Documents (12)

Motion to Dismiss - Unpaid Wages, Commissions, and Bonuses; Hunt & Associates PC; 12.16.2014

Case Topics: Breach of Contract, Wage Payment and Collection Act, Illinois Sales Representative Act – Grounds for Moving: Illinois Sales Representative Act does not apply to employees but only sales representatives. Illinois Sales Representative and Illinois Wage Payment and Collection Acts do not entitle plaintiff to jury trial. Defendant was not plaintiff's employer.

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Motion with Respect to the Pleadings - Consulting Fee Dispute - Reply; Kirkland & Ellis LLP; 10.02.2015

Case Topics: Breach of Contract, Unjust Enrichment, Misappropriation – Grounds for Moving: Claims legally insufficient and allegations do not state a cause of action upon which relief can be granted. Express exemption in contract defeats Plaintiff's claim. Existence of an express contract bars relief from unjust enrichment. Complaint fails to allege that the information Plaintiff claims defendant disclosed fulfills statutory requirements for a trade secret.

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Motion for Judgment on the Pleadings - Independent Contractor Fraud Scheme - Reply; Rieck and Crotty PC; 09.16.2016

Topics: Breach of Contract, Fraud, Unjust Enrichment, Defamation, Conspiracy, Misappropriation, Interference with Prospective Economic Advantage – Grounds for Moving: Defendant contributed business interests. Power of attorney fraudulently obtained. Voluntary Payment Doctrine prohibits recovery. Resignation email contains no false/defamatory statements. Failure to identify particularity needed to determine defamation.

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Motion for Judgment on the Pleadings - Independent Contractor Fraud Scheme - Response; Vedder Price PC; 08.22.2016

Topics: Breach of Contract, Fraud, Unjust Enrichment, Defamation, Conspiracy, Misappropriation, Interference with Prospective Economic Advantage – Grounds for Moving: Defendant contributed business interests. Power of attorney fraudulently obtained. Voluntary Payment Doctrine prohibits recovery. Resignation email contains no false/defamatory statements. Failure to identify particularity needed to determine defamation.

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Motion with Respect to the Pleadings - Consulting Fee Dispute; Kirkland & Ellis LLP; 06.26.2015

Case Topics: Breach of Contract, Unjust Enrichment, Misappropriation – Grounds for Moving: Claims legally insufficient and allegations do not state a cause of action upon which relief can be granted. Express exemption in contract defeats Plaintiff's claim. Existence of an express contract bars relief from unjust enrichment. Complaint fails to allege that the information Plaintiff claims defendant disclosed fulfills statutory requirements for a trade secret.

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Motion for Judgment on the Pleadings - Independent Contractor Fraud Scheme; Rieck and Crotty PC; 05.26.2016

Topics: Breach of Contract, Fraud, Unjust Enrichment, Defamation, Conspiracy, Misappropriation, Interference with Prospective Economic Advantage – Grounds for Moving: Defendant contributed business interests. Power of attorney fraudulently obtained. Voluntary Payment Doctrine prohibits recovery. Resignation email contains no false/defamatory statements. Failure to identify particularity needed to determine defamation.

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Motion to Dismiss - Employer Withholding of Final Compensation - Reply; Winston & Strawn LLP; 05.19.2016

Case Topics: Wage Payment and Collection Act, Breach of Contract – Grounds for Moving: Wage Payment and Collections Act only reaches compensation owed upon the employee's exit date. No Illinois case has held shared profits actionable under Wage Payment and Collections Act. Defendants improperly named. Plaintiff failed to perform contractual prerequisites necessary to give rise to alleged profits interest.

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Motion to Dismiss - Employer Withholding of Final Compensation - Response Memo; Novack & Macey LLP; 04.27.2016

Case Topics: Wage Payment and Collection Act, Breach of Contract – Grounds for Moving: Wage Payment and Collections Act only reaches compensation owed upon the employee's exit date. No Illinois case has held shared profits actionable under Wage Payment and Collections Act. Defendants improperly named. Plaintiff failed to perform contractual prerequisites necessary to give rise to alleged profits interest.

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Motion to Dismiss - Employer Withholding of Final Compensation; Winston & Strawn LLP; 02.29.2016

Case Topics: Wage Payment and Collection Act, Breach of Contract – Grounds for Moving: Illinois Wage Payment and Collections Act only reaches compensation unequivocally owed upon the employee's exit date. No Illinois case has ever held shared profits actionable under Illinois Wage Payment and Collections Act. Defendants are improperly named. Plaintiff failed to perform certain fundamental contractual prerequisites necessary to give rise to alleged profits interest.

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Motion to Dismiss - Asset Management Joint Partnership Dispute - Sur-Reply; Baugh Dalton Carlson & Ryan LLC; 04.08.2015

Case Topics: Breach of Contract, Breach of Fiduciary Duty, Unjust Enrichment, Tortious Interference with Contract, Fraud – Grounds for Moving: Court lacks personal jurisdiction under the Illinois long-arm statute. The exercise of personal jurisdiction over Defendant would violate state and federal due process requirements.

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Motion to Dismiss - Asset Management Joint Partnership Dispute - Sur-Response; Jaffe Raitt Heuer & Weiss PC, Brown & Brown PC; 03.30.2015

Case Topics: Breach of Contract, Breach of Fiduciary Duty, Unjust Enrichment, Tortious Interference with Contract, Fraud – Grounds for Moving: Court lacks personal jurisdiction under the Illinois long-arm statute. The exercise of personal jurisdiction over Defendant would violate state and federal due process requirements.

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Motion to Dismiss - Peer Review and Coerced Employment Resignation - Reply; Katten Muchin Rosenman LLP; 12.22.2015

Case Topics: Breach of Contract, Fraud – Grounds for Moving: Defendant is immune from civil liability under Hospital Licensing Act. Action is barred by mutual release of claims with a valid Settlement Agreement. Attempts to sidestep the effect of release of claims each fail as a matter of law.

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