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Case 2:18-cv-01591-APG-PAL Document 7 Filed 08/31/18 Page 1 of 13

P. STERLING KERR, ESQ.


1
Nevada Bar No. 3978
2 GEORGE E. ROBINSON, ESQ.
Nevada Bar No. 9667
3 LAW OFFICES OF P. STERLING KERR
2450 St. Rose Parkway, Suite 120
4
Henderson, Nevada 89074
5 Telephone No. (702) 451–2055
Facsimile No. (702) 451-2077
6 Email: sterling@sterlingkerrlaw.com
7
Email: george@sterlingkerrlaw.com
Attorneys for Plaintiff
8
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
LAW OFFICES OF P. STERLING KERR

9
2450 St. Rose Parkway, Suite 120, Henderson, Nevada 89074

10
Telephone: (702) 451-2055 Facsimile: (702) 451-2077

INTERNATIONAL MARKETS LIVE, Case No.: 2:18-cv-01591-APG-PAL


11 INC., a New York corporation dba
ATTORNEYS AT LAW

iMARKETSLIVE;
12 PLAINTIFF’S EMERGENCY
Plaintiffs, MOTION FOR AN EX PARTE
13 v. TEMPORARY RESTRAINING
ORDER AND PRELIMINARY
14
BLUE CAPITAL FX, LLC, an Arizona INJUNCTION
15
limited liability case; KEN IBIZUGBE, an
individual; HEATHER LOPEZ, an
16 individual; NATE BARNES, an individual;

17 Defendants.

18

19

20 Pursuant to Federal Rule of Civil Procedure 65, Plaintiff International Markets Live,
21
Inc. dba iMarketslive (hereinafter “IML”), respectfully moves the Court for an emergency ex
22
parte temporary restraining order and a preliminary injunction against Defendants Blue
23
Capital FX, LLC (hereinafter “BCFX”), Ken Ibizugbe (hereinafter “Ibizugbe”), Nate Barnes
24

25 (hereinafter “Barnes”) and Heather Lopez (hereinafter “Lopez”).

26 This Ex Parte Motion is based upon the pleadings and the records on file herein, the
27
Declaration of Jason Brown In Support of Plaintiff’s Motion for Temporary Restraining Order
28

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and Preliminary Injunction (“Brown Decl.”), and the oral argument of counsel, if any. In
1

2 support of this Motion, Plaintiff attaches the following Exhibits: the Declaration of Jason

3 Brown; and the [Proposed] Order Granting the Ex Parte Temporary Restraining Order and
4
Preliminary Injunction.
5
MEMORANDUM OF POINTS AND AUTHORITIES
6

7
I. INTRODUCTION

8 Injunctive relief must be granted to IML against Defendants Ibizugbe, Barnes, and
9 Lopez, through their new company, Blue Capital FX, LLC are using confidential information
10
improperly taken from IML in clear breach of their confidentiality agreements to steal IML
11
customers and contractors. The Court must stop this illegal conduct as it is irreparably
12

13 harming IML’s business.

14 II. BACKGROUND
15
IML is a company that provides its customers with educational tools and information to
16
trade foreign and crypto currencies (“Forex Trading”). See Exhibit 1, Affidavit of Jason Brown.
17
IML’s products are distributed under a direct sales model and are offered to individuals on a
18

19 subscription basis. Id. IML’s products help IML provide customers with technology, education,

20 and research for Forex Trading. Id. IML contracts with IBOs in an independent contractor
21
relationship as a way to effectuate the direct sales model of its products and services. Id. These
22
contracts are called Independent Business Owner (“IBO”) Agreements. Id. All IML IBOs
23

24
become IBOs of IML products only after entering into an IBO Agreement requiring the IML

25 distributor to agree to IML’s Policies and Procedures. See Exhibit 2, IML Policies and
26 Procedures. Ibizube, Lopez, and Barnes all became independent contractors for IML by signing
27
the IBO Agreements.
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Ibizube, Lopez, and Barnes breached their IBO Agreements with IML by, among other
1

2 things, by leaving IML and immediately starting a competing company BCFX. Defendants’

3 unconscionable actions run much deeper than simply breaching their contractual obligations. Id.
4
Ibizube, Lopez, and Barnes have conspired to bribe, solicit, recruit, and entice other IML IBOs,
5
customers, and traders away from IML and to BCFX. Id. Said Defendants then acted out their
6

7
conspiracy by bribing, soliciting, recruiting, and enticing other IML IBOs and traders away from

8 IML and to BCFX. Id. Moreover, Defendants reprehensible behavior extends to knowingly and
9 intentionally stealing Confidential Information and intellectual property from IML for their own
10
profit and gain. In order to halt Defendants’ duplicitous actions from further irreparably harming
11
Plaintiff, this Court must grant injunctive relief by granting a temporary restraining order and
12

13 promptly setting a hearing for a preliminary injunction.

14 III. EMERGENCY EX PARTE RELIEF IS APPROPRIATE


15
Ibizube, Lopez, and Barnes have engaged in a pattern of duplicitous actions which
16
have irreparably harmed Plaintiff in this jurisdiction. Said Defendants originally worked for
17
IML and by virtue of their employment positions had access to IML’s proprietary information
18

19 and trade secrets. Said Defendants breached their obligations under their IBO Agreements and

20 engaged in a pattern of duplicitous conduct by: leaving IML and immediately starting a
21
competing company BCFX; conspiring to bribe, solicit, recruit, and entice other IML IBOs,
22
customers, and traders away from IML and to BCFX; bribing, soliciting, recruiting, and
23

24
enticing other IML IBOs and traders away from IML and to BCFX; and knowingly and

25 intentionally stealing Confidential Information and intellectual property from IML for their
26 own profit and gain.
27
Accordingly, Plaintiff respectfully requests that this Court to restrain Defendants from
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(1) bribing, soliciting, recruiting or enticing IML IBOs, customers, and traders; (2) and
1

2 misappropriating Plaintiff’s trade secrets, confidential corporate information, and other

3 proprietary information. An ex parte order preserves the status quo ante and prevents
4
irreparable harm. See Granny Goose Foods, Inc., v. Brotherhood of Teamsters, 415 U.S. 423,
5
439 (1974). This is precisely the type of relief Plaintiff seeks here. In seeking an order
6

7
restraining Defendants from further irreparably harming Plaintiff, Plaintiff is requesting this

8 Court’s assistance to preserve the status quo antebellum and prevent irreparable harm until
9
the Court is able to hold a hearing on these issues. Courts may grant an ex parte temporary
10
restraining order when: (1) immediate and irreparable injury, loss, or damage will result to the
11
applicant before the adverse party can be heard; and (2) the moving party demonstrates the
12

13 reason notice should not be required. Fed. R.Civ. P. 65(b).

14 IV. STATEMENT OF FACTS


15
IML is a company that provides its customers with educational tools and information to
16
trade foreign and crypto currencies (“Forex Trading”). IML’s products are distributed under the
17
direct sales model and are offered to individuals on a subscription basis. IML’s products help
18

19 IML provide customers with technology, education, and research for Forex Trading. IML

20 contracts with IBOs in an independent contractor relationship as a way to effectuate the direct
21
sales model of its products and services. These contracts are called Independent Business Owner
22
(“IBO”) Agreements. See Exhibit 1. All IML IBOs become IBOs of IML products only after
23

24
entering into an IBO Agreement requiring the IML distributor to agree to IML’s Policies and

25 Procedures.
26
The IBO states that each distributor has carefully read and agrees to comply with IML’s
27
Policies and Procedures. IML’s Policies and Procedures require, among other things, that:
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• IBOs may not directly or indirectly recruit other IBOs or customers for other
1

2 network marketing businesses;

3 • IBOs may not participate as a distributor in another network marketing company


4
that sells and distributes similar products to IML;
5
• IBOs must not sell, or attempt to sell, any competing non-IML programs, products,
6

7 or services to IML IBOs or customers;

8 • The Confidentiality Provision in the Policies and Procedures states:


9
During the term of the Agreement, Company may supply to
10 Independent Affiliates confidential information, including, but not
limited to genealogical and Downline reports, customer lists,
11 customer information developed by Company or developed for and
12
on behalf of Company by Independent Affiliates (including, but not
limited to, credit data, customer and Independent Affiliate profiles
13 and product purchase information), Independent Affiliate lists,
manufacturer and supplier information, business reports,
14 commission or dales reports and such other financial and business
15
information which Company may designate as confidential. All
such information (whether in written or electronic format) is
16 proprietary and confidential to Company and is transmitted to
Independent Affiliates in strictest confidence on a “need to know”
17
basis for use solely in Independent Affiliates business with
18 Company. Independent Affiliates must use their best efforts to keep
such information confidential and must not disclose any such
19 information to any third party, or use this information for any non-
company activity directly or indirectly while on Independent
20
Affiliate and thereafter.
21
See Exhibit 2.
22
On or about February 18, 2017, Defendant Ibizugbe entered into an IBO Agreement
23

24 requiring the IBO to agree to IML’s Policies and Procedures. See Exhibit 1. On or about May

25 15, 2018, Defendant Lopez entered into an IBO Agreement requiring the IBO to agree to
26
IML’s Policies and Procedures. Id. On or about May 13, 2018, Defendant Barnes entered into
27
an IBO Agreement requiring the IBO to agree to IML’s Policies and Procedures. Id. At all
28

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times relevant herein, Ibizube, Lopez, and Barnes knew and were aware of the terms of the
1

2 IML Policies and Procedures, including the prohibitions against recruiting IML IBOs and

3 traders to leave IML, the prohibition against working for a competitor of IML, and the
4
prohibition against providing Confidential Information and intellectual property to anyone
5
outside of IML.
6

7
IML believed that Ken Ibizugbe was a skilled Forex trader, and the company wanted

8 him to transfer to a different department in IML where he could hone his skills and eventually
9 become a Swipe Trade Master, a full-time trader. Id. In doing so, he could develop and use his
10
skills as a trader to the betterment of IML and himself. Id. Before he became a Swipe Trade
11
Master, Ibizube began misrepresenting to people in presentations at events that he was already
12

13 a Swipe Trade Master. At the Tempo event in Tempe, Arizona, Ibizube was using this IML

14 platform to recruit IML IBOs, including prominent IBOs, to join a new company that he was
15
forming. Id.
16
In early August of 2018, Ibizube informed IML that instead of becoming a Swipe Trade
17
Master, he no longer desired to work for IML, and that he was going to start his own trading
18

19 business called Blue Capital FX (“BCFX”) using the confidential information he obtained from

20 IML. Ibizube has access to client and IBO lists which he used, and is currently using, to
21
actively recruit IML customers and IBOs to BCFX. IML employees tried to persuade him not
22
to violate his agreement with IML, but they were told that he was going to start BCFX with
23

24
IML IBOs and customers anyway.

25 Defendants are currently using IML confidential information to wrongfully recruit


26 hundreds of IML IBOs to BCFX including high-ranking IBOs to the severe detriment of IML.
27

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IML asks this Court to issue a TRO against Defendants ordering Defendants to refrain from
1

2 use of any and all confidential and trade secret information obtained from IML.

3 V. LEGAL ARGUMENT
4
In light of the facts above, and applying the controlling law, the Court should award
5
the temporary relief requested in this motion and described in the Proposed Order. First, IML
6

7
is likely to prevail on the merits of this case because the company will be able to show that

8 Defendants are actively violating the confidentiality agreements they entered into with IML;
9 as well as committing tortious acts by unlawfully taking IML customers and IBOs by using
10
IMLs confidential information. Second, Defendant’s wrongful activities are causing Plaintiff
11
irreparable harm in the form loss of thousands of IBOs and customers and untold harm to
12

13 Plaintiff’s good will and reputation among its consumers. Third, the balance of equities favors

14 Plaintiff because, in the absence of injunctive relief, Plaintiff’s confidentiality agreements


15
become meaningless and any former contractor for IML can take IML’s confidential client
16
lists and trade secrets without penalty, whereas if injunctive relief is granted, Defendant will
17
simply be required to observe contract law and the law of fair trade practices. Fourth, the
18

19 public interest favors entering an injunction, because public policy favors enforcing contracts

20 and the Uniform Trade Secrets Act. Accordingly, Plaintiff respectfully asks this Court to grant
21
Plaintiff’s requested relief, as set forth in the Proposed Order.
22
A. PLAINTIFF IS ENTITLED TO A TEMPORARY RESTRAINING ORDER AND
23 PRELIMINARY INJUNCTION BECAUSE OF DEFENDANTS’ USE OF IML’S
24
CONFIDENTIAL AND TRADE SECRET INFORMATION AND CONTINUED
COMMISSION OF TORTIOUS INTERFERENCE
25
The sine qua non of injunctive relief is a showing of irreparable injury and the
26

27
inadequacy of legal remedies which is exactly what we have in this situation. See Sampson v.

28 Murray, 415 U.S. 61, 88 (1974). The rule governing temporary restraining orders is contained

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in FRCP 65 which states in relevant part:


1

2 (b) Temporary Restraining Order.

3 (1) Issuing Without Notice. The court may issue a temporary


restraining order without written or oral notice to the adverse
4
party or its attorney only if:
5
(A) specific facts in an affidavit or a verified
6 complaint clearly show that immediate and
7
irreparable injury, loss, or damage will result to the
movant before the adverse party can be heard in
8 opposition; and
9 (B) the movant's attorney certifies in writing any
10
efforts made to give notice and the reasons why it
should not be required.
11
Federal jurisprudence further holds that to obtain injunctive relief the plaintiff must
12

13 demonstrate: (1) a likelihood of success on the merits; (2) irreparable harm in the absence of

14 an injunction; (3) that the balance of equities tips in plaintiff’s favor; and (4) that injunctive
15
relief is in the public’s interest. See Munaf v. Geren, 553 U.S. 674, 689-690, 128 S.Ct. 2207,
16
2218-2219, 171 L.Ed.2d 1 (2008); Amoco Production Co. v. Gambell, 480 U.S. 531, 542, 107
17
S.Ct. 1396, 94 L.Ed.2d 542 (1987); Weinberger v. Romero-Barcelo, 456 U.S. 305, 311-312,
18

19 102 S.Ct. 1798, 72 L.Ed.2d 91 (1982); Winter v. Natural Resources Defense Council, Inc.,

20 555 US 7 - Supreme Court 2008. AstraZeneca LP v. Apotex, Inc., 633 F.3d 1042, 1049 (Fed.
21
Cir. 2010). The standard for a temporary restraining order is the same as the standard for a
22
preliminary injunction. See Stuhlbarg Int'l Sales Co., Inc. v. John D. Brush & Co., 240 F.3d
23

24
832, 839 n. 7 (9th Cir. 2001). Nevada state law requires the same showing. University Sys. v.

25 Nevadans for Sound Gov't, 100 P. 3d 179 - Nev: Supreme Court 2004
26
1. PLAINTIFF IS LIKELY TO SUCCEED ON THE MERITS
27
Defendants Ibizuge, Lopez, and Barnes have clearly breached IML’s Policies and
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Procedures by using the confidential “genealogical and Downline reports, customer lists,
1

2 customer information developed by Company or developed for and on behalf of Company

3 by Independent Affiliates, Independent Affiliate lists, manufacturer and supplier


4
information, business reports” in order to illegally capture IML clientele and contractors for
5
their own new company, Blue Capital FX, LLC. In taking these wrongful and unlawful
6

7
steps to steal IML clients and IBOs, the business torts of intentional interference with

8 contractual relations was committed. Additionally, by speaking to prospective clients of


9 IML at the meetings and through the social media groups established for IML, Defendants
10
have committed tortious interference with prospective business advantage.
11
2. IML WILL BE IRREPARABLY HARMED IN THE ABSENCE OF A
12
TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION
13
Pursuant to Nevada state law, “NRS 33.010 provides, in relevant part, ‘An injunction
14
may be granted in the following cases: ... 2. When it shall appear by the complaint or
15

16 affidavit that the commission or continuance of some act, during the litigation, would

17 produce great or irreparable injury to the plaintiff.’" The Nevada Supreme Court states that
18
the injunction is appropriate when “the defendant's conduct, if allowed to continue, will
19
result in irreparable harm for which compensatory damages is an inadequate remedy.
20
Number One Rent-A-Car v. Ramada Inns, 94 Nev. 779, 780, 587 P.2d 1329, 1330 (1978).”
21

22 Sobol v. Capital Management Consultants, 726 P. 2d 335 - Nev: Supreme Court 1986. The

23 Sobol Court goes on to state, “acts committed without just cause which unreasonably
24
interfere with a business or destroy its credit or profits, may do an irreparable injury and thus
25
authorize issuance of an injunction. Guion v. Terra Marketing of Nev., Inc., 90 Nev. 237,
26

27
240, 523 P.2d 847, 848 (1974).” Id. “Courts often use the terms ‘immediate’ and

28 ‘irreparable’ in the context of determining whether to grant injunctive relief. See NRCP

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65(b) (permitting temporary restraining orders if specific facts show "immediate and
1

2 irreparable injury, loss, or damage"); Dixon v. Thatcher, 103 Nev. 414, 415-16, 742 P.2d

3 1029, 1029-30 (1987) (concluding that a preliminary injunction to stop a foreclosure is


4
proper where there is a reasonable likelihood of success and a threat of irreparable harm)The
5
common understanding of ‘immediate’ is ‘instant or direct.’ Sam v. Com., 13 Va.App. 312,
6

7
411 S.E.2d 832, 839 (1991).” Hamm v. Arrowcreek HOA, 183 P. 3d 895 - Nev: Supreme

8 Court 2008.
9 Here, BCFX is using IML’s trade secret and confidential information to commit acts
10
directly on point with the Sobol Court’s decision. Id. Defendants are wrongfully pursuing
11
IML clients through engagement with IML clients at IML events. Defendants are using
12

13 social media groups under the protection of the confidentiality agreement which were used

14 to recruit IBOs and customers to IML for BCFX. The lost of IBOs and customers to BCFX
15
is causing immediate and irreparable harm to IML. IML’s IBOs, customers, and potential
16
customers are currently being adversely affected by defamation, violations of the
17
confidentiality provision of the IBO contract’s policy and procedures provisions, and
18

19 tortious inference with clients and prospective clients. It will be very difficult to make an

20 accurate calculation as to the damage caused by these wrongful acts of the Defendants.
21
3. THE BALANCE OF HARDSHIPS IS IN FAVOR OF IML
22
The balance of hardships assesses the relative effect of granting or denying an
23

24
injunction on the parties. See Clark Co. School Dist. v. Buchanan, 112 Nev. 1146, 1150,

25 924 P.2d 716, 719 (1996). In this case, the balance of hardships tips decidedly in IML’s
26 favor. First, as already discussed, IML will suffer irreparable harm if BCFX continues to
27
use IML’s client lists and trade secrets to unlawfully recruit IML IBOs and customers. If
28

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BCFX continues to violate the agreement and commit tortious interference, IML’s current
1

2 IBOs may believe that their contracts with IML are meaningless and they can violate the

3 contracts without repercussion. Additionally, IML IBOs may begin to lose trust in the
4
company if IML does not protect their downline by not enforcing the contracts. IML has
5
much to lose if the injunction is not granted.
6

7
Defendants have the hardship of following their IML agreements in order to build a

8 customer base for BCFX. Defendants will have to generate business from methods of
9 marketing that do not tortuously interfere with IML’s current or prospective clients. These
10
hardships only come from following the agreements they entered into with IML and other
11
statutory and legal authority.
12

13 4. INJUNCTIVE RELIEF IS IN THE PUBLIC’S INTEREST

14 The main public policy at issue in this case is the right to contract and to enforce
15
valid contracts, namely confidentiality agreements. The confidentiality agreement in this
16
case does not prevent Defendants from employment. See Exhibit 2. The agreement makes
17
the reasonable restriction as to misappropriating Plaintiff’s trade secrets, confidential
18

19 corporate information, and other proprietary information.

20 B. IML REQUESTS THAT DEFENDANT BE ORDERED TO SHOW CAUSE


REGARDING THE ISSUANCE OF A PRELIMINARY INJUNCTION
21

22 The standard for issuance of a preliminary injunction is the same as the standard for

23 issuance of a temporary restraining order. See Stuhlbarg Int’l Sales Co., Inc. v. John D.
24
Brush & Co., 240 F.3d 832, 839 n.7 (9th Cir. 2001). IML has met its burden with respect
25
that standard. Accordingly, IML respectfully requests that this Court issue a show-cause
26

27 order requiring Defendant to demonstrate why the Court should not issue a preliminary

28 injunction continuing the relief granted in the temporary restraining order.

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VI. CONCLUSION
1

2 For the reasons set forth above, IML respectfully requests that the Court enter

3 an order temporarily restraining Defendant from the following acts:


4
• Defendants shall immediately refrain from using any IML customer list,
5
trademark, trade secret, program information, or any other confidential information and/or
6

7
materials, including downlines, back-office data, binary options trading software, and binary

8 options trading algorithms;


9 • Defendants shall immediately refrain from disclosing any IML customer list,
10
trademark, trade secret, program information, or any other confidential information and/or
11
materials;
12

13 • Defendants shall immediately return any equipment, or other materials,

14 including but not limited to, hard copies of documents and/or data, electronic copies of
15
documents and/or data, emails, and any other material containing or referring to any IML
16
customer list, trademark, trade secret, program information, or any other confidential
17
information and/or materials;
18

19 • Defendants shall immediately refrain from conducting and soliciting any business,

20 accepting any employment by or rendering professional services to, any person or


21
organization that is or was a IML distributor, trader, and/or client, which includes that
22
BCFX shall not conduct business with those Defendants who are former IML IBOs or
23

24
traders; and

25 • Defendants shall immediately refrain from soliciting, recruiting, bribing, and/or


26 enticing IML IBOs and/or traders to violate their contracts with IML and/or misappropriate
27
IML’s Confidential Information and/or intellectual property.
28

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IML also requests that the Court order Defendant to show cause regarding the
1

2 issuance of a preliminary injunction, and set a hearing on IML’s request for a preliminary

3 injunction.
4
Dated this 31st day of August, 2018.
5

6
LAW OFFICES OF P. STERLING KERR
7

8 /s/ P. Sterling Kerr


P. STERLING KERR, ESQ.
9 Nevada Bar No. 3978
GEORGE E. ROBINSON, ESQ.
10
Nevada Bar No. 9667
11 LAW OFFICES OF P. STERLING KERR
2450 St. Rose Parkway, Suite 120
12 Henderson, Nevada 89074
Telephone No. (702) 451–2055
13
Facsimile No. (702) 451-2077
14 Email: sterling@sterlingkerrlaw.com
Email: george@sterlingkerrlaw.com
15 Attorneys for Plaintiffs
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