STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
CLARKE, FEELINGS &
ASSOCIATES LLP, an organization,
Plaintiff(s),
v.
DEV_TYP,
Defendant(s).
Case Number: RSC-CV-3388
Presiding: Hon.
CIVIL COMPLAINT
CIVIL COMPLAINT
PLAINTIFF, Clarke, Feelings & Associates LLP, by and through the undersigned counsel,
alleges the following:
INTRODUCTION
1. On the 18th of June 2024, MatthewSandringham, as Managing Partner of Clarke,
Feelings & Associates LLP, hired Defendant Dev_typ. Through his employment, he was
engaged in an employment contract which prohibited a number of things including
non-compete.
JURISDICTION & VENUE
2. The court has jurisdiction to hear “all civil and criminal cases or controversies.”
Ridgeway State Constitution Article V, Section IV.
3. Venue is proper as the tortious actions alleged herein took place in Ridgeway County,
Ridgeway.
PARTIES
4. Clarke, Feelings & Associates (“Plaintiff”) is a Partnership under the Ridgeway State
Code of Statutes - its business address is in Palmer Plaza.
5. Dev_typ (“Defendant”) is a resident of Ridgeway County. He is also a citizen of the State
of Ridgeway—his personal home address is unknown; but it is understood that he resides
within the applicable jurisdiction as hereinafter referenced and applied in this case.
FACTS
I. Employment at Clarke, Feelings & Associates LLP
6. On the 18th day of June 2024, Defendant engaged in an employment contract with
Plaintiff. In this employment contract there were specific conditions in which the
Defendant was bound to follow.
7. One of these sections was Section 6, which regarded Non Compete. Section 6 directs that
the employee may not engage in any attorney level work without the expressed
permission from the “employer” (in this case the Plaintiff).
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
- 1 -
8. Defendant knowingly broke this contract when they began employment with the Center
for Individual Rights.
II. Engagement in a contract with the Center for Individual Rights
9. On the 1st of August 2024, Plaintiff became aware that Defendant had become employed
by the Centrr for Individual Rights - this employment beginning on the 25th of July 2024.
10. Defendant knowingly sought this employment, knowing that it would breach his already
existing contract with his original employer - The Plaintiff.
11. His employment was confirmed by Singhski, who is currently the President of the Center
for Individual Rights.
FIRST CAUSE OF ACTION
BREACH OF CONTRACT - 1 R. STAT. § 3107
12. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
13. On the 18th of June 2024, Plaintiff and the Defendant entered into an employment
contract so Defendant could begin his employment as a Junior Associate within the firm.
14. Section 6 of the employment contract states “The employee agrees to not assume other
judicial, legal secretarial work, paralegal work, or attorney-level work without specific
permission from the Employers for the duration of their employment.”
15. Defendant violated this clause in the employment contract when - knowingly - on the
25th of July, they became employed by the Center for Individual Rights as an Advocate,
and began “attorney-level work” for their Law Firm.
16. In violating his non-compete and working for another firm, he took time away from our
firm aiding the work of the Center for Individual Rights, instead of completing important
legal business for the firm, causing harm to the firm and its clients.
RELIEF
WHEREFORE, Plaintiff requests the court to grant relief to redress the injury as follows:
a. Declaratory relief declaring that Defendant broke the contract entered into on the 18th of
June 2024;
b. Punitive Damages in the amount of $5000.
c. Granting Plaintiff such other further relief as the court finds just and proper.
August 4, 2024 Respectfully submitted,
MatthewSandringham
Counsel of Record
Clarke, Feelings & Associates, LLP.
Managing Partner
R. Bar. No. 16103
Attorney for Plaintiff
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
- 2 -
