the employment and payroll histories for all of
Keystone's job applicants;
(b) Keystone's client lists, including contact names;
-2-
(c) Keystone's rate sheets and fee schedules for permanent
placements, and
(d) Keyatone's confidential sales strategies and client
billing rates.
On March 31, 1995, Hammaker terminated her employment with
Plaintiff. In her termination letter, she stated that she was
ending her employment with Keystone so that she could "stay home
with [her] children." On May 1, 1995, Hammaker went to work for
Defendant capital Area Temporary Serv ices. capital Area is a
temporary help business and is a competitor of Plaintiff.
Hammaker is employed by capital Area as an employment
representativa, the same position sha had when she worked for
Plaintiff. As an employment representativa, Hammaker seeks out
potential job applicants in direct competition with Keystone. As
recently as August 15, 1995, Hammaker participated in a job fair in
which Keystone was also participating. At that fair, companies
that are long-time cl ients of Keystone were also participants.
Hammaker's exhibit booth on behal f of capital Area Temporary
Services was set up not more than fifty (50') feet from Keystone's.
On May 26, 1995, a Complaint and Motion for preliminary
Injunction was filed by Plaintiff, and on July 25, 1995, Plaintiff
received the Answer of Defendants.
-3-
There is ample case law for the proposition that reasonable
restrictions may be imposed on an employee after that employee
terminates his or her employment. In Keystone Temporary Services.
Inc. v. Johnson. Clarke and The Drexel Group. Inc., Judge Lewis of
the Dauphin County court of Common Pleas held that the covenant at
issue in this lawsu it was" reasonable as to duration and geographic
extent, and reasonably necessary for the protection of Keystone
Temporary Services, Inc. without imposing undue hardship..." A
copy of Judge Lewis I Order is attached to this Memorandum as
Exhibit A.
other courts have reached similar conclusions. In Judqe
Associates. Inc. v. Belcher, 71 D&C 2d 112 (1975), the court
concluded that a restrictive covenant barring for one year the
former employee from working for a competitor within a 60 mile
radius was reasonable.
In National Risk Manaqement. Inc. v. Branwell, 819 F.Supp. 417
(E.D. Pat 1993), the court stated that a restrictive covenant is
yalid under Pennsylvania law if it meets a four-part test: (1) the
covenant is ancillary to an employment contractr (2) the covenant
is supported by adequate considerationr (3) the covenant is
reasonably limited as to time and geographic scoper and (4) the
covenant is necessary to protect the employer. Defendants cannot
reasonably argue that requirements (1) through (3) have not been
met. They intend to cIa im, however, that the covenant is not
-5-
necessary to protect Keystone because the Defendants have taken
steps to make certain that Hammaker is not dealing with any
companies or job applicants who were clients of Keystone's when she
worked there. Defendants contend that while Hammaker may be
partially restrained from dealing with clients sho worked with as
an employee of Keystone, it would be unreasonable to bar her
completely from working in the temporary help business in
accordance with the provisions of the restrictive covenant.
Initially, we note that the facts will show that Hammaker has
participated at events which include present and former clients of
Keystone. However, even if there is no direct evidence that
Hammaker has been dealing with Keystone's clients, the covenant not
to compete still needs to be enforced in accordance with its terms.
The evidence will show that the temporary help business is
extremely competitive. Information regarding the pricing of
services is proprietary, since temporary h~lp companies bid against
each other, in part, based upon price. Hammaker knows how Keystone
prices its services. She knows the strategies and methods employed
by Keystone in preparing its proposals to clients. All of this
information is now available to Capital Area, a direct competitor
of Keystone, whose offices are virtually across the street from
Keystone.
Even if Hammaker has no dealings with any of the clients of
Keystone she dealt with while working for Keystone, her ability to
-6-
use the information she does have to the detriment of Keystone is
substantial. Moreover, Keystone is seeking only to prevent
Hammaker from working within 50 miles of Lemoyne until March 31,
1996. This allows Keystone the time it needs to revise its client
strategies and pricing methods so that Hammaker no longer can use
the information she obtained while working for Keystone to
Keystone's detriment. simply enjoining Hammaker from dealing with
Keystone's clients and from revealing or using information she
obtained while working for Keystone while allowing her to continue
to work for capital Area Temps will not protect Keystone. such an
injunction is virtually unenforceable. For these reasons, the
restrictive covenant must be enforced in accordance with its
express terms.
B. ENFORCEMENT OF THE COVENANT NOT TO COMPETE
IWULD NOT IMPOSE AN UNDUE HARDSHIP ON
HAMMAKER.
The Pennsylvania courts have held that the hardship brought
about because of the enforcement of a covenant not to compete must
be reviewed with an eye to what is reasonably necessary to protect
the interest of the employer. Jacobson and Co. v. Int. Environment
corp., 427 Pa. 439, 235 A.2d 612 (1967). These interests include
-7-
alleges violations of the Minimum Wage Act and the Fair Labor
Standards Act. Based upon these allegations, Defendants argue that
Plaintiff should not be able to enjoin Defendants from continuing
to violate the covenant not to compete because of the doctrine of
unclean hands.
Assuming for the sake of argument that Plaintiff has, in fact,
violated the aforementioned statute, it does not bar Plaintiff's
entitlement to injunctive relief. In stouffer v. stouffer, 465 Pa.
558, 351 A.2d 236, 244 (1976), the Supreme Court stated:
The bar of unclean hands is applicable in
Pennsylvania only where the wrongdoing of the
plaintiff directlv affects the equitable
relationship subsisting between the parties
and is directly connected with the matter in
controversy. l'
(emphasis added)
There is no averment in any of the pleadings filed by the
Defendants which claims that Hammaker left her employment with
Plaintiff because she was not being paid overtime or the minimum
wage. The evidence will show that this issue was raised for the
first time only after Plaintiff sought its injunctive relief.
Moreover, the evidence will show that the claims are baseless.
Since the alleged violations of law did not have any effect on
l' For example, one who signs a restrictive covenant under
duress may avoid its applicability using the doctrine of unclean
hands. Worldwide Audit Services v. Richter, 402 Pa.Super 584, 587
A.2d 772, 777 (1991).
-9-
EXHIBIT A
06/1~/1~~5 10;30
UJlll'~3 "~ljl
HI'"
lll\~~rl.~r~ .:~r,
.
tori J. /I ,I mDllI k l.! l'
520 A Noeth Jrd Ste..t
1I'0rmlo)'gLurg, PI. J104,l
(7 Jl) fJO-OJ63
Personel In t'orlllitf:iorll_
Birth Placer
8Irt/l DatA:
/larri,Llng I j',\
f~bruary 19,1~60
551 18l-42-BSJO
Hdllltlll Exr:elhnt
~A.t..tillll
Cedal' clift' IIjqh so:hocl, eMnl' 11111, 1'.\
Academic; Septomh~r 1975 to JunA 1~18
II/Jrrlsbueq ArA" CL'nvnunHy (011''19, Hlto'isburg, FA
AccounUng; Soptwmber 197/3 to August 1979
LJlUllQy;nen t 1iJ./Jtory:
January 1994 to I'resont 1''',1I1HCUI'J1S Ent&eprilHIB, Ino.
3500 IndlJSLri/ll Rd/ld
lIarrlnLurq. PA 11110
supBcvisorr fenest Ju~~s
,lob Titla, AdmlnJste4tivlJ Assistant
Exper1,mce: . Accounts l'ayohll'/ (open systems Account.tng)
· p.'Iyro11
. p"r.sonnlll
. /lanJUn'l 11.111 Inr I'rssIdollt ot tt.. Cumpany
. Dank DeFosl ts
. Ordering of ,,11 supplies Cor the company
. 'l)'pin'1 ""rnapond"ncll, telophones, and tiling
september 1993 1.0 JI1JlUHY 1994
I'reJqht-I,l1nd-Sky, Inr:.
1000 Sycamore str.et
Harrisburg, fA J1104
SuperVisor, rlud Shaffer
Job T1tlo: ntlling Clark
E:Jlp"rIellClll · Acel,wllt. /llir,;1I11',,111e
. R/ltll1~ all billJng
. payrull enf:,-y
. AssI/Jt In !J]Hlldll'h
, l'cepllrln1 "~nk deposH.
. Typlllll, telephon.., and tHing
PlAlNnFI"B
EXHIBIT
'.
f
J
.,
06/14/1~95 10:30 111161545~
03,~1"U3 u&: U 'l1'717 :32 ~\I~lJ
t.l:"l J''-'' - , ,- ....;~,... ,-.....
T11.~~5lURI'S E~T,
.----.-
:,"
Hay 1991 to September 1993
Hn19', Gibbons" Company, IIlO.
7 f:llst tlllil. Strsot
Mochllllicsburg, PA 17055
SupSI"visor:
Scott D. Br1ggs
.rob Tit:la:
Socruta.y
. Dictation (D1ct~phone) snd typing
· Talnpllor.ell
. Firllding customor qUlutlons on Unemployment
. Filing Unomployment fOl'/ns
. Hail
· Filing
Expe. i8n.:'6:
S8pte~er 1990 tu Nay 1991 Vodge City Rostaurant
I'axton Street
Hud,bu.g, PA
Supel'Visor: 1J0U\lldS Krick
.ro~ Titl,,: Waitrss.
Expor ient:.: . Customer lntaraction walting en tables
. Host...
october 190U to August 1989 ~enoraJ Electric Compllny
2J33 Hsrket Street
Camp Hill, FA 17011
Sup.rvisor: Richard Prestia
Job Title: Customer Survlr:e
EKperienca:
. Large volume of talephone clllls
· Set up sarvice calls
· Field customer complaints
· Invoicing
. Typing Ilnd filinV
Additional ExvaCJrnC81 Wordperfact ~.l, kotus 1-2-3, aUlttro
Personal refe~anC8M available upon ~aqu.5t.
QJ~
"
06/14/1995 10:30
71 77615~59
H::VSTll € PERSO I U
kEYSTONE PERSONNEL , ~EYSTONE TEMPORARY SERVICES
360 Karkot Streot
Lomoyn.. FA 1704]
(717) 761-~e60
-
--
....
-
!!!il'1.0YlWlT AGiBl'Ji!llT
Z e ,I n aft err e fer r a rl
:J_ lladlymnl-p.-{
.
to.. tho 'F.mploy.o') .nd
Thh Aguement mid. thlo _ ft; d.y uf !J:.l,T/f', I IV.!l!f, bet"eon
kEYSTORB P!RSOKHEL , l!YSTOHE TEHPORARY SERVICES. IHG., a renn.ylvanla Company
to . I the 'Employor'), and
(hereinafter ..Cerred
IIHEREA9. Employer dOll... tu prumote th. growth of Employ.. fo.. the
mutual benefit of Employe.. and Employee by insuring .Slinst unCair comp.tition
b7 An, one or mar. of 'mplo1eel of Employer who.. lifnplo)'m.nt relation,hip mar
c...., and
~IESEAB, tmployer deaire to more Cully .It forth the terma of the
employmant r.lationlhlp for the bonefit of bnth tho Employer and Employee.
11011. THEREFORE, In con.ideratloll of the foregolnR. Employe.. .nd
Employee agroe e. followe.
1. IIHl'LOnIMT.
Employer ehall hire Employee and Employee .hall eorve Employer
in the cap.dty of IlIlployment Repreuntat1ve. Employee ehal1 perform ae an
Employment Rop",".ntatlve for end cn b.hl1C of the Employer by perCorming certaLn
dutlee Including but not lImited Lo thooe dutie. enumerated on Exhibit 'A',
attached hereto "hlch ehlll bl cllhd th. job deecrlptlon. Thil job dllcdpUon
mlY be modified from tlmo to time by the ~nployer eo long ae thol. modlfic.tlon.
relate to the perfolmence of dut.te. "' In Employm.nt S.pre..nut1ve.
PLAlNTIR"8
EXHIBIT
F\:'ri,0
--'~;' "
06/14/1995 10:30
7177615459
~:EVSTllE PERSClU_1.
Dfl'I.oYHENT AOR!IlmNT
Z . II.Ql1&i .
Employ.. .h.ll h. ..qui red to "ark on . fiu doy colond.r "eek
b.tw..n th. houra of '{:t90-S:00 E..lort. Stondud Tim. through
la.t.rn St.ndard Tim. at a location to be Delected by Employer,
S. FILES. RECORDS AND UAT^.
It Ie und.rstood .nd .gr.od h.r.tu th.t tho nam.., addr.....,
fil.., Job ord.r., {arm., recordA and other aallent bu.in.GI data of the
.ppl'l.cantl .nd client companl.. of Employer con.titute a valu.ble UGlt of
Dnployer and are trade IOcrete of th. r.mployor, In the event th.t Employ.e'e
employment r.htionehlp with E1nploYAr .hell b. termln.tod, whether voluntully
or Involuntarily, Employ.. ogr... that h. or .he will k..p confidential Dueh
InfOrmAtion, that h. or ehe will not attempt to benefit poreonaUy In eny vay
from the dhelo.uu of 8"y euch informAtion relotln& to add cllento, that h. or
.he viII not .ell, give or di.clo., any .ueh name., eddreea,. or other e.lient
buelne.. data of Employ.r'. cilento to any competitor of Employer and, th.t h.
or .h. will not make any offort, dluctly or Indirectly, on hie or her 0"" b.holf
or on the beh.lf of .ny other perlun or buelne.. entity to .ncour.g, .ny of e.id
eUent. of Elnplot.r to withhold their p.tronag. from Employer, It I. further
under.tood that no files, r.cord., tH. uth.r ullent budne.. d.te of Employer
.h.ll b. removed from the office. of Employ.r without the upr.eA prior conaent
of Employer,
4. TRAININO.
Elnployer .h.ll b, reeponelhle for providing tr.lnlng .t it. own
exp.neo to t.he b.n.fit of Employ.e in order thet he or eh. m.y Improv. hh or her
.killo II an ElDploJlll.nt Reproe.ntetlv.. The amount of GIld training, the
location of .eld training .nd t.he ..t.ent. of .uch tr.lning ,hall be at tho
diler.tlon of Employ.r,
S. FACILlllli.
Employer eh.ll "0 r"'llon.I~I" for providing .11 f.dUtl...
n.e..eary for the performance of dill I., a. .n I':lnl,loy...nt Repreeentetlve,
e. PIlOBATION.
Employ.r and Employ.. Ol'knowledge th.t tho fir.. ninety (POI
daya of the Ernploym.nt Agreemenl .hal1 cnn.titut. wh.t Ie known a. a
OG/1.1I1SS5 10:30
71 77G1545S
~,EY5TOE F1:RSO.n
PI\GE 05
'prob.tionery period". At the concluolon of ..Id probetlonary period, Employer
thall heve the right to reteln or dlucherge Employe. with or wllhout c.u..,
nnployer (urther reurvee the right to terminate eny tim. theredter en employee
not fully complying with hit or her Jou uAocr/ptlon and dutiea II directed, or
en7 r..tont Illtad under perlgrtph eleven (II), Termination,
7. RBSTRICTIV~ COV!N~r.
Employea doet horeby ..p,.....y cOVlnent, promi.. and egrea that
during the turn uf hll Dr her eml,loyment .nd for a period of on. (1) yur
following th. termination of hll or h.. employment, for lny r...on what.oever,
he or ahe .hall not, either ftI prlnclp.1 or on behalf of, or In conjonction w1th,
an7 oth.r penon. firm, pBrtnerohlp. company or corpoution. either e. agent,
employe., pertner, officer, director, I'oo.ullont, or ony other capacity, directly
or Indirectly, wllhin e redlus of filly (50) mile. from Employer'. principe I
offlc. do any of the followlog'
A. Employ.. .h.1l nllt ongtge In the .mployment egency or
t.mporary help buolne.. in competition with Employer,
B. &nIploye. .g..". thot he or eht tholl not .oliclt or
contRct any of Employer'. cH.ntt with whom h. or .he
dtllt during the employment rtl.tlonehlp.
O. Employ.. .gr.e. thet h. Dr .he 8hell not aoHelt, divert
Dr take eway p"tlntiol eppUcentB or client comp.niee of
Employer within ..Id f1fty ('0) mUe rediuI of
Employ.r'. ptlndpal oHice for tho period of one (1)
yeer from the tormlnaUon of hh or her employment
r.1BtionBhlp.
8. COKPKNSATION.
Employer ogr... to r:<'mp.n.ot. Ett,ployeB for the porformancD of
Illaplo7U'"nt llaprelentaUv. In the fullll1/lnK monnr., I the Employee .hBll eernJGJ),oO
per week, plu8 bonus If qu.lifl..,
9. BENEFITS.
Employer .grtel to .'roville .alaried Employee the following
fringe b8nef1tll
A. VlcBtion II accllmulated at B nte of 83% per month or 5
daY8 for ..ory 6 month8, Aft.r 5 rure, 3 "..k. vaclUon
11 ulnod ot I rete of 1. 25t l'lr month. Thlt is
cllculatod from YOllr onnlvorelry date to your InnLvernr,.
uet., Vlr'tion tlmo can not b. carried over from yoar
to year, it. r:1U,t \m URlld by rOUt enniverl.ry datil
~.
. ;,.-
. '- ..,
KEYSTONE PERSONNEL' KEYSTONE TEMPORARY SERVICES, INC.
360 Market Street
Lemoyne, PA 17370
(717) 761-5860
FAX (717) 761-5459
JOB DESCRIPTION
EMPLOYMENT REPRESENTATIVE
Employee shall represent Employer fer the purposes of securing employment for
Employer's applicents and securing ~ualified applicants fer placement with
Employer's client ec".pnies. Arnor.g the responsibilities and expectations in
advancing toward these goals, Empleyee shall.
1. t.:!ke a minimt:.":1 cf 15 telephe~.e calls Fer ~ay to secure r,el< job orders I
"hile in traini~g, ho"ever. ;:7.Flo)'ee is E>:Fected to make a minimum of so
telephone calls Fer day to sec~re new jo~ orders;
2. Obtain bona fi~e Job Orders fre~ client ce~Fanies.
3. Stri\'e to ex,a~1 tr.e nt:.'T.ber ef client ce""anies ,;ho ....ill utilize the
professional serdces of !:mplC)'er.
4. Frepare and cause sd\'ertise~ents regularly in order to solicit qualified
aFplicants. ;:7.;:10)'ee shall to entitled to _ lines of a~...erthing per
,.eek (see me~o fer individual lineage).
5. Screen and interview applicants in crder to determine ~ualifications.
6. Ccn~uct reference checks eit~er by telephor.e, forn letter or other
correspon~ence. ~eference c~seks should be dcne on all ap;:licants prior
to send outs.
7. Refer qualified applicants to client ""',panies (by prcdding a client
ce:r,par.y with a ..lection cf reSl:..7,es) ar.d, similarly, enenge persenal
interviews cet...een applicants and client ce:rFanies (send cuts).
8. Froperly doc\:""ent all tranHcticns, discussier,s and processes from time of
initial contact ...ith applicent through interview, acceptence. placements
cr assig~'T.ents, This includes ~aintenance ef referral sr.eets of current
ectivity and preper notations en all files.
9.
Negotiate in a professional ~anner as an intermediary
applicants and client cc~panies to cc,c,unicate
information and avoid misun~erstandings,
and crcker between
full end ccmplete
10.
~aintain continued positive relaticnships with all client ccmpanies and
applicants to ~enitor their needs and present status.
11.
~:ate-every effert to discharge all reeponsibllities in tr.e most efficient
and cost-effecti\'e manner.
PlAINTlFPs
EXHIBIT
8/.)l'U~ L""
- '-"~,
',..
.' .
12. Attend all professional, job-related conferences, seminars and training
event a as may. from time to time, be required by Employer when~ver
posaible.
13., Haintain accurate and timely records of any incidental expenses for which
reimbursement may be expected.
14. Hsintsin accurate contact log ,heets and statistics ss may be required by
Emplo)'er.
15. Endeavor to prcmote the profeEsiona1 reputation of Emplo)'er within the
area's business co~~unity.
.
.
.
--~._~-
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J:i!..l1n.lll, r1 g'SXd.Ji.dA...tl.iJ"'.A A_:~....yh 7J..L (~diItJ ,
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PlAINTlFf'8
EXHIBIT
,
f'J).'hll)' C... ( Y ----.--
-.-.-..-......----..--.---.. . ...--,.,
-..--".--,-,..---". .._--_..~.,_..~_._-- " -~-
ZQ 3Wd
'"f.tISd3J .~.)lSi,3~
lSl,19UtL ('('01 ~l&'/~II~Q
DEPARTMENT OF TIlE AIlMY
HEADQUARTERS CARLISLE BlRRACKS
CARLISLE, PEHHIYlVAHIA , 10'3,'002
Auqust 1, 1995
""It '0
.1'1""011 C:,
Ann)' cOl1\ll\llnity Service
SUBJECTl Carlisle BarrackK 7th Annual Job Fair
Dear Colleague:
This letter ie a follow-up to our first letter dated June
21, 1995 concerning the 7th Annual Carlisle Job Fair being held
on August 15, 1995, at the Carlisle Barracks Cmrununity support
Center, (old Officers' Club) Euilding 313, from 2 p.m. to 7:00 p.m.
First I would like express my thanks for your participation
In thi. mutually worthy progra~\. Curing these times of high
unemployment, it is very important to I1'ske contact with the
individuals who are in real r.eed of employment, as ",all as those
individuala who have just ~rr~~~j in tho area and are juat
atarting their surch for CUI' 1; ",:T":lt,
En~losed you will find a copy of tho "trip map of Carlisle
Barrack. with the Community Support Center and parking area
highlighted. Please fold thil paper and display the "EXHIBITOR"
,.ction on your automobile dalhbcard when entering Carlisle
Barrack" w. are asking that III employerR arrive between 12
noon and 1 p.m. on the day of Augult 15th to ensure that ell
vahicle, gat unloaded and parked before c~r orientation which is
Bchedulod tor 1145 p.m.
Th, Military pollco have been alerted cor.coming thil event
and will direct you to the Cc~~unit.y Support Center. '{au may
unload your automobiln in front of the Center, but will then be
directed to park els.where, ~,have forty parking places
r,..rved for the o::lployers Gn a "flret conI! - first served"
ba.i.. Cones will b, sat up by the Military police reserving
th.s. .pac... Pr.I!ASE 00 /lOT 110VE rUESE COllES. If YOll
participated in the Jcb rair last year, you already know that
parking i. vRry scarce on carli.l. BarraokB. I wculd aleo
caution you not to park in any psrking Bpace designated as a ten
minute, thirty min'.lto parkir.g or car pool parking, The 11ilitary
Police will not heeitate to ticket tho8u cars.
. ~...~ ., _';' Q",..1n""tl a 1l',IO of the intlnior of the COl1\lnunity
PlAINTIFF'S
EXHIBIT
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22, V:C:CRY EXPRESS
- 23, C;,_::,L: SL!::: :03 CE:-JTER
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2';, PE~l:A. C:V:L SEf\VICE
.5, B~SEhU OF STATE EMPLOY,
~..!5. 1,'1510:: Q\.,-i5T
.., .,27. HERSHEY 11EDICAL CENTER
CIVILIAlI FERSO}.')lSL 28, I;CF.';'",:,ESTE?.}; l,rJTUA:. LIfE'
CHII.D';'IME SACC 29. SCH!;EIDER NATICl'AL -14,
....-A!J.1' INC, 30. PA S';'ATE POLICE );1..,15,
~ BOOK OF THE lJ.O:,TH CLea.' 31, KELLY TEMP SERVICES 4 (-.
~ COMPUTER LEhRN ING I\ETWORK 32, PRt:L;E:-;TlAL 1:15, COI.Ii'A.'fi 47.
KEYSTOllE TEMI' SERVICES 33, no:; ':'CN .; 8,
WENDY'S ,P'>-34 .1CAW,:SLE.H~~prT1\L 0:9,
l1TA SCHOOL 35.c'A.P:lt$;,!0.~~::-TEr1P~ i
MOlfu-XENTAL LH'!:: U;SUilJ.J:CE Jb, r~E~~IlERS-is7.tL.. ,;,...
), FA.G.11ERS TRUST COI1PA.>.JY 37, RESTART TEHPS I Il;C,
l, MANPOWER ]8, r.l<:r LIFE
I, JACK GAUGHEN RE^L70R 39, JFC ASSOCIATES
I, RADIO SHJ,CK 40. 1lC',w',IA Y PACK!,Gl:: SYSTt;X
\, PRIMERICA FINA.'1CrA!, 5\'5. 41, HIRE Qt:ru.ITY
I, SHEETZ, INC 0, fED. nlJREAIJ OF PRISONS
" TUCKEY l'oECHANICJ\L __. ~j. H:iJ, CGPRECTlONI\L H:S7.
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UNITED TECHNicAL ASS
PNC BANK
ROADWAY EXPRESS, I~C
D\1YER GROUP TRADE
TURKEY HILL
HARY KAY
STRADLEY
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August 24, 1995
VIA FEDERAL EXPRESS
Honorable J. Wesley Oler, Jr.
Cumberland county Courthouse
One Courthouse Square
Carlisle, PA 17013
Re: Xeystone Personnel , Xeystone Temporary Service.,
Inc. v. Lori J. Hammaker and capital Area
TemDorarv Services. Inc.. No. 95-2882
Dear Judge Oler:
In anticipation of the hearing which will be held on August
28, 1995, in the above-referenced matter, I enclose Defendants'
Brief in opposition to Plaintiff's Motion for Preliminary
Injunction. This brief will be filed with the Clerk on the day
of the hearing. By copy of this letter, I am serving opposing
counsel with Defendants' Brief via overnight mail.
Very truly yours,
Jl4-dtfL /ftJ" LJ
Sandra A. Girifal;o~ -
eMS/ce
Enclosure
cc: Theodore Adler, Esquire
171m
According to the Agreement, Ms. Hammaker was hired to work
as an Employment Representative 5 days per week, 0 hours per day.
she was paid $360 per week. However, shortly after the start of
her employment, Keystone required Ms. Hammaker to spend a
significant portion of her time performing the duties of a
cleaning person, delivery service, telemarketer and receptionist,
and working well beyond her scheduled time, for which she was not
compensated. On March 31, 1995, after less than ten months at
Keystone, Ms. Hammaker voluntarily terminated her employment.
On May 1, 1995, Ms. Hammaker began employment with capital
as an Employment Coordinator. On May 26, 1995, Keystone filed a
Complaint and Motion for a Preliminary Injunction seeking to
enjoin Ms. Hammaker's employment with Capital based upon the
"Restrictive Covenant" found in the Agreement. Keystone's motion
must be denied because (1) Keystone cannot meet the threshold
requirements for issuance of a preliminary injunction and (2)
Keystone's claims, which sound in equity, are barred by the clean
hands doctrine.
B. Employee agrees that he or she shall not solioit or eontaet
any of Employer'e elients with whom he or she dealt during
the employment reletionship.
C. Employee sgrees that he or she shall not solleit, divert or
take away potential applicants or client eompanies of
Employer within and fifty (50) mile radius of Employer's
principal office for the period of one (1) year from the
termination of his or her employment relationship.
-2-
prohibiting them from el~aging in employment in competition with
Rollins for a poriod of two yoarD. Although the trial court
found the employmont agreements valid, the court denied Hollins'
motion for preliminary injunction because Rollins (ailed to
establish any harm at all reSUlting from the employees' violation
of the covenants not to compete. Id. at 601, 557 A.2d at 413.
The Superior Court affirmed the trial court's decision noting
that since Hollins' former employees hod not stolen or solicited
any of Rollins' customers or taken any customer lists, Hollins
"was threatened with no greater harm to 'customer relationships'
from [its former employees], than from any other similarly
situated employee not formerly employed by [Rollins]." Id. at
602, 557 A.2d at 414.
Dased upon similar facts, the Superior Court
affirmed the denial of a preliminary injunction in Harsco Corp.
v. Klein, 395 Pa. Super. 212, 576 A.2d 1118 (1990). In Harsco, a
19 year employee named Klein terminated his employment with
Harsco and began working for a competitor. The court denied
Harsco's motion for a preliminary injunction to enforce a
restrictive covenant because "there was no likelihood of
immediate and irreparable harm to Harsco by refusing the
injunction." Id. at 217, 576 A.2d at 1121. ~'he Superior Court
affirmed noting that when Klein resigned his employment he was
not dealing directly with clients and that "in any event the
customers in [Harsco's industry] would be generally known to all
of the firms in the same business. . ,II Id,
-4-
An alleged violation 01 u restrictive covenant by
itself is not enough to warrant the issuance of an injunction.
Ms. Hammaker is not competing with Kayntone because she has not
knowingly solicited or diverted any of Keyntone's clients nor has
she ever knowingly diverted any potential applicantn from
Keystone's employ. Moreover, as in Hollins and l1arnco, the
customers in the temporary personnel field are generally known to
all companies in the same business as Keystone. As in pollins,
Keystone is not threatened by Ms. Hammaker any more than it would
be from any other capital employee not formerly employed by
Keystone.
Keystone's own actions contradict its allegation
that it will suffer immediate and irreparable injury if a
preliminary injunction is not issued. Keystone knew Ms. Hammaker
was intending to commence employment with Capital as early as
April 13, 1995. Nonetheless, Keystone waited nearly six weeks,
until May 26, 1995, to seek a preliminary injunction and then,
after filing its Motion, did nothing to expedite the resolution
of this matter, either through request for an emergency hearing
or otherwise. Keystone can not show that it has suffered or will
suffer immediate and irreparable injury and, therefore, its
request for a preliminary injunction should be denied.
2. Keystone Does Not Have a Clear Right to a
Prelimilli!U'_Jnj!!m:1.;Lol} .___
Keystone can not establish a clear right to
enforce the "Restrictive Covenant" against Mn. Hammaker. In
order for a covenant not to compete to be enforceable in
-~-
Hammaker, it shou 1 d not be en IOITed. li~.g 119I.9iHl'-[L!!QF].,._J~m!inmel!t
Corp. v. Martucci, 390 I'a. bIll, Db A.2d 038 (1957) (Court
refused to enforce covenant pl:ohibiting former employee from
working for competitor within 100 mile radius for one year on
basis that c~venant posed an undue hardship on employee but was
not reasonably necessary to protect the employer).
b. The EmJllQyment Agreement is Unenforceable
Keystone can not now enforce the Agreement
because it materially breached the Agreement during Ms.
Hammaker's employment. ott v. Buehler Lumber Co., 373 Pa. Super.
515, 541 A.2d 1143 (1988) (party who materiallY breaches contract
can not complain of breach of contract by other party); United
states v. curtis T. Bedwell & Sons. Inc., 506 F. Supp. 1324
(E.D.Pa. 1981) (same). Paragraph 2 of the Employment Agreement
states that the "Employee shall be required to work on a five day
calendar week between the hours of 8:00 - 5:00." See, Exhibit
"A" to Keystone's Complaint at , 2. In actuality, Ms. Hammaker
was routinely required to work through lunch, in the evenings,
and on weekends and to be on call without being compensated.
Furthermore, Paragraph 1 of the Agreement
states that Ms. Hammaker was hired as an "Employment
Representative" and her job description could only be mortified if
the modifications related to the performance of duties as an
Employment Reprosentative. NonetheloBB, os diucussed above,
Keystone did /lot omploy Ms. Hammaker Bolely as an Employment
Hepresentative an pl-omised in tho Agl'eement, but rather, it
-'1-
required her perform a vadety of tiwks totally unrelated to the
work of an Employment HeprCl;entilt i ve. Under pennsy 1 vania 1 aw,
Keystone's material breaches of the Agl-eement void any obligation
Ms. Hammaker may have had under the Agreement.
B. Kevstone Comes to This Court with Unclean Hands
Keystone may not invoke the equitable powers of this
Court because it comes to this Court with unclean hands. As has
been stated by the Supreme Court of Pennsylvania for over a
quarter century, "He who seeks equity must do equity." I~azer v.
Sarqent Electric co., 407 Pa. 169, lBO A.2d 63 (1962); Spraque v.
Casey, 520 Pa. 38, 550 A.2d 184 (1988). The clean hands doctrine
is applicable "where a party seeking affirmative relief is guilty
of fraud, unconscionable conduct or bad faith directly related to
a matter at issue which injures the other party and affects the
balance of the equities between the litigants." Equiblmk v.
Adle. 1no" 407 Pa. Super. 553, 595 A.2d 1284 (1991).
As discussed in detail above, Keystone knowingly
breached its Agreement with Ms. Hammaker from its very inception.
Ms. Hammaker never acted solely as an Employment Representative
for Keystone. Further, Ms. Hammake," was regularly required to
work evenings, weekends, through lunch and was required to be on
call. Keystone never paid Ms. lIammaker for overtime even though
it was required to do so unde,. the Filir l.abor titandards Act, 29
U.B.C. S 20] et seq., pennsylvania'n Minimum Wage Act of ]96B, 43
1'.13. S ])] .101 et seg., and 'l'he W,~qe Payment ilnd Collection Law,
4:J 1'.1l. 260.1 et seq.
"B-
CmlT l .'lC!\T!L.9f._PEIlY!CE
1, I'lIlhluul1 M. :;lI'yku,', hereby certify that 011 this 24th day
III AII<J II II I , )1)')'), I caulled a t.'ue and correct copy of Defendants'
111'101 In opplJlIlIlon to Plaintiff's Motion COl' Preliminary
Injllnctlon 10 be nerved via federal express, overnight delivery
IIpon cOlll11101 IllItod bolow:
'J'hoodore A. Adler, Esquire
Reager & Adler, P.C.
2331 Harket street
camp Hill, PA 17011-4642
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Defendants are without knowledge or information sufficient to
form a belief as to the truth of the remainder of this allegation
which is, therefore, denied.
5. After reasonable investigation, Defendants are
without knowledge or information sufficient to form a belief 8S
to the truth of this allegation for the reason that they do not
know to what time period Plaintiff refers. It is admitted that
Capital Area is in the temporary help business and is a
competitor of Plaintiff.
6. After reasonable investigation, Defendants are
without knowledge or information sufficient to form a belief as
to the truth of this allegation for the reason that they do not
know to what time period Plaintiff refers. It is admitted that
Ms. Hammaker has been engaged in performing services as an
employment representative.
7. After reasonable investigation, Defendants are
without knowledge or information sufficient to form a belief as
Ms. Hammaker's reputation in this regard.
8. Paragraph 7 of the Employment Agreement, being in
writing, speaks for itself and therefore no response to this
allegation is required.
9. Admitted.
10. Admitted with the exception that Ms. Ilammaker
became employed with Capital Area May 1, 1995.
-2-
11. Denied. On the contrary, Ms. Hammaker has not
competed with Plaintiff and has not solicited or otherwise taken
away Plaintiff's employees or clients.
12. This allegation is a conclusion of law to which no
response is required.
WHEREFORE, Defendants Lori J. Hammaker and capital Area
Temporary Services, Inc. request jUdgment in their favor and
against Plaintiff Keystone Personnel & Keystone Temporary
Services, Inc., together with costs of suit, and any relief the
Court deems just and proper.
NEW MATTER
13. Plaintiff does not have a likelihood of success on
the merits and is not, therefore, entitled to a preliminary
injunction.
14. There is no threat of immediate and irreparable
harm and, therefore, Plaintiff is not entitled to a preliminary
injunction.
15. Plaintiff's claims are barred by Plaintiff's own
breaches of the Employment Agreement.
16. Plaintiff's claims are barred by Plaintiff's
violations of the Fair Labor Standards Act, The Minimum Wage Act
of 1968 and Pennsylvania's Wage Payment and Collection law.
17. Plaintiff comes to this court with unclean hands.
18. The non-competition clause in the Employment
Agreement is invalid as a matter of law.
-3-
19. The non-competition clause in the Employment
Agreement is not reasonable 1n time or scope and not reasonably
necessary to the protection of Plaintiff's business interests.
20. Plaintiff's claims are barred by a failure of
consideration.
21. The Employment Agreement is invalid.
22. Ms. Hammaker has not solicited, diverted or taken
away any employee or client of Plaintiff.
23. Ms. Hammaker has not breached the employment
Agreement.
WHEREFORE, Defendants respectfully request judgment in their
favor and against Plaintiff Keystone Personnel & Keystone
Temporary Services, Inc., together with costs of suit, and any
relief the Court deems just and proper.
COUNTERCLAIMS OF DEFENDANT LORI HAMMAKER
COUNT I - Violation of the Fair Labor Standards Act.
24. It is believed and therefore averred that
Plaintiff is an enterprise engaged in commerce whose annual gross
volume of sales made or business produced, exclusive of retail
excise taxes, is not less than $500,000.
25. Ms. Hammaker began working for Plaintiff in June,
1994 when she was hired to be an Employment Representative. She
voluntarily terminated her employment effective March 31, 1995.
26. During the course of her employment, Ms. Hammaker
was expected to perform duties beyond those of Employment
-4-
Representative, including receptionist, cleaning lady,
telemarketing and messenger duties.
27. While employed by Plaintiff, Ms. Hammaker was a
non-exempt employee under the Fair Labor Standards Act (FLSA").
28. Pursuant to the FLSA, Plaintiff was required to
pay Ms. Hammaker time and one half for every hour Ms. Hammaker
worked in excess of 40.
29. Ms. Hammaker was expected to and frequently worked
in excess of forty hours per week, both in the evenings and on
the weekends. In addition, Ms. lIammaker was expected to and did
work through her lunch hour on a regular basis.
30. Plaintiff knew, or should have known, that Ms.
Hammaker was working in excess of 40 hours per week.
31. Pursuant to Plaintiff's practice, Ms. Hammaker was
permitted to show only 8 hours per day on her time records.
32. Ms. Hammaker's hourly rate while employed by
Plaintiff was $9.00.
33. Plaintiff did not pay Ms. Hammaker for the hours
she worked in excess of 40 in any workweek.
34. Plaintiff violated the FLSA by failing to pay Ms.
Hammaker overtime pay for hours worked in excess of forty per
week and by failing to keep accurate records of time worked.
35. Certain records that will assist in the
determination of the overtime compensation owed to Ms. Hammaker
are within the exclusive control of Plaintiff and Ms. Hammaker is
unable to state at this time the exact amount owing to her.
-5-
These records should be made available during discovery and Ms.
Hammaker will then amend her pleading herein to set forth the
amount due her.
36. In addition to the amount of overtime compensation
due her, Ms. Hammaker is entitled to liquidated damages in an
amount equal to the amount of overtime compensation owed plus
reasonable attorney's fees and costs which are mandatory,
pursuant to 29 U.S.C.S. S216(b).
WHEREFORE, Defendant Lori J. liammaker respectfully requests
judgment in her favor and against Plaintiff Keystone Personnel ,
Keystone Temporary Services, Inc., for her unpaid overtime
compensation, liquidated damages in the same amount and
reasonable attorneys' fees and costs, together with any
additional relief the Court deems just and proper.
COUNT II - Violations ot The Minimum Waqe Act of 1968
37. The allegations of Paragraphs 20 - 36 are
incorporated herein by reference.
38. Plaintiff is an employer and Ms. Hammaker was an
employee of Plaintiff within the meaning of The Minimum Wage Act
of 1968 ("MWA").
39. Pursuant to MWA, plaintiff was required to pay Ms.
Hammaker time and one half for every hour she worked in excess of
40 in a workweek.
40. Plaintiff's failure to pay Ms. liammaker time and
one half for every hour she worked in excess of 40 in a workweek
-6-
CERTIFICATE OF SE~E
I, cathleen M. Stryker, hereby certify that on this 24th day
of July, 1995, I causod a true and correct copy of Defendants'
Answer to Plaintiff's Complaint, New Matter and Counterclaims to
be served via first-class, overnight U.S. mail upon counsel
listed below:
Thsodore A. Adler,Esquire
Reager , Adler, P.C.
2331 Market Street
Camp Hill, PA 17011-4642
1/ ,/
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CATHLtEN M,
II. J ,
M
16ml
VERIFlCATION
BRIAN GAUGIIAN hereby etatee that he is Vice proeident
of Capital Area Temporary Services and that the facte set forth
in Defendants' Response to Plaintiff's Motion for Preliminary
Injunction are true and correct to the best of his knowledge,
information and belief. The undersigned understands that the
statements herein are made subject to tho penalties of 18 Pa.
C.S.A. S4904 relating to unsworn falsification to authorities.
. "'-"..):(-4.' '- ,,,./
BRIAN OAUGIIAY
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Datedl
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KEYSTONE PERSONNEL , KEYSTONE
TEMPORARY SERVICES, INC.,
Plaintiff
IN THE COURT OF COKMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
LORI J. HAMMAKER and
CAPITAL AREA TEMPORARY
SERVICES, INC.,
IN EQUITY
Defendants
o R D E R
AND NOW, thJ 5
day of
, 1995, after a
hearing on Plaintiff' 5 Motion for Preliminary Injunction, said
Motion is hereby GRANTED.
BY THE COURT:
J.
Exhlhlt A
~YSTONB PERSONNBL , KBYSTONB
TEMPORARY SERVICES, INC.
360 Market street
Lemoyne, PA 17043
Plaint! ff
I IN THB COURT or COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I
I
I
I
I NO.
v.
LORI J. IlAKHAKER
21 Heidi Terrace
Camp Hill, PA 17011
and
CAPITAL AREA TEMPORARY
SERVICES, INC.
839 Market street
Lemoyne, PA 17043
Defendants
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do 50, the case may proceed without you and a judgment may be
entered against you by the court without further notice for any
money claimed in the complaint, or for any other claim or relief
requested by the plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TA~ THIS PAPER TO YOUR LAWYER AT ONCE. Ir
YOU DO NOT HAVB A LAWYER OR CANNOT AFFORD ONB, GO TO OR
TELBPHONB THE OFFICB SET FORTH BEr~W TO FIND OUT WHERB
YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor
cumberland county Courthouse
One Courthouse square
Carlislo, PA 17013
(717) 240-6200
4. On June 6, 1994, Plaintiff and Defendant Hammaker
executed a written employment agreement (hereinaft~r "Employment
Agreement") by which Plaintiff agreed to employ Defendant Hammaker
as an employment representative in consideration of Plaintiff
pay ing Defendant Hammaker $360.00 per week. A copy of the
Employment Agreement is attached hereto as "Exhibit A."
5. At all times relevant and material to plaintiff's cause
of action, Defendant capital Area is a temporary help business, and
is a direct competitor of plaintiff.
6. At all times relevant and material to Plaintiff's cause
of action, Defendant Hammaker has been engaged in performing
services as an employment representative.
7. Defendant Hammaker has the reputation of possessing
certain skills in the rendering of such services.
8. By paragraph seven (7) of the Employment Agreement,
Defendant Hammaker agreed that during the twelve (12) month period
immediately following her termination of emploYlnent with plaintiff,
she would not, in any area within f !fty (50) miles of any of
Plaintiff's businesses, engage, either directly or indirectly, in
competition with the business activity carried on by Plaintiff.
9. Defendant Hammaker terminated her employment with
Plaintiff on March 31, 1995.
10. In April, 1995, th'3 exact dllte of which is unknown,
Defendant Hammaker obtained employment as an employme'lt
-2-
representative with Dsfendant capital Area, a business located
within fitty (50) miles of Plaintiff's business and In competition
with Plaintiff.
11. Upon information and belief, Defendant Hammaket" has,
since the date of her employment with Defendant capital Area,
engaged in the temporary help business in competition with
plaintiff and has or will solicit, divert or take away persons and
companies who are potential applicants and clients of Plaintiff.
12. The aforementioned actions of Defendant Hamllaker
constitute breaches of the Employment Agreement.
WHEREFORE, Plaintiff, Keystone Personnel' Keystone Temporary
Services, Inc., respectfully requests this Honorable Court tOI
(a) permanently enjoin Defendant, Lori J. Hammaker, from
soliciting business from or rendering services to any person or
entity which violates the terms of the Emp:oyment Agreement for II
period of twelve (12) months from the date of the termination of
Defendant Hammaker's employment with Plaintiff I
(b) permanently enjoin Defendant, Capital Area Temporary
Services, Inc., froro soliciting, obtaining or using the services of
Defendant Hammaker for a period of twelve (12) months from the date
of the termination of Defendant Hammaker's employment with
Plaintiff I
-]-
KEYSTONE PERSOHllEL , KEYSTONE TEMPORARY SERVICES
360 Market Street
Lemoyne.,A 17043
(717) 761-5860
DiPLO\'P."!I'f hGREEHENT
This Agree"'e:1t made this (; day of .[):L-11r, ,19.!l!/.
KEYSTOIlE PER50HllEL , KEYSTOIlE 'fEP.POR.~ SERVICES, II/C., a Pennsylvania
bet\,'een
~h.Jre.inafter . referred
0t.J2I, /0d~--:.r,n h /1
,
to as tl-,e ';:mployee') a:1d
\iliEREAS. !:::-,plc)'er desires to promote tr,e growth of !:~plo)'ee for the
mutual benefit of ;:'T.plo)'er and Emplc)'ee by insurir,g against unfair eompetiticn
by anyone or more of emj'lo)'eea of E:r.;>lo)'er "hosa employment relationship may
t ~
as
the
Company
'Employer'), and
(hereinafter referred
eea sa; and
\,'JlEREAS. E~j'lo)'er desire to more fully set forth the terms of the
emplo)'ment relationship fcr the ber,efit of both tl-,e Employer and Employee.
!lOll, THEREFCRE, in cor.si~eration of the foregoing, Employer and
Emplc)'ee agree as foUc"s I
1. EHPLOYME!lT.
!:m;>lcyer shall hire employee e:1d E:nplu)'ee shall sen'e Emplo)'er
in the capacity of Employment Representative. !:mplo)'ee [hsll perform 81 an
Employment Representat1\oe for end on behalf of the !:rnplo)'er by Ferforminll certain
duties including but not limited to tho~e ~uties enumernted on Exhibit 'A',
attached hereto which shsll be called the job description. This job description
may be modified from ti:r.e lO time by the Employer so long 81 those modifications
relate .to the pe r forme:1ce of tlul1e s as an Emplo)'ment Representa tive.
i
D1PLOYHElIT AGREDlEIlI
2. !lOURS.
Employee shall be required to work on a five day calendar ~eek
between tha houra of 't:{'(j-S:OO Eastern Standard Time thr.oush
Eaatern Standard Tima at a location to be selected by Emp10j'er.
3. FILES. RECORDS AIm DATA.
It is understood and agreed hereto that the names, addresses,
files, Job orders, fore,S. records er.d other salient busine69 data of the
applicants ond client companies of !:mployer cor,nitute a valuable, asset of
Employer snd are tra~e secrets of the Emplo)'er, !n the event tr.at L~ployee's
employment relationship ",ith Emplo)'er ,hall be terrr.inated, "r,ether voluntarily
or invol\:ntarily, Empleyee agrees tr.s t he or she ....ill keep ccnfi~ential cuch
inforrr.ationl that )-,e or she ~'ill not HtoJnFt to Cee,efit persor,ally in any ~'ay
from the disclosure of any such infor~ation relating to said clients; that he or
she will not sell, give or disclose any ,uch r:ernel, addresses cr other solient
business dsta of Employer's clients to any competitor of Employer and, that he
or she will not malta ar.y effort, directly or indirectly, on his or her o~-n behalf
or on the behalf of any other person or business entity to encourage sny of said
clients of Emplo)'er to ,"ithhold their ptrons&e from Emplo)'er. It is further
undentood that no files, records, cr cther salient business data of Employer
shsll te removed from the offices of Employer ....ithout the express prior consent
of E..'T.plo)'er.
4. TMI!lIliG.
Srr,plo)'er ,hall be respcnsible fer providing training st its wn
expense to tho benefit cf Employee in ordH that r.e or ,he may imrro,'e his or hor
skills as on EmploY::lent Represenlstive. T)-,e e~c\Jnt of said training, the
location of said training nnd the e>:t.ent cf suc!l troining shall be at the
discretion of Employer,
S. fACILITIES.
Employer shall bo rHponsiblo for providing all facilities
necessery for the performance of duties os an Employment Representotivo.
6. PROE.~TlOII.
Employer ond Employee aclmowledge that the first ninety (90)
days of the Employment Agreement shall constitute ....hat ia kno~-n aa a
i
'probationary period'. At the conclusion of said probationary period, Employer
shall have the right to retain or discharge Emplo)'ee uith or loIithout cause.
Employer further reSeL'ves the right to terminate any time thereafter an employee
not fully complying with his or her job description and duties as directed, or
any reasons listed under paragraph eleven (11), Termination.
7. RESTRICTIVE COVEnANT.
Emplo)'ee does hereby expL'essly covenant, promise end agree that
during the term of his or her l'mployment and for a period of one (1) )'ear
following the terminBt.10:l of his or her emplo)'ment, for any reason whatsoever,
he or she shall not, eit~,er ea principal or on behalf of, Ot' in conjunction with,
any other person, firm, partnership, company or ccrporation, either as agent,
employee. partner, officer. director, consultant or any other capacity, directly
or indirectly, within a radius of fifty (50) miles from Employer's principal
office do any of the followingl
A. Employee shall nut engage in the employ~ent agency or
temporary heljl business in competition "ith Emjllo)'er.
B. Employee agre~s that he or she shall not solicit or
contact any of Employer's clients with whcm he or she
dealt during the employment relationship.
c. EmplC)'ee agroes that he or she shall not solicit, divert
or take a,,'ay putential applicants or client companies of
Emplo)'er ~'ithin said fifty (50) mile radius of
Employer's prIncipal office for the period of one (1)
)'ear from the terminaUc:l of his or her employment
relationship.
O. CCHPE!/ShTlON.
Employer "grees to compensate!:~ployee for the performance of
Emplo),nent Reprecentati\oo in the follo",inll o,anner, the Employee shall eDrn3~,oo
per week, plul bonus if qualifies.
9. BEIIEFITS.
Employer agrees to Fro'Ji,le saladed Emplc)'ee tr,e follo~'ing
fringe l:enefits I
.~. Vacation is accumulated at a rate of 83% per month or 5
da)'s for e\'ery 6 montha. After 5 )'ears, 3 ~'eeks vacation
is earned at 3 rate of 1.25% per nonth. This is
calculated from )'our anniversary date to )'Our anniverury
date. Vacation tim.. can not be carried ever from year
to year, it mUSl be used by your anniversary date
\
\.
.
DlPLOYHEIIT AGREElIEHT
B. Employee sholl be entitled t.O the followinll holidayal
Chrhtm8B, p.~morial Day, Fourth of July. Labor Day,
Thanksllivinll and lI~w Year's Day.
.
c. Paid sick leave 13 available only for full-time, selaried
employees end shall be determined, at the discretion of
Emplo)'er .
D. Dinner costs for attending various business meetinge ",hen
related to tte industry to be paid by Employer unless
otherwisa sUted in advence. Seminar costs to be handled
in the sema ""anner, CC:\I'~ntion costs will be on e
contest or ber,\\s basis,
10. CDNTROL.
Err,plo)'Er shall rescrve the right to direct and control the
assignment of applicants/temporary employees and client companies to !:mployee and
Employee agrees to accapt the responsibility assillned to him by Employer.
11. TERHIHATIOII.
!:mplo)'ee may voluntuily termir.! te the employment relationship
provided ha or she notify E:nployer tIIO (2) "eel<s in ad,'ence es to the dete of his
or her termination.
A. Employer may terminete the employmer.t relationship for
the followina raasonGI
1. Violation of the code of ethics established by the
National ASGociaticn of Persennel Consultents or
National Association of Temporary Services.
2. Violation of the licensingle,,'s of the Com:nonl.'ulth
of Pe::nsylvcnia and/or fe~eral regulations
governing elllplo)'l"ent allendes or temporary help
Eervicas.
3. Any continued course of conduct ,,'hich is
detri,r.ental to the Employer "hich after notice by
Employer to Emplo)'ee ia continced by Emplo)'ee.
This conduct csn inc1u~e, but is not limited to,
intoxication on the Job, abusi\'e language, irn.1lOral
conduct. tardine6S and unexcused absences, refusal
to follow Emplo)'er policies or instructions in the
performance of his or her duties.
4. Any time durinll the probstionary period without
cause.
22. Denied. Plaintiff believes that Hammaker has
communicated with present or former clients of Plaintiff.
23. Denied as a legal conclusion.
WHBRBFORB. Plaintiff requests the relief sought in the
Complaint in Equity.
ANSWER TO COUNTERCLAIMS
COUNT I
24. Admitted.
25. Admitted.
26. Denied. Ms. Hammaker was not "expected" to perform any
duties beyond thoBe Bet forth in her employment agreement.
Hammaker worked in a two person off ice. At times, she answered her
own phonel at times she emptied her own trash canl and at times she
delivered documents to clients. All of these activities were done
by Hammaker on her own volition, and were not required by the
Plaintiff.
27. Denied as a legal conclusion.
28. Denied aB a legal concluBion. In further response, it is
averred that lIammaker waB a salaried employee, as set forth in the
employment agreement.
29. Denied. Ms. Hammaker was not "expected" to work in
excess of forty hours per week or to work through her lunch hour.
lI11mmakll!" B hourB of work were l!stllbl i shed by her employment
-2-
agreement. If Hammaker did in fact work in excess of forty hours
or through her lunch hour, it was on her own volition.
30. Denied. Plaintiff incorporates herein the avermsnts of
paragraph 29 of this Answer to Counterclaim.
31. Denied. Plaintiff did not require or "permit" Hammaker
to show only eight hours per day on her time cards.
32. Denied. Hammaker was not an hourly employee. In
accordance with the employment agl"eement, she received a salary of
$360/week.
33. Denied. Hammaker was a salaried employee. If in fact,
Hammaker worked in excess of forty hours per week, she did so on
her own volition.
34. Denied as a legal conclusion.
35. Denied. Hammaker knows she was a salaried employee, and
was entitled only to her salary plus applicable bonuses, all of
which have been paid by the Plaintiff.
36. Denied as a legal conclusion.
WH!R!FOR!, Plaintiff requests judgment in its favor and
against Defendant Hammaker under Count I of her Count.erclaim.
~Q!,J1tT-ll
37. Plaintiff incorporfttes herein by reference the averments
of paragraphs 20-36 of its Heply to New Hatter and Answer to
Counterclaim.
-)-
38. Denied as a legal conclusion.
39. Denied as a legal conclusion. In further response, it is
averred that Hammaker was a salaried employee.
40. Denied as a legal conclusion.
WHBREFORE, Plaintiff requests judgment in its favor and
against Defendant Hammaker under Count II of her Counterclaim.
kQ.lW'l' I I I
(Incorrectlv Desicrnated as Count II in the Counterclaiml
41. The averments of paragraphs 20-40 of plaintiff's Reply to
New Matter and Answer to Counterclaim are incorporated herein by
reference.
42. Denied as a legal conclusion.
WHBRBFORE, Plaintiff requests judgment in its favor and
against Defendant Hammaker under Count III of her Counterclaim.
llilli MA'l'TEH TO COUNTEHCLAIMS
43. Plaintiff is a service establishment.
44. Defendant Hammaker was employed under a bona fide
individual employment contract.
45. Defendant Hammaker pel'formed her duties under only
general supervision and provided service that required special
training.
-4-
CIRTIrICATI or BIRVICS
AND NOW, this 14th day of August, 1995, I hereby verify that
I have caused a true and correct copy of the foregoing document to
be placed in the u.s. mail, first class, postage prepaid and
addressed as follows:
Sandra A. Girifalco, Esquire
cathleen M. stryker, Esquire
STRADLEY, RONaN, STEVENS & YOUNG
2600 One Commerce Square
Philadelphia, PA 19103-7098
I
,
/
/ ('I j,/~
THEO~E A. ADLER, ESQUIRE
TO TliE PlAINTIFF: YOU ARE HEflEBY NOTIFIED
TO FilE A WRITTEN RESPONSE TO THE
ENCLOSED NEW MATTER WITIUN TWENTY 1201
DAYS FROM SERVICE HEREOF OR A JUDGMENT
MAY BE ENTEHED AGAINST YOU,
~~HIlJ~ 8~/(1tJ
~O NEY FOR D~ENDAN
, (
KEYSTONE PERSONNEL & KEYSTONE
TEMPORARY SERVICES, INC.,
Plaintiff
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-2882 Equity Term
LORI J. HAMMAKER and
CAPITAL AREA TEMPORARY
SERVICES, INC.,
Defendant
DEFENDANTS' RESPONSE TO PLAXNTIFF'S
MOTION FOR PRELIMINARY INJUNCTION
Defendants, Lori J. Hammaker and Capital Area Temporary
Services, Inc., by their attorneys, Stradley, Ronon, Stevens &
Young, hereby respond to Plaintiff's Motion for Preliminary
Injunction as follows:
1. This allegation is a conclusion of law to which no
response is required.
2. It is admitted that Plaintiff has filed a
Complaint seeking an injunction against Lori J. Hammaker. It is
denied that Defendant Hammaker violated any valid terms of her
employmsnt agresment with Plaintiff.
3. No response required. Defendants incorporate
herein by reference their Answer, New Matter and Counterclaims, a
copy of which is attached as Exhibit "A".
4. This allegation is a conclusion of law to which no
response is required.
5. This allegation is a conclusion of law to which no
response is required.
WHEREFORE, Defendants respectfully request that this
Honorable Court deny Plaintiff's Motion for Preliminary
Injunction and grant Defendants their attorneys fees and costs
and such other and further relief as this Court may deem just.
NEW MATTER
6. Plaintiff does not have a likelihood of success on
the merits and is not, therefore, entitled to a preliminary
injunction.
7. There is no threat of immediate and irreparable
harm and, therefore, Plaintiff is not entitled to a preliminary
injunction.
B. Plaintiff's claims are barred by Plaintiff's own
breaches of the Employment Agreement.
9. Plaintiff's claims are barred by a failure of
consideration.
10. Plaintiff's claims are barred by Plaintiff's
violations of the Fair Labor standards Act, The Minimum Wage Act
of 196B and Pennsylvania's Wage Payment and Collection law.
-2-
11. Plaintiff comes to this court with unclean hands.
12. 'l'he restr icti vo covenant in tho Employment
Agreement ie not reasonable in time or scope and not reasonably
necessary to the protection of Plaintiff's business interests.
1J. The restrictive covenant is invalid as a matter of
law.
14. The Employment Agreement is invalid.
15. Ms. Hammaker has not solicited, diverted or taken
away any employee or client of Plaintiff.
16. Ms. Hammaker has not breached the Employment
Agreement.
WHEREFORE, Defendants respectfully request judgment in their
favor and against Plaintiff Keystone Personnel & Keystone
Temporary Services, Inc., together with costs of suit, and any
relief the Court deems just and proper.
tL
S~ dra A. G r co
9hthleen M. tryker, Esquire
STRADLEY, RONON, STEVENS & YOUNG
2600 One Commerce Square
Philadelphia, PA 19l0J-7098
(215) 564-8000
Attorneys for Defendants,
Lori J. Hammaker and capital
Area Temporary Services, Inc.
161171
-J-
VERIfiCATION
LORI J. HAMMAKER hereby states that the facts set forth
in Defendants' Response to plaintiff's Motion for preliminary
Injunction are true and correct to the best of her knowledge,
information and belief. 'I'he undersigned understands t.hat the
statements herein are made subject to the penalties of 18 Pa.
C.B.A. 54904 relating to unsworn falsification to authorities.
~{.., ~ Nl"",~d/ p,{~
LO I J. AMMAl<ER
Datedl
Ih11JlIK
'7 J' q~'
. ~) .1
, ,
YIlUlICATION
7'.3,'th. ,)
BRIAN GAUGHAtj/
)
, /
,~ .' /
Yrt t . .'........--.
.
BRIAN GAUGHAN hereby states that the facts set forth in
Defendants' Answer and New Matter to Plaintiff's Complaint, New
Matter and counterclaims are true and correct to the best of his
knowledge, information and belief. The undersigned understands
that the statements herein are made subject to the penalties of
18 Pa. C.B.A. 54904 relating to unsworn falsification to
authorities.
Datedl
167901
.../" J /-1;
KIYSTONI PIRSONNIL . KIYSTONI
TIMPORARY SIRVICIS, INC.,
PlaintiU
IN THB COURT or COMMON PLBAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
v.
NO. 95-2882 IgUITY TBRM
LORI J. HAMMAKER and
CAPITAL ARBA TEMPORARY
SBRVICES, INC.,
Defendant.
PLAINTIFF'S RBPLY TO NBW HATTER
CONTAINED IN DBFBNDANTS' RBSPONSB TO PLAINTIFF'S
MOTION FOR PRBLIMINARY INJUNCTION
6. Denied as a legal conclusion.
7. Denied as a legal conclusion. To the extent that the
averments of paragraph ., of Defendants' New Matter require a
response, it is averred that Plaintiff has and will suffer
irreparabl e harm if an injunct ion is not granted because of the
threat of a continuing violation of the restrictive covenant by
Defendant Hammaker and the resulting incalculable damage that may
be suffered by Plaintiff.
O. Denied as a legal conclusion.
9. Oenied a6 a legal conclusion.
10. Denied as a legal conclusion.
.
11. Denied as a legal conclusion. In further response, it is
denied that Plaintiff violated any applicable laws or regulations.
12. Denied as a legal conclusion. In further response, the
restrictive covenant is reasonably necessary to protect Plaintiff's
business interests.
13. Denied as a legal conclusion.
14. Denied as a legal conclusion.
15. Denied. Plaintiff believes, and therefore avers, that
Hammaker has or will compete with Plaintiff for clients and
business.
16. Denied as a legal conclusion.
WHEHEFORE, Plaintiff requests the relief sought in its Motion
for Preliminary Injunction.
RESPECTFULLY SUBMITTED,
IlEAGEH , ADLER', P.C.
/
Date r '/Yi'/\'
a I. (
Y 1_--/-_,,-__
'flllmD6llE A. ADLEH, ESQUIRE
Identification No. 16267
2331 Market street
Camp 11111, l'A 17011-4642
('/1 .,) '16] -1] B ]
Attorneys for Plaintiff
-2-
VBRlrICATIOH
I, SHERRY L. SHUMAKER, hereby verify that I am the President
of Keystone Personnel & Keystone Temporary Services, Inc., and as
such, I am authorized to verify the averments of the foregoing
document are true and correct to my personal knowledge, infor-
mation and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. S4904, relating to
unsworn falsification to authorities.
KEYSTONE PERSONNEL & KEYSTONE
TEMPORARY SERVICES, INC.
\"u..~
By: ~/;,
" II
.
A'/
'1/
-". .
. I lilt".
" J.
SHERR't;' L. SHUMAKER
President
Datel >ijl/ I,IS'
~
CBRTIFICATB OF SBRVICB
dl1/i
MD NOlf, this ~ day of August, 1995, I hereby verify that
I have caused a true and correct copy of the foregoing document to
be placed in the U. S. mail, first class, postage prepaid and
addressed as follows:
Sandra A. Girifalco, Esquire
Cathleen M. stryker, Esquire
STRADLEY, RONaN, STEVENS & YOUNG
2600 One Commerce square
Philadelphia, PA 19103-7098
,;/
/~
THE6DORE A. ADLER, ESQUIRE
-3-
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~'11U\DLEY
RONON
STEVENS
OO"OUNG
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t21~I"ht.HlIhl
August 29, 1995
Prothonotary
Cumberland county Courthouse
One Courthouse Square
Carlisle, PA 17013
Re: Keystone Personnel , Keystone Temporary services,
Inc. v. Lori J. Hammaker and capital Area
Temcorarv services. Inc.. No. 95-2882
Dear Sir/Madam:
I enclose herewith for filing an original and one copy of
Defendants' Brief in opposition to Plaintiff's Motion for
Preliminary Injunction, a copy of which was forwarded directly to
Judge aler on August 24, 1995 prior to his hearing the motion on
August 28, 1995.
Please time-stamp the additional copy and return it in the
self-addressed, stamped envelope provided for your convenience.
Thank you for your courtesy and attention in this regard.
Very truly yours, ~
( {,
/tu-.Lu.. J~:du~
Sandra'A. Girifa<1.co (J
SAG/smw
Enclosure
cc: Theodore A. Adler, Esq.
112401.1
Ij1--.!J 0<J2 f4..J 1 Lt
J./\ JLtJ.. .
I
-rJ)J I J) D
JI"a J !it'd
According to thl! Agrl!l!ml!nt, Mil. lIaml1\akl!l" wall hi n.!d to work
as an Employment Representativu 5 daYll pur wuuk, 0 hours per day.
c.
Employee agreee that he 01 ehe shall not solicit, divert or
take away potential BpplicftlllB or client compa.nies of
Employel wllhln anti fifty 150) mlle IOdins of Employer'e
principal oftice for the period of uns (1) yea I' from the
termination of hiu 01" her Employment ndatlollBhip.
She was paid $360 pur wuuk. lIowuvul", Bhortly aftul" the sta,-t of
her employment, Keystone I"equlrud Ms. lIammakur to upend a
significant portion of hur tlmu performing thu dutius of a
cluilning person, delivery uervice, telemarkutur and receptionist,
and working well beyond hur schudulud time, for which she was not
compensated. On March 31, 1995, after lusu than ten months at
Keystone, Ms. Hammaker voluntarily terminatud her employment.
On May I, 1995, Ms. lIammaker began employment with capital
as an Employment coordinator. On May 26, 1995, Kuystone filed a
Complaint and Motion for a Preliminary Injunction ueeking to
enjoin Ms. lIammaker's employment with Capital based upon the
"Restrictive Covenant" found in the Agreement. Keyutone's motion
must be denied because (1) Keystone cannot Illeet tho threshold
requirements for issuance of a preliminary injunction and (2)
Keystone's claims, which sound in equity, are barred by the clean
hands doctrine.
B. Employee agreee that he or ehe shall not eolfell or contact
any of Employer'S clients with whom he 01 she d..lt dUl,lng
the employmsnt relationship,
-2-
II. ARGUMBNT
A. Keystone can not meet the threshold requirements tor a
Preliminary In1unotion
A preliminary injunction is an extraordinary remedy
which should only be granted if the party seeking the injunction
(1) will suffer immediate and irreparable injury if the
injunction is denied and (2) has a clear right to the relief
sought. William v. Children's Hospital of l'ittsburqh, 505 Pa.
263, 479 A.2d 452 (1984); Soia v. Factorvville Sportsmen's Club,
361 Pa. Super. 473, 552 A.2d 1129 (1987). A preliminary
injunction should never issue unless there will be greater harm
done by refusing it than by granting it. /losP. Ass'n v. Com.
Dept. of PUblic Welfare, 495 Pa. 225, 433 A.2d 450 (1981). As
demonstrated below, Keystone's request for a preliminary
injunction fails on all three counts. Most significantly,
Keystone has no evidence of harm.
1. Keystone will not suffer any injury if the
iniunction is denied
OUt" ing the four months Ms. Hammaker has been
employed with Capital, Keystone has not been injured in the
slightest. Keystone's inability to prove immediate and
irreparable injury is fatal to its request for a preliminary
injunction. Hollillli Protectlye Services Co. v. shatfQr, 3B3 Pa.
Super. 598, 557 A.2d 413 (1989).
In HQ~ljll~, two tormer employees of Hollins
Protective Services left its employ to work for a direct
competitor. Both employoes signed restrictive covenants
-3-
prohibiting them from engaging in employment in competition with
Rollins for a period of two years. Although the trial court
found the employment agreements valid, the court denied Rollins'
motion for preliminary injunction because Hollins failed to
establish any harm at all resulting frem the employees' violation
of the covenants not to compete. Id. at 601/557 A.2d at 413.
The superior Court affirmed the trial court's decision noting
that since Hollins' former employees had not stolen or solicited
any of Rollins' customers or taken any customer lists, Rollins
"was threatened with no greater harm to 'customer relationships'
from [its former employees], than from any other similarly
situated employee not formerly employed by [Hollins]." lsL. at
602, 557 A.2d at 414.
Hased upon similar facts, the Superior Court
affirmed the denial of a preliminal-y injunction in lIarsco Corp.
v. Klein, 395 Pa. Super. 212, 576 A.2d 1118 (1990). In lIarsco, a
19 year employee named Klein terminated his employment with
liars co and began working for a competitor. '1'he court denied
Jlarsco's motion for a preliminary injunction to enforce a
restrictive covenant because "there was no likelihood of
immediate and irreparable harm to lIarsco by l-efusing the
injunction." Id. at 21'/, 576 A.2d at 1121. The Superior Court
affirmed noting that when Klein l"oBigne>d his employment he was
not dealing directly with clientll and that "in any event the
customers in lllarsco'll industry] would be generally known to all
of the firms in tho llame bus i neSB. . ." 19->.
"4-
Hammaker, it ohould not be enforced, UQQ Mgrqan'O 1I0me Equipment
Corp. v. Martucci, 390 I'a. 6111, IJ6 A.2d 1130 (1957) (Court
refused to enforce covenant prohibiting former employee from
working for competitor within JOO mile radius for one year on
basis that covenant posed an undue hardBhlp on employee but was
not reasonably necessary to protect the employer).
b. 'I'he EmpIQYment-Ilgreelllent is Unenforceable
Keystone can not now enforce the Agreement
because it materially breached the Agreement during Ms.
Hammaker's employment. ott v. Buehler Lumber co., 373 1'a. Super.
515, 541 A.2d 1143 (1900) (party who materially breaches contract
can not complain of breach of contract by other party); United
States v. Curtis T. Dedwell & Sons. Inc., 506 F. Supp. 1324
(E.D.Pa. 1981) (same). Paragraph 2 of the Employment Agreement
states that the "Employee shall be required to work on a five day
calendar week between the hours of 8:00 - 5:00." See, Exhibit
"A" to Keystone's Complaint at ~ 2. In actuality, Ms. Hammaker
was routinely required to work through lunch, in the evenings,
and on weekends and to be on call without being compensated.
Furthermore, Paragraph J of the Agreement
states that Ms. Hammaker was hired as an "Employment
Representative" and her job description could only be modified if
the modifications related to the performance of duties as an
Employment Representative. Nonetheless, ao discussed above,
Keystone did not employ Mo. lIammilker solely as an Employment
Representative as promised in the Agreement, but rather, it
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required her perform a variety of tasks tot~lly unrel~ted to the
work of an Employment Representative. Under Pennsylvania law,
Keystone's material breaches of the Agreement void any obligation
Ms. Hammaker may have had under the Agreement.
n. Kevstone Comes to This Court ~it~clean Han~s
Keystone may not invoke the equitable powers of this
Court because it comes to this Court with unclean hands. As has
been stated by the Supreme Court of Pennsylvania for over a
quarter century, "He who seeks equity must do equity." Ma~er v.
Sarqent Electric co., 407 Pa. 169, 100 A.2d 63 (1962); Spraque v.
CaseY, 520 Pa. 30, 550 A.2d 104 (190B). The clean hands doctrine
is applicable "where a party seeking affirmative relief is guilty
of fraud, unconscionable conduct or bad faith directly related to
a matter at issue which injures the other party and affects the
balance of the equities between the litigants." ~guibank v.
Adle. Inc., 407 Pa. super. 553, 595 A.2d 1204 (1991).
As discussed in detail above, Keystone knowingly
breached its Agreement with Ms. Ifammaker from its very inception.
Ms. Hammaker never acted solely as an Employment Representative
for Keystone. Further, Ms. Hammaker w~s regularly required to
work evenings, weekends, through lunch and was required to be on
call. Keystone never paid Ms. lI~mmaker for ovel.time even though
it was required to do so under the Fair Labor standat'ds Act, 29
ll.S.C. S 201 et Beq., l'el1llByJvani~'s Minimum W~gt.! Act 01 1968, 43
I'.S. S 333.101 et seq., and The Wage Payment and Collection Law,
43 I'.S. 260.1 at saq.
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Keystonc's i ntont i 01111 I lnil tOI" i iI I bl-caches of the
Agreement and violations of employec protection laws demonstrate
bad faith and unconscionnble conduct directly rclated to the
matter at issue betweon tho partios (1.0., their employment
relationship) and the equities in this litigation. Under the
clean hands doctrine, Keystone's conduct precludes the Court from
entering the pl-eliminary injunction which Keystone seeks.
III. CONCLUSION
For the foregoing reasons, Defendants Capital Temporary
Serviccs, Inc. and Lori Hammaker respectfully request that this
Court deny Keystone's Motion for Preliminary Injunction.
111m
Attorneys for Defendants,
Lori J. Hammaker and Capital
Area Temporary Services, Inc.
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