Filed: 1/31/2017 1:30:46 PM

48C01-1701-CC-000185 Darlene Likens

Madison Circuit Court 1 Clerk
Madison County, Indiana

STATE OF INDIANA ) IN THE MADISON CIRCUIT COURT 1

)
SS:
COUNTY OF MADISON ) CAUSE NO. 48C01-1701-CC-

CONTINENTAL DESIGN CO., INC. )

)
Plaintiff, )
)
vs. )
)
PAUL WYSONG, )
)
Defendant. )

VERIFIED COMPLAINT FOR DAMAGES, TURNOVER OF PROPERTY,

AND REQEUST FOR INJUNCTIVE RELIEF

Plaintiff Continental Design Co., Inc. ("Continental"), by counsel, states the following as

its COMPLAINT FOR DAMAGES, TURNOVER OF PROPERTY, AND REQUEST FOR INJUNCTIVE RELIEF

against Defendant Paul Wysong ("Defendant"):

PARTIES, JURISDICTION AND VENUE

1. Continental is an Indiana corporation with its principal office located at 1524

Jackson Street, Anderson, IN 46016.

2. Defendant is an adult Ohio resident who, upon information and belief, resides at

211 East Cross Street, Palestine, OH 45352.

3. Jurisdiction over the parties is proper pursuant to Rule 4(A) of the Indiana Rules

of Trial Procedure'; venue is proper in this Court pursuant to Rule 75(A) of the Indiana Rules of

Trial Procedure.

See Lee v. Goshen Rubber Co., 635 N.E.2d 214 (Ind. Ct. App. 1994) (holding that the employee was subject to the
court's jurisdiction as "the employee visited Indiana several times for training, maintained contact by phone and
mail with the employer, and submitted expense vouchers and other claims to the employer's headquarters in
Indiana").
 FACTUAL BACKGROUND

4. On June 26, 2013, Continental and Defendant executed an Employee Agreement

whereas Defendant became an employee of Continental. A true and accurate copy of the

Employee Agreement is attached hereto as Exhibit A and incorporated herein by reference.

5. Defendant was the President of Continental's Quality Division, which is one of

Continental's major business units. Defendant was hired to expand the Quality Division by

finding and developing businesses and then managing those businesses.

6. As part of his employment, Defendant agreed under the Continental Design &

Engineering Contractors Intellectual Property Right Agreement (the "Property Right

Agreement") to devote his full and undivided time to the transaction of Continental's business; to

submit to Continental prompt, complete and accurate reports of his work and expenses; and to

promptly remit to Continental all monies collected by him on Continental's behalf. A true and

accurate copy of the Property Right Agreement is attached hereto as Exhibit B and incorporated

herein by reference.

7. In addition, Defendant executed an Affidavit and Oath of Confidentiality (the

"Confidentiality Agreement") whereas he agreed to keep confidential any and all information

concerning Continental. A true and accurate copy of the Confidentiality Agreement is attached

hereto as Exhibit C and incorporated herein by reference.

8. During the course of his employment, Continental had numerous issues with

Defendant.

9. Defendant consistently provided inadequate and/or incomplete paperwork causing

major delays in payments from customers.

2
 10. Defendant failed to obtain proper paperwork and process orders for jobs causing

Defendant to receive an advance on commissions on account receivables that Continental were

unable to collect.

11. As a result of the issues detailed in paragraphs 8 and 9 supra, Continental received

an abundance of disputed customer invoices resulting in thousands of dollars in write-offs.

12. Defendant deliberately disregarded Continental's hiring procedures and directed

recruiters under his supervision to disregard these same procedures resulting in complications

with new Continental employees.

13. Defendant continuously quarreled with and demeaned Continental's accounting

manager and accounting team, which caused Continental numerous problems.

14. After Continental terminated a former employee, Defendant informed a third-

party individual why the former employee was terminated, which Defendant admitted to

Continental's CEO Judy Nagengast ("Ms. Nagengast"), resulting in upsets and disrepute.

15. Due to the issues directly caused by Defendant's negligence, Defendant's overall

work performance and interactions with other Continental employees, Continental terminated

Defendant's employment on December 29, 2016.

16. Following his termination, Defendant was instructed by Continental to return all

Continental property and work product to the Continental Ohio office.

17. A representative of Continental then visited the Ohio office and discovered that

Defendant, without Continental's consent, had not returned all of Continental's property as

instructed and had either kept some of Continental's property or destroyed it by shredding and/or

deleting the Continental work product from his work computer. A true and accurate photograph

of the shredded documents is attached hereto as Exhibit D and incorporated herein by reference.

3
 18. The property that was kept and/or shredded by Defendant without the consent of

Continental is stated as follows:

a. Passwords to computers, iPad, and any third-party software log-in and

password information;

b. key and ID for Microsoft Office Software on computers left at the Ohio

office;

c. a list of all customer activity by Defendant and Jerome Scott since October 1,

2016 (this would include what customers or prospects they visited, contacted,

quoted or obtained work from);

d. a list of all the prospects he was working on including names, company and

contact information.

e. all resumes obtained from recruiting efforts done while employed by

Continental;

f. Continental's login for its Delta Sky Bonus account in which Defendant

changed the login to his personal email; and

g. all computer backups of Continental's files and data considered work

documents (a., b., c., d., e., f. collectively referred to as the "Property").

19. Additionally, following his termination, Defendant left a post on Continental's

Facebook page stating, among other things, that employment with Continental is "a slow

religious coercion plan to get you to practice and possibly convert over to their scientology

beliefs." A true and accurate screenshot of the Facebook post is attached hereto as Exhibit E and

incorporated herein by reference.

4
 20. Furthermore, Defendant and another individual, wearing masks, picketed outside

of Continental's principal place of business, which the Defendant has admitted, with signs

stating: "Smile! You're entering a Scientology zone"; and "Say NO to their 'IQ' (aka

Scientology) test." A true and accurate photograph of the picketers' signs are attached hereto as

Exhibit F and Exhibit G and incorporated herein by reference.

21. Prior to Defendant's termination, Continental has never had any issues with

picketers at its principal place of business during its existence.

22. The statements contained in Defendant's Facebook post and the statements

published on the signs are patently false and are damaging to the good reputation of Continental.

Count 1
BREACH OF CONTRACT

23. Continental incorporates the preceding paragraphs as if fully set forth herein.

24. The Employee Agreement is a valid and enforceable contract between Continental

and Defendant.

25. Defendant has breached the Employee Agreement by not making to Continental

prompt, complete and accurate reports of his work and expenses beginning October 1, 2016.

26. As a direct and proximate result of the Defendant's breach of the Employee

Agreement, Continental has been damaged.

27. Continental has performed all of its obligations under the Employee Agreement,

and Defendant's breach of the Employee Agreement has not been waived or excused by

Continental. Therefore, Continental has the right to recover damages from Defendant.

28. Because Continental's damages are ascertainable in accordance with fixed rules

of evidence and known standards of value, and there has been an unreasonable delay in payment

of ascertainable amounts, Continental is entitled to an award of prejudgment interest.

5
 WHEREFORE, Plaintiff Continental Design Co., Inc., requests that the Court enter

judgment in its favor and against Defendant Paul Wysong, in an amount Continental will prove,

plus pre-judgment interest, costs, and all other just and proper relief.

Count 2
BREACH OF CONFIDENTIALITY AGREEMENT

29. Continental incorporates the preceding paragraphs as if fully set forth herein.

30. The Confidentiality Agreement is a valid and enforceable contract between

Continental and Defendant.

31. Defendant breached the Confidentiality Agreement by informing a third-party as

to why Continental fired a former employee.

32. As a direct and proximate result of the Defendant's breach of the Confidentiality

Agreement, Continental has been damaged.

WHEREFORE, Plaintiff Continental Design Co., Inc., requests that the Court enter

judgment in its favor and against Defendant Paul Wysong, in an amount Continental will prove,

plus pre-judgment interest, costs, and all other just and proper relief.

Count 3
LIBEL

33. Continental incorporates the preceding paragraphs as if fully set forth herein.

34. The statements made by Defendant were false and damaging to the good

reputation of Continental.

35. Defendant published these unprivileged false and defamatory statements on

Facebook and on signs in order for third-party individuals to see the statements.

36. Defendant failed to exercise reasonable care and/or acted with malice when he

published the false statements.

6
 37. As a result of Defendant's publishing of the false statements, Continental has

been damaged.

WHEREFORE, Plaintiff Continental Design Co., Inc., requests that the Court enter

judgment in its favor and against Defendant Paul Wysong, in an amount Continental will prove,

plus pre-judgment interest, costs, and all other just and proper relief.

Count 4
BREACH OF FIDUCIARY DUTY

38. Continental incorporates the preceding paragraphs as if fully set forth herein.

39. At all times relevant to this dispute, Defendant was an executive of Continental

and the President of its Quality Division.

40. Defendant owed a fiduciary duty to Continental.

41. Defendant breached this fiduciary duty by failing to take reasonable care when he:

1) informed a third-party individual why a former employee was fired; 2) provided inadequate

and/or incomplete paperwork causing major delays in payments from customers; and 3) failed to

obtain proper paperwork and process orders for jobs causing Continental to incur large account

receivables that have gone uncollectable.

42. As a direct result of Defendant's breach of his fiduciary duty, Continental has

been damaged.

WHEREFORE, Plaintiff Continental Design Co., Inc., requests that the Court enter

judgment against Defendant Paul Wysong, for such damages as the Court may determine are

appropriate given his breach of fiduciary duty to Continental and for such other relief as is

appropriate under the circumstances.

7
 Count 5
NEGLIGENCE

43. Continental incorporates the preceding paragraphs as if fully set forth herein.

44. Defendant had a duty to take reasonable care to ensure he did not put Continental

in the way of any potential harm.

45. Defendant breached his duty to take reasonable care and was negligent when he:

1) informed a third-party individual why a former employee was fired; 2) provided inadequate

and/or incomplete paperwork causing major delays in payments from customers; and 3) failed to

obtain proper paperwork and process orders for jobs causing Continental to have large account

receivables that have gone uncollectable, which at the time Defendant should have foreseen that

his acts could harm Continental.

46. As a direct and proximate result of Defendant's negligence in not taking

reasonable care, Continental sustained injury and a loss in an amount to be proven by

Continental.

WHEREFORE, Plaintiff Continental Design Co., Inc., requests that the Court enter

judgment in its favor and against Defendant Paul Wysong, in an amount Continental will prove,

plus pre-judgment interest, costs, and all other just and proper relief.

Count 6
UNJUST ENRICHMENT

47. Continental incorporates the preceding paragraphs as if fully set forth herein.

48. There was an understanding between Continental and Defendant that any advance

commissions paid on account receivables that have gone uncollected would be paid back by

Defendant to Continental.

8
 49. Defendant acknowledged, accepted and benefited from the advance commissions

provided by Continental.

50. Retention of the advance commissions by Defendant without paying the

commissions back to Continental would be unjust.

51. Because Continental's damages are ascertainable in accordance with fixed rules

of evidence and known standards of value, and there has been an unreasonable delay in payment

of ascertainable amounts, Continental is entitled to an award of prejudgment interest.

WHEREFORE, Plaintiff Continental Design Co., Inc., requests that the Court enter

judgment in its favor and against Defendant Paul Wysong, in an amount Continental will prove,

plus pre-judgment interest, costs, and all other just and proper relief.

Count 7
CONVERSION

52. Continental incorporates the preceding paragraphs as if fully set forth herein.

53. Defendant knowingly or intentionally exerted unauthorized control over the

Property of Continental without the consent of Continental.

WHEREFORE, Plaintiff Continental Design Co., Inc. requests that the Court enter a

judgment in its favor and against Defendant Paul Wysong, in an amount to be proven at trial,

costs, and all other just and proper relief.

Count 8
CRIMINAL MISCHIEF

54. Continental incorporates the preceding paragraphs as if fully set forth herein.

55. Defendant recklessly, knowingly, or intentionally shredded, deleted files and

destroyed the Property of Continental without the consent of Continental.

9
 WHEREFORE, Plaintiff Continental Design Co., Inc. requests that the Court enter a

judgment in its favor and against Defendant Paul Wysong, in an amount to be proven at trial,

costs, and all other just and proper relief.

Count 9
CRIME VICTIMS RELIEF ACT

56. Continental incorporates the preceding paragraphs as if fully set forth herein.

57. Under the Indiana Crime Victims Relief Act (Ind. Code 34-24-3-1), Continental

is entitled to recover an amount not to exceed three times its actual damages, costs of the action,

and reasonable attorneys' fees.

WHEREFORE, Plaintiff Continental Design Co., Inc. requests that the Court enter a

judgment in its favor and against Defendant Paul Wysong, in an amount to be proven at trial,

plus treble damages, expenses, prejudgment interest, reasonable attorneys' fees, costs, and all

other just and proper relief.

Count 10
PUNITIVE DAMAGES

58. Continental incorporates the preceding paragraphs as if fully set forth herein.

59. In committing criminal mischief and libel, Defendant acted with malice, fraud,

gross negligence or oppressiveness which was not the result of a mistake of law, honest error of

judgment, overzealousness, mere negligence, or other human failing and, as such, Continental is

entitled to the award of punitive damages.

WHEREFORE, Plaintiff Continental Design Co., Inc., requests that the Court enter

judgment in its favor and against Defendant Paul Wysong for punitive damages in an amount to

be determined, and all other just and proper relief.

10
 Count 11
REQUEST FOR TURNOVER

60. Continental incorporates the preceding paragraphs as if fully set forth herein.

61. Defendant has not returned Continental's Property.

62. There is no dispute that the Property belongs to Continental.

63. As such, Continental requests that Defendant or any person in possession of the

Property be ordered to turn over the Property to Continental.

WHEREFORE, Plaintiff Continental Design Co., Inc. respectfully requests that

Defendant Paul Wysong be ordered and directed to turn over the Property to Continental.

Count 12
APPLICATION FOR PRELIMINARY INJUNCTION

64. Continental incorporates the preceding paragraphs as if fully set forth herein.

65. Continental requests that this Court enter a preliminary injunction to prevent

further irreparable harm to Continental pending final resolution of this lawsuit. Continental asks

that the Court enjoin Defendant from (a) publishing defaming information about Continental; (b)

picketing or causing individuals to picket in front of Continental's business with signs that

contain published defaming information; and (c) destroying any and all Continental Property that

may still be in his possession.

66. Continental has shown a right of recovery and a likelihood of success on the

merits.

67. Continental will suffer irreparable harm without Court intervention and there is no

adequate remedy at law.

68. The threatened injury to Continental outweighs any possible harm to Defendant.

11
 69. Public interest is served by an injunction because it will ensure that false

information about Continental not be published for public viewing.

Requested Relief

WHEREFORE, Continental Design Co., Inc. respectfully requests the following relief:

1. A Preliminary Injunction enjoining Defendant Paul Wysong from: (a) publishing

defaming information about Continental; (b) picketing or causing individuals to

picket in front of Continental's business with signs that contain published

defaming information; and (c) destroying any and all Continental property that

may still be in his possession;

2. An expedited hearing on Continental's Request for Preliminary Injunction; and

3. An Order awarding Continental its damages, including its costs, treble and

punitive damages, attorneys' fees related to this action, and all other and further

relief as the Court may deem just and proper.

12
 VERFICIATION

I, Judy Nagengast, swear or affirm under the penalties of perjury that the factual

statements in this Verified Complaint for Damages are true and accurate to the best of my

knowledge, information and belief

Continental Design Co., Inc.

Dated: 1/31/7017

Respectfully submitted,

/
Antho 41119P, Atty. No. 32127-49
Mitchell A. Greene, Atty. No. 33782-49
Attorneys for Continental Design Co., Inc.

ALERDING CASTOR HEWITT LLP

47 S. Pennsylvania St., Suite 700
Indianapolis, IN 46204
Phone: (317) 829-1910
Fax: (317) 423-2089
aroach@alerdingcastor.com
mgreenealerdingeastor.com

13
 Filed: 1/31/2017 1:30:46 PM
48C01-1701-CC-000185 Darlene Likens
Madison Circuit Court 1 Clerk
Madison County, Indiana

CONTINENTAL Inc
EMPLOYEE AGREEMENT

CONTINENTAL Inc, located at 1524 Jackson St, Anderson, IN 46016 in Madison County,
hereby employs Paul Wysong, herein referred to as employee, to serve and perform such duties at
such times and places and in such manner as Continental Inc. may from time to time direct.

Employee agrees to faithfully perform the duties assigned to him to the best of his ability, to
devote his full and undivided time to the transaction of the company's business, to make to
company prompt, complete and accurate reports of his work and expenses, and to promptly remit
to company all monies of company collected by his or coining in to his possession.

In consideration of such service, company agrees to pay employee compensation at the rate of
Eighty thousand dollars and 00/100 ($80,000.00) yearly. This will be paid at an hourly rate of
Thirty eight dollars and 47/100 ($38.47) per hour.
-

Employee shall receive 3% commission of all Quality Gross*rofFts. This commission is to be

paid monthly, upon employment.

The parties acknowledge that at the termination of this agreement, by either party and in any
manner, the payment to employee of wages earned to the date of such termination shall be in full
satisfaction of all claims against company under this agreement.

Changes or additions to this agreement will be in the form of an addendum attached to this
contract and signed by both parties. The undersigned acknowledges that no other agreements in
the form of wages, raises, employment conditions, training, etc. have been made either in writing
or verbally other than what is in this contract or in an attached addendum.

IN WITNESS WHEREOF, the parties have executed this agreement at Continental Inc on the -
0/(i day of , 2013.

Employee

DA-O
Difetor of 1-111all es urces

EXHIBIT A
 CONTINENTAL DESIGN COMPANY

EMPLOYEE AGREEMENT ADDENDUM

ITEM 1. VACATION PAY -- Employee is eligible for 3 week vacation upon employment,
Vacation must he taken to be to be paid. Any unused vacation will be forfeited at
employee's anniversary.

ITEM 2. HOLIDAYS - There are 6 paid holidays during the calendar year. These
holidays are paid if they are worked or not. If you decide to work
on the holiday, you will be paid for any time you do work, as well as for
the 8 hours of holiday pay. These holidays are as follows:

New Years Day Memorial Day

Labor Day Thanksgiving Day

Independence Day Christmas Day

NOTE: The above are our only paid holidays. We do not pay, for example, for
the Friday after Thanksgiving even though our client is closed. You would only
be paid for that Friday if you had been approved to work.

ITEM 3. PERSONAL DAYS Employee will be allowed two paid personal day after 1
year of service. These days are non-cumulative and must be used by employee's
employment anniversary. They are not paid unless used.

ITEM 4. INSURANCE - All Continental Design Employees are eligible for

Medical/Dental Insurance coverage FIRST OF THE MONTH FOLLOWING
A 30-DAY WAITING PERIOD. Continental provides this coverage for a small
charge for it's full time employees and gives the option to the employee to
purchase family coverage for spouse and children. PLEASE NOTE THAT
CONTINENTAL DESIGN DOES NOT PAY FOR FAMILY COVERAGE.

If, upon employment, you have chosen to opt out of our Health Insurance
Coverage, your Base hourly pay has been adjusted to allow for this. If, in the
future, you elect Health Insurance Coverage through the Continental Design &
Engineering Group Policy, your base hourly pay may be reduced accordingly.
ITEM 5. PAY AND RAISES - The following rates have been determined for the purpose
of this contract:

Straight time $80,000/year, paid at the rate of $38.47/hr

Overtime N/A
Pay raises are based on individual performance. PAY RATES AND
RAISES ARE TO BE KEPT CONFIDENTIAL AND SHOULD
ONLY BE DISCUSSED WITH CONTINENTAL DESIGN CO.
HUMAN RESOURCES PERSONNEL. PLEASE DO NOT DISCUSS
YOUR PAY RATE OR RAISES WITH CO-WORKERS OR WITH
OUR CUSTOMER.

ITEM 6. PAY SCHEDULE - Paychecks are issued weekly on Friday. TIME

SHEETS MUST BE TURNED IN TO THE PAYROLL
DEPARTMENT BY MONDAY MORNING. Your paycheck is based
upon your time sheet. Please take care to see that we receive it in a timely
manner.

NOTE: Your first paycheck will be issued the first Friday after completion
of the workweek. The workweek ends on Sunday.

IN WITNESS WHEREOF, the parties have executed this agreement and it is understood that no
other agreements except those stated in this document and the "CONTINENTAL INC
EMPLOYEE AGREEMENT" exist and this agreement is executed at Continental Inc. on the
day of , 2013.

Employee

Direr44u.1* esources
 Filed: 1/31/2017 1:30:46 PM
48C01-1701-CC-000185 Darlene Likens
Madison Circuit Court 1 Clerk
Madison County, Indiana

CONTINENTAL DESIGN & ENGINEERING

CONTRACTORS INTELLECTUAL PROPERTY RIGHT AGREEMENT

My employer, Continental Design & Engineering, has contracted with different customers to
provide services and/or furnish personnel to provide services for their companies. In
consideration of my assignment by my employer to perform such services for said customer, and
of the compensation paid for my services, I assign Continental Design and/or their customer all
rights, title and interest in and to all patents, trademarks, service marks, mask works and
copyrights to the following intellectual property that I conceive, make, invent, create or suggest
during my assignment:

Writings, designs, inventions and work relating to any matter or thing including processes and
methods of manufacture and software, that are connected with my work for Continental Design
or that are related to the business of Continental Design or its subsidiaries, as such business
exists or is anticipated at the time the rights come into existence.

Such writings, designs, inventions and works are the absolute property of Continental Design.

I will promptly disclose such writings, designs, inventions and works to Continental Design.

I will execute all lawful papers that Continental Design considers necessary or helpful (I) in the
prosecution of patent, trademark, service mark, mask work and copyright applications on such
writings, designs, inventions, and works, or (ii) in the conduct of any interference, litigation or
other controversy in connection with such writings, designs, inventions and works.

All expenses incident to the filing and prosecution of such applications and the conduct of any
such interference, litigation, or other controversy will be borne by Continental Design.

I will not reveal any information concerning writings, designs, inventions, works, proprietary
information, trade secrets and other confidential matters, developed or obtained as a result of my
assignment, to any person unless approved by a duly authorized Continental official.

Dated 5A11/1 10. , 2013

(witness)

EXHIBIT B
 Continental Design & Engineering Employee Non-Compete Agreement

For good consideration and as an inducement for Continental Design &

Engineering to employee, the undersigned employee hereby agrees not to directly or
indirectly compete with the business of the company for a period of two years following
termination of employment and notwithstanding the cause or reason for termination.

The term "not compete" as used herein shall mean that the employee shall not
solicit customers or employees of Continental Design & Engineering or Personnel
Recruiters & Consultants.

The employee acknowledges that the company shall or may in reliance of this
agreement provide employee access to trade secrets, customers and other confidential
data and good will. Employee agrees to retain said information as confidential and not to
use said information on his or her own behalf or disclose same to any third party. The
employee shall not disclose, divulge, discuss, copy or otherwise use or suffer to be used
in any manner in competition with, or contrary to the interest of the company, the
marketing plans or strategies, inventions, ideas, discoveries, product research or
engineering data, if any, or other trade secrets, pertaining to the business of the company;
it being acknowledged that all such information is confidential and the exclusive property
of the company.

This non-compete agreement shall be in full force and effect from commencement
of employment and the period following the date of employment termination specified
above.

This agreement shall be binding upon and insure to the benefit of the parties, their
successors, assigns, and personal representatives.
----
i
Signed this 1 day of ( JO I 11 2013.

ein.LA:2.1612-3 'Cjik_.

Employee
 Filed: 1/31/2017 1:30:46 PM
48C01-1701-CC-000185 Darlene Likens
Clerk
Madison Circuit Court 1
Madison County, Indiana

AFFIDAVIT AND OATH OF CONFIDENTIALITY

, being duly sworn upon my oath say:

I am offering this affidavit as an employee of Continental Design & Engineering.

2. I am aware that, in my employment with Continental Design, from time to time, I may
gain personal knowledge of other persons who are employed by Continental Design or
persons or other entities who are customers of Continental Design.

3. The information I learn about said persons or customers in my employment with

Continental Design is confidential and promise to maintain that confidentiality unless
properly authorized to release same.

4. Said information is not to be disclosed to anyone without a duly executed release being
received from the person or customer about whom the information is sought or upon
Court order that the same be disclosed.

5. I further pledge and covenant to keep confidential any and all information concerning
Continental Design or its principals, which information I may obtain in my employment
with Continental Design, which would include but not necessarily be limited to its
customer list, its trade secrets, and its finances.

6. I realize that any unauthorized disclosure of any information, which I may obtain in the
conduct of my employment with Continental Design, about Continental Design, its
customers or other employees of Continental is a violation of my oath of confidentiality
and would subject me to termination of my employment with Continental Design and
could result in the institution of legal proceedings for damages occasioned by my breach
of this Affidavit and Oath of Confidentialit

Dated:

signature

(..)..)1./1Q3-1, 6:)
typed/printed name

State of Indiana
SS:
County of
Before me, a Notary Public in and for said County and State, personally appeared
on , 20 and, being duly sworn by me upon
h oath, executed the foregoing document as
h free and voluntary act.

, Notary Public, a
resident of County
My commission expires:

EXHIBIT C
 Filed: 1/31/2017 1:30:46 PM
48C01-1701-CC-000185 Darlene Likens
Clerk
Madison Circuit Court 1
Madison County, Indiana

twha ley@continento' x Matthew Wdharns - x sales engineering "I, X hueme@confinental (2) Continental Inc. x Obituary of Bnttney
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Page Messages Notifications Insights Publishing Tools Settings Help

Reviews
Check-ins Paul Wysong reviewed Continental, Inc.
3 mins */#
Mentions
Shares (1) What I find most interesting about the reviews below is the fact that Jeff Rhodes is the Director of
Marketing for Continental Inc.. Craven Work is a fake page. Jim Crockett works as a recruiter. Bianca
Requests Furst is employed within HR. Jack Russell worked in recruiting and Tennille Whaley is also a recruiter. All
these people are employees of Continental Inc. leaving reviews as if they were actual customers or
people whom used their services. The ONLY real review on here is this one and the below review left by
Invite Friends to Like This Page
Rob Bainter
nvite your friends to like Continental, Inc.
If you want to work for a scientology based company then this is the place for you! Check out "wise .
org/en_US/1-ron-hubband/results/pg001. html#nagen" and scroll down to Continental's CEO, Judy
Matt Petty Invite Nagengast. as from the very first IQ test they have you take to every CSW and Dangerous Situation
Report they have you fill out, it's all a slow religious coercion plan to get you to practice and possibly
convert over to their scientology beliefs.
Judy Maurer Invite
When and IF you get any of your agreed to bonus payments. it's only after accounting (whom has no
accounting degree) manipulates the numbers until your bonus is just a fraction of what you're actually
Greg Caine Invite owed yet nobody can explain where the missing tens-of-thousands of dollars have gone in the mean
time.
Do yourself your soul and your family a favor and just find other employment!
Emily Whaley Invite

See All Friends

. 7, Chat (86)
NIL
V

EXHIBIT E
 Filed: 1/31/2017 1:30:46 PM
48C01-1701-CC-000185 Darlene Likens
Clerk
Madison Circuit Court 1 unty, Indiana