Unformatted text preview: atfield recalled that he has been to Florida only
three times, in January 2003, 2004 and 2005, to attend company meetings at a Fort
Lauderdale hotel, and that, during the last trip, he was in Florida less than 48 hours.
Hatfield alleged that AutoNation maintained a very stringent attendance policy at the
meetings and, at the time of the 2005 meeting, he had been ill and was advised not to
travel, but attended due to AutoNation's attendance policy. Hatfield stated that, at the
2005 meeting, he was given a binder, but he did not take or copy the binder. Hatfield
claimed that, since leaving AutoNation, he has been unemployed, he has not had any
employment agreement with another dealership, and he does not work for the other
Mercedes Benz dealership mentioned in AutoNation's amended complaint. 239 AutoNation filed an emergency motion for temporary injunction, and shortly thereafter
filed an emergency motion to require specific performance of the contractual venue
selection and to enjoin misuse of AutoNation's confidential proprietary and trade secret
information. AutoNation set its specific performance motion for hearing before the trial
court, and Hatfield cross-noticed his motion to dismiss for the same hearing.
The day before the hearing, AutoNation served five affidavits in opposition to Hatfield's
Declaration. Gary Cancinos, an AutoNation eSupport Analyst and former AutoNation
customer service spet, stated in his affidavit that, when Hatfield was the general
manager of the Houston dealership, there were multiple written communications,
including electronic communications, between the customer service department and
Hatfield. Cancinos further alleged that the customer service department, from
AutoNation's Fort Lauderdale headquarters, provided Hatfield continuous customer
relations support including service, sales transactions, and finance. Cancinos added that
the signature block on Hatfield's e-mails to his online customers provided a Fort
Lauderdale address for contacting Hatfield by mail. Marc Cannon, AutoNation's Vice
President of Corporate Communications, explained in his affidavit that he routinely sent
from AutoNation's Fort Lauderdale headquarters general field bulletins and other
information mechanisms, and that, when Hatfield attended the annual leadership
meetings in Fort Lauderdale, Hatfield was given confidential and pro...
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This note was uploaded on 09/30/2012 for the course ENC 102 taught by Professor Deria during the Spring '08 term at FIU.
- Spring '08