Lawsuit Concerning Wilf Blum and 30m CPRK Stock:
Deep Blue Marine et al v. Krajewski - OCR extract Part 1
DEEP BLUE MARINE, INC., a Nevada corporation; ALEXANDER LlNDALE, LLC, a Utah limited liability company; and WILF BLUM, an individual,
EDWARD KRAJEWSKI, an individual,
JOHN DOES 1-10, individuals,
COMPLAINT (JURY TRIAL REQUESTED)
Assigned To : Campbell, Tena
Assign. Date : 5/20/2008
Description: Deep Blue Marine et al v. Krajewski
For causes of action against Defendant Edward Krajewski, Plaintiffs Deep Blue Marine and Wilf Blum allege as follows:
1. Plaintiff, Deep Blue Marine (Deep Blue) is a Nevada corporation with its
headquarters in Midvale, Utah.
2. Plaintiff, Alexander Lindale, LLC, is an Utah limited liability company.
3. Plaintiff, Wilf Blum ("Blum") is a resident of the State of Utah.
4. Defendant Edward Krajewski ("Krajewski"), also known as Ed Krajewski, also known as "Capted", is a resident of the Commonwealth of Pennsylvania.
5. Defendants John Does are individuals whose identity is currently unknown but will become known through discovery.
JURISDICTION AND VENUE
6. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1332.
7. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 (a)(2 and 3).
8. This is an action for damages and injunctive relief arising from
Defendant's obsessive compulsive publication of false and defamatory statements about Plaintiffs and the disclosures of proprietary information of Deep Blue in violation of an express Non-disclosure Agreement in a concerted effort to try to destroy Plaintiffs and their business relationships.
9. The conduct of Defendant amounts to defamation per se, defamation per quod, intentional interference with business relations and contracts, breach of contract, and breach of the covenant of good faith and fair dealing.
10. Plaintiff Deep Blue's stock symbol is DPBM.
11. Plaintiff Deep Blue's I-hub symbol is DPBE.
12. Plaintiff Wilf Blum is the CEO for Deep Blue.
13. Randy Champion is the Vice President of Deep Blue.
14. Defendant Krajewski was employed as a contract employee, and often referred to as the operations manager for Deep Blue between March of 2006 and February of 2007.
15. As operations manager for Deep Blue Marine, Krajewski had access to proprietary information of Deep Blue.
16. Krajewski signed an Employee/Contractor Non-Disclosure and Drug Free Agreement ("Agreement") on October 10, 2006. See Exhibit A, Employee/Contractor Non-Disclosure and Drug-Free Agreement, attached hereto and fully incorporated by this reference.
17. Pursuant to the Non-Disclosure Agreement, Krajewski agreed that during the course of his employment, and after the termination of employment, he would not disclose trade secrets as defined in the Agreement.
18. The Agreement specifically included as trade secrets of Deep Blue both technical and business information including, but not limited to methods, processes, discussions, plans, techniques, equipment, locations, discoveries, recovered materials, research projects, sources of supplies, financial data and marketing, contract amounts and/or salaries, corporate income, disbursements, expenditures, and /or merchandising systems or plans.
19. Defendant Krajewski has and continues to publish statements on investment message boards of investment internet sites, including but not limited to Investorshub ("I-hub") for Deep Blue Marine, I-hub for Oceanic Research and Recovery, Inc., and Golden Boards, which disclose proprietary information in violation of the Agreement.
20. I-hub is an internet website that has message boards for publicly traded companies. Individuals are allowed to become members on these boards in order to converse with other investors about the specific company.
21. Golden Boards is a similar Internet website that provides a message board for individual investors to discuss their investments and the specific company related to the message board.
22. Defendant Krajewski is a member on a number of internet investment message boards, including I-hub for Deep Blue Marine, I-hub for Oceanic Research and Recovery, Inc., and Golden Boards.
23. Defendant Krajewski posts on message boards under the name "capted".
24. Defendant Krajewski also posts on message boards under the name "fubar".
25. Plaintiff, Alexander Lindale, until May 16, 2008, had an Independent contractor relationship with Copper King Mining Corporation to provide public relations services.
26. As a result of Defendant's incessant defamatory and misleading postings about Plaintiffs, Plaintiffs have responded to numerous calls from officials of Copper King who were concerned about the postings by Defendant.
27. Since the onslaught of Defendant's false and defamatory postings about Plaintiffs, Copper King terminated its contract with Plaintiff Alexander Lindale.
28. As a result of the termination of the Copper King contract, Alexander Lindale stands to lose 30,000,000 shares of restricted stock in Copper King.
29. Plaintiff Wilf Blum has had business and consulting relationship with Oceanic Research and Recovery.
30. Defendant Krajewski has posted more than 1500 messages about Plaintiffs on investment message boards.