Attorneys for Plaintiffs Maple Mountain Enterprises Inc., d/b/a Modere Enterprises, Inc., and Neways Holdings, L.P.
IN THE FOURTH JUDICIAL DISTRICT COURT IN AND FOR UTAH COUNTY, STATE OF UTAH
Plaintiffs Maple Mountain Enterprises Inc., d/b/a Modere Enterprises, Inc., and Neways Holdings, L.P. (collectively, together with their predecessors and controlled affiliates, “Modere”), by and through their counsel of record, hereby allege, assert and complain against Defendants Justin Prince (“Prince”), Prince’s company, JPBG, LLC (“JPBG”), (collectively, “Defendants”) as follows:
INTRODUCTION
This case involves a deliberate effort by the Defendants to, under contract with Modere, to sabotage and cripple Modere’s business, solicit its salesforce, use Modere’s trade secret and proprietary information, and set up a business to compete with Modere.
Beginning around August 2023, if not earlier, while under contract and associated with Modere as a senior leader of the company, Prince (together with his company) violated their contractual obligations and fiduciary duties owed to Modere and disseminated to key Modere associates—independent contractor distributors titled “Social Marketers”— throughout the company highly confidential business information and misinformation regarding Modere’s debt obligations, its financial wherewithal, its future business outlook, the status of its CEO, and its commitment to improved technology and new The clear purpose of this information campaign was