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Unformatted text preview: assistance, direction, supervision and support to aid him
in operating his dealership. AutoNation further alleged that Hatfield committed tortious
acts in Florida by misappropriating and converting AutoNation's trade secrets and other
confidential proprietary business information and by coming to AutoNation's 2005
leadership meeting in Florida under false pretenses to obtain information while knowing
that he did not intend to remain an AutoNation general manager. Moreover, AutoNation
pled that Hatfield contractually agreed to venue in Broward County.
Hatfield moved to dismiss the action for lack of personal jurisdiction and failure to state a
cause of action. Hatfield alleged that the trial court did not have personal jurisdiction over
him under Florida's long-arm statute, that minimum contacts did not exist between
himself and Florida, and that AutoNation failed to state a cause of action alleging he had
committed any tortious *1239 acts. Hatfield attached to his motion to dismiss a sworn
declaration stating that he is a citizen and resident of Texas; he has lived in Texas
continuously since 1986; he has never lived in Florida; he has never worked in Florida;
he has never owned, and does not own, any real property in Florida; he does not maintain
any bank accounts in Florida; he has not entered into any contracts in Florida; and he
does not regularly transact, and has not transacted, any business in Florida.
Responding to AutoNation's allegations, Hatfield's sworn declaration also stated that he
signed the "Confidentiality, No-Solicitation/No-Hire and Non-Compete Agreement" on
the understanding that, if he did not sign the agreement, then he would lose his job.
Hatfield stated that he was given, and signed, the agreement in Texas. Hatfield contended
that he has never been to AutoNation's offices or headquarters in Florida. Hatfield stated
that he attended a limited number of business meetings in Florida, but only because he
was required to do so as part of his job. H...
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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