AmeriPride Services Inc. v. Peterson

Filing 37

AMENDED CONSENT INJUNCTION to include Exhibit 1: IT IS HEREBY ORDERED that: The parties' Stipulated Motion for Entry of Consent Injunction (Filing 35 ) is granted. Peterson will not, for a period of one year, beginning on April 10, 2018, and ending on April 9, 2019, within the Textile Rental Business, directly or indirectly solicit, or engage in business-related contact with, (a) any customer of AmeriPride with which Peterson did business and had personal contact during the last six m onths of his employment with AmeriPride, or (b) any customer identified on Exhibit 1 hereto, which Peterson concedes were AmeriPride customers with which he had contact and did business with while he was an AmeriPride employee. No geographic restr iction is included or necessary because of the foregoing limitation. "Textile Rental Business" is defined as the products and services offered by AmeriPride during the last six months of Peterson's AmeriPride employment. Peterson wi ll not divulge to any person any Confidential Information, as defined below, until such time as such Confidential Information has become public knowledge other than as a result of a disclosure by Peterson or those acting in concert with him or on his behalf. "Confidential Information" is defined as all information not generally known to the public, in spoken, printed, electronic or any other form or medium relating directly or indirectly to AmeriPride's customer lists, pros pect lists, financial information, marketing strategies, pricing information, business plans, training information, employment policies, customer requirements, and any other information marked or otherwise identified or treated by AmeriPride as &q uot;Confidential," or understood by a reasonable person to be confidential. This Court shall retain continuing jurisdiction over this action for purposes of enforcing this Consent Injunction notwithstanding the entry of any Order of Dismissal in this case. Ordered by Senior Judge Joseph F. Bataillon. (ADB)

UNITED STATES DISTRICT COURT
DISTRICT OF NEBRASKA

AmeriPride Services Inc.,

CASE NO 8:18-CV-00096

Plaintiff,
v.
Jeffrey Peterson,
Defendant.
AMENDED CONSENT INJUNCTION
This matter is before the Court on the parties' Stipulated Motion for Entry of Consent
Injunction (Filing 35). Upon consideration,
IT IS HEREBY ORDERED that:
1.

The parties' Stipulated Motion for Entry of Consent Injunction (Filing 35) is

granted.
2.

Peterson will not, for a period of one year, beginning on April 10, 2018, and

ending on April 9, 2019, within the Textile Rental Business, directly or indirectly solicit, or
engage in business-related contact with, (a) any customer of AmeriPride with which Peterson did
business and had personal contact during the last six months of his employment with
AmeriPride, or (b) any customer identified on Exhibit 1 hereto, which Peterson concedes were
AmeriPride customers with which he had contact and did business with while he was an
AmeriPride employee.

No geographic restriction is included or necessary because of the

foregoing limitation.
3.

“Textile Rental Business” is defined as the products and services offered by

AmeriPride during the last six months of Peterson’s AmeriPride employment.

4.

Peterson will not divulge to any person any Confidential Information, as defined

below, until such time as such Confidential Information has become public knowledge other than
as a result of a disclosure by Peterson or those acting in concert with him or on his behalf.
5.

“Confidential Information” is defined as all information not generally known to

the public, in spoken, printed, electronic or any other form or medium relating directly or
indirectly to AmeriPride’s customer lists, prospect lists, financial information, marketing
strategies, pricing information, business plans, training information, employment policies,
customer requirements, and any other information marked or otherwise identified or treated by
AmeriPride as “Confidential,” or understood by a reasonable person to be confidential.
6.

This Court shall retain continuing jurisdiction over this action for purposes of

enforcing this Consent Injunction notwithstanding the entry of any Order of Dismissal in this
case.
DATED this 24th day of April, 2018.
s/ Joseph F. Bataillon
Senior United States District Judge

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EXHIBITC
LIST OF AMERIPRIDE CUSTOMERS
1. Adult Pediatric Urology/Pacific Surgery Center

2. Alamo Drafthouse
3. Big Fred's
4. Charred
5. Creighton Prep-Compass
6. Dante Pizzeria
7. Fuzzy's Taco Shop
8. Growler USA
9. Heartland Fertility
10. Hickory Villa
11. Immanuel Retirement Community
12. Jake's Cigars
13. KB Buildings
14. Kolache Factory
15. La Casa
16. La Mesa
17. Legends Patio Bar
18. Lighthouse Bar and Grill
19. Lighthouse Pizza
20. Market Basket
21. Nebraska Spine
22. Ollie and Hobbes
23. Over Easy
24. Phoenix
25 . Potbelly
26. Primary Care Physicians
27. Shadow Ridge
28. Sioux City Convention Center
29. Smitty's Garage
30. Southwest Lincoln Surgery Center
31 . Swartz Deli
32. Tanner's
33 . Tiburon
34. UNMC Pediatric Dentistry
35. YMCA of Greater Omaha

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