Plaintiff Amberstone Consulting, a tax preparation business, claimed that defendant Nelly Botton, an employee for over 20 years until she voluntarily terminated her employment, took a client list to begin her own tax preparation agency, contacted all clients for whom she had previously prepared taxes and communicated with them to solicit their business away from plaintiff.

Plaintiff also claimed that defendant Frantz Paul, who was terminated from his employment with plaintiff for allegedly stealing funds, assisted Botton in her new business by obtaining documents and information concerning plaintiff’s clients, and providing them to Botton.