On December 29, 2017 a
VERIFIED COMPLAINT FOR DAMAGES 1. BREACH OF THE DUTY OF LOYALTY 2. BREACH OF CONTRACT 3. TRADE SECRET MISAPPROPRIATION; ETC
was filed
involving a dispute between
Danone Simpson Insurance Services Llc Dba Montage Insurance Solutions,
and
Ligonde Edwige,
Nielsen Insurance Group Inc. Dba Nielsen Benefits Group,
for civil
in the District Court of Los Angeles County.
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ORIGINAL (SPACE BELOW FOR FILING STAMP ONLY)
HENRY J. JOSEFSBERG, ESQ. FILED
SBN 136772 Su; tor Cou
4050 East Katella Avenue rt of Califomia
ountv of Los Anaales
Suite 205
Los Alamitos, California 90720
Telephone No. (562) 342-9401
Telecopier No. (562) 342-9403
whe DEC 29 2017
secutive Offican Clerk
Henryjjesq@Gmail.com Deputy
Attorney for Plaintiff
DANONE SIMPSON INSURANCE SERVICES LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA, UNLIMITED JURISDICTION
COUNTY OF LOS ANGELES
10
DANONE SIMPSON INSURANCE | Case No.
BC 688417
11
SERVICES LLC DBA: MONTAGE
INSURANCE SOLUTIONS, Amount in Controversy Exceeds
12
$25,000.00]
Plaintiff,
13 VS. VERIFIED COMPLAINT FOR
14 | DAMAGES
EDWIGE LIGONDE, an individual; NIELSEN | Breach of the Duty of Loyalty
15 INSURANCE GROUP, INC., a California | Breach of Contract
corporation, DBA: NIELSEN BENEFITS Trade Secret Misappropriation
16 GROUP, and DOES 1-10, Interference with Contract
Interference with At-Will Contract
17 Defendants. Interference with Prospective
Economic Advantage
18 Unfair Business Practices
19
Plaintiff DANONE SIMPSON INSURANCE SERVICES, INC. alleges as follows:
20
21
22
PARTIES
nN? 1 Plaintiff DANONE SIMPSON INSURANCE SERVICES, INC. Is a corporation and
23
Nr
we conducted business, at all times relevant to this matter, in Los Angeles County, California.
me
@ 2 Defendant EDWIGE LIGONDE is an individual and at all times relevant to this matter,
25
~s conducted business in Los Angeles, County, California.
3 Defendant NIELSEN INSURANCE GROUP, INC. is, on information and belief, a
27
California corporation, conducting business as NIELSEN BENEFITS GROUP, and at all times relevant
28
-le
Verified Complaint
Document Filed Date
December 29, 2017
Case Filing Date
December 29, 2017
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ORIGINAL (SPACE BELOW FOR FILING STAMP ONLY) HENRY J. JOSEFSBERG, ESQ. FILED SBN 136772 Su; tor Cou 4050 East Katella Avenue rt of Califomia ountv of Los Anaales Suite 205 Los Alamitos, California 90720 Telephone No. (562) 342-9401 Telecopier No. (562) 342-9403 whe DEC 29 2017 secutive Offican Clerk Henryjjesq@Gmail.com Deputy Attorney for Plaintiff DANONE SIMPSON INSURANCE SERVICES LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA, UNLIMITED JURISDICTION COUNTY OF LOS ANGELES 10 DANONE SIMPSON INSURANCE | Case No. BC 688417 11 SERVICES LLC DBA: MONTAGE INSURANCE SOLUTIONS, Amount in Controversy Exceeds 12 $25,000.00] Plaintiff, 13 VS. VERIFIED COMPLAINT FOR 14 | DAMAGES EDWIGE LIGONDE, an individual; NIELSEN | Breach of the Duty of Loyalty 15 INSURANCE GROUP, INC., a California | Breach of Contract corporation, DBA: NIELSEN BENEFITS Trade Secret Misappropriation 16 GROUP, and DOES 1-10, Interference with Contract Interference with At-Will Contract 17 Defendants. Interference with Prospective Economic Advantage 18 Unfair Business Practices 19 Plaintiff DANONE SIMPSON INSURANCE SERVICES, INC. alleges as follows: 20 21 22 PARTIES nN? 1 Plaintiff DANONE SIMPSON INSURANCE SERVICES, INC. Is a corporation and 23 Nr we conducted business, at all times relevant to this matter, in Los Angeles County, California. me @ 2 Defendant EDWIGE LIGONDE is an individual and at all times relevant to this matter, 25 ~s conducted business in Los Angeles, County, California. 3 Defendant NIELSEN INSURANCE GROUP, INC. is, on information and belief, a 27 California corporation, conducting business as NIELSEN BENEFITS GROUP, and at all times relevant 28 -le Verified Complaint