On this day, the Court considered Plaintiff’s Motion for Expedited Discovery (“Motion”)
IT IS THEREFORE ORDERED that commencing immediately and concluding on January 31, 2024, Plaintiffs and Defendants shall be permitted to engage in limited expedited discovery (no more than ten (10) interrogatories (including subparts), ten (10) document requests, and three (3) in-person depositions (limited to 4 hours each), including to the following subjects: a. The identity of Brown’s employer, the entities for whom he has performed services; b. Defendants’ alleged use of Plaintiffs’ confidential information; c. Brown’s recruitment and hiring at or by IRIS or any of its parents, subsidiaries and affiliates, including offer letter, application, references, job description, incentives, compensation, and communications regarding his recruitment and hiring; d. Any seminar/webinar/sales pitch given by Brown; e. The development, testing, marketing, and licensing during the twelve-month period preceding Brown’s hiring, and the same information for the period following his hiring, for the following products: Outsourcing and Firm Management; f. Since Brown’s hiring, the states in the products identified in paragraph (e) above have been marketed, sold or licensed, in which Brown was involved; g. The factual allegations in the Company’s Complaint; h. The development, testing, marketing, and licensing during the twelve-month period preceding Brown’s departure from the Company, and the same information for the period following his departure, for the following products, in which Brown was involved: Xpitax, CCH Axcess, and CAS.
The identities of customers to whom the products identified in paragraph (i) above were marketed, sold or licensed during the twelve-month period preceding Brown’s departure from the Company and in which Brown was involved, and the same information for the period following his departure; j.
The profits earned by the Company for the products identified in paragraph (i) above during the twelve-month period preceding Brown’s departure from the Company and in which Brown was involved, and the same information for the period following his departure; k. The states in the products identified in paragraph (i) above have been marketed, sold or licensed during the twelve-month period preceding Brown’s departure from the Company, and the same information for the period following his departure; l. The alleged confidential information identified in the Complaint and the measures the Company employed to protect said information; m. Brown’s job duties with the Company, including the identity of the customers with whom he interacted; n. The forensic examination performed by the Company, as identified in the Complaint: and o.
Parties retain all rights in responding and objecting to any discovery requests.