- 5 -
1993 and beyond, and he continued to sell award products to
customers which he had previously serviced for Balfour.
Also on June 14, 1991, petitioner filed suit in Federal
District Court (the District Court) against Balfour and its
parent corporation, Town & Country Corp. (T&C). Petitioner's
complaint and amended complaint asserted claims mainly for:
(1) Breach of contract, (2) destruction of his equity in his
sales territory, (3) failure to pay wages under Connecticut law,
(4) unlawful deductions from wages in violation of Connecticut
law, (5) conversion, and (6) constructive discharge. Neither the
complaint nor the amended complaint alleged that Balfour or T&C
caused petitioner to suffer a physical or emotional injury, and
neither pleading prayed for damages from such an injury. In
their answers, Balfour and T&C denied the material allegations
set forth in petitioner's pleadings, and they asserted various
affirmative defenses and counterclaims against him for breach of
contract, conversion, replevin, unjust enrichment, breach of duty
of loyalty, tortious interference, and unfair competition.
On March 13, 1992, petitioner served Balfour with
interrogatory responses identifying and describing his requested
damages to include: (1) $3,012,793 for breach of contract,
(2) $1.2 million for lost equity, (3) $9,359,849 for failure to
pay wages; (4) $1,262,448 for unlawful deduction from wages,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011