Case 3:22-cv-00333-LRH-CLB Document 1 Filed 07/25/22 Page 1 of 35
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`Sydney R. Gambee (Nevada Bar No. 14201)
`HOLLAND & HART LLP
`9555 Hillwood Drive, 2nd Floor
`Las Vegas, NV 89134
`Tel: 702.669.4600
`Fax: 702.669.4650
`srgambee@hollandhart.com
`Attorneys for Plaintiffs
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`
`
`IN THE UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA, NORTHERN DIVISION
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`
`Case No.:
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`COMPLAINT
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`MISSION HEALTHCARE SERVICES,
`LLC, a California limited liability company;
`and HEALTHY LIVING AT HOME -
`CARSON CITY, LLC, a Nevada Limited
`Liability Company,
`
`Plaintiffs,
`
`
`v.
`
`BATTLE BORN HOME HEALTH, LLC, a
`Nevada limited liability company; JESSICA
`CONNANT (CRISP), an individual;
`ANGEL VASQUEZ BARNES, an
`individual; and JOSEPH BARNES, an
`individual,
`
`Defendants.
`
`Plaintiffs Mission Healthcare Services, LLC (“MHS”), and Healthy Living at Home –
`Carson City, LLC (“HLH Carson City”) (collectively “Mission”), by and through their
`undersigned counsel, HOLLAND & HART LLP, file this Complaint for injunctive relief and
`damages against Defendants, Jessica (Crisp) Conant (“Crisp”), Angel Vasquez Barnes (“A.
`Barnes”), and Joseph Barnes (“J. Barnes”), (collectively the “Employee Defendants”), and
`Battle Born Home Health, LLC (“Battle Born”) (Battle Born and the Employee Defendants are
`collectively referred to herein as the “Defendants”) and hereby allege as follows:
`///
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`9555 HILLWOOD DRIVE, 2ND FLOOR
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`Case 3:22-cv-00333-LRH-CLB Document 1 Filed 07/25/22 Page 2 of 35
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`PARTIES
`MHS is a California limited liability company with its principal place of business
`1.
`in San Diego, California.
`HLH Carson City is a Nevada limited liability company with its principal place of
`2.
`business in Carson City, Nevada.
`MHS and HLH Carson City transact business, provide home health care services
`3.
`in, and have employees Carson City Nevada, in addition to other locations across the United
`States.
`Upon information and belief, Battle Born is a Nevada limited liability company
`4.
`with its principal place of business located at 307 West Winnie Lane, # 5, Carson City, NV,
`89703. Battle Born transacts business, provides home health care services, and has, and/or is
`preparing to have employees in Carson City, NV.
`Upon information and belief, Crisp is an individual residing in Carson City,
`5.
`Nevada, and is a former employee of Mission who is now employed by and performs services
`for Battle Born and/or has an ownership or equity interest therein.
`Upon information and belief, A. Barnes is an individual residing in Reno, Nevada,
`6.
`and is a former employee of Mission who is now employed by and performs services for Battle
`Born and/or has an ownership or equity interest therein.
` Upon information and belief, J. Barnes is an individual residing in Reno, Nevada,
`7.
`and is a former employee of Mission who is now employed by and performs services for Battle
`Born and/or has an ownership or equity interest therein.
`JURISDICTION AND VENUE
`This Court has jurisdiction over this action based upon 28 U.S.C. § 1331.
`8.
`Defendants are subject to the personal jurisdiction of this Court because they
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`reside and operate businesses in the state of Nevada, and because they have transacted and are
`currently transacting business in the state of Nevada, which gives rise to their liability to
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`9555 HILLWOOD DRIVE, 2ND FLOOR
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`Case 3:22-cv-00333-LRH-CLB Document 1 Filed 07/25/22 Page 3 of 35
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`Plaintiffs.
`10. Venue is proper in the United States District Court for the District of Nevada
`pursuant to 28 U.S.C. 1391(a), because Nevada is the state in which Defendants reside and
`where a substantial part of the events or omissions giving rise to the claims occurred.
`FACTUAL BACKGROUND
`Mission and the Home Health and Hospice Industry
`A.
`HLH Carson City has provided personalized, life-changing home health and
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`hospice services in Nevada for many years.
`In 2021, Mission Healthcare Services, Inc., acquired HLH Carson City.
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`13. When Mission Healthcare Services, Inc. acquired HLH Carson City, all the HLH
`Carson City assets, liabilities, contracts, including without limitation contracts with its
`employees, were assigned to MHS and related entities.
`14. Mission provides custom and personalized home health and hospice services
`throughout several western states including Arizona, California, Idaho, Nevada, Oregon,
`Washington, and Utah. Mission’s platform in Utah includes skilled nursing services, physical
`therapy, occupational therapy, speech therapy, home health aides, medical social workers, end
`of life, and hospice care (the “Business”).
`15. Mission employs a team of talented and caring health care professionals dedicated
`to serving patients with the appropriate combination of clinical skill and personal care. Mission
`has expended considerable time and resources identifying, recruiting, hiring, and training these
`professionals.
`16. Mission operates the Business in an extremely competitive environment with a
`number of national, regional, and local home health and hospice service companies within their
`footprint vying for the opportunity to serve the same patient population.
`17. Mission has long-standing relationships with many referral sources, including but
`not limited to physicians, hospitals, skilled nursing and care facilities (“Referral Sources”), and
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`9555 HILLWOOD DRIVE, 2ND FLOOR
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`has expended substantial money and time in developing and maintaining those relationships.
`In an effort to gain and maintain a competitive advantage, Mission expends
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`substantial time, effort, and resources developing, maintaining, and creating, among other
`things: (i) institutional knowledge, processes, documentation, and know-how in both clinical
`services and marketing as well as confidential and proprietary information pertaining to its
`Referral Sources and its employees (collectively the “Business Information”); (ii) trade secrets,
`including techniques, strategies, and information about its Referral Sources, employees, and
`patients (the “Trade Secrets”); and (iii) relationships with employees, communities, Referral
`Sources, and third party vendors.
`19. Mission’s Business requires that certain employees receive information, including
`without limitation, Business Information and/or Trade Secrets, related to its Business,
`employees, and Referral Sources for the purpose of continuing to build the Mission brand,
`advertising, and obtaining and retaining Referral Sources, patients, and employees.
`The process of developing a team of health care professionals, community
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`partners, Referral Sources, and patients in this industry is lengthy, difficult, and expensive and
`requires Mission and its competitors to develop and maintain close personal relationships with
`Referral Sources, patients, and employees. In addition, Mission must has obtained a competitive
`advantage over competitors by having a clear understanding of each Referral Source, patient,
`and employee’s needs and preferences, and developing and employing the most efficient and
`effective way to meet or exceed those needs. Such an understanding can only be developed
`through years of gathering information, developing relationships, and delivering service
`consistent with the unique needs of the patients and within the specifications of the Referral
`Sources. It would take a startup competitor many years to catch up with Mission.
`21. Mission operates in an extremely competitive industry in which its competitors,
`including Battle Born, would greatly benefit from obtaining Mission’s Confidential
`Information. Accordingly, Mission takes care to safeguard and protect its Confidential
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`9555 HILLWOOD DRIVE, 2ND FLOOR
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`Case 3:22-cv-00333-LRH-CLB Document 1 Filed 07/25/22 Page 5 of 35
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`Information from disclosure or use by others.
`B.
`Battle Born’s Operation in the Home Health and Hospice Market.
`22. While it would typically take a long period of time and significant resources to
`build a home health company from scratch, the Employee Defendants together devised a
`scheme at least by November 2021 in which they planned to and did instantly launch a profitable
`home health company by improperly acquiring Mission’s business, assets, and resources
`(including its employees) without having to pay for it.
`The Employee Defendants’ scheme was to form Battle Born while they were still
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`employed and being paid by Mission. On information and belief, to this end, while they were
`waiting for the needed licensing and approvals to be obtained before Battle Born could be
`operational and take patients, they began siphoning off Mission’s Confidential Business
`Information and Trade Secrets and soliciting Mission’s employees to leave Mission and work
`for Battle Born the moment it could open its doors.
`On information and belief, in breach of their fiduciary duties and duty of loyalty
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`to Mission, each of the Employee Defendants accepted employment with and for Battle Born
`and began serving Battle Born’s interests (not Mission’s) while still employed by and receiving
`compensation from Mission.
`In other words, while the Employee Defendants were employed by and receiving
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`compensation from Mission, and in direct breach of their several obligations to Mission, the
`Employee Defendants recruited Mission’s employees and contractors, including each other, for
`Battle Born, even using Mission’s resources to do so.
`Also contrary to their duties, the Employee Defendants spoke ill of Mission and
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`discouraged employees and contractors from continuing employment with Mission.
`27. When a Mission employee expressed a willingness to work for Battle Born, he or
`she was instructed by the Employee Defendants to continue to take a paycheck from Mission
`until it was time for Battle Born to launch. This way, Mission was funding the scheme, and the
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`9555 HILLWOOD DRIVE, 2ND FLOOR
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`Case 3:22-cv-00333-LRH-CLB Document 1 Filed 07/25/22 Page 6 of 35
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`Employee Defendants had no financial risk as they waited for Battle Born to get the necessary
`state and federal approvals.
`improperly utilized Mission’s Business
`The Employee Defendants also
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`Information and Trade Secrets as they formed and launched Battle Born, including without
`limitation, to solicit Mission’s employees and contractors and/or to solicit Mission’s Referral
`Sources.
`Battle Born filed its initial State and Business License Application on February 2,
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`2022, listing Messers Brian Krug and Derek Beal as managers of the limited liability company.
`Upon information and belief, Battle Born provides or is planning to provide home
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`health care services, including skilled nursing, physical therapy, occupational therapy, speech
`therapy, social services, and CNS services in Carson City, Minden, Gardnerville, and Dayton,
`Nevada, as a direct competitor with Mission and its Business.
`Through their scheme, Defendants have solicited and hired multiple Mission
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`employees and contractors, though some remain employed by Mission as instructed. It is
`Defendants’ intent to utilize Mission’s Business Information and Trade Secrets and reap the
`benefits of their improper solicitation of Mission’s employees and contractors, in order to
`quickly take Battle Born from the start-up phase to a fully functioning competitor of Mission.
`C. Mission’s Business Information and Trade Secrets.
`32. Mission possesses Business Information, which includes but is not limited to,
`information about Mission, its Referral Sources, employees, and clients; information about the
`Business, including without limitation its operations and financial information; future plans of
`every type; pricing schedules, lists, promotions, and products; marketing and sales strategies
`including without limitation information and strategy regarding Referral Sources; concepts,
`designs, models, strategies, procedures, ideas, and know how; employee and patient personally
`identifiable information; agreements and contract terms; business methods; all information
`employees may obtain, prepare or analyze during the course of employment; research materials;
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`Case 3:22-cv-00333-LRH-CLB Document 1 Filed 07/25/22 Page 7 of 35
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`memoranda; correspondence or other documentation; payroll and compensation information;
`personnel files including without limitation performance information; information concerning
`compensation of third parties, consultants, and vendors; and business models.
`33. Mission also possesses Trade Secrets, which include but are not limited to, data,
`formulas and processes related to strategic alliances and relationships with vendors, Referral
`Sources, patients, employees, and third parties, and including without limitation, confidential
`techniques, strategies, and information about Referral Sources, employees, and patients.
`34. Mission’s Business Information and Trade Secrets are not generally known to the
`public or within the industry and have independent economic value because the information is
`not readily ascertainable by independent investigation.
`35. Mission takes reasonable precautions to ensure confidentiality of its Business
`Information and Trade Secrets. Such efforts include, among others: (i) implementing policies
`limiting access to the such information; (ii) requiring employees to acknowledge their receipt
`of an employee handbook; (iii) entering into non-disclosure or confidentiality agreements with
`its employees; (iii) restricting employees’ physical and technological access to the subject
`information; (iv) securing the information’s physical and electronic storage; and (v) limiting
`distribution of the information only to those employees who need the information to perform
`their specific job functions.
`For example, Mission maintains password protections, trains employees to
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`safeguard information, and operates in a culture and environment which requires employees to
`understand and take seriously the need to keep all Business Information and Trade Secrets
`confidential.
`Because the Employee Defendants occupied key positions within the Mission
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`organization, at all material times during their employment, the Employee Defendants were
`given access to and were permitted to use Mission’s Business Information and/or Trade Secrets.
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`HOLLAND & HART LLP
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`In addition to the steps outlined above, Mission required the Employee Defendants
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`to contractually agree to refrain from describing, disclosing, misappropriating, publishing,
`taking, transmitting, or using Mission’s Business Information or Trade Secrets for any purpose
`other than to further Mission’s Business.
`39. Specifically, HLH Carson City required employees to sign the Employee
`Acknowledgement and Receipt of Healthy Living at Home Handbook form (the “HLH Carson
`City Handbook Acknowledgement”) whereby the Employee Defendants acknowledged receipt
`of the Healthy Living Network Employee Handbook (the “HLH Carson City Handbook”), the
`Non-Disclosure and Assignment of Inventions Agreement (the “HLH Carson City NDA”), and
`the Code of Conduct (the “HLH Carson City Code of Conduct”) (collectively, the “HLH Carson
`City Employment Agreements”).
`By signing the HLC Carson City Handbook Acknowledgement, the Employee
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`Defendants agreed that they “would be responsible for reading[,]” had read, and would observe
`and abide by the conditions of employment, policies, and rules contained in the HLH Carson
`City Handbook, as well as other HLH Carson City policies, such as those prohibiting disclosure
`of HLH Carson City’s Business Information and Trade Secrets.1
`The Employee Defendants also each agreed that the HLH Carson City Handbook
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`was an accurate representation of his or her obligations to HLH Carson City.
`By signing the HLH Carson City Handbook Acknowledgement, the Employee
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`Defendants each agreed that they would “have access to sensitive information that [HLH Carson
`City does] not share with [its] competitors, the public, or even other employees who do not need
`to know the information to do their jobs. This information belongs to the Company.
`[Employees] may not use it for personal gain or for the benefit of someone else, like another
`employer or one of [HLH Carson City’s] competitors. The information is provided to
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`1 Crisp signed the HLH Handbook acknowledgement on July 17, 2018, J. Barnes signed it on
`August 17, 2018, and A. Barnes signed it on August 10, 2018.
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`HOLLAND & HART LLP
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`[employees] to use in performing work for the Company. Except as permitted by law or as
`necessary in the regular course of your duties . . . [employees] may not divulge confidential
`information to any third party without express written permission from the President of the
`Company.”
`By signing the HLH Carson City Handbook Acknowledgement, the Employee
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`Defendants also agreed that if they left “employment with the Company for any reason” each
`would “continue to treat as private and privileged any such sensitive information” and would
`not “use, reveal, or communicate to any person or entity any of this information without the
`written approval of the Company.”
`By signing the HLH Carson City Handbook Acknowledgement, the Employee
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`Defendants also agreed that “[t]heft, misappropriation, or unauthorized possession or use of
`property, documents, records, or funds belonging to the Company, or any patient or employee,
`removal of the same from Company premises without authorization,” “[d]ivulging confidential
`information of any kind to any unauthorized person(s) or without an official need-to know
`requirement,” or “[o]btaining unauthorized confidential information pertaining to patients or
`employees”2 constituted misconduct and that upon learning about any such misconduct,
`including but not limited to the use or disclosure of the HLH Carson City’s Business
`Information or Trade Secrets, the Company “will pursue legal remedies” against each of them.
`By signing the HLH Carson City NDA, each of the Employee Defendants agreed
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`that during their employment, and at “all times thereafter” each would “hold in the strictest
`confidence and [would] not use, except for the benefit of the Company, or disclose to any
`person, firm, or corporation, without written authorization from the Company’s President or a
`company officer, any [Confidential] Information, including, without limitation, information
`concerning project development and production, marketing plans and strategy, business plans
`and projections, finances, operations, billing methods and client and contact lists or other
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`2 Id. at p. 24.
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`subject matter pertaining to any business of the Company or any of its clients as defined
`above.”3
`By signing the HLH Carson City NDA, each of the Employee Defendants also
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`agreed that they would “hold in the strictest confidence and [would] not use, except for the
`benefit of the Company, or disclose to any person, firm, or corporation, without written
`authorization from the Company’s President or a company officer, any [Business Information
`or Trade Secret] Information, including, without limitation, information concerning project
`development and production, marketing plans and strategy, business plans and projections,
`finances, operations, billing methods and client and contact lists or other subject matter
`pertaining to any business of the Company or any of its clients as defined above.”
`By signing the HLH Carson City NDA, each of the Employee Defendants also
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`agreed that they would “maintain in secrecy all [Business Information and Trade Secret]
`Information and other confidential and/or proprietary information relating to the Company and
`its officers and/or directors and [would] use such Information only in the course of performing
`[their] duties” for the Company, and that they would “maintain in trust all such [Business
`Information and Trade Secret] Information as the Company’s property, including but not
`limited to, all documents, work papers, telephone directories, notes, and any and all copies
`thereof” in their possession or under their control.
`By signing the HLH Carson City NDA, each of the Employee Defendants also
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`agreed that they would “return to the Company any and all equipment, computer, disks, notes,
`notebooks, documents, memoranda, proposals, reports, files, forms, samples, books,
`correspondence, lists, or other written records affecting or relating to the Company, or created
`by [the Employee Defendant] during his or her employment with the Company, and any and all
`copies thereof” which were in the Employee Defendant’s possession.
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`3 Crisp signed the HLH Carson City NDA on July 17, 2018, A. Barnes signed it on August 1,
`2018, and J. Barnes signed it on August 12, 2018.
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`By signing the HLH Carson City NDA, each of the Employee Defendants also
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`agreed that they would not “at any time, either during the term of employment or for a period
`of one (1) year thereafter . . . whether as an owner, partner, shareholder, agent, employee,
`creditor, or otherwise, directly or indirectly, solicit, interfere with, divert, disrupt or attempt to
`disrupt any present business relationship, either contracted or otherwise, between the Company,
`its affiliates, successors in interest, or assigns, and any merchant, customer, advertiser, client or
`employee of the Company, its affiliates, successors in interest, or assigns.”
`By signing the HLH Carson City NDA, each of the Employee Defendants also
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`agreed that they would not “at any time, either during the term of employment or for a period
`of one (1) year thereafter, . . ., whether as an owner, partner, shareholder, agent, employee,
`creditor, or otherwise, directly or indirectly, solicit, interfere with, divert, disrupt or attempt to
`disrupt any business relationship, either contracted or otherwise, between the Company, its
`affiliates, successors in interest, or assigns, and any prospective merchant, customer, advertiser
`or client with whom the Company, its affiliates, successors in interest, or assigns have initiated
`a business contact.”
`By signing the HLH Carson City Code of Conduct, each of the Employee
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`Defendants agreed that he or she would refrain from “obtaining any personal benefit by virtue
`of [their] employment” with HLH Carson City, that they would “disclose to the Corporate
`Compliance Officer any financial interest, ownership interest or any other relationship” that
`they had with “the Company’s customers, vendors, or competitors,” that they would not use
`HLH Carson City Business Information or Trade Secrets for their “own personal benefit or for
`the benefit of any other person or entity, except the Company while employed by the Company
`or at any time thereafter,” and that they would “promptly report all violations or suspected
`violations of [the] Standards of Conduct by other Employees verbally to the Corporate
`Compliance Officer or the compliance hotline or in writing to the Corporate Compliance
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`9555 HILLWOOD DRIVE, 2ND FLOOR
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`Officer.”4
`In addition to the HLH Carson City Employment Agreements, as a requirement of
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`their employment, each of the Employee Defendants executed a Non-Disclosure and
`Confidentiality Agreement with Mission (the “Mission NDA”).
`By signing the Mission NDA, the Employee Defendants agreed that they would
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`“maintain [Mission] Confidential Information in strictest confidence for the sole and exclusive
`benefit of [Mission]” and that they would not, “without prior written approval” from Mission
`“publish, copy, or otherwise disclose to others, or permit the use by others for their benefit or
`to the detriment of [Mission], any Confidential Information” that belongs to Mission and that
`they would “return any and all records, notes, and other written, printed, or tangible materials”
`in their possession to Mission immediately.5
`
`D.
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`While The Employee Defendants Worked for Mission They, Conspired to Leave
`Mission to Operate and a Competing Business using Mission’s Business
`Information and Trade Secrets to Wrongfully Recruit Mission Employees,
`Referral Sources and Patients.
`
`Crisp was employed as the Administrator of HLH Carson City between
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`approximately July 7, 2016, and January 19, 2022.
`55. As the Administrator, Crisp managed HLH Carson City’s entire business operation
`and was the chief administrative employee at HLH Carson City. The owners and officers of
`Mission extended substantial trust and authority to Ms. Crisp, and she was charged with
`maintaining and overseeing the daily operations and quality of HLH Carson City.
`To perform these tasks, Crisp was required to perform numerous key corporate
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`initiatives, including to, among other things, development of company and organizational goals,
`implement health regulations and standards, promote and assist with interdepartmental
`
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`4 Crisp signed the HLH Code of Conduct on July 17, 2018, A. Barnes signed it on August 1, 2018,
`and J. Barnes signed it on August 12, 2018.
`5 Crisp signed the Mission NDA on November 19, 2021, J. Barnes signed it on December 2, 2021,
`and A. Barnes signed it on December 2, 2021.
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`9555 HILLWOOD DRIVE, 2ND FLOOR
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`Case 3:22-cv-00333-LRH-CLB Document 1 Filed 07/25/22 Page 13 of 35
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`communication and cooperation, assist in the development of employees through recruitment,
`retention, training, motivation, and rewards, establish and ensure implementation of
`performance goals, assist with the long term planning and implementation of strategic
`educational, patient care, research, revenue, and public relations programs, manage fiscal
`activities of the agency, coordinate special departmental activities, monitor record systems,
`develop policies, develop and enhance employee performance and fulfilment, oversee care
`delivery and patient outcomes, ensure compliance with federal, state, and local laws and
`standards.
`The performance of these duties provided Crisp with access to Mission business
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`information, including Business Information and Trade Secret Information on a daily basis.
`J. Barnes was employed with Mission from August 12, 2018, through January 19,
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`2022, as a registered nurse case manager.
`As a registered nurse case manager, J. Barnes was responsible for, among other
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`things, working with and managing Mission’s clinical staff, working with software programs
`including having key access to same, coordinating patient care and understanding and planning
`patient care for Mission’s patients including working directly with Mission’s developed referral
`sources, coordinating employee schedules and patient visits, supervising LPN and HHA field
`staff, providing education to employees regarding Mission’s policies, practices and care
`standards, being familiar with and follow Medicare and Medicaid regulations, observing,
`assessing, and documenting patient symptoms and progress, and performing home care visits
`as needed.
`The performance of these duties allowed J. Barnes to gain access to Mission’s
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`information, including Business Information and Trade Secret information and develop direct
`relationships with Mission’s clinical employees and referral sources.
`A. Barnes was employed with Mission from August 1, 2018, through January 19,
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`2022, as a certified nurse assistant.
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`9555 HILLWOOD DRIVE, 2ND FLOOR
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`Case 3:22-cv-00333-LRH-CLB Document 1 Filed 07/25/22 Page 14 of 35
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`62. As a Certified Nurse Assistant, A. Barnes was responsible for, among other things,
`assisting in the implementation of patient care plans, performing tasks assigned by his
`supervising RN, charting, observing and reporting safety hazards and other issues seen in
`patients’ homes, and other duties assigned by an RN.
`The performance of these duties allowed A. Barnes to gain access to Mission
`63.
`Business Information and Trade Secret information and develop direct relationships with
`Mission’s clinical employees, including RNs, and its patients.
`64. Upon information and belief, Crisp began providing services and performing
`actions for Battle Born’s benefit during her employment with Mission and while being paid by
`Mission.
`65. Upon information and belief, Crisp affirmatively hid from Mission that she had
`formed and begun performing services for Battle Born, a direct competitor of Mission, while
`she remained employed by and received paychecks from Mission.
`66. Upon information and belief, A. Barnes and J. Barnes were each aware that Crisp
`had formed and begun providing services for Battle Born but failed to disclose that information
`to Mission.
`67. Upon learning that Crisp had, in violation of her contractual obligations to
`Mission, not only begun forming a competing home health agency while employed by Mission
`but was doing so utilizing Mission’s resources including Mission’s Business Information and
`Trade Secret information and was negatively interfering with Mission’s business and at-will
`employment relationships, Mission terminated Crisp’s employment.
`68. Within thirty minutes of terminating Crisp’s employment, A. Barnes and J. Barnes
`each resigned without notice and effective immediately.
`69. Upon information and belief, Crisp began working for Battle Born during her
`employment with Mission. Upon information and belief, A. Barnes and J. Barnes performed
`some actions or services for Battle Born during their employment with Mission and became
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`9555 HILLWOOD DRIVE, 2ND FLOOR
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`LAS VEGAS, NV 89134
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`HOLLAND & HART LLP
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`Case 3:22-cv-00333-LRH-CLB Document 1 Filed 07/25/22 Page 15 of 35
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`employees of Battle Born immediately after their employment with Mission ended.
`Upon information and belief, each of the Employee Defendants consp