Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / memo-in-support-of-tro-pi-motion.docx
memo-in-support-of-tro-pi-motion.docx
Parties
HARKNESS LLP
Plaintiff Arbor Health Technologies Inc
Clearwater Audit Partners LLP
Calloway LLP
Parties Arbor Health Technologies Inc
Equity Inc
Stonebridge Investigative Group LLC
Hargrove Forensic Economics LLC
Dates
November 21, 2025
September 8, 2020
August 9, 2024
August 26, 2024
August 30, 2024
September 15, 2025
October 3, 2025
November 19, 2025
October 21, 2024
August 30, 2029
Amounts
$187.4
$1,016,866
$577,500
$385,000
$39,366
$4.80
$400,000
$11.20
$11.7
$5.9
Obligations
This obligation shall survive the termination of Employee's employment and shall continue in effect indefinitely
Section 10 of the Separation Agreement provides that upon any material breach by Farris of Sections 6 through 9: (a) AHT shall have the right to immediately cease all remaining separation payments (including COBRA subsidies); (b) Farris shall be obligated to return all separation consideration previously paid or provided, including the net after-tax value of the cash severance, the value of the COBRA subsidies received, and the value realized from the exercise of the accelerated stock options; (c) AHT shall be entitled to seek and obtain immediate injunctive relief, including a temporary restraining order and preliminary injunction, in any court of competent jurisdiction, without the requirement of posting a bond or other security; and (d) In addition to injunctive relief and clawback rights, any breach of Section 6 (Non-Disparagement) or Section 7 (Confidentiality) shall entitle AHT to liquidated damages in the amount of $250,000, "plus actual damages to the extent they exceed such liquidated damages amount
Section 16 provides that the prevailing party in any litigation arising under or related to the Separation Agreement shall be entitled to recover its reasonable attorneys' fees and costs
Fourth, where a temporary restraining order is sought, the court must determine whether the movant faces immediate and irreparable harm requiring relief prior to a full hearing on the preliminary injunction motion