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Displaying 54-57 of 57 results

No. 28-1 RESPONSE AND OBJECTION to Motion re 7 MOTION for Expedited Discovery filed by Defendant IRIS ...

Document Wolters Kluwer United States, Inc. et al v. Brown et al, 4:23-cv-01478, No. 28-1 (W.D.Mo. Nov. 28, 2023)
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.
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No. 4-1 NOTICE OF PROCESS SERVER by Plaintiffs CCH Incorporated, Wolters Kluwer United States, Inc

Document Wolters Kluwer United States, Inc. et al v. Brown et al, 4:23-cv-01478, No. 4-1 (W.D.Mo. Nov. 20, 2023)
c/o John R. Ashcroft, Secretary of State 600 W. Main Street, Rm.
The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are: Laura M. Jordan, Esq. Thompson Coburn, LLP, One US Bank Plaza, St. Louis, MO 63101 Peter Steinmeyer, Esq. Epstein Becker & Green, P.C., 227 W. Monroe St., Ste.
3250, Chicago, IL 60606 If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
’ I personally served the summons on the individual at (place) on (date) ; or ’ I left the summons at the individual’s residence or usual place of abode with (name) on (date) , and mailed a copy to the individual’s last known address; or , a person of suitable age and discretion who resides there, ’ I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization) on (date) ; or ’ I returned the summons unexecuted because ’ Other (specify): , who is ; or My fees are $ for travel and $ for services, for a total of $ 0.00 .
Date: Server’s signature Printed name and title Server’s address Additional information regarding attempted service, etc:
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No. 2-1 NOTICE OF PROCESS SERVER by Plaintiffs CCH Incorporated, Wolters Kluwer United States, Inc

Document Wolters Kluwer United States, Inc. et al v. Brown et al, 4:23-cv-01478, No. 2-1 (W.D.Mo. Nov. 20, 2023)
To: (Defendant’s name and address) Nathan Brown 213 Troon Ct. St. Albans, MO A lawsuit has been filed against you.
The answer or motion must be served on the plaintiff or plaintiff’s attorney, Laura M. Jordan, Esq. whose name and address are: Thompson Coburn, LLP, One US Bank Plaza, St. Louis , MO 63101 Peter Steinmeyer, Esq. Epstein Becker & Green, P.C., 227 W. Monroe St., Ste.
3250, Chicago, IL 60606 If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
’ I personally served the summons on the individual at (place) on (date) ; or ’ I left the summons at the individual’s residence or usual place of abode with (name) on (date) , and mailed a copy to the individual’s last known address; or , a person of suitable age and discretion who resides there, ’ I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization) on (date) ; or ’ I returned the summons unexecuted because ’ Other (specify): , who is ; or My fees are $ for travel and $ for services, for a total of $ 0.00 .
Date: Server’s signature Printed name and title Server’s address Additional information regarding attempted service, etc:
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No. 3-1 NOTICE OF PROCESS SERVER by Plaintiffs CCH Incorporated, Wolters Kluwer United States, Inc

Document Wolters Kluwer United States, Inc. et al v. Brown et al, 4:23-cv-01478, No. 3-1 (W.D.Mo. Nov. 20, 2023)
c/o John R. Ashcroft, Secretary of State 600 W. Main Street, Rm 322 Jefferson City, MO 65101 A lawsuit has been filed against you.
The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are: Laura M. Jordan, Esq. Thompson Coburn, LLP, One US Bank Plaza, St. Louis, MO 63101 Peter Steinmeyer, Esq. Epstein Becker & Green, P.C., 227 W. Monroe St., Ste.
3250, Chicago, IL 60606 If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
’ I personally served the summons on the individual at (place) on (date) ; or ’ I left the summons at the individual’s residence or usual place of abode with (name) on (date) , and mailed a copy to the individual’s last known address; or , a person of suitable age and discretion who resides there, ’ I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization) on (date) ; or ’ I returned the summons unexecuted because ’ Other (specify): , who is ; or My fees are $ for travel and $ for services, for a total of $ 0.00 .
Date: Server’s signature Printed name and title Server’s address Additional information regarding attempted service, etc:
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