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Procedural Posture

Procedural Posture

Plaintiff sued defendants for misappropriation of trade secrets, breach of contract, breach of fiduciary duty, unfair competition in violation of Ca. Bus. & Prof. Code § 17200, and tortious interference with prospective economic advantage. Plaintiff moved for a preliminary injunction.

Overview

Plaintiff alleged that defendant former employees breached an employment agreement prohibiting them from, inter alia, soliciting any customers they served or whose name became known to them during their employment with plaintiff for one year following the termination of their employment. The court held that plaintiff was entitled to a preliminary injunction. Plaintiff demonstrated a likelihood that it would prevail on the merits of its claims to protect its trade secret customer list, to enforce the agreements, and to prevent unfair competition. Plaintiff would suffer irreparable harm absent the entry of injunctive relief as a result of the breach of client confidentiality, conversion of plaintiff’s property and information, incalculability of damages, loss of goodwill, and the threat to office stability and procedures caused by defendants’ violations. The balance of hardships favored granting injunctive relief because an injunction merely prohibited defendants from misappropriating trade secrets, and required them to comply with the reasonable terms of their agreements. Issuance of an injunction would promote the public interest.

Outcome

Motion for a preliminary injunction was granted. Defendants were enjoined from soliciting business from any of plaintiff’s customers whom defendants served or whose name became known to defendants while in plaintiff’s employ, and from accepting business or account transfers from clients whom defendants wrongfully solicited. Appellant was represented by a business attorney.

Procedural Posture

Appellant property owner challenged the adverse summary judgment on its claims for damages from the United States District Court for the Eastern District of California. Appellant also challenged the district court’s granting of appellee oil companies’ motion in limine to exclude evidence of certain permits issued under the Mineral Leasing Act.

Overview

Appellant property owner initiated an action against appellee oil companies for appellees’ alleged failure or refusal to transport oil from a property via its crude oil pipelines, which caused damages to appellant in lost profits on the sale of crude, as well as diminution in value on the sale of the property because appellee refused pipeline access. The district court returned a general verdict in appellant’s favor but awarded zero damages. The district court also granted appellees’ motion in limine to exclude evidence of certain permits issued under the Mineral Leasing Act. Appellant challenged the judgment, and the court affirmed. The court held that appellant waived its right to object to the verdict because it failed to object when the verdict was read. The court also held that the district court’s evidentiary rulings could only be reversed only upon a showing of abuse of discretion. The court held that all of the factors weighed and considered by the district court indicated that the ruling on the motion in limine was highly discretionary, and the district court’s ruling was not an abuse of its discretion.

Outcome

The court affirmed the general verdict in favor of appellant property owner and the award of zero damages, as well as the granting of appellee’s motion in limine to exclude evidence because appellant waived its right to object to the verdict because it failed to object when the verdict was read. The court found no abuse of discretion in the ruling on the motion in limine.

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