Free Affidavit in Opposition to Motion - District Court of California - California

Case i3:O7—cv—O2748-IVIHP Document 27-2 Filed O7/06/2007 Page ti of 1
I containing the provisions restricting posbemploytnent competition that I refused. I refused to
2 condition my employment with CMC on giving up the right to worlt in the promotional products-
3 industry shouid I quit or he tired. I was informed by Bruce Molloy that I was tired because I
4 would not sign a non—discIosure agreement. At the time I left CMC, I sent to my customer
5 contracts a neutrally worded email notifying them of my departure and providing new contract ·
6 information. i ‘ _
7 3. I took no CMC property with me when I left CMC. I did not take a copy of
8 CMC’s customer Iist or copies, in either paper or electronic form, of any other information that I
9 understand CMC to he claiming are trade secrets.
I0 4. After being fired, I went to work for my hushand°s new business, which started in
x ll _ husiness on May I4, 2007. I have learned much about the promotional products industry and my
Q I2 best prospects for earning income are in that industry.
13 5. I have not used Ch/lC’s customer list to solicit business of any customers of CMC
gg; I4 since I was tired by that company. Some of CMC’s customers have contacted me. On behalf of i
i dg WE I5 our new business, I have not solicited any customer of CMC that did not contact me first. For I
16 example, Chevron Federal Credit Union contacted my after I was tired by CMC. In response to
E7 that contact, I offered to sell products to Chevron Federal Credit Union. They declined to buy. i i
I8 I declare under penalty of perjury that the statements in the foregoing declaration are true
l9 and correct and that I am competent to testify to them. I
20 Executed this day ot June 2007 at ééémw, California. *
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Case Na. osctntaarion or CHRISTINA cnntsto IN oPt¤oslTl0t~t to
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Case 3:07-cv-02748-MHP

Document 27-2

Filed 07/06/2007

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