Legal Document: JOLIE SLATON, AN INDIVIDUAL VS SCOTT DAVALOS, AN INDIVIDUAL, ET AL.

On February 08, 2024 a Complaint; Filed by: Jolie Slaton, an individual (Plaintiff); As to: Scott Davalos, an individual (Defendant); Garurav Srivastava, an individual (Defendant); Veecon Biotech, LLC, a limited liability company (Defendant) was filed involving a dispute between Slaton Jolie, and Davalos Scott, Srivastava Garurav, Veecon Biotech Llc, for Contractual Fraud (General Jurisdiction) in the District Court of Los Angeles County.

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I Jeffre C. Bogert (SBN 132778)
LAW OFFICES OF JEFFREY C. BOGERT
827 Moraga Drive
Los Angeles, CA 90049
Telephone: (424) 293-272
bogertlaw@orttlookcom

Attorney for: PLAINTIFF, JOLIE SLATON
5

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY oF LOS ANGELES CENTRAL DISTRICT

JOLIE SLATON, an individual.
10
PLAINTIFF, CASE NO.

COMPLAINT FOR DAMAGES
12
I, Breach of Contract
2, Intentional Misrepresentation
SCOTT DAVALOS, an individual, GAURAV 3. Negligent Misrepresentation
SRIVASTAVA, an individual, and VEECON 4. Promise Without Intent to Perform
14 BIOTECH, LLC, a limited liability company, 5. Fraud
and DOES 1-20, inclusive.
15 DEMAND FOR JURY TRIAL
DEFENDANTS.
16

I
COMPLAINT FOR DAMAGES
NATURE OF THE CASE

2 This is an action for damages based upon fraudulent activities perpetrated by Scott

Davalos, an individual ("Davalos"), Gaurav Srivastava, an individual ("Srivastava"), and Veecon

4 Biotech, LLC, a limited liability company ("Veecon"). Davalos, Srivastava, Veecon and DOES

1-20, inclusive, are hereinafter collectively referred to as "Defendants".

Defendants entered into sales contracts with Jolie Slaton, an individual ("Plaintiff', and

others, and then failed to perform, never intended to perform, and/or ultimately made significant
7
misrepresentations to Plaintiff, which Plaintiff relied upon in entering said contracts with
8
Defendants. Further, in reliance upon Defendants'isrepresentations, Plaintiff expended
9
considerable effort and financial resources, and secured contracts on behalf of Defendants.
10
Plaintiff brings this complaint against Defendants for all damages and remedies available
ll
because of Defendants'raudulent conduct, including but not limited to damages related to
12
wasted efforts, significant expenses and "sweat equity" promised in reliance upon
Defendants'epresentations
and fraudulent conduct.

15 JIJRISLICTION AND VENIJF,

16 1. This Court has jurisdiction over this action pursuant to the California

Constitution, Article VI, Section 10, which grants the Superior Court "original jurisdiction in all

causes except those given by statute to other courts." The statutes under which this action is

brought do not specify any other basis for jurisdiction.

2. This Court has jurisdiction over all defendants because, upon information and
20
belief, each party is either a citizen of California, has sufficient minimum contacts in California,
21

2
COMPLAINT FOR DAMAGES
1 or otherwise intentionally avails itself of the California market to render this Court's jurisdiction

2 over it consistent with traditional notions of fair play and substantial justice.

3 3. Venue as to each Defendant is proper in this judicial district pursuant to California

Code of Civil Procedure sections 395(a1 and 395.5 because the acts herein complained of

occurred in the County of Los Angeles.

4. Venue as to Defendants is also proper in this judicial district pursuant to thc Sales

Representative Agreement, further described below, which provided for all courts in the County
7
of Los Angeles as the exclusive jurisdiction.
8

9
THE PARTIES
10
5. Plaintiff, Jolie Slaton is an individual, and always herein mentioned as "Plaintiff',
ll
who was over eighteen years old and a resident of the County of Los Angeles in the State of
12
California, Plaintiff through her entity, Medical Partners Innovations International, at all relative

times herein, intcracted and transacted with all defendants both in the United States and

14 internationally.

15 6. Plaintiff is informed and believes, and thereupon alleges that Scott Davalos is an

16 individual over the age of eighteen who resides within the State of California. Plaintiff is

informed and believes, and thereupon alleges that Davalos is, and was, the Vice President of

Marketing & Sales at Defendant, Veecon.

7. Plaintiff is informed and believes, and thereupon alleges that Gaurav Srivastava
19
is,, an individual over the age of eighteen who resides within the State of California. Plaintiff is
20
informed and believes, and thereupon alleges that Srivastava was the Chairman of Defendant,
21
Veecon.
22

3
COMPLAINT FOR DAMAGES
1 8. Plaintiff is informed and believes, and thereupon allegcs that Defendant Veecon

2 is, and was, a limited liability company registered in the State of Delaware and qualified to do

3 business in the State of California.

9. The true names and capacities, whether individual, corporate, associate, or

otherwise, of Defendants named herein as DOES 1-20 are unknown to Plaintiff at this time, and

therefore, said Defendants are sued by such fictitious names. Plaintiff will seek leave to amend
6
this Complaint to insert the true names and capacities of said Defendants when the same
7
becomes known to Plaintiff. Plaintiff is informed and believes, and based thereupon alleges, that
8
each of the fictitiously named Defendants are responsible for the fraudulent and wrongful acts
9
alleged herein and is therefore liable to Plaintiff as alleged hereinafter.
10
10. Plaintiff is informed and believes, and based thereupon allcges, that at all times
11
relevant hereto, Defendants, and each of them, were the agents, employees, managing agents,
12
supervisors, co-conspirators, parent corporation, joint employers, alter egos, successors, and/or

joint ventures of the other Defendants, DOES 1-20, and each of them, and in doing the things
14 alleged herein, were acting at least in part within the course and scope of said agency,

15 employment, conspiracy, joint employer, alter ego status, successor status and/or joint venture

16 and with the permission and consent of each of the other Defendants.

17 11. Plaintiff is informed and believes, and based thereupon allegcs, that Defendants,

and each of them, including those defendants named as DOES 1-20 acted in concert with one

another to commit the wrongful acts alleged herein and aided, abetted, incited, compelled and/or
9
coerced one another in the wrongful acts alleged herein, and/or attempted to do so.
20
12. Plaintiff is further informed and believes, and based thereupon alleges, that
21
Defendants, and each of them, including those defendants named as DOES 1-20, and each of
22

4
COMPLAINT FOR DAMAGES
1 them, fonued and executed a conspiracy or common plan pursuant to which they would commit

2 the unlawful acts alleged herein, with all such acts alleged herein done as part of and pursuant to

said conspiracy, intended to cause and actually causing Plaintiff bann.

13. Whenever and wherever reference is made in this Complaint to any act or failure

to act by a Defendant or co-Defendant, such allegations and references shall also be deemed to

mean the acts and/or failures to act by each Defendant acting individually, jointly, and severally.
6
14. Plaintiff is informed and believes, and based thereon alleges, that there exists such
7
a unity of interest and ownership between Defendants, each of them, and DOES 1-20, that the
8
individuality and separateness of Defendants have ceased to exist, and that despite the formality
9
and formation of a purported corporate existence, Defendants, including DOES 1-20, are in
10
reality, one and the same, and any corporate existence and the protections such existence provide
11
should be disregarded in equity and for the ends of justice, because such disregards is necessary
12
to avoid fraud and injustice to Plaintiff herein.

14 GENERAL ALLEGATIONS
15 15. Paragraphs 1-14 are incorporated herein as if set forth herein in full.

16 16. Defendants Davalos and Srivastava, on behalf of Defendant Veecon, engaged in

discussions with Plaintiff to become an exclusive sales representative for Defendant, Veecon,

medical testing device products in El Salvador, Guatemala, and Mexico.

19
17. Defendants proposed that Plaintiff sell Veecon's Salivary Nanoscale Diagnostics

technology (" Salivary Diagnostics Technology" or "Technology" ), which was being advertised
20
as a breakthrough in cancer detection and screening.
2]

5
COMPLAINT FOR DAMAGES
I 18. Attached hereto as Exhibit A is a true and correct copy of Dcfcndant, Veecon*s

2 brochure that was provided to Plaintiff and is incorporated herein.

3 19. In discussions with Plaintiff, Defendants represented that the Salivary Diagnostics

Technology was ready for both manufacture and distribution and that Veecon had all the

necessary approvals and licenses to market and sell its product in the United States and

internationally.
6
20. Further, Defendants reprcscnted to Plaintiff that Dr. David Wong ("Dr. Wong") at
7
the University of California, Los Angeles, had developed the Salivary Diagnostics Technology
8
and that Dr. Wong worked at, or in a developmental capacity, with Defendant Veecon.
9
21. Based upon these representations, Plaintiff entered a "Sales Representative
10
Agreement" with Defendants for the exclusive right to act as the sales representative of Veecon's
11
products in Mexico, Guatemala, EI Salvador, and Costa Rica.

22. Attached hereto as Exhibit B is a true and correct copy of a Veecon Biotech LLC

Sales Representative Agreement and incorporated by reference herein.

14 23. Per the Sales Representative Agreement, Defendants agreed to pay Plaintiff

15 commissions for each unit of Veecon's products sold.

16 24. In exchange for the commission and exclusive right to sell Defendants'roducts,

17 Plaintiff agreed to actively promote the sales of the Salivary Diagnostics Technology on behalf

of Defendants in numerous regions on an exclusive basis to include Mexico and Central America

but not to be limited thereto.

25. In furtherance and in reliance on Defendants'epresentations and the agreement,
20
Plaintiff actively promoted the Salivary Diagnostics Technology in Mexico and Guatemala, El
21
Salvador and Costa Rica handling all inquiries for Defendants in those locations.
22

6
COMPLAJNT FOR DAMAGES
1 26. Plaintiff spent considerable time and resources developing a business plan,

2 developing relationships with doctors, professional associations, and government officials and

secured numerous letters of intent for the purchase of Defendants'alivary Diagnostics

Techno logy.

27. Plaintiff eventually learned that Dr. Wong did not have a partnership nor

relationship with Defendants and that Defendants did not have the proper license to sell and
6
distribute the Salivary Diagnostics Technology.
7

8
FIRST CAUSE OF ACTION
9
(Breach of Contract — Plaintiff against all Defendants)
10
28. Plaintiff realleges and incorporates herein by reference all allegations contained in
ll
Paragraphs 1 through 27, inclusive, as though fully set forth herein.
12
29. Pursuant to THE SALES REPRESENTATIVE AGREEMENT, Defendants

contracted with Plaintiff to be the exclusive sales representative of Salivary Diagnostics

14 Technology in Mexico and Central America.

15 30. Defendants agreed to pay Plaintiff a percentage for each unit of thc Salivary

16 Diagnostics Technology sold.

17 31. Defendants breached the Sales Representative Agreement by not having the

proper and necessary licenses to sell and distribute thc Salivary Diagnostics Technology.

19
32. Plaintiff performed all its obligations to Defendants pursuant to the Sales

Representative Agreement except for those obligations which Plaintiff is prevented or excused
20
from performing because of Defendants'reach.
21

7
COMPLAINT FOR DAMAGES
1 33. As a proximate and direct rcsull of Defendants'rcach of ihe Sales

2 Representative Agreement, Plaintiff has sustained damages according to proof and continues to

3 sustain damages because of Defendants'reach.

SECOND CAUSE OF ACTION

(Intentional Misrepresentation — Plaintiff against all Defendants)

34. Plaintiff reallcgcs and incorporates herein by reference all allegations contained in
7
Paragraphs I through 33, inclusive, as though fully set forth herein.
8
35. Defendants made representations of material fact, that (i) Dr. Wong was the
9
developer of the Salivary Diagnostics Technology, (ii) Dr. Wong was in partnership with
10
Defendants on the Technology, and (iii) Defendants had all the necessary licenses to sell the
11
Technology. Defendants further represented in the Sales Representative Agreeinent that it
12
"engaged in the business of development, manufacture, distribution and sales*'f the

Technology. None of these representations were true.

14 36. Defendants made the representations knowing that they were false. Defendants

15 further made the representations with the intent to defraud Plaintiff and induce Plaintiff into

16 entering into the Sales Representative Agreement with Defendants.

17 37. In justifiable reliance on Defendants'epresentations, Plaintiff spent considerable

resources to develop business plans, engage, foster, and develop regional relationships, and

secure letters of intent for purchase orders, to sell the Technology. Plaintiff reasonably believed

Defendants'epresentations were true and acted in justifiable reliance upon
Defendants'epresentations.
21

8
COMPLAINT FOR DAMAGES
1 38. As a direct and proximate result of Defendants'raudulent conduct, Plaintiff has

2 been damaged according to proof, and continues to sustain damages according to proof.

3 39. Defendants acted willfully, wantonly, and maliciously in making its false

4 representations such that Defendants are subject to punitive damages.

THIRD CAIJSE OF ACTION

(Negligent Misrepresentation — Plaintiff against all Defendants)
7
40. Plaintiff reallegcs and incorporates herein by reference all allegations contained in
8
Paragraphs I through 39, inclusive, as though fully set forth herein.
9
41. Defendants made representations of material fact, that (i) Dr. Wong was the
10
developer of the Salivary Diagnostics Technology, (ii) Dr. Wong was in partnership with
11
Defendants on the Technology, and (iii) Defendants had all the necessary licenses to sell the
12
Technology. Defendants further represented in the Sales Representative Agreement that it

"engaged in the business of development, manufacture, distribution and sales" of the

14 Technology. None of these representations were true.

15 42. Defendants should have known that such representations were false, and

16 Defendants had no reasonable grounds to believe that such representations were true.

Defendants were therefore negligent in making the representations to Plaintiff.

18 43. Defendants made the representations with the intent to induce Plaintiff to enter

into the Sales Representative Agreement. In j ustifi able reliance on Defendants'epresentations,
9

Plaintiff spent considerable resources to develop business plans, engage, foster, and develop
20
regional relationships, and secure letters of intent for purchase orders, to sell the Technology.
21

9
COMPLAINT FOR DAMAGES
I Plaintiff reasonably believed Defendants'epresentations were true and acted in justifiable

2 reliance upon Defendants* representations.

3 44. As a direct and proximate result of Defendants'raudulent conduct, Plaintiff has

4 been damaged according to proof, and continues to sustain damages according to proof.

45. Defendants acted willfully, wantonly, and maliciously in making its false

representations such that Defendants are subject to punitive damages.
6

7
FOURTH CAUSE OF ACTION
8
(Promise Without Intent to Perform — Plaintiff against all Defendants)
9
46. Plaintiff realleges and incorporates herein by reference all allegations contained in
10
Paragraphs 1 through 45, inclusive, as though fully sct forth herein.
11
47. Defendants promised to pay Plaintiff a commission percentage for Plaintiff's
12
services in developing and executing sales of Defendants'alivary Diagnostics Technology.
13 48. Defendants made these promises without ever intending to perform them since

14 Defendants did not, at the time of making the promises, have the requisite licenses necessary to

15 engage in the sale of the Technology.

16 49. In reliance upon Defendants promises, Plaintiff was induced into entering into the

17 Sales Representative Agreement and performed services pursuant to that agreement. Plaintiff

spent considerable resources to develop business plans, engage, foster, and develop regional

relationships, and secure letters of intent for purchase orders, to sell the Technology, under the

reasonable belief that Defendants were able to sell and supply the Technology.
20

10
COMPLAINT FOR DAMAGES
I 50. Plaintiff was unaware that Defendants did not intend to perform as promised and

2 Plaintiff acted in justifiable reliance that Defendants would be able to sell the product it was

Plaintif
3 purporting to be selling.

51. As a direct and proximate result of Defendants'raudulent conduct,

been damaged according to proof, and continues to sustain damages according to proof.

52. Defendants acted willfully, wantonly, and maliciously in making its false
ha

representations such that Defendants are subject to punitive damages.
7

FIFTH CAUSE OF ACTION

(FRAUD — Plaintiff against all Defendants)
10
53. Plaintiff realleges and incorporates herein by reference all allegations contained in
11
Paragraphs I through 52, inclusive, as though fully set forth herein.
12
54. Plaintiff's fraud allegations are based on information related to the
defendants'ction
in 2016, 2017, 2018 and thereafter. However, any concern or consternation related to

14 Plaintiff's belief, pro or con on Defendants'ction, became crystal clear in October 2023.

15 55. At that time, Plaintiff learned for the first time that defendants were not confused

16 or mistaken on possession or application for licenses, FDA approval, or the right to market

Veecon devices. I

18 56. In October, Gaurav Srivastava was the subject of a published expose entitled, The

Old 7'm a Secret Spy, Pay Me 'on. (see Exhibit C attached).

57. Plaintiff, having read the article and seeing the elaborate web of lies defendants
20
could spin and/or had spun over a decade, PIaintiff knew for a fact that Defendants made the
21
underlying representations knowing that they were false.
22

11
COMPLAINT FOR DAMAGES
1 S8. Defendants further made the representations with the intent to defraud Plaintiff

2 and to induce Plaintiff into entering the Sales Representative agreement.

3 59. In justifiable reliance on Defendants'epresentations, Plaintiff spent considerable

time, effort, and monies.

60. As a direct and proximate result of Defendants'raudulent conduct and their

propensity for deceit; Plaintiff has been damaged according to proof and continues to sustain
6
damages according to proof.
7
61. Defendants acted willfully, wantonly, and maliciously in making their false
8
representations such that Defendants are subject to punitive damages.
9
62. As noted above, Plaintiff spent considerable resources to develop business plans,
10
engage, foster, and develop regional relationships, and secure letters of intent for purchase
11
orders, to sell the Technology. Plaintiff reasonably believed Defendants'epresentations were
12
true and acted in justifiable reliance upon Defendants'epresentations.
13
63. In October 2023, Plaintiff knew for the first-time defendants could say or do

14 anything to their own financial benefit and did to Plaintiff's detriment.

16 PRAYER FOR RF I,IEF

17 WHEREFORE, Plaintiff prays for judgment against all Defendants as follows:

18 1. For general damages according to proof.

2. For special damages according to proof.
19
3. For all punitive damages allowable by law and in an amount sufficient to punish
20
Defendants for thc wrongful conduct alleged herein and to deter such conduct in
21
the future.
22

12
COMPLAINT FOR DAMAGES
4. For all interest as allowed by law.

5. For costs of suit, attorney fees, and any expert witness fees pursuant to law.

6. For post-judgment interest; and

7. For all other relief the Court may deem just and proper

DATED: February 7, 2024

Respectfully Submitted,

LAW OFFICES OF JEFFREY C. BOGERT

Jef
nu
y,/t rkrt,/ Esq,
o
Att y laintiff, Jolie Slaton
12

13
COMPLAINT FOR DAMAGES
JIJRV DEMAND

Plaintiff hereby demands a jury trial on all issues so triable in this action.

DATED: February 7, 2024
7
Respectfully Submitted,

LAW OFFICES OF JEFFREY C. BOGERT

10
By:
Jeffrey g. gKgert, Esq.
AttorhEy for Plaintiff, Jolie Slaton
12

I4
COMPLAINT FOR DAMAGES
VEECON USA Brochure
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~
agf~
~tat rcfnatntng tu ihc iiniv i th
ttbaB bc prvpcftv fctuincit
&

Cofnpafty.
ii'ofnpan)
1 ran~tattoo if ~)," wdl hc an c~pn v i~t iii.

tfi Conduct suctt (Ration.J advcrlls~ ~ profnoluiit caitlpulgil
as fna)'c lippfoprlalc and forward iri Rcpre~cnlai o, v,ifti,
inquincs conccrtung its product whether of n i in,lii ri;.
produced h) such advcftfstng and promotion c~ntfi.ngn~ ~i
ntay bc 4ppfopritttc arid l'orward to Represent~tive
iniptific'roduced
bv such advcntsing. including prompt notit to~tain
of all cut turner contracts and vtsfu .
ct Notify ~'~~vc of@it ~ftcs p~tdc Rcpfciictttatti c
copic& «f qtitttauons and ifivoicc'w Nottfy Representative
piomptl) ol all chanttc.» of prices, avaitahtttt). and
i pcetlir~t tiitis for produ ct ~ivirs~~t h~wirunttcf
I

cttei.tixctw scIlPoets
C~n)f
fluilfifain ufi Itf)ettuafe
& ~~
u&side RctitcscARIYC I;uftcut tcctIAILal &~II@ aui! If donut! lu
in fiittdhnftifff~ 6 .Iuit Iu
@pplicatfun «nitiueef fua 1.1l I
~

Ill Nifpp41rl +ucii 'h.dc%

2 I ufiip Iffi «tiall pay Iu R~tatIVC M Its confpcrisatfuft luf

~Cv~f)
I

if»efx hei .I cufnfntsston» & deserted IA Addend~ 't. On
istical

ill i el I ii '.I ivfe~ in Mtd tcrrttti+ durintt Ihe Iefiu
ii«e I Ihruutth R~rcscntauve of direct)y
ti, iei fit Lei «Ale» diatl fncaA the gttsss Mtcs pf lee uf
2

111efeii,illitu i shilil dnd debts~ b)1 Cotnpank tl.'ks.
ui 'fihaud» 'etui ned. wlcs Lus Included in sttch sa4 & price.
ultiiised c luiifis i I( cit~tufncrs. W fng charges ~
1111:AirlfuAitiini I~&ucit Iu I;ustvfncrs. CortlpaA)'hail pay
Ctedtl

~ uuiu»in)f1 tfi Rcprcscntatfse hy thc 2t)
~ Itrcach tnonth. ofi
pffui Ifiiintti & III~QICM. All Into~ in coAACCIAIA Is'Itti Itic
Wfe iif pfuduCI» there ~r re~cd
Shall bC b)f t&~y
12ffecfly t~i ihc customer. O'ritn~y shall. On a nlifntht) basis,
turwarit to Representative a ~inary report ol all such
ins'incest t c&IIIpany shatl nfuIAr R&~native uf atl
si!rfi&piilutencc sent to thc cost~et.
&I ('wnpan) has tht right at an) tense.at its sole discretion,
Io establish, change. SRer„or atseod tertns oslo ctindltloss
of salt~. prices, delver)f and packing charges. t'vnV~ft)
~hat t hase ihc right tu approve ot kwppruee a iihin re~mfi
Itic .'re.lu 1.1 any eusttimcr and chait hase Ihe right to rt jrct
ssithiin reason any order obtained by Retsrescfttattsck
without liahilil) Iv Repr~ntauve'of eviriinut~ms. @Iid shatt
hast Ihe right 4~ accept the ieturn ur Iv riiwt'e wfie uttfiu'afieiw
or lfi giee tuiy Credit tfi CASt~ri, for Proftucts shfpPcd .i. ii
ll dce01 uppfupflaic.

~I Rcpri:scnultfvc sha/2 Ant bc au041rI/cit Piift whstt riuf represenf
iiu«an)'uottaets.
Or Io quote ~,
Ilset I wc being kutbof &cd 41 sfiy unie iu ewer
~tat oe to sftpt affy docuwcfii'i.
or to iiicur any ex~sc, tthft~ton or ~ibifity
what INV&~. Cx~mi~fM onbehalfoff om~y. ft
i.. Iindcrstoiid snd agreed thtu R~tsttve
is sn
Initial contractor atuf ts not sn employee ol thc
w om~y
7) This s~n~t shaft colnntcINC on thc dsy snd year first sct
forOI shove snd Mlf ctuuinuc In t'ull fiucc snit effect tiir f 6
y~ until cue+ted hy either
~cled Q'ither R~~tstIvc or t. Onlpiany
~y.
This sttrccntcnt Insv lN
by Inc@Its of

~
written notice scAt by registered Insil 41 lhc sddrcss sct forth
~Ing
~~t. Ihc signature of this sgrccA'IcnlL TcrAIIAsuon of this
t'or sny by cithct pity sh'nfl Aol oiif the %

fixity of Comfisny lo psy eo~mion on orders snd ciintrscts
~M by C~y
~~ prior lo cA&tive date of such
~ thc

~.the~~~tive ~ for pu~ of this psrs~h shsll
of sh~cnts src made or Invoices
bc
decnieif sM M ~MAA pcrtod f4Ls csptfcti sAd Aclt
M tfstc ~re of tctuunstion w& given or rcccIv&. addition, fA
su hoiss Ifidh or~ snd contracts thst hsvc bccA placed
IrQ~lssioo to (. ~ybceqf~ly ~ IA
pnor to thc t~insuon date 3$ sforcsRId,

m
hf,
~ ~~
~ t~~n
Ats
if've
ch hssc

l
f

fn
IIOI
fIc
by ('ornpsny
yci
subicct
~ tkc~~n finally approved hy
psymcms when snd
slupped tc the custotner. Oeposft in the
W s customer or hy Wp~tsttve shall he deemed
sny to Company.
constitute Ihc enure undcrstsndinft of thc
sftsVl
. Io tfN s~inmICIII of Rcprcscntsttvc

f~ ~~
~nwevc
m'Ac delusive Mes
~~~~ ot Company In thc

~
.; in A to thts sgreemcnt. and it is

.
~ ~
~~ ~S Scents,
SfftCM~t
fs no eral understst~g or agreement

cnurcly My
set fotth herein, This

vrhcther orsf or vrrftteti, he~fore entered into hcnvccn
ittcd,
cxccpt tn ~~ 5~ + gt„,'"$
)

l ~e R"p~~tvc ~4tt4tt 5@cw:
~
tg@Jf'tl4"teitt
tn

it» Mi ht tn( fn~~
i)ttt(~Q
"' "'i'~""% ~~
i'lttch
4v~ct
tftterv"ib. thc
cause
tt hait ~
4&h~iiiti'tv
CiwiNitialfaf

urtttut~ ~~c ofwNW~y
harm to thc Disclosing Party,
'1

b) Thc fteccivtnft Party will nor acquirc any rights in
te&pert of the Conftdcntial lnforntation of titc
f»~ lus tng Party save: as stated in this A~cement.
c I 4 II Can fidcnual information shN rcrnarn tbc property
of thc Dtsclosing Party and cxccpt as nyrnsty f
~

prov tdcd in thLs Agrccntcnt, thn DiSC44illj Party gtattt~
no I tecnsc m respect of any Confidcntta) fnforrnatton
t I t l) tsclovurc of Confidential Infoanation a) Thc Rccciv tng Party'
t Shall not usc any Confidcnual lnfortnation to thc dctrnttent of
Dlscloslllg Partv of for any purpose UI'hstsocvcr other SLIT
thc purpo~ connected referred to in clause A tpcrntutcd
Ptt tom ).
t t) KVtll keep all Confidential information.t'trtctly v~ftdtmrjal
and will not dtttc lose Conftdcntta) fnforrnartcst uf'tc
Disclosing Party to any third party vv tthnnt thc unttcn
nascent of'hc Disc4sing Party; sav~ in cctttrdsncc wttft the
hftrcctncnt; and
i») iVill not copy or usniattny manner (or atnhcxo.c or peanut dtc
ctIPying IN Usc oA 4fty ( oAMcnt I@I lnfofrftat Ion tiff
afIY PurPIise
other than for the Pcrtmtt&wl P

Case Info

Judge

Kristin S. Escalante Track Judge’s New Case

Case No.

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Document Filed Date

February 08, 2024

Case Filing Date

February 08, 2024

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Document for JOLIE SLATON, AN INDIVIDUAL VS SCOTT DAVALOS, AN INDIVIDUAL, ET AL.

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