BRATTLEBORO — In an amended complaint filed with district court on Dec. 21, attorneys for G.S. Precision contend the company has already suffered irreparable harm due to the actions of a former employee.

In attachments to the amended complaint, G.S. Precision's attorneys reference an article about a civil suit filed against Edward Hewey that ran in the Reformer on Nov. 20. Shortly after the article was printed, states the complaint, G.S. Precision CEO Norm Schneeberger received an email from Don Sporborg, a commodity specialist for Markem-Imaje, one of G.S. Precision's customers in Keene, N.H., an email apparently intended for Hewey.

"From now on, I would ask that there be no conversations regarding your previous knowledge about any processes, suppliers, etc. about the extrusions or other parts you're making for us. Treat the extrusions issue as if you're starting from scratch; as if it's a new product for Sisson. But before we go further, I would like you both to give me your side of the story regarding the disappointing Brattleboro Reformer article. You certainly don't have to, but I think it would be a good idea."


"The import of this message is obvious: Defendant Hewey has been using G.S. Precision confidential and proprietary information including 'previous knowledge about processes, suppliers, etc.' Sisson is now making printer parts for Markem-Imaje that were once made by G.S. Precision. ... Defendant Hewey was not 'starting from scratch' — he was and is using proprietary information obtained from G.S. Precision to assist Sisson in the manufacture of printer parts for Markem-Imaje," notes the amended complaint.

Schneeberger contacted Sporborg, who stated Hewey told him "that he was entitled to, and could, use any information he obtained as a Knappe & Koester employee (prior to the acquisition by G.S. Precision), and that this information could be freely shared."

"He has essentially admitted he has and will continue to disclose G.S. Precision's proprietary information that he erroneously believes is not subject to his Non-Disclosure Agreement," states the complaint. "This is not a theoretical or academic concern about an unrealistic possibility — this is a real and actual harm, and his ongoing and continued conduct presents an imminent threat to G.S. Precision."

Because of this alleged behavior, note the attorneys, the court should issue an injunction against Hewey, preventing him from using any knowledge or documents he took in breach of his non-disclosure agreement.

"G.S. Precision has incurred irreparable harm and will incur further irreparable harm, especially in light of Defendant Hewey's stated erroneous belief that he is not bound to maintain the secrecy of GSP Trade Secrets to which he was exposed as a Knappe & Koester employee."

G.S. Precision filed the civil suit in mid-November, after it learned Hewey, who became a G.S. Precision employee after the company's purchase of Knappe & Koester in Keene, N.H., was soliciting proprietary information from G.S. Precision employees as well as asking others to come work for him at Sisson Engineering in Northfield, Mass.

"Defendant Hewey has threatened G.S. Precision's valuable trade secrets and has thereby threatened its relationship with its valued customer, Customer A, and other customers who have developed trust, goodwill and confidence in G.S. Precision and its ability to maintain the confidentiality of trade secret and confidential and proprietary information," notes the amended complaint.

G.S. Precision is asking the court to award compensation "including but not limited to its damages for loss of its trade secrets and attorneys' fees. G.S. Precision is further entitled to punitive damages because Defendant Hewey improperly misappropriated GSP's Trade Secrets knowingly and maliciously."

Hewey, who lives in Spofford, N.H., left G.S. Precision in February 2015.

"Less than one week after Hewey terminated his employment with G.S. Precision, Second Shift Supervisor Timothy Vaine terminated his employment with G.S. Precision," states the amended complaint. "As Second Shift Supervisor, Timothy Vaine was essentially in charge of G.S. Precision's entire manufacturing process during the second shift at the Keene, N.H. facility and oversaw the entire manufacturing process and was "extremely knowledgeable about the process for Customer A."

Shortly thereafter, another G.S. Precision employee, Eric Snelling, submitted his letter of resignation and told managers he was also going to Sisson. Snelling, according to the court document, was also knowledgeable about the processes related to Customer A, which has been described in previous documents as an aviation components manufacturer. And then in September, Second Shift Supervisor Mark Stevens told managers he was being actively recruited by Hewey to work for Sisson. "Stevens has developed significant expertise and has been provided with GSP Trade Secret information concerning the manufacturing process and methods for (Customer A) ... Defendant Hewey also informed him that he wanted to "steal" certain employees from G.S. Precision to work for Sisson," state the court documents.

Despite the job offer, Stevens decided to remain at G.S. Precision.

About the same time that G.S. Precision sent a letter to Hewey reminding him of his obligations under the non-disclosure agreement, G.S. Precision also learned that Lisa Moran, former customer services manager, was leaving to take a job at Sisson. Moran was described as the "chief contact person with Customer A."

Another employee, only identified as Jane Doe No. 1, unsuccessfully attempted to email confidential documents to Hewey at his Sisson email address. "She was also a primary point of contact with Customer A representatives, had frequent communications with them and developed relationships with them by virtue of her employment with G.S. Precision."

According to the amended complaint, Hewey offered Jane Doe No. 1 a job at Sisson and that she should "grab the tooling sheets" for the part. The email contained a message that included "Hang on to these for me until I get there. Thanks." The employee, after she left G.S. Precision, admitted to sending the documents to her own email account and that she had done so "in poor judgment" and "for sentimental reasons."

However, notes the document, an email with proprietary information on certification did make its way from Jane Doe No. 1 to Hewey. The complaint contends Hewey used the 21-page document to qualify for Sisson's own certification.

In early December, Hewey's attorneys filed a motion to dismiss the G.S. Precision civil suit, contending the company had not proved harm had occurred. In addition to the amended complaint filed on Dec. 21, G.S. Precision filed a motion in opposition to Hewey's motion to dismiss. The new factual allegations in the amended complaint render Hewey's motion moot, contends G.S. Precision's attorneys.

G.S. Precision is represented by Downs Rachlin Martin PLLC. Hewey is represented by Gravel & Shea PC.

Bob Audette can be contacted at 802-254-2311, ext. 160