Preview
JRE Management, LLC sues Defendant GCP Clinical Trial Consultants, Inc.
for breach of contract JRE Management, LLC GCP Clinical
Trial Consultants, Inc. entered into an owner and operator
of JRE, Regina Ezeh, performed consulting services for GCP failed to pay JRE for
services rendered Furthermore, JRE terminated its contract with JRE and Ezeh
JRE Management, LLC limited liability company registered in the state of
GCP Clinical Trial Consultants, Inc. a Texas corporation with its principal
place of business located at 9595 Six Pines Drive, Suite 8210, The Woodlands, TX 77380
Defendant may be served through its registered agent, United States Corporation Agents,
, at 9900 Spectrum Drive , Texas Defendant may also be
served through its Director and President Jeffrey A. Faatz located at 651 Chateau Woods
Parkway Drive, Conroe, Texas 77385.
DISCOVERY CONTROL PLAN
Plaintiff files this suit as an expedited action under Texas Rule of Civil Procedure 169.
Plaintiff intends that this suit be governed by discovery control level one.
Plaintiff seeks only monetary relief of $250,000 or less, excluding interest, statutory or
punitive damages and penalties, and attorney’s fees and costs
JURISDICTION AND VENUE
This Court has jurisdiction and venue over the parties to this action since the matter in
controversy exceeds the sum or value of the minimum jurisdictional limits of the Court,
exclusive of costs and interest.
Venue is proper in Montgomery County, Texas, pursuant to Section 15.002(a) (b) of the
Texas Civil Practice and Remedies Code because t county of the efendant s principal
office Montgomery County.
IV. FACTS
JRE Management, LLC and Defendant GCP Clinical Trial Consultants, Inc. entered into
a contract, the Consulting Agreement (the “Agreement”), on June 24, 2022.
Executing the greement on behalf of JRE was its owner operator, Regina Ezeh.
Executing the greement on behalf of GCP was its President and Director Jeffrey A.
Prior to the signing of the Agreement, had approached Ezeh and informed her that
GCP’s client, confidential , was looking for experienced Clinical Research Associates
(CRAs).
Plaintiff s Original Petition & Jury Demand Page
Consultant shall return all Confidential Information, including any copies thereof, to
Company or, upon request by the Company, shall certify in writing that the Confidential
Information and all copies were destroyed.
Consultant acknowledges that the Company has confidentiality and non disclosure
agreements with Client. Consultant agrees to comply with the Company’s obligations
Accordingly,
under the the Agreementandprovided
confidentiality non disclosure that Ezehagreements was engaged
and to execute to provide
all documentsexperienced,
required for compliance by Client and/or Company.
CONSULTING AGREEMENT
qualified services for various clinical trials conducted by clients of GCP.
This CONSULTING AGREEMENT the “Agreement”) is made and entered into as of
the“Confidential
day of July Information”theshall mean allDate”)
“Effective of the materials,
by and betweeninformation,
GCP and strategies
Clinical Trial that
Specifically,
the Company
Consultants, Ezeh was assigned
treats as confidential
Inc. (“Company”) to perform services
or proprietary
a Texas Corporation, on GCP’s
with including, account
without
a mailing address with
limitation,
of 9595 Six Pinesconfidential
client
names;
Drive, Suiteclient
8210, lists; client files;
The Woodlands, TXclient
77380information;
and JRE Management, vendor names and lists; personnel
LLC (“Consultant”),
For Georgia
the duration of
Limited Liability
information; her Company,
operating employment, with a mailing
and training always
address
manuals; of gave her
3404 Twinrose
operation best
methods efforts
Place,
andMilton, toGA GCP and its
information;
. The Company and Consultant are sometimes referred to individually as a “Party” and
technical, financial, sales, and planning information; client products, strategies, research,
collectively as the “Parties.”
client, confidential
government , and complied
compliance, with JRE’s
and marketing; and side tradeof secrets.
the Agreement.
However, Confidential
Information
Purpose.does not include
Subject to the anytermsinformation
and conditions whichhereof,
(i) wastheknownCompanyto the hereby
public atretains
the time
Whileitworking
wasConsultant with
disclosed GCP,
to to Consultant;
provide had
(ii) no
experienced, disciplinary
lawfully
qualified services history
obtained and and
actually
various anticipated
known
clinical remaining with
trialstoconducted
Consultant,
TimeSponsors
before itand or Contract
wasExpense
disclosed to Research
Reports Consultant,Organizations
Consultant from (“Client”).
shallasubmit
source another thaninvoic
itemized the Company;
documenting andall(iii)
GCP throughout
billable
becomes timeits contractual
and
generally travel
known or relationship
expenses to
availablethe Company
in with
the onconfidential
industry,or before
trade, the
or , day
at the
5public, very
ofother
the month least.
than for
by a
Scope
the of Services
preceding month’s Consultant
work viawillemail assist the Company in providing services to Client
to jeff.faatz@gcpclinicalconsultants.com in
Billable
breach
time, by Consultan
accordance
expenses, with
and orterms
theall others
of of
receipts the
areany
to legal
study duty into
beprotocol,
entered owed to the federal
ICHReplicon,
GCPs, Company.
a timeregulations,
& expenseand any
software
Pursuantprovided
to the
other Agreement
relevant
to the study plan atThe
Consultant nowas guaranteed
services
charge. will
If include40assisting
Consultant hours
fails perCompany
to the
submit week at
with
the requisiteanstudy
hourly
time, rate of
Intellectual Property Rights Consultant acknowledges that all services provided5 by
expenses,
start up and invoice
activities, preby the
study close of
visits, business
site (i.e.,
initiation, 5:00
site PM U.S.
management, Central Time)
interim on
monitoring,the
$120/hour day ofcleanup,
data
Consultant theunder
month, Company
quality
this reserves
assurance,
Agreement the right
document
are subject totothe
review, not process
team
“Works late
support
made submissions
and training,
for until
hire”site the out
close
provision next
in 17
month’s cycle.
visits, and other reasonably necessary tasks as determined by Company or Client.
U.S.C. § 201(b) and that Consultant’s work product shall be the sole property of the
services will be performed by Consultant to the reasonable satisfaction of Company and in
Company.
Guaranteed
accordance Minimum Hours The
with all applicable lawsCompany agrees to
and the highest pay Consultant
professional for a for
standards minimum
clinicalof
40trials.
hoursConsultant
per week will
overreport
the term of theA.
to Jeffrey Agreement, and Consultant
Faatz, the Company agrees to be available
President.
to the Company to provide services upon request. If the Company chooses not to use
Covenant
Consultant’s
Not services
to Compete. In exchange fora the
forcommences
any reasononduring
promises
givenDate
work
by the
week,
Company will
the Company
underpaythis
Term. This
Agreement, Agreement the Effective set forth above and willCompany
continue
Consultant the hourly rate set forth above in Section 4 for a guaranteed number of hoursby
Consultant agrees that he or she will not compete with the
until the end of the Company’s consulting agreement(s) with Client or upon termination of
providing clinical
(i.e. 40 hours) trial that
during consulting
work week.
the Agreement, whichever occurs first.
services to any
Subject Client
to the for whom
restrictions Consultant
set forth below inperformed
Section
13, Company
services agrees that Consultant
on the Company’s behalf duringmay engage
the termin of
other
thisbusiness
Agreementactivities provided
and for one (1)such
year
other business activities do not negatively affect its Service level to Company, its ability to
after termination
Compensation
perform
ofConsultant
this and
its obligations
Agreement
will out
carry
This
be paid covenantonenothundred
its responsibilities
to compete
to Company
applies
twenty toorand
dollars
hereunder
allcause
clinical
no it
trialtocents)
consulting
per services
hour by provided
Company forbyallConsultant
services directly
performed
be in breach of any of its obligations under this Agreement. or
underon behalf
this of any
Agreement other
within person,
14
firm,days after payment
partnership, is received for those services from Client (net 30 days). Company will
or corporation.
notify Consultant
Independent Contractorconditions
Status The required
artiesbyacknowledge
Client for billing travelthat
and agree time, preparation
Consultant
and reporting
duly organized work,
and and other services
formed termination performed
company in the under this
State of Georgia.Agreement.
ConsultantIn addition
is 30 to
notdays’
the written
The Agreement
Warranty ofhad
No aRestrictions
no cause Consultant provision,
represents but
andthe required
warrants at
thattomust least
Consultant
providing
Company’s an itemization
employee, of his/her
officer, agent,time and
or partner expenses,
and shall not Consultant
represent provideoristhe
the public not a
any
party toparty
third any that
Company restrictive
with covenants
an invoice.
Consultant isPaymentortoagreements
an employee,the Consultant that
willwould
officer, agent, not restrict
be made
or partner theorCompany.
ofwithout otherwise
an itemized limit
This
notice:Consultant’s
invoice right
Agreement shallonotability to perform
be construed to the services
create under this Agreement.
an employment, agency, or joint venture
relationship between the arties.
Travel Expenses Consultant understands that occasional travel be required under this
Termination.
Taxes
Agreement
This
The Company Agreement
and that shall notmay
Company
be terminated
withhold
will not federal,
without
directly state,
pay for
causetaxes
or local by either
Consultant’s
party
ortravel
make any thirty
Social
expenses.
(30)
days after the
Security delivery
(FICA)
Consultant to the other
will contributions
be reimbursed forfor
anyofallamount
a reasonable
writtenpaidnotice
toand of termination.
Consultant
necessary under In
travelthis addition,
Agreement
expenses by the
Company
Companymayshall
Consultant immediately
withinbe14solely terminate
responsible
days after payment this
for Agreement
the payment
is received with cause
of allexpenses
for those byfrom
federal, delivery
state, of(net
or local
Client a taxes
written
30
incurred for any compensation paid under this Agreement. Company will give
ClientConsultant
After notice
paying
Form
ofEzeh
days). termination.
Company
1099
willCause
for just
MISC
notify shall
one month
following the end
exist
Consultant oftheof
of
when
all
tax
the beginning
Company
conditions
services,
year.
determines,
required inbyAugust infor itsthesolGCP and
2022,
reimbursement of travel expenses under this Agreement.
discretion, that Consultant has (i) breached a material term of this Agreement, (ii) engaged
inbegan
professional
to as
Benefits
Except breach misconduct
Consultant
set forth above,
detrimental
itsunderstands
contractual and agreestothat,
Consultarelationship
theas performance
will not be with JRE for
a duly organized
reimbursed
ofand
and services
any otherby
under
formed companyfailing
expenses
thisto make
in the
Agreement, State of Georgia Consultant is not eligible for and shall not receive any medical,
incurred (iii)
underdemonstrated
this Agreement, an inability
and Consultantto work with
will othersatonhisbehalf
provide, or herofsole thecost,
Company,all
accident, or workers’ compensation insurance or any benefits available to employees of the
paymentCompany.
for services rendered
necessary equipment, supplies, and instruments.
Page of
Confidentiality
Faatz claim the delayConsultant
in GCP’s acknowledges
payment toandJRE
agrees
wasthat
dueallto
files, records, lists,’s
confidential books,
failure to pay
products, and other materials owned or used by the Company in connection with its
consulting work, including,JRE
butManagement,
not limited to, Confidential Information as defined below
GCP. shall remain the property of the Company and shall be kept confidential Consultant and
used for the sole benefit of the Company and the Client. Consultant further agrees to not
engage in the unauthorized use, disclosure, dissemination, duplication, copying, or transfe
of the Confidential Information. Within ten (10) days after termination of this Agreement,
Page of
Plaintiff s Original Petition & Jury Demand
JRE Management, Page
Nonetheless, Faatz assured Ezeh that she would be paid once confidential fulfilled its
contractual obligations to GCP.
In reliance on this assurance, Ezeh continued to perform work for GCP.
Then, in early October with GCP becoming increasingly in arrears with JRE,
once again assured Ezeh that she would be paid.
Faatz sent an email to employees, blind copy, stating that confidential owed him money
and that he was not going to be able to pay employees per their contracts, but indicated that
he was in the process of resolving the issue with the client.
Despite th fact that it was GCP’s obligation to pay Ezeh regardless of whether
confidential paid it Ezeh yet again gave Faatz the benefit of doubt and continued to
work.
As late as October 20, 2022, Faatz advised that he thought “the kinks [were] all worked
out,” and told Ezeh she should have “no worries on getting paid.”
Then, on or about October 26, 2022, Faatz terminated Ezeh’s employment effective
immediately, without notice or cause
Plaintiff s Original Petition & Jury Demand Page
At the time of termination, JRE owed compensation from GCP for the months of
August, September, and October
Additionally, JRE was owed compensation for the month of November , as GCP
arly terminated the contract without cause. Accordingly, JRE was entitled to a thirty
day notice period.
Ezeh’s 184 hours in August 2022 were approved.
Ezeh’s 176 hours in September 2022 were approved.
Plaintiff s Original Petition & Jury Demand Page
government
(i.e. compliance,
40 hours) during and marketing;
that work and trade secrets. However, Confidential
the Agreement, whichever occursweek.
first. Subject to the restrictions set forth below in Section
Information
13, Companydoesagreesnotthat
include any information
Consultant may engagewhich (i)business
in other was known to theprovided
activities public atsuch
the time
other
it wasbusiness activities
disclosed to do not negatively
Consultant; (ii) affect obtained
lawfully its Serviceand
level to Company,
actually known itsto
ability to
Consultant,
Compensation Consultant will be paid one hundred twenty dollars and no
perform its obligations and carry out its responsibilities to Company hereunder or cause it
beforeper
cents) it was
hour disclosed
by Company to for
Consultant,
all servicesfrom a source
performed under
to be in breach of any of its obligations under this Agreement.
other
thisthan the Company;
Agreement within 14 and (iii)
days after payment
becomes generallyis received
known or foravailable
those services
in thefrom Client (net
industry, 30 days).
trade, Company
or public, otherwillthan by a
notify Consultant
breach by Consultan
Independent Contractor conditions
or others required
StatusofThe by
any arties Client
legal duty for billing
owed to and
acknowledge travel
Preview
JRE Management, LLC sues Defendant GCP Clinical Trial Consultants, Inc. for breach of contract JRE Management, LLC GCP Clinical Trial Consultants, Inc. entered into an owner and operator of JRE, Regina Ezeh, performed consulting services for GCP failed to pay JRE for services rendered Furthermore, JRE terminated its contract with JRE and Ezeh JRE Management, LLC limited liability company registered in the state of GCP Clinical Trial Consultants, Inc. a Texas corporation with its principal place of business located at 9595 Six Pines Drive, Suite 8210, The Woodlands, TX 77380 Defendant may be served through its registered agent, United States Corporation Agents, , at 9900 Spectrum Drive , Texas Defendant may also be served through its Director and President Jeffrey A. Faatz located at 651 Chateau Woods Parkway Drive, Conroe, Texas 77385. DISCOVERY CONTROL PLAN Plaintiff files this suit as an expedited action under Texas Rule of Civil Procedure 169. Plaintiff intends that this suit be governed by discovery control level one. Plaintiff seeks only monetary relief of $250,000 or less, excluding interest, statutory or punitive damages and penalties, and attorney’s fees and costs JURISDICTION AND VENUE This Court has jurisdiction and venue over the parties to this action since the matter in controversy exceeds the sum or value of the minimum jurisdictional limits of the Court, exclusive of costs and interest. Venue is proper in Montgomery County, Texas, pursuant to Section 15.002(a) (b) of the Texas Civil Practice and Remedies Code because t county of the efendant s principal office Montgomery County. IV. FACTS JRE Management, LLC and Defendant GCP Clinical Trial Consultants, Inc. entered into a contract, the Consulting Agreement (the “Agreement”), on June 24, 2022. Executing the greement on behalf of JRE was its owner operator, Regina Ezeh. Executing the greement on behalf of GCP was its President and Director Jeffrey A. Prior to the signing of the Agreement, had approached Ezeh and informed her that GCP’s client, confidential , was looking for experienced Clinical Research Associates (CRAs). Plaintiff s Original Petition & Jury Demand Page Consultant shall return all Confidential Information, including any copies thereof, to Company or, upon request by the Company, shall certify in writing that the Confidential Information and all copies were destroyed. Consultant acknowledges that the Company has confidentiality and non disclosure agreements with Client. Consultant agrees to comply with the Company’s obligations Accordingly, under the the Agreementandprovided confidentiality non disclosure that Ezehagreements was engaged and to execute to provide all documentsexperienced, required for compliance by Client and/or Company. CONSULTING AGREEMENT qualified services for various clinical trials conducted by clients of GCP. This CONSULTING AGREEMENT the “Agreement”) is made and entered into as of the“Confidential day of July Information”theshall mean allDate”) “Effective of the materials, by and betweeninformation, GCP and strategies Clinical Trial that Specifically, the Company Consultants, Ezeh was assigned treats as confidential Inc. (“Company”) to perform services or proprietary a Texas Corporation, on GCP’s with including, account without a mailing address with limitation, of 9595 Six Pinesconfidential client names; Drive, Suiteclient 8210, lists; client files; The Woodlands, TXclient 77380information; and JRE Management, vendor names and lists; personnel LLC (“Consultant”), For Georgia the duration of Limited Liability information; her Company, operating employment, with a mailing and training always address manuals; of gave her 3404 Twinrose operation best methods efforts Place, andMilton, toGA GCP and its information; . The Company and Consultant are sometimes referred to individually as a “Party” and technical, financial, sales, and planning information; client products, strategies, research, collectively as the “Parties.” client, confidential government , and complied compliance, with JRE’s and marketing; and side tradeof secrets. the Agreement. However, Confidential Information Purpose.does not include Subject to the anytermsinformation and conditions whichhereof, (i) wastheknownCompanyto the hereby public atretains the time Whileitworking wasConsultant with disclosed GCP, to to Consultant; provide had (ii) no experienced, disciplinary lawfully qualified services history obtained and and actually various anticipated known clinical remaining with trialstoconducted Consultant, TimeSponsors before itand or Contract wasExpense disclosed to Research Reports Consultant,Organizations Consultant from (“Client”). shallasubmit source another thaninvoic itemized the Company; documenting andall(iii) GCP throughout billable becomes timeits contractual and generally travel known or relationship expenses to availablethe Company in with the onconfidential industry,or before trade, the or , day at the 5public, very ofother the month least. than for by a Scope the of Services preceding month’s Consultant work viawillemail assist the Company in providing services to Client to jeff.faatz@gcpclinicalconsultants.com in Billable breach time, by Consultan accordance expenses, with and orterms theall others of of receipts the areany to legal study duty into beprotocol, entered owed to the federal ICHReplicon, GCPs, Company. a timeregulations, & expenseand any software Pursuantprovided to the other Agreement relevant to the study plan atThe Consultant nowas guaranteed services charge. will If include40assisting Consultant hours fails perCompany to the submit week at with the requisiteanstudy hourly time, rate of Intellectual Property Rights Consultant acknowledges that all services provided5 by expenses, start up and invoice activities, preby the study close of visits, business site (i.e., initiation, 5:00 site PM U.S. management, Central Time) interim on monitoring,the $120/hour day ofcleanup, data Consultant theunder month, Company quality this reserves assurance, Agreement the right document are subject totothe review, not process team “Works late support made submissions and training, for until hire”site the out close provision next in 17 month’s cycle. visits, and other reasonably necessary tasks as determined by Company or Client. U.S.C. § 201(b) and that Consultant’s work product shall be the sole property of the services will be performed by Consultant to the reasonable satisfaction of Company and in Company. Guaranteed accordance Minimum Hours The with all applicable lawsCompany agrees to and the highest pay Consultant professional for a for standards minimum clinicalof 40trials. hoursConsultant per week will overreport the term of theA. to Jeffrey Agreement, and Consultant Faatz, the Company agrees to be available President. to the Company to provide services upon request. If the Company chooses not to use Covenant Consultant’s Not services to Compete. In exchange fora the forcommences any reasononduring promises givenDate work by the week, Company will the Company underpaythis Term. This Agreement, Agreement the Effective set forth above and willCompany continue Consultant the hourly rate set forth above in Section 4 for a guaranteed number of hoursby Consultant agrees that he or she will not compete with the until the end of the Company’s consulting agreement(s) with Client or upon termination of providing clinical (i.e. 40 hours) trial that during consulting work week. the Agreement, whichever occurs first. services to any Subject Client to the for whom restrictions Consultant set forth below inperformed Section 13, Company services agrees that Consultant on the Company’s behalf duringmay engage the termin of other thisbusiness Agreementactivities provided and for one (1)such year other business activities do not negatively affect its Service level to Company, its ability to after termination Compensation perform ofConsultant this and its obligations Agreement will out carry This be paid covenantonenothundred its responsibilities to compete to Company applies twenty toorand dollars hereunder allcause clinical no it trialtocents) consulting per services hour by provided Company forbyallConsultant services directly performed be in breach of any of its obligations under this Agreement. or underon behalf this of any Agreement other within person, 14 firm,days after payment partnership, is received for those services from Client (net 30 days). Company will or corporation. notify Consultant Independent Contractorconditions Status The required artiesbyacknowledge Client for billing travelthat and agree time, preparation Consultant and reporting duly organized work, and and other services formed termination performed company in the under this State of Georgia.Agreement. ConsultantIn addition is 30 to notdays’ the written The Agreement Warranty ofhad No aRestrictions no cause Consultant provision, represents but andthe required warrants at thattomust least Consultant providing Company’s an itemization employee, of his/her officer, agent,time and or partner expenses, and shall not Consultant represent provideoristhe the public not a any party toparty third any that Company restrictive with covenants an invoice. Consultant isPaymentortoagreements an employee,the Consultant that willwould officer, agent, not restrict be made or partner theorCompany. ofwithout otherwise an itemized limit This notice:Consultant’s invoice right Agreement shallonotability to perform be construed to the services create under this Agreement. an employment, agency, or joint venture relationship between the arties. Travel Expenses Consultant understands that occasional travel be required under this Termination. Taxes Agreement This The Company Agreement and that shall notmay Company be terminated withhold will not federal, without directly state, pay for causetaxes or local by either Consultant’s party ortravel make any thirty Social expenses. (30) days after the Security delivery (FICA) Consultant to the other will contributions be reimbursed forfor anyofallamount a reasonable writtenpaidnotice toand of termination. Consultant necessary under In travelthis addition, Agreement expenses by the Company Companymayshall Consultant immediately withinbe14solely terminate responsible days after payment this for Agreement the payment is received with cause of allexpenses for those byfrom federal, delivery state, of(net or local Client a taxes written 30 incurred for any compensation paid under this Agreement. Company will give ClientConsultant After notice paying Form ofEzeh days). termination. Company 1099 willCause for just MISC notify shall one month following the end exist Consultant oftheof of when all tax the beginning Company conditions services, year. determines, required inbyAugust infor itsthesolGCP and 2022, reimbursement of travel expenses under this Agreement. discretion, that Consultant has (i) breached a material term of this Agreement, (ii) engaged inbegan professional to as Benefits Except breach misconduct Consultant set forth above, detrimental itsunderstands contractual and agreestothat, Consultarelationship theas performance will not be with JRE for a duly organized reimbursed ofand and services any otherby under formed companyfailing expenses thisto make in the Agreement, State of Georgia Consultant is not eligible for and shall not receive any medical, incurred (iii) underdemonstrated this Agreement, an inability and Consultantto work with will othersatonhisbehalf provide, or herofsole thecost, Company,all accident, or workers’ compensation insurance or any benefits available to employees of the paymentCompany. for services rendered necessary equipment, supplies, and instruments. Page of Confidentiality Faatz claim the delayConsultant in GCP’s acknowledges payment toandJRE agrees wasthat dueallto files, records, lists,’s confidential books, failure to pay products, and other materials owned or used by the Company in connection with its consulting work, including,JRE butManagement, not limited to, Confidential Information as defined below GCP. shall remain the property of the Company and shall be kept confidential Consultant and used for the sole benefit of the Company and the Client. Consultant further agrees to not engage in the unauthorized use, disclosure, dissemination, duplication, copying, or transfe of the Confidential Information. Within ten (10) days after termination of this Agreement, Page of Plaintiff s Original Petition & Jury Demand JRE Management, Page Nonetheless, Faatz assured Ezeh that she would be paid once confidential fulfilled its contractual obligations to GCP. In reliance on this assurance, Ezeh continued to perform work for GCP. Then, in early October with GCP becoming increasingly in arrears with JRE, once again assured Ezeh that she would be paid. Faatz sent an email to employees, blind copy, stating that confidential owed him money and that he was not going to be able to pay employees per their contracts, but indicated that he was in the process of resolving the issue with the client. Despite th fact that it was GCP’s obligation to pay Ezeh regardless of whether confidential paid it Ezeh yet again gave Faatz the benefit of doubt and continued to work. As late as October 20, 2022, Faatz advised that he thought “the kinks [were] all worked out,” and told Ezeh she should have “no worries on getting paid.” Then, on or about October 26, 2022, Faatz terminated Ezeh’s employment effective immediately, without notice or cause Plaintiff s Original Petition & Jury Demand Page At the time of termination, JRE owed compensation from GCP for the months of August, September, and October Additionally, JRE was owed compensation for the month of November , as GCP arly terminated the contract without cause. Accordingly, JRE was entitled to a thirty day notice period. Ezeh’s 184 hours in August 2022 were approved. Ezeh’s 176 hours in September 2022 were approved. Plaintiff s Original Petition & Jury Demand Page government (i.e. compliance, 40 hours) during and marketing; that work and trade secrets. However, Confidential the Agreement, whichever occursweek. first. Subject to the restrictions set forth below in Section Information 13, Companydoesagreesnotthat include any information Consultant may engagewhich (i)business in other was known to theprovided activities public atsuch the time other it wasbusiness activities disclosed to do not negatively Consultant; (ii) affect obtained lawfully its Serviceand level to Company, actually known itsto ability to Consultant, Compensation Consultant will be paid one hundred twenty dollars and no perform its obligations and carry out its responsibilities to Company hereunder or cause it beforeper cents) it was hour disclosed by Company to for Consultant, all servicesfrom a source performed under to be in breach of any of its obligations under this Agreement. other thisthan the Company; Agreement within 14 and (iii) days after payment becomes generallyis received known or foravailable those services in thefrom Client (net industry, 30 days). trade, Company or public, otherwillthan by a notify Consultant breach by Consultan Independent Contractor conditions or others required StatusofThe by any arties Client legal duty for billing owed to and acknowledge travel