Global Verge Files New Civil Complaint Against People Helping People and CEO Derrick Rodgers

CIVIL COVER SHEET

Clark County, Nevada

Case No.--

(Assigned by Clerk's Office)

A-I0-618291-C

VIII

I.Party Information

Plaintiff(s) (name/address/phone):

GLOBALVERGE,

INC.,a Nevada Corporation

Attorney (name/address/phone):

Brian R. Hardy, Esq. (NV Bar No.1 0068)

Marquis& Aurbach

10001 Park Run Drive

Las Vegas, NV 89145

(702) 382-0711

Defendant( s) (name/address/phone):

DERRICK L. RODGERS,an individual; PEOPLE HELPING

PEOPLE, INC

Attorney (name/address/phone):

II. Nature of Controversy(Please check applicable bold category and

applicable subcategory,if appropriate)

DArbitration Requested

Civil Cases

RealProperty

Torts

DLandlordffenant

DUnlawfu1 Detainer

oTitle to Property

DForeclosure

DLiens

oQuiet Title

oSpecific Performance

oCondemnation/Eminent Domain

DOther Real Property

DPartition

oPlanning/Zoning

Negligence

DNegligence - Auto

DNegligence - MedicallDental

DNegligence - Premises Liability

(Slip/FalJ)

oNegligence - Other

oProduct Liability

DProduct LiabilitylMotor Vehicle

oOther TortslProduct Liability

DIntentional Misconduct

DTorts/Defamation (Libel/Slander)

DInterfere with Contract Rights

DEmployment Torts(Wrongful termination)

DOther Torts

DAnti-trust

oFraud/Misrepresentation

oInsurance

DLegal Tort

oUnfair Competition

Probate

Other Civil Filing Types

Estimated Estate Value: __

DSummary Administration

oGeneral Administration

DSpecial Administration

DSet Aside Estates

DTrust/Conservatorships

oIndividual Trustee

oCorporate Trustee

oOther Probate

DConstruction Defect

DChapter 40

oGeneral

~ Breach of Contract

DBuilding& Construction

DInsurance Carrier

oCommercial Instrument

oOther Contracts/ Acct/Judgment

DCollectionof Actions

~ EmploymentContract

oGuarantee

oSale Contract

oUniformCommercial Code

oCivil Petition for Judicial Review

oForeclosure Mediation

oOther Administrative Law

oDepartment of Motor Vehicles

DWorker's Compensation Appeal

oAppeal from Lower Court(also check

applicable civil case box)

DTransfer from Justice Court

DJustice Court Civil Appeal

oCivil Writ

DOther Special Proceeding

DOther Civil Filing

oCompromise of Minor's Claim

oConversion of Property

DDamage to Property

DEmployment Security

oEnforcement of Judgment

DForeign Judgment - Civil

oOther Personal Property

DRecovery of Property

DStockho1der Suit

DOther Civil Matters

III. Business Court Requested(Please check appJicab1ecategory;for Clark or Washoe Counties only.)

D

NRS Chapters 78-88

D

Investments (NRS 104Art. 8)

D

Commodities (NRS 90)

0

Deceptive Trade Practices (NRS 598)

D

o

Securities (NRS 90)

0

Trademarks (NRS 600A)

June 8,2010

Date

Enhanced Case Mgmt/Business

Other Business Court Matters

NevadaAOe - Planning and Analysis Division

M&A:1l429-0031065275

i.noc6/8/20109:27 AM

or representative

Form PA 20]

Rev.2.0E

1

Marquis & Aurbach

AVECE M. HIGBEE, ESQ.

2

Nevada Bar No. 3739

BRIAN R. HARDY, ESQ.

3

Nevada Bar No. 10068

1000 1Park Run Drive

4

Las Vegas, Nevada 89145

(702)382-0711

5

(702) 382-5816Facsimile

ahigbee@ marquisaurbach.com

6

bhardy@ marquisaurbach.com

Attorneys for Plaintiffs

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Electronically Filed

06/08/201001:24:03 PM

CLERK OF THE COURT

DISTRICT COURT

CLARK COUNTY, NEVADA

vs.

COMPLAINT

EXEMPT FROM ARBITRATION

(Request for Injunctive Relief)

GLOBAL VERGE, INC.,a Nevada Corporation,

Plaintiff,

A-I0-618291-C

Case No.:

Dept. No.VI I I

DERRICK L. RODGERS, an individual;

PEOPLE HELPING PEOPLE, INC.; and Roe

Corporations I through X, and Does I through X,

inclusive

Defendants.

Plaintiff, Globalverge, Inc. ("Global Verge"), by and through its counsel of record, Marquis& Aurbach, hereby claims against Defendants Derrick L. Rodgers ("Rodgers") and People Helping People, Inc. ("PHP") and alleges as follows:

JURISDICTIONAL ALLEGATIONS

1.

Plaintiff Global Verge is and was at all times relevant, a Nevada corporation

conducting business in Clark County, Nevada.

2.

Defendant Rodgers is and was an independent contractor for Global Vergeup to and until November 16, 2009 and who executed a Non-Disclosure / Non-Circumvent Agreement with Global Verge on or about July30, 2009.

3.

Defendant

PHP isa foreign corporation

conducting

business online at

http.z/www.teamgg.com

andhttp://www.phpico.com

which is a direct competitor of Global

Verge that has retained the services of Defendant Rodgers as itsCEO.

Page 1 of 11

M&A:11429~003 I063539_l.DOC6/8/20]01:30

PM

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4.

The true names and capacities, whether individual, corporate, associate, or

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otherwise of the Defendants named herein as DOES I through X, inclusive, and ROE

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CORPORATIONS I through X, inclusive, are unknown to Plaintiff at this time. Therefore

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Plaintiff sues said Defendants by fictitious names and will ask the Court to amend this Complaint

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to show the true names and capacities of each DOE and ROE Defendant as such time when the

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same are ascertained. Said DOE and ROE Defendants are responsible for damages suffered by

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Plaintiff, therefore, Plaintiff sues said Defendants by such fictitious names.

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STATEMENT OF FACTS

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5.

Global Verge provides products and services through a unique business model

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which allows individuals and companies to purchase products at wholesale and sell any or all of

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the products from a retail store. Global Verge enlists certain qualified individuals as independent

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contractors.

However, given its unique business model and online presence, Global Verge

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maintains certain confidential and proprietary information.

6.

Defendant Rodgers was provided access to and maintained some, if not all, of Global Verge's confidential and proprietary information. However, prior to providing Defendant Rodgers with access to its confidential and proprietary information, Global Verge entered into a Non-Disclosure / Non-Circumvent Agreement (the "NDA") with Defendant Rodgers on or about July 30, 2009. A copy of the NDA is attached hereto as Exhibit 1.

7.

Section 3 of the NDA entitled Non-DisclosurelNon-Circumvent

provides:

Receiving Party will not disclose the Confidential Information of the Disclosing Part, except as is expressly authorized by the Agreement. Each Receiving Party may disclose the Confidential Information of Disclosing Party to its own employees assisting in making an evaluation of the Confidential Information; provided, however, that such employees are advised of the confidentiality and no- use obligations hereunder and are legally obligated by written agreement or otherwise to maintain the confidentiality

and non..use of the Confidential

Information.

In no event will a Receiving Party disclose Confidential Information to third parties unless it obtains the prior written consent of Disclosing Party; provided, that prior to any such disclosure, Receiving Party shall first obtain a written non-disclosure agreement from such third party containing terms and conditions substantially similar to those set forth herein.

If requested, a copy of such executed agreement will be provided to Disclosing Party. In addition, if there are three or more parties to the Agreement, then Confidential Information may be shared among multiple Receiving Parties, unless Disclosing Party provides a written notice restricting such sharing of information.