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118 views9 pagesComplaint Drybar v. Mango.2018
Steven Mango was sued by his former employer Drybar for spreading lies about them.
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0% found this document useful (0 votes)
118 views9 pagesComplaint Drybar v. Mango.2018
Steven Mango was sued by his former employer Drybar for spreading lies about them.
Uploaded by
Database 1Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
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1 || HELENE WASSERMAN, Bar No. 130134 eSienr Guu et Cantons
K. KAYVAN IRADJPANAH, Bar No. 267548 County of Orange
LITTLER MENDELSON, P.C- 0104/2018 at 03:02:03 PM
633 West Sth Street, 63rd Floor Clark pf the Super Co
Los Angeles, CA 90071 ay Gantice NguyensDeputy Clerk
Telephone: " 213.443.4300
Fax Nos 213.443.4299
Emails: _hwasserman@littler.com;
kiradjpanah@littler.com
©, MISHELL P. TAYLOR, Bar No. 256850
AMBERLY A. MORGAN, Bar No. 273891
LITTLER MENDELSON, P.C.
501 W. Broadway, Suite 900
San Diego, CA 93101.3577
Telephone: 619.232.0441
Fax Ni 619.232.4302
Emails: _mtaylor@littler.com; amorgan@littler.com
eC er aAaneon
Attomeys for Plaintiff
11 ]| DRYBAR HOLDINGS LLC
SUPERIOR COURT OF CALIFORNIA
COUNTY OF ORANGE Judge Frederick P. Hom
DRYBAR HOLDINGS LLC, Case No, 30-2018-00968066.CU-BC-CJC
* Plaintiff, PLAINTIFF’S COMPLAINT FOR:
6 v. (1) BREACH OF CONTRACT
" STEVEN MANGO, (2) DEFAMATION
8 Defendant. (3) INTENTIONAL INTERFERENCE WITH
PROSPECTIVE ECONOMIC BENEFIT
(4) NEGLIGENT INTERFERENCE WITH
PROSPECTIVE ECONOMIC BENEFIT
(5) BREACH OF COVENANT OF GOOD
FAITH AND FAIR DEALING; AND
(© UNFAIR COMPETITION, CALIFORNIA
BUSINESS AND PROFESSIONS CODE §
17200, ET SEQ.
‘COMPLAINT 9
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Plaintiff DRY BAR HOLDINGS LLC (“Plaintiff’ or “Drybar’) for its Complaint against
Plaintiff STEVEN MANGO (“Plaintiff) alleges and states as follows:
1. This civil action seeks to prevent the immediate and irreparable harm now being suffered or
about to be suffered by Plaintiff as a result of Defendant’s breach of his Contract with Plaintiff and
defamatory and tortious conduct set forth below.
PARTIES AND JURISDICTION
2, Plaintiff is, and at all relevant times was, a Delaware corporation headquartered and doing
business in Orange County, California,
3. It is Plaintiff's information and belief that Defendant is, and was at all relevant times, an
individual residing in the County of Los Angeles, California.
4, This Court has jurisdiction over this entire action because this is a civil action wherein the
matter in controversy, exclusive of interest, exceeds $25,000.00 and because Plaintiff seeks equitable
relief.
5. Venue is proper in the Superior Court, County of Orange, because Plaintiff and Defendant
entered into a Contract, and agreed that the County of Orange, State of California, would retain
jurisdiction to enforce the Contract.
FACTS COMMON TO ALL CAUSES OF ACTIO!
6. Plaintiff is a corporation with over 90 blow-
