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STATE OF
MICHIGAN
rN
THE
3RD
JUDTcTAL
crRcurr couRT
LISA
WOOD,Plaintiff
V.
MICHAEL ILITCH,
JIMMY
SHEMAMI,ILITCH
HOLDINGS,
INC
A
Michigan
Corporation,
RICHARD
FENTONand,LITTLE
CAESARENTERPRISES,
lNC.
a
Michigan CorporationJointly
and severally
Defendants
9llood,
l,laa v
IJITTIII
CEA8AR8
INC
,
Hon.
John
H
Gillls,
Jr.
1211212009
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Douglas
A.
McKinney(P35430)Attorney
for Plaintiff
P.
O.
Box
214145Auburn
Hills,
Michigan48321-4145(248)587-5075FIRST
AMENDED COMPLAINT
NOW COMES PlaintiffLISA WOOD
by and
through
her
attorney
Douglas
A.
McKinney,
hereby
brings
the following
complaint
againstdefendantsMICHAEL
lL|TCH,
JIMMY
SHEMAMI,
ILITCH
HOLDINGS,
INC
a
Michigan
Corporation,
RICHARD
FENTON
and,
LITTLE
CAESAR
ENTERPRISES
for
(i)
breach
of
contract;
(ii)
conspiracy(iii)misappropriation of trade secrets;(iv)breach of fiduciaryduties; and
(v)
negligence
infailing
to
protect
or
defend
the trade secret
and
intellectualpropertyof
Plaintiff
Lisa
Wood.
in
support thereof
avers asfollows:
JURISDIGTIONAND
VENUE
1.
Defendant,
Michaelllitch is
a
resident
of the city
of
Bingham Farms,County of
Oakland,State
of
Michigan.
 
2.
Plaintiff'sactionarises
out of
defendantLITTLE CAESAR ENTERPRISES,
lNC,
its
agents,ownersand employee'sof theirfiduciary and contractual duties
owed
to
Plaintiff,LisaWood.
Plaintiff,
Lisa
Wood
is
an
individual
currentlyresiding
in
the
Township
of
Harrison,
County ofMacomb
Michigan.
Defendant
JimmyShemami
for all
times
relevant herein
was
an
employee ofCorporateDefendant andwas employed
in
the
City
of
Detroit, County
ofWayne,State
of
Michigan.
DefendantILITCHHOLDINGS,
lNC.
a
Michigan Corporation
with its
principal
place
of
businesslocated
in
the
City
of
Detroit, County
of
Wayne,State
of
Michigan.
Defendant,
RichardFenton
is
an
employee
of
Corporate
Defendant
and
is
employed
in
the
City
of
Detroit, County
of
Wayne State of
Michigan.
Defendant,Little CaesarEnterprises,Inc.
is
a
corporation
with
itsprincipal
place
ofbusinesslocated
in
the
City
of
Detroit county
of
Wayne State of
Michigan.
The,
defendants'
actsgiving
rise
to
this dispute
occurred
at
least
in
part
within
the
City
of
Detroit, CountyofWayne, State
of
Michigan
and, on
information
and
beliefdefendantsregulady conduct
business
within
the
City
of
Detroit, County ofWayne,
State
of
Michigan.
Venue
is
thereforeproper
in
this
Court.
Although
the
harm
caused
by
Defendants'
wrongful
acts
is
not
fullyascertainable,Plaintiff's damages
i
exceed$25,000,exclusive
of
costs,
interestand attorneyfees.
3.
4.
5.
6.
7.8.9.
 
10.
This, Court
has
jurisdictionsincethis action
is
betweenpartiesof the same
stateand
theamount
in
controversy
exceeds$25,000,COMMON
ALLEGATIONS
11.
Plaintiff,
Lisa
Wood
developed
a
restaurant
concept
that
involved
a
uniqueprocessof
selling
pizzadrive
through
on the water.
12.
At the
insistence
of
Ronaldllitch,son
of
Defendant
Michael llitch,this
concept
was
presented
to the
owner
of
CorporateDefendant Michael
llitch's
attorney
by
Plaintiff.
13.
On
or
about
January/February
2004
the
information concerning
Plaintiff's
marketingand businessstrategies,
and
variousotherintellectual
propertieswere
described
to the
agentsand
attorneys
of
Defendant
Little
Caesars including
its
president
David
Scarvano
andattorney
Jay
Bielfield,
14.
In
additionPlaintiffprovidedDefendant Little Caesars
artwork
and
proposed
menus
for
her
businessconcept"Pizza
On The Water" and/or
"Pizza
By
Boat"
through
its
trademarkattorneyof
Corporate
DefendantMartin
Caruso.
15.
This, informationconcerning
was
highly confidential
and not
known in
the
publicdomain.
16.
The, Defendantsmade specific
promises
to
the
Plaintiff
Lisa
Wood
that
including
but
not limited
to the
concept, slogansand artwork created
by
Plaintiff would
be
protected
bythe
use
of
trademark
and/or
copyright
laws
for
future use
and
Plaintiff
executedthat
agreement.
17.
The agreement
was
reduced to
writing
by
the
Defendant.
18.
The
Plaintiff
accepted
and
the
Defendants did
executesaid
agreement.
of 00

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