In order to entice Plaintiff to end her employment relationship with RBCWealth Management, Defendant John Macco, as president and owner
MFG, offeredPlaintiff the following terms
employment with his company:,a. a 5% equity stake in MFG;
responsibility for a book
business containing $25 million in assets;
a quarterly $5,000 bonus; and
$60,000 per year.
. Additionally, in connection with Plaintiff s transfer
client accountsfrom RBC Wealth Management to MFG, Defendant Macco further committed to ensurepayment
contract buyout, IRA and account closing fees.
In reliance on Defendant Macco's promises, Plaintiff terminated heremployment with RBC Wealth Management and began working at MFG on or aboutDecember
Less than two months later, Plaintiffs employment with MFG wasterminated without cause on February 3, 2009.
As a result, Plaintiff lost clients due to the sudden change
COUNT ONE: BREACH OF CONTRACT -MFG
Plaintiff reincorporates by reference the allegations
set forth fully herein.
At all relevant times, the promises made by Defendant Macco were fullyenforceable contractual obligations, as the relationship entered into between Plaintiff andDefendant MFG was marked by offer, acceptance and consideration. The engagementconstituted an enforceable contract between the parties under which MFG is obligated