1038-00006 · Calderwood & Harkness LLP · Court Filings

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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

DECLARATION OF THERESA YUN-PARK IN SUPPORT OF PLAINTIFF'S MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION

I, Theresa Yun-Park, hereby declare and state as follows, pursuant to 10 Del. C. § 3927, under penalty of perjury:

I am the General Counsel of Cascade Retail Holdings Inc. ("CRH" or the "Company"). I submit this Declaration in support of CRH's Motion for a Temporary Restraining Order and Preliminary Injunction against Defendants Priya Rathore, Derek Linden, Sonia Kaczmarek, Amara Osei, Brent Halvorsen, Lucia Fernandez-Gill, Nathan Tsao, Kira Johansson (collectively, the "Individual Defendants" or the "Rathore Group"), and Verdana Commerce Group, Inc. ("Verdana" or "VCG"). I have personal knowledge of the facts set forth herein, or have obtained them through my role as General Counsel of CRH and through my review of CRH's business records maintained in the ordinary course of business. I am competent to testify to these matters if called as a witness. This Declaration is filed on March 5, 2025.

I. BACKGROUND OF THE DECLARANT

1. My full name is Theresa Yun-Park. I serve as the General Counsel of Cascade Retail Holdings Inc. I have held this position continuously since January 2018.

2. I joined CRH in January 2018. Throughout the entire period relevant to this action — from at least January 2025 through the present — I have served as the Company's General Counsel and have been actively involved in the matters described herein.

3. As General Counsel, my responsibilities include overseeing all legal affairs of the Company. This encompasses, among other areas, employment law matters, intellectual property protection, corporate governance, litigation management, regulatory compliance, mergers and acquisitions, and the negotiation and administration of commercial agreements. I supervise a team of twelve in-house attorneys and several paralegals and legal operations professionals.

4. I report directly to Marcus Langford, the Chief Executive Officer of CRH. In the ordinary course of my duties, I work closely with Roland Ashby, the Chief People Officer, as well as business unit leaders across the organization, including those in the merchandising division. I regularly interface with CRH's Board of Directors and its Audit Committee on matters involving legal risk, compliance, and litigation.

5. In my capacity as General Counsel, I am thoroughly familiar with the Company's employment agreements, confidentiality policies, trade secret protections, and the events giving rise to this action. I have personally reviewed and approved the form of employment agreement used for senior executives and directors within CRH, including the restrictive covenant provisions contained therein. I am also familiar with the circumstances surrounding the coordinated resignations of the eight Individual Defendants and their subsequent employment by Verdana Commerce Group, Inc., as described in detail below.

II. OVERVIEW OF CASCADE RETAIL HOLDINGS INC.

6. CRH is a corporation organized and existing under the laws of the State of Delaware. The Company is headquartered at 2200 Elliott Avenue West, Suite 3400, Seattle, Washington 98119. CRH is publicly traded on the Nasdaq Stock Market under the ticker symbol "CRHL."

7. CRH is an omnichannel retail and ecommerce company. The Company operates 387 brick-and-mortar retail locations across 34 states, as well as a robust direct-to-consumer ecommerce platform accessible at www.cascaderetail.com. CRH's retail operations span multiple product categories, including home goods, apparel, seasonal décor, hardlines, softlines, and private-label merchandise. The Company serves millions of customers annually through both its physical stores and its digital platform, and its business model depends upon the seamless integration of its in-store and online channels.

8. For fiscal year 2024 (ending January 31, 2025), CRH generated approximately $6.82 billion in total revenue. As of late February 2025, CRH's approximate market capitalization was approximately $4.1 billion. CRH employs approximately 47,000 individuals across its corporate headquarters, regional offices, distribution centers, and retail locations.

9. CRH's merchandising division is the core engine of the Company's business. The merchandising division is responsible for product selection, vendor negotiations, private-label development, seasonal planning, pricing strategy, and ecommerce assortment strategy. In fiscal year 2024, the merchandising division generated approximately $2.3 billion in gross merchandise value. The performance and strategic direction of the merchandising division are critical to CRH's competitive positioning, revenue growth, and profitability. CRH has invested hundreds of millions of dollars over many years to develop the merchandising capabilities, vendor relationships, data analytics infrastructure, and proprietary strategies that drive this division's performance.

10. The merchandising division's competitive advantage rests on proprietary information that is not publicly available and that CRH takes extensive measures to protect. This proprietary information includes, but is not limited to: (a) vendor negotiation playbooks containing CRH's negotiation strategies, pricing thresholds, and contractual terms with hundreds of vendors; (b) seasonal buying algorithms developed over multiple years at significant expense; (c) private-label sourcing strategies, including detailed cost models and margin targets; (d) ecommerce assortment algorithms that optimize product selection and pricing for the Company's online platform; (e) customer segmentation data derived from CRH's proprietary analytics systems; and (f) a confidential five-year category expansion roadmap that identifies the specific product categories, geographic markets, and timetables for CRH's planned growth over the next five years. This information, individually and collectively, represents the product of substantial investment in time, resources, and expertise, and constitutes trade secrets and confidential business information of immense competitive value.

III. THE DEPARTING EMPLOYEES AND THEIR EMPLOYMENT AGREEMENTS

A. Priya Rathore

11. Priya Rathore joined CRH on June 3, 2019, as Vice President, Merchandising Strategy. On that date, Rathore executed an Employment Agreement with CRH containing restrictive covenant provisions, including non-competition, non-solicitation, and perpetual confidentiality obligations, all governed by the laws of the State of Delaware. The execution of the Employment Agreement was a condition of Rathore's employment with CRH, and Rathore acknowledged in writing that the restrictive covenants were reasonable and necessary to protect CRH's legitimate business interests.

12. On March 15, 2021, Rathore was promoted to Senior Vice President, Merchandising. In connection with her promotion, Rathore executed an Amended and Restated Employment Agreement on that same date. The Amended and Restated Employment Agreement contains substantively identical restrictive covenant provisions to those in her original Employment Agreement, and was supported by additional, independent consideration. Specifically, in connection with the promotion and the execution of the Amended and Restated Employment Agreement, Rathore received a $150,000 promotion bonus and an enhanced restricted stock unit ("RSU") grant valued at approximately $725,000, with a four-year ratable vesting schedule. Rathore acknowledged in writing that the additional consideration was adequate and that the restrictive covenants set forth in the Amended and Restated Employment Agreement were reasonable and enforceable.

13. Under the terms of Rathore's Amended and Restated Employment Agreement, her restrictive covenant obligations include: (a) an eighteen (18)-month post-termination non-competition restriction, which prohibits Rathore from working for, consulting with, or otherwise providing services to any competitor of CRH in the omnichannel retail or ecommerce space anywhere in the United States; (b) a twenty-four (24)-month non-solicitation provision, which prohibits Rathore from directly or indirectly soliciting, recruiting, or hiring any CRH employee, or soliciting or diverting business from any CRH vendor or customer; and (c) perpetual confidentiality obligations prohibiting the disclosure, use, or misappropriation of CRH proprietary information and trade secrets at any time during or after her employment.

14. Rathore's fiscal year 2024 compensation at CRH consisted of a base salary of $485,000, a target annual bonus of $290,000 (representing approximately 60% of her base salary), and unvested RSUs. As of her resignation date of February 7, 2025, approximately $362,500 in RSUs remained unvested and subject to forfeiture or clawback under the terms of her Amended and Restated Employment Agreement. The forfeiture provisions of the agreement expressly provide that unvested RSUs are forfeited upon voluntary termination, and that RSUs vested within the twelve months preceding a breach of the restrictive covenants are subject to clawback.

15. As Senior Vice President, Merchandising, Rathore was the most senior merchandising executive at CRH. She had direct oversight of all merchandising strategy, vendor relationships, private-label programs, and category planning across the Company's entire retail and ecommerce platform. Rathore reported directly to CEO Marcus Langford and participated in executive leadership meetings, board presentations, and strategic planning sessions. She was the principal architect of CRH's merchandising strategy and served as the executive sponsor of Project Ridgeline, described in Section IV below. All other members of the Rathore Group reported directly or indirectly to Rathore.

B. The Other Seven Departing Employees (the "Rathore Group")

16. In addition to Rathore, seven other senior merchandising employees resigned from CRH simultaneously on February 7, 2025. Each of these employees had executed an employment agreement with CRH containing restrictive covenant provisions governed by the laws of the State of Delaware, including non-competition, non-solicitation, and perpetual confidentiality obligations. In each case, the execution of the employment agreement was a condition of employment or promotion, and each employee received substantial consideration in connection with the agreement, including base salary, bonus eligibility, and equity compensation.

17. The seven additional departing employees, together with their titles, tenure, base compensation, and non-compete terms, are as follows:

(a) Derek Linden — Vice President, Hardlines Merchandising. Linden was employed by CRH for approximately seven (7) years. His base salary was $340,000. His employment agreement contains an eighteen (18)-month post-termination non-competition restriction.

(b) Sonia Kaczmarek — Vice President, Softlines Merchandising. Kaczmarek was employed by CRH for approximately five (5) years. Her base salary was $325,000. Her employment agreement contains an eighteen (18)-month post-termination non-competition restriction.

(c) Amara Osei — Director, Private Label Strategy. Osei was employed by CRH for approximately four (4) years. Her base salary was $265,000. Her employment agreement contains a twelve (12)-month post-termination non-competition restriction.

(d) Brent Halvorsen — Director, Seasonal Planning & Analytics. Halvorsen was employed by CRH for approximately six (6) years. His base salary was $258,000. His employment agreement contains a twelve (12)-month post-termination non-competition restriction.

(e) Lucia Fernandez-Gill — Director, Vendor Relations (Domestic). Fernandez-Gill was employed by CRH for approximately five (5) years. Her base salary was $248,000. Her employment agreement contains a twelve (12)-month post-termination non-competition restriction.

(f) Nathan Tsao — Senior Manager, eCommerce Merchandising. Tsao was employed by CRH for approximately three (3) years. His base salary was $195,000. His employment agreement contains a twelve (12)-month post-termination non-competition restriction.

(g) Kira Johansson — Senior Manager, Category Analytics. Johansson was employed by CRH for approximately four (4) years. Her base salary was $192,000. Her employment agreement contains a twelve (12)-month post-termination non-competition restriction.

18. The non-solicitation periods for the seven employees listed above range from eighteen (18) to twenty-four (24) months, depending on the employee's seniority and the terms of the applicable employment agreement. All eight departing employees — Rathore and the seven listed above — are subject to perpetual confidentiality obligations regarding CRH's proprietary information and trade secrets.

19. A true and correct copy of Rathore's Amended and Restated Employment Agreement dated March 15, 2021, is attached hereto as Exhibit 1. Representative copies of the employment agreements of the other seven departing employees are attached hereto as Exhibits 2 through 8, respectively.

IV. PROJECT RIDGELINE AND ACCESS TO CONFIDENTIAL AND TRADE SECRET INFORMATION

A. Description of Project Ridgeline

20. In or about October 2024, CRH's merchandising division completed a comprehensive, five-year strategic category expansion plan known internally as "Project Ridgeline." Project Ridgeline was developed over an approximately eighteen-month period at substantial cost and represented the culmination of extensive market research, data analysis, vendor outreach, competitive intelligence, and strategic planning conducted by senior merchandising leadership under Rathore's direction. The development of Project Ridgeline involved the expenditure of millions of dollars in internal resources and external consulting fees.

21. Project Ridgeline encompasses the following categories of proprietary and trade secret information: (a) proprietary vendor negotiation playbooks detailing CRH's negotiation strategies, pricing thresholds, contractual terms, volume-based rebate structures, and relationship management protocols with hundreds of vendors across all product categories; (b) seasonal buying algorithms developed over multiple years at significant expense, which enable CRH to optimize inventory procurement timing, quantities, and pricing based on historical sales patterns, weather data, macroeconomic indicators, and consumer behavior models; (c) private-label sourcing strategies, including detailed cost models identifying manufacturing partners, raw material costs, production lead times, quality benchmarks, and target margin structures for CRH's private-label product lines; (d) ecommerce assortment algorithms that govern product selection, dynamic pricing, promotional strategy, and personalization across CRH's digital platform; and (e) a confidential category expansion roadmap identifying specific product categories, geographic markets, target consumer demographics, competitive positioning strategies, capital expenditure requirements, and timetables for CRH's planned growth over the next five years.

22. Project Ridgeline was treated as highly confidential within CRH. Access to Project Ridgeline materials was restricted to senior merchandising leadership on a strict need-to-know basis. The materials were stored on CRH's secure Sundial Systems environment, protected by multi-factor authentication and role-based access controls. Only a limited number of employees — fewer than twenty individuals across the entire Company — were granted access to the full Project Ridgeline materials. Employees with access to Project Ridgeline were required to acknowledge CRH's confidentiality policies, and reminders of their confidentiality obligations were communicated in connection with the distribution of Project Ridgeline materials. Project Ridgeline documents were watermarked "CONFIDENTIAL — DO NOT DISTRIBUTE" and tracked through a document management system that logged access and download activity.

B. The Rathore Group's Access to Confidential Information

23. All eight departing employees had direct and extensive access to Project Ridgeline materials and other confidential CRH information by virtue of their senior roles in the merchandising division. Their access was commensurate with their positions and responsibilities, and in each case, the employee's role required regular interaction with and use of the Company's most sensitive proprietary data.

24. Rathore, as Senior Vice President overseeing the entire merchandising division, had the broadest access of any employee to CRH's confidential and trade secret information. Rathore had unrestricted access to the full Project Ridgeline roadmap, including all five-year expansion plans and associated financial projections. She had access to vendor negotiation playbooks covering all product categories, all private-label cost models and margin analyses, and CRH's customer segmentation analytics. Rathore personally presented Project Ridgeline to CRH's Board of Directors on November 12, 2024, and led the executive strategy sessions at which the plan was discussed and refined. Rathore's knowledge of CRH's merchandising strategy is comprehensive, detailed, and current.

25. Derek Linden and Sonia Kaczmarek, as Vice Presidents of Hardlines Merchandising and Softlines Merchandising, respectively, had direct access to Project Ridgeline components in their respective product categories. They had detailed knowledge of vendor terms, pricing structures, margin targets, and category expansion plans within their divisions. Both Linden and Kaczmarek participated in the development of Project Ridgeline and attended executive strategy sessions at which the plan was discussed.

26. Amara Osei, as Director of Private Label Strategy, had access to all proprietary private-label sourcing strategies, cost models, manufacturing partner information, and margin targets. Osei was responsible for the development and management of CRH's private-label product lines, which represent a significant and growing portion of the Company's revenue and margin profile. Osei's knowledge extends to the identity and capabilities of CRH's private-label manufacturing partners, pricing and volume commitments, and planned product introductions for the next several years.

27. Brent Halvorsen, as Director of Seasonal Planning & Analytics, had access to CRH's proprietary seasonal buying algorithms and demand forecasting models. Halvorsen was instrumental in developing the quantitative models that underpin CRH's seasonal inventory procurement strategy. These algorithms incorporate years of historical sales data, proprietary consumer behavior analytics, and external data inputs, and represent a significant competitive advantage for CRH in optimizing inventory levels and minimizing markdown exposure.

28. Lucia Fernandez-Gill, as Director of Vendor Relations (Domestic), had extensive access to vendor negotiation term sheets, relationship data, and commercial terms for CRH's domestic vendor base. Fernandez-Gill maintained direct relationships with CRH's top domestic vendors and had detailed knowledge of pricing structures, volume commitments, rebate schedules, co-marketing arrangements, and contractual terms — information that, if disclosed to a competitor, could be used to undercut CRH's vendor relationships and negotiating leverage.

29. Nathan Tsao and Kira Johansson, as Senior Managers of eCommerce Merchandising and Category Analytics, respectively, had access to CRH's proprietary ecommerce assortment algorithms and customer segmentation data. Tsao was responsible for the digital merchandising strategy that drives CRH's online platform, and had detailed knowledge of the algorithms governing product selection, dynamic pricing, and promotional optimization. Johansson was responsible for customer segmentation analytics and had access to the proprietary data models used to identify, target, and retain CRH's most valuable customer segments across both physical and digital channels.

30. The information to which these eight employees had access is of immense competitive value and would provide a direct competitor with immediate and detailed insight into CRH's most closely guarded strategic plans, vendor economics, pricing models, and operational capabilities. Disclosure of this information to a competitor would enable the competitor to replicate CRH's strategies, undercut its vendor relationships, target its customer segments, and preempt its planned category expansions — all to CRH's significant and lasting detriment.

V. THE COORDINATED RESIGNATION

31. On Friday, February 7, 2025, at approximately 4:47 PM Pacific Standard Time, all eight members of the Rathore Group submitted simultaneous resignation letters via email to their respective managers and to CRH's Human Resources department. Each resignation was stated to be effective immediately. The resignation letters were brief and virtually identical in structure and language, each stating that the employee was resigning "to pursue other opportunities." None of the resignation letters identified the employee's prospective new employer or acknowledged the employee's ongoing restrictive covenant obligations.

32. The simultaneous nature of the resignations — all eight submitted at precisely the same time, on a Friday afternoon at the close of business — was plainly coordinated. The timing was evidently designed to minimize the opportunity for CRH to respond before the weekend and to maximize the disruption to CRH's operations by depriving the merchandising division of its entire senior leadership team in a single stroke.

33. On Monday, February 10, 2025, Chief People Officer Roland Ashby alerted me to the fact that all eight members of the senior merchandising leadership team had submitted simultaneous resignations the prior Friday evening. Ashby confirmed that the resignations were effective immediately and that none of the departing employees had provided the advance notice required under their respective employment agreements. I immediately recognized the significance and coordinated nature of the departures and initiated a review of the applicable employment agreements and restrictive covenants.

34. On February 12, 2025, I directed CRH's in-house legal team, working in coordination with the Company's IT department, to take two immediate steps: (a) confirm the existence, terms, and enforceability of the restrictive covenant provisions in each departing employee's employment agreement; and (b) conduct an internal audit of the departing employees' data access, download activity, and usage patterns on CRH's information systems during the period preceding their resignations. I also directed the IT department to immediately disable all access credentials associated with the departing employees' accounts and to preserve all relevant electronic records.

35. The IT audit identified anomalous data access and download patterns from CRH's Aldermere Systems and Pinnacle Health IT environments associated with the departing employees' accounts during the period from approximately January 10, 2025 through February 4, 2025. Specifically, the audit revealed a marked increase in file downloads and data exports from these accounts during this period — a period that, as described below, coincided with the recruitment of the departing employees by Verdana. The nature and volume of the files accessed and downloaded were highly unusual and inconsistent with the employees' ordinary workflow during prior comparable periods.

36. Based on the IT department's preliminary findings, approximately 14,327 files, totaling approximately 2.8 gigabytes ("GB") of data, were downloaded from CRH systems to personal cloud storage accounts (including personal Hollowell Health IT and Larkspur Technologies accounts) during this period. The downloaded files include, among other things, Project Ridgeline presentations and supporting materials, vendor negotiation term sheets, private-label cost models, customer segmentation data, seasonal buying algorithm documentation, and other proprietary merchandising analytics and planning documents. The scope and nature of the downloaded materials are described in greater detail in Section X below.

VI. VERDANA COMMERCE GROUP, INC. AS A DIRECT COMPETITOR

37. Verdana Commerce Group, Inc. ("Verdana" or "VCG") is a corporation organized and existing under the laws of the State of Delaware. Verdana is headquartered at 400 Christiana Gateway, Suite 700, Wilmington, Delaware 19801. Verdana is a privately held omnichannel retail and ecommerce company specializing in home goods, apparel, and seasonal décor. Verdana operates approximately 215 retail locations across 22 states and maintains an ecommerce platform.

38. Verdana's estimated annual revenue for fiscal year 2024 is approximately $1.9 billion. In the third quarter of 2023, Verdana was acquired by Greystone Capital Partners, LP, acting through its investment vehicle Greystone Capital Fund VII, LP, at an enterprise value of approximately $2.4 billion. Greystone holds a majority equity stake in Verdana and exercises significant control over the company's strategic direction, capital allocation, and senior leadership decisions. Elliot Westbrook serves as Managing Partner of Greystone Capital Partners and, on information and belief, is actively involved in Verdana's growth strategy.

39. Verdana directly competes with CRH in at least twenty-eight (28) overlapping product categories, including home goods, seasonal décor, private-label apparel, kitchen and dining, outdoor living, and several other categories. These overlapping categories represent the very core of CRH's merchandising strategy and are central to the growth plans articulated in Project Ridgeline. CRH and Verdana compete for the same customers, the same vendors, the same retail locations, and the same market share in these categories.

40. In January 2025, Verdana publicly announced a "transformational growth initiative" targeting $4 billion in revenue by 2028. The announcement, which appeared in a press release issued on January 15, 2025, specifically cited planned expansion into CRH's strongest categories, including private-label home goods and seasonal décor. This announced growth trajectory would more than double Verdana's current revenue and bring the company into direct, intensified competition with CRH in the very categories that are the focus of Project Ridgeline. The timing of Verdana's announcement — just weeks before the coordinated resignations — is, in my view, not coincidental.

41. CRH and Verdana are direct competitors. Any use by Verdana of CRH's confidential information, trade secrets, or strategic plans would cause direct, quantifiable, and in many respects irreparable harm to CRH's competitive position. The risk of such harm is dramatically heightened by the fact that Verdana has hired the entire senior leadership team of CRH's merchandising division — the very individuals who developed and possess the most detailed knowledge of CRH's proprietary merchandising strategies.

VII. VERDANA'S RECRUITMENT OF THE RATHORE GROUP AND PUBLIC ANNOUNCEMENT

42. On February 14, 2025, Verdana issued a press release titled "Verdana Commerce Welcomes Industry-Leading Merchandising Team to Accelerate Growth," publicly announcing the hiring of Priya Rathore and all seven other departing CRH employees. The press release praised the team's "deep expertise in omnichannel merchandising, vendor strategy, and data-driven retail," and described the hiring as a "cornerstone" of Verdana's growth initiative. A true and correct copy of this press release is attached hereto as Exhibit 9.

43. The press release announced that Rathore had been appointed President, Merchandising & Strategy at Verdana — a newly created position. The creation of this senior leadership role and the simultaneous hiring of seven additional merchandising professionals from CRH makes clear that Verdana's recruitment was not a matter of individual hiring decisions, but rather a deliberate and coordinated effort to acquire CRH's entire merchandising leadership team and, with them, CRH's proprietary knowledge and strategic capabilities.

44. Based on information and belief, informed by CRH's subsequent investigation conducted by Aurelian Investigations Group Inc. and by the forensic analysis of CRH-issued devices, the recruitment of the Rathore Group was orchestrated over a period of several weeks. Warren Dietrich, Chief Executive Officer of Verdana, and Elliot Westbrook, Managing Partner of Greystone Capital Partners, met with Rathore at a private dinner in New York City on January 6, 2025. On information and belief, this dinner was the occasion at which Verdana's recruitment proposal was first presented to Rathore, and at which the plan to recruit additional CRH merchandising personnel was discussed.

45. Rathore signed her offer letter with Verdana on January 27, 2025. The remaining seven employees signed offer letters with Verdana between January 28 and February 4, 2025. The aggregate sign-on bonuses for all eight employees totaled approximately $6,200,000, with Rathore alone receiving a sign-on bonus of $1,500,000. The extraordinary magnitude of these sign-on bonuses underscores the deliberate and well-funded nature of the recruitment effort, and is consistent with Verdana's and Greystone's intent to acquire not merely the general skills of these employees, but the specific institutional knowledge, vendor relationships, and strategic intelligence they developed at CRH.

46. Rathore's compensation package at Verdana, as described in her offer letter and related term sheet, includes a base salary of $650,000, a target annual bonus of $520,000 (representing 80% of her base salary), and an equity interest representing 1.5% of VCG's fully diluted equity. This compensation represents a significant premium over Rathore's CRH compensation — an increase of approximately 34% in base salary and approximately 79% in target bonus — and evidences Verdana's intent to acquire not merely Rathore's general skills and experience, but her specific institutional knowledge, strategic plans, vendor relationships, and the proprietary information she developed and had access to at CRH. The equity grant, in particular, aligns Rathore's financial interests with Verdana's growth trajectory, further incentivizing the use of CRH's competitive intelligence.

47. Between January 13 and January 24, 2025, members of the Rathore Group exchanged encrypted messages coordinating the timing and logistics of their departure from CRH. These messages were identified through forensic analysis of CRH-issued mobile devices conducted by Pinnacle Forensics LLC. Although the content of some encrypted messages could not be fully recovered, the metadata and unencrypted fragments recovered confirm that the departing employees were in regular communication regarding their simultaneous resignations and the transfer of CRH files to personal storage accounts during this period.

VIII. COMPETITIVE HARM AND IRREPARABLE INJURY TO CRH

48. The departure of the entire senior merchandising leadership team to a direct competitor has caused, and if not restrained will continue to cause, irreparable harm to CRH that cannot be adequately compensated by money damages alone. The harm to CRH is ongoing and will intensify with each day that the departing employees are permitted to work in merchandising roles at Verdana, bringing with them CRH's most closely guarded competitive intelligence.

49. The eight departing employees collectively held the deepest institutional knowledge of CRH's merchandising operations. They were the architects and custodians of Project Ridgeline and were intimately familiar with every aspect of CRH's merchandising strategy, vendor relationships, pricing models, private-label sourcing, and ecommerce assortment. Their simultaneous departure has left the merchandising division without its leadership, creating a significant operational and strategic void. Martin Cho, Vice President of Merchandising, is currently serving as interim acting Senior Vice President, Merchandising. While Mr. Cho is a capable executive, he was not previously a member of the inner circle with full access to Project Ridgeline, and the sudden loss of the entire senior leadership team has severely disrupted CRH's merchandising operations, including vendor negotiations, seasonal planning for the spring and summer 2025 seasons, and the ongoing execution of the category expansion roadmap.

50. The harm to CRH is substantially compounded by the fact that the departing employees have joined a direct competitor that is actively and publicly targeting expansion in CRH's strongest product categories. Verdana's announced growth initiative specifically targets the categories at the core of CRH's merchandising strategy and Project Ridgeline. The departing employees possess the very strategic roadmap, proprietary data, vendor intelligence, and operational playbooks that Verdana would need to execute its growth initiative at CRH's direct expense. The risk that CRH's proprietary information will be used by Verdana to replicate, undercut, or preempt CRH's strategies is not speculative — it is the obvious and foreseeable consequence of Verdana's deliberate recruitment of CRH's entire merchandising leadership team.

51. If the departing employees are permitted to work in merchandising roles at Verdana in violation of their restrictive covenants, CRH will suffer irreparable competitive injury, including but not limited to:

(a) Loss of the competitive advantage embodied in Project Ridgeline and related trade secrets, which represent years of investment and development effort and cannot be replicated or restored once disclosed to a competitor;

(b) Loss of vendor relationships cultivated over years through proprietary negotiation strategies, as Verdana could leverage CRH's confidential vendor terms, pricing thresholds, and rebate structures to poach CRH's vendors or extract more favorable terms at CRH's expense;

(c) Disruption to CRH's private-label business and seasonal planning operations, as the departing employees' knowledge of CRH's manufacturing partners, cost models, and seasonal buying algorithms could be used to replicate or undermine CRH's private-label product lines and inventory optimization strategies;

(d) Erosion of CRH's ecommerce market position through Verdana's use of CRH's proprietary algorithms and customer segmentation data to improve Verdana's own digital platform and target CRH's most valuable customer segments.

52. The nature of this harm — involving trade secrets, confidential strategic plans, proprietary algorithms, and key vendor and customer relationships — is inherently difficult to quantify and cannot be made whole through an award of monetary damages. Once CRH's trade secrets are disclosed to Verdana, the competitive advantage they confer is permanently lost. Once CRH's vendor relationships are undermined or its strategic plans preempted, no amount of monetary compensation can restore CRH to the position it would have occupied but for the breach. This constitutes classic irreparable injury of the kind routinely recognized by courts of equity as warranting injunctive relief.

53. CRH has retained Veltrano Consulting Group LLC, and specifically Dr. Franklin Oberg, a recognized expert in competitive damages and trade secret valuation, to quantify the economic damages CRH has suffered and will continue to suffer as a result of Defendants' conduct. However, even a full recovery of monetary damages cannot restore the competitive advantage lost from the disclosure of CRH's most sensitive strategic information to its direct competitor. Monetary damages, while substantial, are an inadequate remedy for the ongoing and compounding competitive harm that will result if Defendants are not restrained by this Court.

IX. CRH'S PROTECTIVE MEASURES AND ENFORCEMENT EFFORTS

54. CRH takes extensive and reasonable measures to protect its confidential information and trade secrets. These measures include, but are not limited to:

(a) Requiring all employees with access to sensitive information — including all members of the Rathore Group — to sign employment agreements containing restrictive covenant and confidentiality provisions as a condition of employment or promotion;

(b) Implementing role-based access controls on its Sundial Systems and Pinnacle Health IT systems, so that employees are granted access only to the confidential information necessary for their job functions;

(c) Maintaining written confidentiality policies distributed to all employees and requiring annual acknowledgment of those policies;

(d) Conducting regular training programs on information security, trade secret protection, and employees' obligations under their employment agreements;

(e) Restricting access to Project Ridgeline and related materials to senior merchandising personnel on a strict need-to-know basis, with fewer than twenty individuals granted access to the full Project Ridgeline materials;

(f) Watermarking confidential documents and tracking access and download activity through CRH's document management and logging systems.

55. Upon discovery of the coordinated departures, CRH acted promptly and diligently to investigate the circumstances and protect its interests. Specifically:

(a) On February 12, 2025, I confirmed the existence and enforceability of the restrictive covenant provisions in each departing employee's employment agreement;

(b) On February 18, 2025, CRH engaged Calderwood & Harkness LLP as outside litigation counsel to advise on enforcement of the restrictive covenants and potential claims arising from the coordinated departures;

(c) On February 20, 2025, CRH engaged Pinnacle Forensics LLC, a digital forensics firm, to conduct forensic imaging and data analysis of CRH-issued devices and systems used by the departing employees;

(d) On February 21, 2025, CRH engaged Aurelian Investigations Group Inc., a corporate investigations firm, to investigate the circumstances surrounding the coordinated departure, including the nature and timing of Verdana's recruitment efforts;

(e) On February 25, 2025, CRH, through counsel, sent cease-and-desist letters to all eight departing employees individually, to Verdana Commerce Group, Inc., and to Greystone Capital Partners, LP, demanding immediate compliance with the departing employees' restrictive covenant obligations, the return of all CRH confidential information and trade secrets, and the preservation of all relevant evidence. The letters specifically notified the recipients of the existence and terms of the departing employees' non-compete, non-solicitation, and confidentiality obligations and warned that CRH would seek judicial relief if those obligations were not honored.

56. Despite CRH's cease-and-desist demands, the Individual Defendants and Verdana have not complied. No departing employee has confirmed that he or she will honor the applicable restrictive covenant obligations. On information and belief, the departing employees have commenced or intend to commence work at Verdana in merchandising roles that directly and unambiguously violate the non-competition provisions of their employment agreements. Verdana has not responded to CRH's cease-and-desist letter and has not confirmed that it will refrain from employing the departing employees in prohibited roles. CRH's investigation is ongoing, but the evidence gathered to date confirms the urgent need for injunctive relief.

X. DATA EXFILTRATION

57. CRH's internal IT audit and the preliminary findings of Pinnacle Forensics LLC (Dr. Rajiv Anand, Engagement Lead) have confirmed that between January 10, 2025 and February 4, 2025, approximately 14,327 files totaling approximately 2.8 gigabytes of data were downloaded from CRH's Aldermere Systems and Pinnacle Health IT environments to personal cloud storage accounts — including personal Hollowell Health IT and Larkspur Technologies accounts — associated with members of the Rathore Group. This download activity was vastly disproportionate to any prior comparable period and is inconsistent with any legitimate business purpose.

58. Based on the preliminary forensic analysis, the downloaded files include, but are not limited to:

(a) Project Ridgeline strategic presentations and supporting materials, including the full five-year category expansion roadmap and associated financial projections;

(b) Vendor negotiation term sheets containing confidential pricing, rebate, and contractual terms for CRH's relationships with hundreds of vendors;

(c) Private-label cost models identifying manufacturing partners, raw material costs, production costs, margin targets, and planned product introductions;

(d) Customer segmentation data derived from CRH's proprietary analytics systems, including identification of CRH's highest-value customer cohorts and their purchasing patterns; and

(e) Other proprietary merchandising analytics and planning documents, including seasonal buying algorithm documentation, ecommerce assortment data, and competitive positioning analyses.

59. The timing of the data exfiltration is significant. The downloads commenced on approximately January 10, 2025, just four days after the January 6, 2025 dinner meeting between Rathore, Verdana CEO Warren Dietrich, and Greystone Managing Partner Elliot Westbrook at which, on information and belief, the recruitment proposal was first presented to Rathore. The downloads continued through February 4, 2025, just three days before the coordinated resignations on February 7, 2025. This timeline strongly suggests — and CRH believes the evidence will ultimately establish — that the departing employees systematically gathered CRH's most sensitive and competitively valuable information in anticipation of, and in preparation for, their coordinated departure to Verdana.

60. On information and belief, none of the departing employees had any legitimate business reason to download 14,327 files to personal cloud storage during this period. CRH's information security policies expressly prohibit the transfer of Company confidential information to personal devices or personal cloud storage accounts. The volume, nature, and timing of the downloads are wholly inconsistent with the employees' ordinary work activities and are consistent with the deliberate and systematic misappropriation of CRH's trade secrets and confidential business information. CRH's forensic investigation is continuing, and I anticipate that additional evidence of data exfiltration and misuse may be uncovered.

XI. CONCLUSION AND REQUEST FOR RELIEF

61. For all of the foregoing reasons, and based on the facts set forth in this Declaration, CRH respectfully requests that this Court grant a Temporary Restraining Order and Preliminary Injunction restraining all eight Individual Defendants — Priya Rathore, Derek Linden, Sonia Kaczmarek, Amara Osei, Brent Halvorsen, Lucia Fernandez-Gill, Nathan Tsao, and Kira Johansson — from commencing or continuing employment in any merchandising, strategy, vendor management, or related role at Verdana Commerce Group, Inc. (or any affiliate, parent, or subsidiary thereof) during the pendency of this action and for the duration of their respective non-competition periods as set forth in their employment agreements with CRH.

62. CRH further respectfully requests that the Court enter an order requiring all Individual Defendants and Verdana Commerce Group, Inc. to immediately return to CRH all confidential information and trade secrets of CRH in their possession, custody, or control, in whatever form or medium, and to certify under oath that all such materials have been returned and that no copies have been retained. CRH further requests that the Court order all Defendants to preserve all evidence of data transfers, file downloads, communications (including encrypted messages), and any other materials relating to the recruitment of the Rathore Group, the coordinated resignations, and the use or disclosure of CRH confidential information.

63. CRH is prepared to post an appropriate injunction bond as may be required by the Court under the circumstances.

I declare under penalty of perjury under the laws of the State of Delaware that the foregoing is true and correct.

Executed on March 5, 2025, at Seattle, Washington.

________________________________________

Theresa Yun-Park General Counsel Cascade Retail Holdings Inc. 2200 Elliott Avenue West, Suite 3400 Seattle, WA 98119

EXHIBIT LIST

The following exhibits are referenced in this Declaration. True and correct copies are filed contemporaneously herewith as separate attachments.

CERTIFICATE OF SERVICE

I, Bernard Crawford, hereby certify that on March 5, 2025, a true and correct copy of the foregoing Declaration of Theresa Yun-Park in Support of Plaintiff's Motion for Temporary Restraining Order and Preliminary Injunction, together with all exhibits referenced therein, was served upon the following counsel of record by electronic filing through the Court's electronic filing system and by email:

Catherine Nygaard, Esquire Whitfield, Nygaard & Doyle LLP 1000 North Market Street, Suite 1500 Wilmington, DE 19801 cnygaard@wndlaw.com Counsel for the Individual Defendants (the "Rathore Group")

Gavin Blackhall, Esquire Blackhall & Soren LLP 300 Delaware Avenue, Suite 900 Wilmington, DE 19801 gblackhall@blackhallsoren.com Counsel for Defendant Verdana Commerce Group, Inc.

________________________________________

Bernard Crawford (Bar No. 5831) CALDERWOOD & HARKNESS LLP 1301 K Street NW, Suite 1200 Washington, DC 20005 Telephone: (202) 555-7400 Facsimile: (202) 555-7401 bcrawford@calderwoodharkness.com

Counsel for Plaintiff Cascade Retail Holdings Inc.

CASCADE RETAIL HOLDINGS INC.,

Plaintiff,

PRIYA RATHORE, DEREK LINDEN, SONIA KACZMAREK, AMARA OSEI, BRENT HALVORSEN, LUCIA FERNANDEZ-GILL, NATHAN TSAO, KIRA JOHANSSON, and VERDANA COMMERCE GROUP, INC.,

Defendants.

Exhibit No.	Description
Exhibit 1	Amended and Restated Employment Agreement of Priya Rathore (dated March 15, 2021)
Exhibit 2	Employment Agreement of Derek Linden
Exhibit 3	Employment Agreement of Sonia Kaczmarek
Exhibit 4	Employment Agreement of Amara Osei
Exhibit 5	Employment Agreement of Brent Halvorsen
Exhibit 6	Employment Agreement of Lucia Fernandez-Gill
Exhibit 7	Employment Agreement of Nathan Tsao
Exhibit 8	Employment Agreement of Kira Johansson
Exhibit 9	Verdana Commerce Group, Inc. Press Release dated February 14, 2025 ("Verdana Commerce Welcomes Industry-Leading Merchandising Team to Accelerate Growth")
Exhibit 10	CRH Organizational Chart — Merchandising Division (Pre-Departure)

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
DECLARATION OF THERESA YUN-PARK IN SUPPORT OF PLAINTIFF'S MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION
I, Theresa Yun-Park, hereby declare and state as follows, pursuant to 10 Del. C. § 3927, under penalty of perjury:
I am the General Counsel of Cascade Retail Holdings Inc. ("CRH" or the "Company"). I submit this Declaration in support of CRH's Motion for a Temporary Restraining Order and Preliminary Injunction against Defendants Priya Rathore, Derek Linden, Sonia Kaczmarek, Amara Osei, Brent Halvorsen, Lucia Fernandez-Gill, Nathan Tsao, Kira Johansson (collectively, the "Individual Defendants" or the "Rathore Group"), and Verdana Commerce Group, Inc. ("Verdana" or "VCG"). I have personal knowledge of the facts set forth herein, or have obtained them through my role as General Counsel of CRH and through my review of CRH's business records maintained in the ordinary course of business. I am competent to testify to these matters if called as a witness. This Declaration is filed on March 5, 2025.
I. BACKGROUND OF THE DECLARANT
1. My full name is Theresa Yun-Park. I serve as the General Counsel of Cascade Retail Holdings Inc. I have held this position continuously since January 2018.
2. I joined CRH in January 2018. Throughout the entire period relevant to this action — from at least January 2025 through the present — I have served as the Company's General Counsel and have been actively involved in the matters described herein.
3. As General Counsel, my responsibilities include overseeing all legal affairs of the Company. This encompasses, among other areas, employment law matters, intellectual property protection, corporate governance, litigation management, regulatory compliance, mergers and acquisitions, and the negotiation and administration of commercial agreements. I supervise a team of twelve in-house attorneys and several paralegals and legal operations professionals.
4. I report directly to Marcus Langford, the Chief Executive Officer of CRH. In the ordinary course of my duties, I work closely with Roland Ashby, the Chief People Officer, as well as business unit leaders across the organization, including those in the merchandising division. I regularly interface with CRH's Board of Directors and its Audit Committee on matters involving legal risk, compliance, and litigation.
5. In my capacity as General Counsel, I am thoroughly familiar with the Company's employment agreements, confidentiality policies, trade secret protections, and the events giving rise to this action. I have personally reviewed and approved the form of employment agreement used for senior executives and directors within CRH, including the restrictive covenant provisions contained therein. I am also familiar with the circumstances surrounding the coordinated resignations of the eight Individual Defendants and their subsequent employment by Verdana Commerce Group, Inc., as described in detail below.
II. OVERVIEW OF CASCADE RETAIL HOLDINGS INC.
6. CRH is a corporation organized and existing under the laws of the State of Delaware. The Company is headquartered at 2200 Elliott Avenue West, Suite 3400, Seattle, Washington 98119. CRH is publicly traded on the Nasdaq Stock Market under the ticker symbol "CRHL."
7. CRH is an omnichannel retail and ecommerce company. The Company operates 387 brick-and-mortar retail locations across 34 states, as well as a robust direct-to-consumer ecommerce platform accessible at www.cascaderetail.com. CRH's retail operations span multiple product categories, including home goods, apparel, seasonal décor, hardlines, softlines, and private-label merchandise. The Company serves millions of customers annually through both its physical stores and its digital platform, and its business model depends upon the seamless integration of its in-store and online channels.
8. For fiscal year 2024 (ending January 31, 2025), CRH generated approximately $6.82 billion in total revenue. As of late February 2025, CRH's approximate market capitalization was approximately $4.1 billion. CRH employs approximately 47,000 individuals across its corporate headquarters, regional offices, distribution centers, and retail locations.
9. CRH's merchandising division is the core engine of the Company's business. The merchandising division is responsible for product selection, vendor negotiations, private-label development, seasonal planning, pricing strategy, and ecommerce assortment strategy. In fiscal year 2024, the merchandising division generated approximately $2.3 billion in gross merchandise value. The performance and strategic direction of the merchandising division are critical to CRH's competitive positioning, revenue growth, and profitability. CRH has invested hundreds of millions of dollars over many years to develop the merchandising capabilities, vendor relationships, data analytics infrastructure, and proprietary strategies that drive this division's performance.
10. The merchandising division's competitive advantage rests on proprietary information that is not publicly available and that CRH takes extensive measures to protect. This proprietary information includes, but is not limited to: (a) vendor negotiation playbooks containing CRH's negotiation strategies, pricing thresholds, and contractual terms with hundreds of vendors; (b) seasonal buying algorithms developed over multiple years at significant expense; (c) private-label sourcing strategies, including detailed cost models and margin targets; (d) ecommerce assortment algorithms that optimize product selection and pricing for the Company's online platform; (e) customer segmentation data derived from CRH's proprietary analytics systems; and (f) a confidential five-year category expansion roadmap that identifies the specific product categories, geographic markets, and timetables for CRH's planned growth over the next five years. This information, individually and collectively, represents the product of substantial investment in time, resources, and expertise, and constitutes trade secrets and confidential business information of immense competitive value.
III. THE DEPARTING EMPLOYEES AND THEIR EMPLOYMENT AGREEMENTS
A. Priya Rathore
11. Priya Rathore joined CRH on June 3, 2019, as Vice President, Merchandising Strategy. On that date, Rathore executed an Employment Agreement with CRH containing restrictive covenant provisions, including non-competition, non-solicitation, and perpetual confidentiality obligations, all governed by the laws of the State of Delaware. The execution of the Employment Agreement was a condition of Rathore's employment with CRH, and Rathore acknowledged in writing that the restrictive covenants were reasonable and necessary to protect CRH's legitimate business interests.
12. On March 15, 2021, Rathore was promoted to Senior Vice President, Merchandising. In connection with her promotion, Rathore executed an Amended and Restated Employment Agreement on that same date. The Amended and Restated Employment Agreement contains substantively identical restrictive covenant provisions to those in her original Employment Agreement, and was supported by additional, independent consideration. Specifically, in connection with the promotion and the execution of the Amended and Restated Employment Agreement, Rathore received a $150,000 promotion bonus and an enhanced restricted stock unit ("RSU") grant valued at approximately $725,000, with a four-year ratable vesting schedule. Rathore acknowledged in writing that the additional consideration was adequate and that the restrictive covenants set forth in the Amended and Restated Employment Agreement were reasonable and enforceable.
13. Under the terms of Rathore's Amended and Restated Employment Agreement, her restrictive covenant obligations include: (a) an eighteen (18)-month post-termination non-competition restriction, which prohibits Rathore from working for, consulting with, or otherwise providing services to any competitor of CRH in the omnichannel retail or ecommerce space anywhere in the United States; (b) a twenty-four (24)-month non-solicitation provision, which prohibits Rathore from directly or indirectly soliciting, recruiting, or hiring any CRH employee, or soliciting or diverting business from any CRH vendor or customer; and (c) perpetual confidentiality obligations prohibiting the disclosure, use, or misappropriation of CRH proprietary information and trade secrets at any time during or after her employment.
14. Rathore's fiscal year 2024 compensation at CRH consisted of a base salary of $485,000, a target annual bonus of $290,000 (representing approximately 60% of her base salary), and unvested RSUs. As of her resignation date of February 7, 2025, approximately $362,500 in RSUs remained unvested and subject to forfeiture or clawback under the terms of her Amended and Restated Employment Agreement. The forfeiture provisions of the agreement expressly provide that unvested RSUs are forfeited upon voluntary termination, and that RSUs vested within the twelve months preceding a breach of the restrictive covenants are subject to clawback.
15. As Senior Vice President, Merchandising, Rathore was the most senior merchandising executive at CRH. She had direct oversight of all merchandising strategy, vendor relationships, private-label programs, and category planning across the Company's entire retail and ecommerce platform. Rathore reported directly to CEO Marcus Langford and participated in executive leadership meetings, board presentations, and strategic planning sessions. She was the principal architect of CRH's merchandising strategy and served as the executive sponsor of Project Ridgeline, described in Section IV below. All other members of the Rathore Group reported directly or indirectly to Rathore.
B. The Other Seven Departing Employees (the "Rathore Group")
16. In addition to Rathore, seven other senior merchandising employees resigned from CRH simultaneously on February 7, 2025. Each of these employees had executed an employment agreement with CRH containing restrictive covenant provisions governed by the laws of the State of Delaware, including non-competition, non-solicitation, and perpetual confidentiality obligations. In each case, the execution of the employment agreement was a condition of employment or promotion, and each employee received substantial consideration in connection with the agreement, including base salary, bonus eligibility, and equity compensation.
17. The seven additional departing employees, together with their titles, tenure, base compensation, and non-compete terms, are as follows:
(a) Derek Linden — Vice President, Hardlines Merchandising. Linden was employed by CRH for approximately seven (7) years. His base salary was $340,000. His employment agreement contains an eighteen (18)-month post-termination non-competition restriction.
(b) Sonia Kaczmarek — Vice President, Softlines Merchandising. Kaczmarek was employed by CRH for approximately five (5) years. Her base salary was $325,000. Her employment agreement contains an eighteen (18)-month post-termination non-competition restriction.
(c) Amara Osei — Director, Private Label Strategy. Osei was employed by CRH for approximately four (4) years. Her base salary was $265,000. Her employment agreement contains a twelve (12)-month post-termination non-competition restriction.
(d) Brent Halvorsen — Director, Seasonal Planning & Analytics. Halvorsen was employed by CRH for approximately six (6) years. His base salary was $258,000. His employment agreement contains a twelve (12)-month post-termination non-competition restriction.
(e) Lucia Fernandez-Gill — Director, Vendor Relations (Domestic). Fernandez-Gill was employed by CRH for approximately five (5) years. Her base salary was $248,000. Her employment agreement contains a twelve (12)-month post-termination non-competition restriction.
(f) Nathan Tsao — Senior Manager, eCommerce Merchandising. Tsao was employed by CRH for approximately three (3) years. His base salary was $195,000. His employment agreement contains a twelve (12)-month post-termination non-competition restriction.
(g) Kira Johansson — Senior Manager, Category Analytics. Johansson was employed by CRH for approximately four (4) years. Her base salary was $192,000. Her employment agreement contains a twelve (12)-month post-termination non-competition restriction.
18. The non-solicitation periods for the seven employees listed above range from eighteen (18) to twenty-four (24) months, depending on the employee's seniority and the terms of the applicable employment agreement. All eight departing employees — Rathore and the seven listed above — are subject to perpetual confidentiality obligations regarding CRH's proprietary information and trade secrets.
19. A true and correct copy of Rathore's Amended and Restated Employment Agreement dated March 15, 2021, is attached hereto as Exhibit 1. Representative copies of the employment agreements of the other seven departing employees are attached hereto as Exhibits 2 through 8, respectively.
IV. PROJECT RIDGELINE AND ACCESS TO CONFIDENTIAL AND TRADE SECRET INFORMATION
A. Description of Project Ridgeline
20. In or about October 2024, CRH's merchandising division completed a comprehensive, five-year strategic category expansion plan known internally as "Project Ridgeline." Project Ridgeline was developed over an approximately eighteen-month period at substantial cost and represented the culmination of extensive market research, data analysis, vendor outreach, competitive intelligence, and strategic planning conducted by senior merchandising leadership under Rathore's direction. The development of Project Ridgeline involved the expenditure of millions of dollars in internal resources and external consulting fees.
21. Project Ridgeline encompasses the following categories of proprietary and trade secret information: (a) proprietary vendor negotiation playbooks detailing CRH's negotiation strategies, pricing thresholds, contractual terms, volume-based rebate structures, and relationship management protocols with hundreds of vendors across all product categories; (b) seasonal buying algorithms developed over multiple years at significant expense, which enable CRH to optimize inventory procurement timing, quantities, and pricing based on historical sales patterns, weather data, macroeconomic indicators, and consumer behavior models; (c) private-label sourcing strategies, including detailed cost models identifying manufacturing partners, raw material costs, production lead times, quality benchmarks, and target margin structures for CRH's private-label product lines; (d) ecommerce assortment algorithms that govern product selection, dynamic pricing, promotional strategy, and personalization across CRH's digital platform; and (e) a confidential category expansion roadmap identifying specific product categories, geographic markets, target consumer demographics, competitive positioning strategies, capital expenditure requirements, and timetables for CRH's planned growth over the next five years.
22. Project Ridgeline was treated as highly confidential within CRH. Access to Project Ridgeline materials was restricted to senior merchandising leadership on a strict need-to-know basis. The materials were stored on CRH's secure Sundial Systems environment, protected by multi-factor authentication and role-based access controls. Only a limited number of employees — fewer than twenty individuals across the entire Company — were granted access to the full Project Ridgeline materials. Employees with access to Project Ridgeline were required to acknowledge CRH's confidentiality policies, and reminders of their confidentiality obligations were communicated in connection with the distribution of Project Ridgeline materials. Project Ridgeline documents were watermarked "CONFIDENTIAL — DO NOT DISTRIBUTE" and tracked through a document management system that logged access and download activity.
B. The Rathore Group's Access to Confidential Information
23. All eight departing employees had direct and extensive access to Project Ridgeline materials and other confidential CRH information by virtue of their senior roles in the merchandising division. Their access was commensurate with their positions and responsibilities, and in each case, the employee's role required regular interaction with and use of the Company's most sensitive proprietary data.
24. Rathore, as Senior Vice President overseeing the entire merchandising division, had the broadest access of any employee to CRH's confidential and trade secret information. Rathore had unrestricted access to the full Project Ridgeline roadmap, including all five-year expansion plans and associated financial projections. She had access to vendor negotiation playbooks covering all product categories, all private-label cost models and margin analyses, and CRH's customer segmentation analytics. Rathore personally presented Project Ridgeline to CRH's Board of Directors on November 12, 2024, and led the executive strategy sessions at which the plan was discussed and refined. Rathore's knowledge of CRH's merchandising strategy is comprehensive, detailed, and current.
25. Derek Linden and Sonia Kaczmarek, as Vice Presidents of Hardlines Merchandising and Softlines Merchandising, respectively, had direct access to Project Ridgeline components in their respective product categories. They had detailed knowledge of vendor terms, pricing structures, margin targets, and category expansion plans within their divisions. Both Linden and Kaczmarek participated in the development of Project Ridgeline and attended executive strategy sessions at which the plan was discussed.
26. Amara Osei, as Director of Private Label Strategy, had access to all proprietary private-label sourcing strategies, cost models, manufacturing partner information, and margin targets. Osei was responsible for the development and management of CRH's private-label product lines, which represent a significant and growing portion of the Company's revenue and margin profile. Osei's knowledge extends to the identity and capabilities of CRH's private-label manufacturing partners, pricing and volume commitments, and planned product introductions for the next several years.
27. Brent Halvorsen, as Director of Seasonal Planning & Analytics, had access to CRH's proprietary seasonal buying algorithms and demand forecasting models. Halvorsen was instrumental in developing the quantitative models that underpin CRH's seasonal inventory procurement strategy. These algorithms incorporate years of historical sales data, proprietary consumer behavior analytics, and external data inputs, and represent a significant competitive advantage for CRH in optimizing inventory levels and minimizing markdown exposure.
28. Lucia Fernandez-Gill, as Director of Vendor Relations (Domestic), had extensive access to vendor negotiation term sheets, relationship data, and commercial terms for CRH's domestic vendor base. Fernandez-Gill maintained direct relationships with CRH's top domestic vendors and had detailed knowledge of pricing structures, volume commitments, rebate schedules, co-marketing arrangements, and contractual terms — information that, if disclosed to a competitor, could be used to undercut CRH's vendor relationships and negotiating leverage.
29. Nathan Tsao and Kira Johansson, as Senior Managers of eCommerce Merchandising and Category Analytics, respectively, had access to CRH's proprietary ecommerce assortment algorithms and customer segmentation data. Tsao was responsible for the digital merchandising strategy that drives CRH's online platform, and had detailed knowledge of the algorithms governing product selection, dynamic pricing, and promotional optimization. Johansson was responsible for customer segmentation analytics and had access to the proprietary data models used to identify, target, and retain CRH's most valuable customer segments across both physical and digital channels.
30. The information to which these eight employees had access is of immense competitive value and would provide a direct competitor with immediate and detailed insight into CRH's most closely guarded strategic plans, vendor economics, pricing models, and operational capabilities. Disclosure of this information to a competitor would enable the competitor to replicate CRH's strategies, undercut its vendor relationships, target its customer segments, and preempt its planned category expansions — all to CRH's significant and lasting detriment.
V. THE COORDINATED RESIGNATION
31. On Friday, February 7, 2025, at approximately 4:47 PM Pacific Standard Time, all eight members of the Rathore Group submitted simultaneous resignation letters via email to their respective managers and to CRH's Human Resources department. Each resignation was stated to be effective immediately. The resignation letters were brief and virtually identical in structure and language, each stating that the employee was resigning "to pursue other opportunities." None of the resignation letters identified the employee's prospective new employer or acknowledged the employee's ongoing restrictive covenant obligations.
32. The simultaneous nature of the resignations — all eight submitted at precisely the same time, on a Friday afternoon at the close of business — was plainly coordinated. The timing was evidently designed to minimize the opportunity for CRH to respond before the weekend and to maximize the disruption to CRH's operations by depriving the merchandising division of its entire senior leadership team in a single stroke.
33. On Monday, February 10, 2025, Chief People Officer Roland Ashby alerted me to the fact that all eight members of the senior merchandising leadership team had submitted simultaneous resignations the prior Friday evening. Ashby confirmed that the resignations were effective immediately and that none of the departing employees had provided the advance notice required under their respective employment agreements. I immediately recognized the significance and coordinated nature of the departures and initiated a review of the applicable employment agreements and restrictive covenants.
34. On February 12, 2025, I directed CRH's in-house legal team, working in coordination with the Company's IT department, to take two immediate steps: (a) confirm the existence, terms, and enforceability of the restrictive covenant provisions in each departing employee's employment agreement; and (b) conduct an internal audit of the departing employees' data access, download activity, and usage patterns on CRH's information systems during the period preceding their resignations. I also directed the IT department to immediately disable all access credentials associated with the departing employees' accounts and to preserve all relevant electronic records.
35. The IT audit identified anomalous data access and download patterns from CRH's Aldermere Systems and Pinnacle Health IT environments associated with the departing employees' accounts during the period from approximately January 10, 2025 through February 4, 2025. Specifically, the audit revealed a marked increase in file downloads and data exports from these accounts during this period — a period that, as described below, coincided with the recruitment of the departing employees by Verdana. The nature and volume of the files accessed and downloaded were highly unusual and inconsistent with the employees' ordinary workflow during prior comparable periods.
36. Based on the IT department's preliminary findings, approximately 14,327 files, totaling approximately 2.8 gigabytes ("GB") of data, were downloaded from CRH systems to personal cloud storage accounts (including personal Hollowell Health IT and Larkspur Technologies accounts) during this period. The downloaded files include, among other things, Project Ridgeline presentations and supporting materials, vendor negotiation term sheets, private-label cost models, customer segmentation data, seasonal buying algorithm documentation, and other proprietary merchandising analytics and planning documents. The scope and nature of the downloaded materials are described in greater detail in Section X below.
VI. VERDANA COMMERCE GROUP, INC. AS A DIRECT COMPETITOR
37. Verdana Commerce Group, Inc. ("Verdana" or "VCG") is a corporation organized and existing under the laws of the State of Delaware. Verdana is headquartered at 400 Christiana Gateway, Suite 700, Wilmington, Delaware 19801. Verdana is a privately held omnichannel retail and ecommerce company specializing in home goods, apparel, and seasonal décor. Verdana operates approximately 215 retail locations across 22 states and maintains an ecommerce platform.
38. Verdana's estimated annual revenue for fiscal year 2024 is approximately $1.9 billion. In the third quarter of 2023, Verdana was acquired by Greystone Capital Partners, LP, acting through its investment vehicle Greystone Capital Fund VII, LP, at an enterprise value of approximately $2.4 billion. Greystone holds a majority equity stake in Verdana and exercises significant control over the company's strategic direction, capital allocation, and senior leadership decisions. Elliot Westbrook serves as Managing Partner of Greystone Capital Partners and, on information and belief, is actively involved in Verdana's growth strategy.
39. Verdana directly competes with CRH in at least twenty-eight (28) overlapping product categories, including home goods, seasonal décor, private-label apparel, kitchen and dining, outdoor living, and several other categories. These overlapping categories represent the very core of CRH's merchandising strategy and are central to the growth plans articulated in Project Ridgeline. CRH and Verdana compete for the same customers, the same vendors, the same retail locations, and the same market share in these categories.
40. In January 2025, Verdana publicly announced a "transformational growth initiative" targeting $4 billion in revenue by 2028. The announcement, which appeared in a press release issued on January 15, 2025, specifically cited planned expansion into CRH's strongest categories, including private-label home goods and seasonal décor. This announced growth trajectory would more than double Verdana's current revenue and bring the company into direct, intensified competition with CRH in the very categories that are the focus of Project Ridgeline. The timing of Verdana's announcement — just weeks before the coordinated resignations — is, in my view, not coincidental.
41. CRH and Verdana are direct competitors. Any use by Verdana of CRH's confidential information, trade secrets, or strategic plans would cause direct, quantifiable, and in many respects irreparable harm to CRH's competitive position. The risk of such harm is dramatically heightened by the fact that Verdana has hired the entire senior leadership team of CRH's merchandising division — the very individuals who developed and possess the most detailed knowledge of CRH's proprietary merchandising strategies.
VII. VERDANA'S RECRUITMENT OF THE RATHORE GROUP AND PUBLIC ANNOUNCEMENT
42. On February 14, 2025, Verdana issued a press release titled "Verdana Commerce Welcomes Industry-Leading Merchandising Team to Accelerate Growth," publicly announcing the hiring of Priya Rathore and all seven other departing CRH employees. The press release praised the team's "deep expertise in omnichannel merchandising, vendor strategy, and data-driven retail," and described the hiring as a "cornerstone" of Verdana's growth initiative. A true and correct copy of this press release is attached hereto as Exhibit 9.
43. The press release announced that Rathore had been appointed President, Merchandising & Strategy at Verdana — a newly created position. The creation of this senior leadership role and the simultaneous hiring of seven additional merchandising professionals from CRH makes clear that Verdana's recruitment was not a matter of individual hiring decisions, but rather a deliberate and coordinated effort to acquire CRH's entire merchandising leadership team and, with them, CRH's proprietary knowledge and strategic capabilities.
44. Based on information and belief, informed by CRH's subsequent investigation conducted by Aurelian Investigations Group Inc. and by the forensic analysis of CRH-issued devices, the recruitment of the Rathore Group was orchestrated over a period of several weeks. Warren Dietrich, Chief Executive Officer of Verdana, and Elliot Westbrook, Managing Partner of Greystone Capital Partners, met with Rathore at a private dinner in New York City on January 6, 2025. On information and belief, this dinner was the occasion at which Verdana's recruitment proposal was first presented to Rathore, and at which the plan to recruit additional CRH merchandising personnel was discussed.
45. Rathore signed her offer letter with Verdana on January 27, 2025. The remaining seven employees signed offer letters with Verdana between January 28 and February 4, 2025. The aggregate sign-on bonuses for all eight employees totaled approximately $6,200,000, with Rathore alone receiving a sign-on bonus of $1,500,000. The extraordinary magnitude of these sign-on bonuses underscores the deliberate and well-funded nature of the recruitment effort, and is consistent with Verdana's and Greystone's intent to acquire not merely the general skills of these employees, but the specific institutional knowledge, vendor relationships, and strategic intelligence they developed at CRH.
46. Rathore's compensation package at Verdana, as described in her offer letter and related term sheet, includes a base salary of $650,000, a target annual bonus of $520,000 (representing 80% of her base salary), and an equity interest representing 1.5% of VCG's fully diluted equity. This compensation represents a significant premium over Rathore's CRH compensation — an increase of approximately 34% in base salary and approximately 79% in target bonus — and evidences Verdana's intent to acquire not merely Rathore's general skills and experience, but her specific institutional knowledge, strategic plans, vendor relationships, and the proprietary information she developed and had access to at CRH. The equity grant, in particular, aligns Rathore's financial interests with Verdana's growth trajectory, further incentivizing the use of CRH's competitive intelligence.
47. Between January 13 and January 24, 2025, members of the Rathore Group exchanged encrypted messages coordinating the timing and logistics of their departure from CRH. These messages were identified through forensic analysis of CRH-issued mobile devices conducted by Pinnacle Forensics LLC. Although the content of some encrypted messages could not be fully recovered, the metadata and unencrypted fragments recovered confirm that the departing employees were in regular communication regarding their simultaneous resignations and the transfer of CRH files to personal storage accounts during this period.
VIII. COMPETITIVE HARM AND IRREPARABLE INJURY TO CRH
48. The departure of the entire senior merchandising leadership team to a direct competitor has caused, and if not restrained will continue to cause, irreparable harm to CRH that cannot be adequately compensated by money damages alone. The harm to CRH is ongoing and will intensify with each day that the departing employees are permitted to work in merchandising roles at Verdana, bringing with them CRH's most closely guarded competitive intelligence.
49. The eight departing employees collectively held the deepest institutional knowledge of CRH's merchandising operations. They were the architects and custodians of Project Ridgeline and were intimately familiar with every aspect of CRH's merchandising strategy, vendor relationships, pricing models, private-label sourcing, and ecommerce assortment. Their simultaneous departure has left the merchandising division without its leadership, creating a significant operational and strategic void. Martin Cho, Vice President of Merchandising, is currently serving as interim acting Senior Vice President, Merchandising. While Mr. Cho is a capable executive, he was not previously a member of the inner circle with full access to Project Ridgeline, and the sudden loss of the entire senior leadership team has severely disrupted CRH's merchandising operations, including vendor negotiations, seasonal planning for the spring and summer 2025 seasons, and the ongoing execution of the category expansion roadmap.
50. The harm to CRH is substantially compounded by the fact that the departing employees have joined a direct competitor that is actively and publicly targeting expansion in CRH's strongest product categories. Verdana's announced growth initiative specifically targets the categories at the core of CRH's merchandising strategy and Project Ridgeline. The departing employees possess the very strategic roadmap, proprietary data, vendor intelligence, and operational playbooks that Verdana would need to execute its growth initiative at CRH's direct expense. The risk that CRH's proprietary information will be used by Verdana to replicate, undercut, or preempt CRH's strategies is not speculative — it is the obvious and foreseeable consequence of Verdana's deliberate recruitment of CRH's entire merchandising leadership team.
51. If the departing employees are permitted to work in merchandising roles at Verdana in violation of their restrictive covenants, CRH will suffer irreparable competitive injury, including but not limited to:
(a) Loss of the competitive advantage embodied in Project Ridgeline and related trade secrets, which represent years of investment and development effort and cannot be replicated or restored once disclosed to a competitor;
(b) Loss of vendor relationships cultivated over years through proprietary negotiation strategies, as Verdana could leverage CRH's confidential vendor terms, pricing thresholds, and rebate structures to poach CRH's vendors or extract more favorable terms at CRH's expense;
(c) Disruption to CRH's private-label business and seasonal planning operations, as the departing employees' knowledge of CRH's manufacturing partners, cost models, and seasonal buying algorithms could be used to replicate or undermine CRH's private-label product lines and inventory optimization strategies;
(d) Erosion of CRH's ecommerce market position through Verdana's use of CRH's proprietary algorithms and customer segmentation data to improve Verdana's own digital platform and target CRH's most valuable customer segments.
52. The nature of this harm — involving trade secrets, confidential strategic plans, proprietary algorithms, and key vendor and customer relationships — is inherently difficult to quantify and cannot be made whole through an award of monetary damages. Once CRH's trade secrets are disclosed to Verdana, the competitive advantage they confer is permanently lost. Once CRH's vendor relationships are undermined or its strategic plans preempted, no amount of monetary compensation can restore CRH to the position it would have occupied but for the breach. This constitutes classic irreparable injury of the kind routinely recognized by courts of equity as warranting injunctive relief.
53. CRH has retained Veltrano Consulting Group LLC, and specifically Dr. Franklin Oberg, a recognized expert in competitive damages and trade secret valuation, to quantify the economic damages CRH has suffered and will continue to suffer as a result of Defendants' conduct. However, even a full recovery of monetary damages cannot restore the competitive advantage lost from the disclosure of CRH's most sensitive strategic information to its direct competitor. Monetary damages, while substantial, are an inadequate remedy for the ongoing and compounding competitive harm that will result if Defendants are not restrained by this Court.
IX. CRH'S PROTECTIVE MEASURES AND ENFORCEMENT EFFORTS
54. CRH takes extensive and reasonable measures to protect its confidential information and trade secrets. These measures include, but are not limited to:
(a) Requiring all employees with access to sensitive information — including all members of the Rathore Group — to sign employment agreements containing restrictive covenant and confidentiality provisions as a condition of employment or promotion;
(b) Implementing role-based access controls on its Sundial Systems and Pinnacle Health IT systems, so that employees are granted access only to the confidential information necessary for their job functions;
(c) Maintaining written confidentiality policies distributed to all employees and requiring annual acknowledgment of those policies;
(d) Conducting regular training programs on information security, trade secret protection, and employees' obligations under their employment agreements;
(e) Restricting access to Project Ridgeline and related materials to senior merchandising personnel on a strict need-to-know basis, with fewer than twenty individuals granted access to the full Project Ridgeline materials;
(f) Watermarking confidential documents and tracking access and download activity through CRH's document management and logging systems.
55. Upon discovery of the coordinated departures, CRH acted promptly and diligently to investigate the circumstances and protect its interests. Specifically:
(a) On February 12, 2025, I confirmed the existence and enforceability of the restrictive covenant provisions in each departing employee's employment agreement;
(b) On February 18, 2025, CRH engaged Calderwood & Harkness LLP as outside litigation counsel to advise on enforcement of the restrictive covenants and potential claims arising from the coordinated departures;
(c) On February 20, 2025, CRH engaged Pinnacle Forensics LLC, a digital forensics firm, to conduct forensic imaging and data analysis of CRH-issued devices and systems used by the departing employees;
(d) On February 21, 2025, CRH engaged Aurelian Investigations Group Inc., a corporate investigations firm, to investigate the circumstances surrounding the coordinated departure, including the nature and timing of Verdana's recruitment efforts;
(e) On February 25, 2025, CRH, through counsel, sent cease-and-desist letters to all eight departing employees individually, to Verdana Commerce Group, Inc., and to Greystone Capital Partners, LP, demanding immediate compliance with the departing employees' restrictive covenant obligations, the return of all CRH confidential information and trade secrets, and the preservation of all relevant evidence. The letters specifically notified the recipients of the existence and terms of the departing employees' non-compete, non-solicitation, and confidentiality obligations and warned that CRH would seek judicial relief if those obligations were not honored.
56. Despite CRH's cease-and-desist demands, the Individual Defendants and Verdana have not complied. No departing employee has confirmed that he or she will honor the applicable restrictive covenant obligations. On information and belief, the departing employees have commenced or intend to commence work at Verdana in merchandising roles that directly and unambiguously violate the non-competition provisions of their employment agreements. Verdana has not responded to CRH's cease-and-desist letter and has not confirmed that it will refrain from employing the departing employees in prohibited roles. CRH's investigation is ongoing, but the evidence gathered to date confirms the urgent need for injunctive relief.
X. DATA EXFILTRATION
57. CRH's internal IT audit and the preliminary findings of Pinnacle Forensics LLC (Dr. Rajiv Anand, Engagement Lead) have confirmed that between January 10, 2025 and February 4, 2025, approximately 14,327 files totaling approximately 2.8 gigabytes of data were downloaded from CRH's Aldermere Systems and Pinnacle Health IT environments to personal cloud storage accounts — including personal Hollowell Health IT and Larkspur Technologies accounts — associated with members of the Rathore Group. This download activity was vastly disproportionate to any prior comparable period and is inconsistent with any legitimate business purpose.
58. Based on the preliminary forensic analysis, the downloaded files include, but are not limited to:
(a) Project Ridgeline strategic presentations and supporting materials, including the full five-year category expansion roadmap and associated financial projections;
(b) Vendor negotiation term sheets containing confidential pricing, rebate, and contractual terms for CRH's relationships with hundreds of vendors;
(c) Private-label cost models identifying manufacturing partners, raw material costs, production costs, margin targets, and planned product introductions;
(d) Customer segmentation data derived from CRH's proprietary analytics systems, including identification of CRH's highest-value customer cohorts and their purchasing patterns; and
(e) Other proprietary merchandising analytics and planning documents, including seasonal buying algorithm documentation, ecommerce assortment data, and competitive positioning analyses.
59. The timing of the data exfiltration is significant. The downloads commenced on approximately January 10, 2025, just four days after the January 6, 2025 dinner meeting between Rathore, Verdana CEO Warren Dietrich, and Greystone Managing Partner Elliot Westbrook at which, on information and belief, the recruitment proposal was first presented to Rathore. The downloads continued through February 4, 2025, just three days before the coordinated resignations on February 7, 2025. This timeline strongly suggests — and CRH believes the evidence will ultimately establish — that the departing employees systematically gathered CRH's most sensitive and competitively valuable information in anticipation of, and in preparation for, their coordinated departure to Verdana.
60. On information and belief, none of the departing employees had any legitimate business reason to download 14,327 files to personal cloud storage during this period. CRH's information security policies expressly prohibit the transfer of Company confidential information to personal devices or personal cloud storage accounts. The volume, nature, and timing of the downloads are wholly inconsistent with the employees' ordinary work activities and are consistent with the deliberate and systematic misappropriation of CRH's trade secrets and confidential business information. CRH's forensic investigation is continuing, and I anticipate that additional evidence of data exfiltration and misuse may be uncovered.
XI. CONCLUSION AND REQUEST FOR RELIEF
61. For all of the foregoing reasons, and based on the facts set forth in this Declaration, CRH respectfully requests that this Court grant a Temporary Restraining Order and Preliminary Injunction restraining all eight Individual Defendants — Priya Rathore, Derek Linden, Sonia Kaczmarek, Amara Osei, Brent Halvorsen, Lucia Fernandez-Gill, Nathan Tsao, and Kira Johansson — from commencing or continuing employment in any merchandising, strategy, vendor management, or related role at Verdana Commerce Group, Inc. (or any affiliate, parent, or subsidiary thereof) during the pendency of this action and for the duration of their respective non-competition periods as set forth in their employment agreements with CRH.
62. CRH further respectfully requests that the Court enter an order requiring all Individual Defendants and Verdana Commerce Group, Inc. to immediately return to CRH all confidential information and trade secrets of CRH in their possession, custody, or control, in whatever form or medium, and to certify under oath that all such materials have been returned and that no copies have been retained. CRH further requests that the Court order all Defendants to preserve all evidence of data transfers, file downloads, communications (including encrypted messages), and any other materials relating to the recruitment of the Rathore Group, the coordinated resignations, and the use or disclosure of CRH confidential information.
63. CRH is prepared to post an appropriate injunction bond as may be required by the Court under the circumstances.
I declare under penalty of perjury under the laws of the State of Delaware that the foregoing is true and correct.
Executed on March 5, 2025, at Seattle, Washington.
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Theresa Yun-Park General Counsel Cascade Retail Holdings Inc. 2200 Elliott Avenue West, Suite 3400 Seattle, WA 98119
EXHIBIT LIST
The following exhibits are referenced in this Declaration. True and correct copies are filed contemporaneously herewith as separate attachments.
CERTIFICATE OF SERVICE
I, Bernard Crawford, hereby certify that on March 5, 2025, a true and correct copy of the foregoing Declaration of Theresa Yun-Park in Support of Plaintiff's Motion for Temporary Restraining Order and Preliminary Injunction, together with all exhibits referenced therein, was served upon the following counsel of record by electronic filing through the Court's electronic filing system and by email:
Catherine Nygaard, Esquire Whitfield, Nygaard & Doyle LLP 1000 North Market Street, Suite 1500 Wilmington, DE 19801 cnygaard@wndlaw.com Counsel for the Individual Defendants (the "Rathore Group")
Gavin Blackhall, Esquire Blackhall & Soren LLP 300 Delaware Avenue, Suite 900 Wilmington, DE 19801 gblackhall@blackhallsoren.com Counsel for Defendant Verdana Commerce Group, Inc.
________________________________________
Bernard Crawford (Bar No. 5831) CALDERWOOD & HARKNESS LLP 1301 K Street NW, Suite 1200 Washington, DC 20005 Telephone: (202) 555-7400 Facsimile: (202) 555-7401 bcrawford@calderwoodharkness.com
Counsel for Plaintiff Cascade Retail Holdings Inc.
CASCADE RETAIL HOLDINGS INC.,
Plaintiff,
v. | C.A. No. 2025-0198-MTZ
PRIYA RATHORE, DEREK LINDEN, SONIA KACZMAREK, AMARA OSEI, BRENT HALVORSEN, LUCIA FERNANDEZ-GILL, NATHAN TSAO, KIRA JOHANSSON, and VERDANA COMMERCE GROUP, INC.,
Defendants.
Exhibit No. | Description
Exhibit 1 | Amended and Restated Employment Agreement of Priya Rathore (dated March 15, 2021)
Exhibit 2 | Employment Agreement of Derek Linden
Exhibit 3 | Employment Agreement of Sonia Kaczmarek
Exhibit 4 | Employment Agreement of Amara Osei
Exhibit 5 | Employment Agreement of Brent Halvorsen
Exhibit 6 | Employment Agreement of Lucia Fernandez-Gill
Exhibit 7 | Employment Agreement of Nathan Tsao
Exhibit 8 | Employment Agreement of Kira Johansson
Exhibit 9 | Verdana Commerce Group, Inc. Press Release dated February 14, 2025 ("Verdana Commerce Welcomes Industry-Leading Merchandising Team to Accelerate Growth")
Exhibit 10 | CRH Organizational Chart — Merchandising Division (Pre-Departure)