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Lisa Wood v. Little Caesar Enterprises, Michael Ilitch, et. al. (Case No. 08--018537-CZ)

Lisa Wood v. Little Caesar Enterprises, Michael Ilitch, et. al. (Case No. 08--018537-CZ)

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Plaintiff Lisa Wood filed a five count civil case in Wayne County's (MI) 3rd Judicial Circuit Court against Little Caesars Enterprises, Michael Ilitch and others alleging (1) Breach of Contract; (2) Promissory Estoppel; (3) Breach of Fiduciary Duties; (4) Negligence; and (5) Conspiracy. (Case No. 08--018537-CZ).
Plaintiff Lisa Wood filed a five count civil case in Wayne County's (MI) 3rd Judicial Circuit Court against Little Caesars Enterprises, Michael Ilitch and others alleging (1) Breach of Contract; (2) Promissory Estoppel; (3) Breach of Fiduciary Duties; (4) Negligence; and (5) Conspiracy. (Case No. 08--018537-CZ).

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Published by: Archive It on Dec 29, 2008
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05/09/2014

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STATE OF MICHIGANIN THE 3
RD
JUDICIAL CIRCUIT COURT
LISA WOOD, PlaintiffCase No. 08--018537-CZv.Judge Hon. John H. Gillis, JrLITTLE CAESARS, INC. a MichiganCorporation, ILITCH HOLDINGS, INC aMichigan Corporation, RICHARD FENTONCHRISTOPHER ILITCH and MICHAEL ILITCH,Jointly and severallyDefendants / Douglas A. McKinney (P35430)Attorney for PlaintiffP. O. Box 214145Auburn Hills, Michigan 48321-4145(248) 601-1689 / 
VERIFIED COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF
NOW COMES Plaintiff LISA WOOD by and through her attorney Douglas A.McKinney, hereby brings the following complaint for injunctive relief against defendantsLITTLE CAESARS, INC., MICHAEL ILITCH and RONALD ILITCH for (i) breach ofcontract; (ii) misappropriation of trade secrets; (iii) breach of fiduciary duties; and (iv)negligence in failing to protect or defend the trade secret and intellectual property ofPlaintiff Lisa Wood. in support thereof avers as follows:
JURISDICTION AND VENUE
1. Plaintiff’s action arises out of defendant LITTLE CAESARS ENTERPRISES, INC itsagents, owners and employees of their fiduciary and contractual duties owed toPlaintiff, Lisa Wood.
 
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2. Defendant ILITCH HOLDINGS, INC is a Michigan Corporation with its principal placeof business located in the City of Detroit, County of Wayne, State of Michigan.3. Plaintiff Lisa Wood is an individual currently residing in the Township of Harrison,County of Macomb Michigan.4. Defendant Little Caesars, Inc. is a corporation with its principal place of businesslocated in the City of Detroit county of Wayne State of Michigan.5. The Defendant Michael Ilitch is a resident of the city of Bingham Farms, County ofOakland, State of Michigan6. Defendant ILITCH HOLDINGS
,
INC. a Michigan Corporation with its principal placeof business located in the City of Detroit, County of Wayne, State of Michigan.7. The Defendant Richard Fenton is an employee of Corporate Defendant and isemployed in the City of Detroit, County of Wayne, State of Michigan.8. The Defendant Christopher Ilitch is an employee of Corporate Defendant and isemployed in the City of Detroit, County of Wayne, State of Michigan.9. The Defendants’ acts giving rise to this dispute occurred in whole or in part withinthe City of Detroit, County of Wayne, State of Michigan and, on information andbelief, Defendants regularly conduct business within the City of Detroit, County ofWayne, State of Michigan. Venue is therefore proper in this Court.10. Although the harm caused by Defendants’ wrongful acts is not fully ascertainable,Plaintiff’s damages exceed $25,000, exclusive of costs, interest and attorney fees.11. This Court has jurisdiction since this action is between parties of the same state andthe amount in controversy exceeds $25,000.
 
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COMMON ALLEGATIONS
12. Plaintiff. Lisa Wood developed a restaurant concept that involved a unique processof selling pizza drive-thru on the water.13. At the insistence of Ronald Ilitch, son of Defendant Michael Ilitch, this concept waspresented to the owner of Corporate Defendant Michael IIitch’s attorney by Plaintiff.14. On or about January/February 2004 the information concerning Plaintiff’s marketingand business strategies, and various other intellectual properties were described tothe agents and attorneys of Defendant Little Caesars including its president DavidScarvano and attorney Jay Bielfield.15. In addition Plaintiff provided Defendant Little Caesars art work and proposed menusfor her business concept “Pizza On The Water” and/or “Pizza By Boat” through itstrademark attorney of Corporate Defendant Martin Caruso.16. This information concerning was highly confidential and not known in the publicdomain.17. The Defendants made specific promises to the Plaintiff Lisa Wood that including butnot limited to the concept, slogans and artwork created by Plaintiff would beprotected by the use of trademark and/or copyright laws for future use and Plaintiffexecuted that agreement.18. That in reasonable reliance upon these expressed promises the Plaintiff described indetail her concept, the slogans she had developed and turned over to Defendant theunique artwork created in her own hand.

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