COMPLAINT

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                          Filing # 125986147 E-Filed 05/01/2021 02:41:49 PM

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,
IN AND FOR PALM BEACH COUNTY, FLORIDA

PATIENT DEPOT, LLC, a Florida limited CASE NO. 502020CA012726XXXXMB
liability company;

Plaintiffs,

Vv.

ACADIA ENTERPRISES, INC., a Florida
corporation, RYAN O’CONNOR, and
LORI ANN O’CONNOR,

Defendants.
/

SECOND AMENDED COMPLAINT

  

Plaintiff, PATIENT DEPOT, LLC (“Plaintiff or "Patient Depot"), by and through
undersigned counsel, hereby files its Amended Complaint against Defendants, ACADIA
ENTERPRISES, INC. (“Acadia”), RYAN O’CONNOR, and LORT ANN 0’CONNOR
(collectively the “Defendants”), and in support thereof, states as follows:

INTRODUCTION

This is an action brought by Patient Depot against Defendants for breach of Sales
Representative Agreements. Specifically, Plaintiff seeks to (a) enjoin Defendants from
improperly using or disclosing any of Patient Depot’s confidential information; (b) enjoin
Defendants from improperly using or…