IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION COMPLAINT

Similar documents
Case 1:09-cv Document 1 Filed 10/19/2009 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case 2:12-cv RCJ -GWF Document 1 Filed 07/26/12 Page 1 of 6 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

Case 1:19-cv DLI-SJB Document 1 Filed 02/12/19 Page 1 of 16 PageID #: 1

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT

IN CIRCUIT COURT OF PULASKI COUNTY, ARKANSAS DIVISION. v. CASE NO. COMPLAINT

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE AT NASHVILLE : : : : : : : : Defendant.

Case 3:17-cv Document 1 Filed 09/01/17 Page 1 of 6 PageID #: 1

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI

Case 1:15-cv KMW Document 1 Entered on FLSD Docket 12/11/2015 Page 1 of 10 UNITED STATE DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.

CUNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION

Case: 1:16-cv Document #: 111 Filed: 09/19/17 Page 1 of 16 PageID #:1029

COMPLAINT FOR DECLARATORY JUDGMENT. Plaintiff Board of Education of the City of Chicago (the School Board ), by and through

Case 4:17-cv Document 1 Filed in TXSD on 08/30/17 Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

STROOCK & STROOCK & LAVAN LLP

FILED: NEW YORK COUNTY CLERK 07/11/ :26 PM INDEX NO /2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/11/2016

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION. CIVIL ACTION NO. 3:18-cv-437-DJH NAVIGATORS INSURANCE COMPANY

Case: 1:17-cv Document #: 62 Filed: 01/22/18 Page 1 of 35 PageID #:1692

Case 1:16-cv SMV-WPL Document 1 Filed 11/23/16 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

: : : : : : : : : : : : Plaintiff Impulse Marketing Group, Inc., by its attorneys, Klein, Zelman, Rothermel &

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION. Civil Action No. 09-CV-367

Case 1:18-cv Document 1 Filed 12/18/18 Page 1 of 9. Plaintiff, Defendant.

Case 4:16-cv SMR-HCA Document 1 Filed 12/12/16 Page 1 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF IOWA CENTRAL DIVISION

Case KG Doc 1 Filed 08/10/18 Page 1 of 12 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

Case: 1:16-cv Document #: 141 Filed: 12/06/17 Page 1 of 19 PageID #:1455

Case 2:09-cv EEF-JCW Document 1 Filed 12/23/09 Page 1 of 12

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION

Information & Instructions: Response to a Motion To Lift The Automatic Stay Notice and Proof of Service

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Plaintiff R.J. Zayed ( Plaintiff or Receiver ), through his undersigned counsel

Case 4:18-cv Document 1 Filed 01/02/18 Page 1 of 11 UNITED STATES DISTRICT COURT

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Case: 1:18-cv Document #: 1 Filed: 12/19/18 Page 1 of 20 PageID #:1

Case 2:14-cv Document 1 Filed 05/29/14 Page 1 of 14 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE ) ) ) ) ) ) ) ) ) ) )

FILED: NEW YORK COUNTY CLERK 09/11/ :43 PM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/11/2017

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

Case 4:16-cv RGE-SBJ Document 59 Filed 02/08/18 Page 1 of 14

Case 1:08-cv Document 1 Filed 10/21/2008 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS

Case 1:17-cv Document 1 Filed 10/26/17 Page 1 of 20 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK. Defendants COMPLAINT

Case 7:18-cv NSR Document 1 Filed 08/23/18 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK. JURY TRIAL DEMANDED vs.

Case: 1:18-cv Document #: 1 Filed: 08/03/18 Page 1 of 9 PageID #:1

Case: 1:17-cv Document #: 1 Filed: 07/05/17 Page 1 of 14 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case 1:12-cv ELH Document 1 Filed 03/30/12 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND NORTHERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA

4:10-cv TLW Date Filed 03/18/10 Entry Number 1 Page 1 of 12

FILED: NEW YORK COUNTY CLERK 06/12/ :05 PM INDEX NO /2013 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 06/12/2017 EXHIBIT A

Case 2:10-cv EEF-JCW Document 1 Filed 02/23/10 Page 1 of 13

Case: 4:14-cv Doc. #: 1 Filed: 10/03/14 Page: 1 of 16 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

8:17-cv RFR-FG3 Doc # 1 Filed: 05/26/17 Page 1 of 14 - Page ID # 1 UNITED STATES DISTRICT COURT DISTRICT OF NEBRASKA

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

OAKLAND DIVISION CASE NO.:

Case 1:18-cv LTS-DCF Document 1 Filed 01/11/18 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.

AMERICAN ARBITRATION ASSOCIATION

Case Document 2540 Filed in TXSB on 09/12/13 Page 1 of 8 IN THE UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

Case 9:18-cv DMM Document 1 Entered on FLSD Docket 04/05/2018 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE#

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE ) ) ) ) ) ) ) ) VERIFIED COMPLAINT UNDER 6 DEL. C

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA. ) Civil Action No. ) CV-03-J-0615-S. Defendants. )

Index No. $UMMVM. which is the residence of certain Defendants; and a substantial part of the events alleged occurred within this County.

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

Case 3:17-cv Document 1 Filed 06/30/17 Page 1 of 10

Case CSS Doc 179 Filed 12/23/15 Page 1 of 7 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

FILED: NEW YORK COUNTY CLERK 03/06/ :17 PM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/06/2017

Case 1:11-cv SS Document 274 Filed 09/08/17 Page 1 of 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS ) ) ) ) ) ) ) ) ) ) ) )

Case 1:17-cv VSB Document 1 Filed 05/16/17 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

: In re: : Chapter 11 : BAYOU GROUP, LLC, et al., : Case No.: (ASH) : Debtors. : Jointly Administered :

INTRODUCTION. TECHNOLOGIES, INC. ("UBER" or "Defendant") pursuant to North Carolina's Unfair and

Case 1:16-cv ECF No. 1 filed 12/19/16 PageID.1 Page 1 of 5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN

Case 2:18-cv JAW Document 1 Filed 05/21/18 Page 1 of 11 PageID #: 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MAINE

FILED: KINGS COUNTY CLERK 11/03/ :08 AM INDEX NO /2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/03/2016

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

FILED: NEW YORK COUNTY CLERK 02/16/ :40 PM INDEX NO /2016 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/28/2017

SUFFOLK FLANAGAN & ASSOCIATES, PLLC, MURACA & KELLY LLP, DENNIS KELLY, DAVID GROSSMAN, and SUZANNE FLANAGAN,

Case 3:09-cv N Document 1924 Filed 10/17/13 Page 1 of 4 PageID 52653

Case: 1:18-cv Document #: 1 Filed: 02/14/18 Page 1 of 11 IN THE DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. CROIX ) ) ) ) ) ) ) ) ) )

2:13-cv CWH Date Filed 06/26/13 Entry Number 1 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION

IN THE TWENTY-FIRST JUDICIAL CIRCUIT ST. LOUIS COUNTY STATE OF MISSOURI ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION. Plaintiff, Civil Action No. COMPLAINT FOR PATENT INFRINGEMENT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION. Case No.

Case 1:18-cv UNA Document 1 Filed 01/16/18 Page 1 of 7 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

Case 0:14-cv JEM Document 1 Entered on FLSD Docket 12/11/2014 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

: : : : : : : : : : ANSWER OF DEFENDANT FABRICE TOURRE. his Answer to the Complaint dated April 16, 2010 (the Complaint ) filed by Plaintiff the

Case 1:16-cv Document 1 Filed 06/10/16 Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

Case 1:16-cv UU Document 38 Entered on FLSD Docket 05/11/2016 Page 1 of 14

Case: 4:16-cv Doc. #: 1 Filed: 02/09/16 Page: 1 of 30 PageID #: 1

Case 1:14-cv TWP-TAB Document 1 Filed 09/09/14 Page 1 of 13 PageID #: 1

Case 3:17-cv Document 1 Filed 12/11/17 Page 1 of 20 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

Case 2:18-cv SJF-SIL Document 1 Filed 05/25/18 Page 1 of 14 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

Case 5:12-cv MAD-DEP Document 25 Filed 03/26/13 Page 1 of 9

Case 4:10-cv TSH Document 1 Filed 07/09/10 Page 1 of 11 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

Case 2:10-cv WHW -MAS Document 23 Filed 03/18/11 Page 1 of 13 PageID: 97

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA

Case 1:17-cv Document 1 Filed 11/10/17 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK. vs. JURY TRIAL DEMANDED

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Plaintiff(s) Case No: 09-cv-3332 MJD/JJK

Case 4:17-cv Document 1 Filed 07/14/17 Page 1 of 18

Case 1:15-cv MGC Document 1 Entered on FLSD Docket 07/27/2015 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case 1:15-cv LTS Document 1 Filed 04/13/15 Page 1 of 13

Case 3:18-cv Document 1 Filed 10/25/18 Page 1 of 23 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

JURISDICTION AND VENUE

Case 4:18-cv Document 1 Filed in TXSD on 01/04/18 Page 1 of 13

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION

Case 5:08-cv JF Document 13 Filed 06/24/2008 Page 1 of 7

Transcription:

Case 1:17-cv-03261-ELR Document 1 Filed 08/28/17 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION HEIDRICK & STRUGGLES, INC., v. Plaintiff, Case No. KATIE BELL, Defendant. COMPLAINT Plaintiff Heidrick & Struggles, Inc. ( Heidrick or the Company ) brings this Complaint seeking damages and other relief against its former employee, Defendant Katie Bell ( Bell ). Bell has breached the terms of her employment agreement with Heidrick by refusing to repay a portion of the $350,000 in bonuses that she received from Heidrick before abruptly resigning to work for one of Heidrick s competitors and, as a result, Heidrick has sustained damages. Parties 1. Heidrick & Struggles, Inc. is a Delaware corporation with its headquarters and principal place of business located at 233 South Wacker Drive in Chicago, Illinois. Heidrick is a worldwide professional services firm, specializing in the fields of executive search, culture shaping and leadership consulting. Heidrick has an office located at 1180 Peachtree Street NE in Atlanta, Georgia.

Case 1:17-cv-03261-ELR Document 1 Filed 08/28/17 Page 2 of 9 2. Katie Bell is an individual who, on information and belief, resides at 6800 Wright Road, Atlanta, Georgia 30328. Bell is a former employee of Heidrick, who worked at the Company s Atlanta, Georgia office. Jurisdiction and Venue 3. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. 1332. Heidrick is a Delaware corporation whose principal place of business is located in Illinois. Bell is a citizen of Georgia. The matter in controversy in this action exceeds $75,000, exclusive of interest and costs. 4. Venue in this Court is proper under 28 U.S.C. 1391 because this judicial district is where a substantial part of the events giving rise to the claim occurred. Bell s Employment with Heidrick 5. In consideration and as a condition of her employment with Heidrick, Bell signed a letter agreement which set forth the terms and conditions of her employment with Heidrick. (A copy of Bell s signed offer letter dated February 28, 2015 (the Letter Agreement ) is attached as Exhibit A). 1 6. Bell s first day of employment with Heidrick was April 20, 2015. 1 The Consultant Business Protection Agreement exhibit referenced at page 3, paragraph 8 of the Letter Agreement has been intentionally omitted from Exhibit A hereto because it is not relevant to the allegations in this Complaint and contains confidential business information of the Company. -2-

Case 1:17-cv-03261-ELR Document 1 Filed 08/28/17 Page 3 of 9 7. Bell was employed as a Partner in the Life Sciences Practice based in Heidrick s Atlanta, Georgia office. $200,000. 8. Upon her hire, Bell began receiving an annual base salary of 9. As a Partner, Bell was eligible to participate in the Company s bonus programs and benefits programs. 10. The Company also agreed to provide Bell with the following additional compensation: (1) a one-time sign-on payment of $50,000, payable within thirty (30) days of her first day of employment (the Sign-On Payment ); (2) a minimum 2015 bonus of $150,000, payable in March 2016 (the 2015 Bonus ); and (3) a minimum 2016 bonus of $150,000, payable in March 2017 (the 2016 Bonus ). (Ex. A., 5). 11. The Letter Agreement obligates Bell to reimburse Heidrick for portions of the Sign-On Payment, 2015 Bonus, and 2016 Bonus if she were to resign her employment with Heidrick within three (3) years of the payment date of the Sign-On Payment: The additional payments set forth in Paragraph 5 may be subject to certain repayment obligations based on your decision to leave Heidrick.... Should you resign from Heidrick for any reason... within three years of the payment date of the Sign-On Payment, you agree to reimburse Heidrick the amount of any Sign-On Payment and the difference between any minimum portion of such amounts set forth in the Agreement and any amounts you would have received under the -3-

Case 1:17-cv-03261-ELR Document 1 Filed 08/28/17 Page 4 of 9 (Ex. A., 6). Company s bonus programs, reduced on a pro-rated basis by one thirty-sixth (1/36 th ) per full month from the date of payment, within thirty (30) business days following your termination date. Further, you agree to, at the time of such separation, provide Heidrick with written authorization to deduct and/or offset that amount from any compensation or other sums that may be due to you as part of your final pay. If you fail to provide such authorization or to timely repay your minimum compensation amounts described above, you agree to reimburse Heidrick for all reasonable cost and fees associated with its attempt to recover the amounts owed by you. 12. Bell executed the Letter Agreement on March 6, 2015, thereby acknowledg[ing her] acceptance of [its] terms and agree[ing] to be bound by [the] letter agreement, including with regard to her repayment obligations as set forth in Paragraph 6. (Ex. A., p. 5). 13. On April 30, 2015, Heidrick paid Bell the Sign-On Bonus in the amount of $50,000. of $150,000. 14. On March 15, 2016, Heidrick paid Bell the 2015 Bonus in the amount 15. Based upon her actual performance and in accordance with Heidrick s bonus programs, Bell would have received a 2015 Bonus in the amount of $26,087. Therefore, the amount of Bell s 2015 Bonus subject to the repayment obligations set forth in the Letter Agreement is $123,913. -4-

Case 1:17-cv-03261-ELR Document 1 Filed 08/28/17 Page 5 of 9 of $150,000. 16. On March 31, 2017, Heidrick paid Bell the 2016 Bonus in the amount 17. Had Bell not been entitled to a minimum guaranteed 2016 Bonus of $150,000 as provided for in the Letter Agreement, based upon her actual performance and in accordance with Heidrick s bonus programs, Bell would have received a 2016 Bonus in the amount of $41,100. Therefore, the amount of Bell s 2016 Bonus subject to the repayment obligations set forth in the Letter Agreement is $108,900. 18. Heidrick would not have employed Bell or paid her the Sign-On Payment, 2015 Bonus, or 2016 Bonus but for her agreement to perform the terms of the Letter Agreement. Bell s Resignation and Refusal To Comply With Her Contractual Repayment Obligations 19. On March 31, 2017, the very same day that Bell was paid her 2016 minimum guaranteed bonus of $150,000, Bell informed Heidrick by email that she was resigning her employment with Heidrick, effective April 14, 2017. 20. On April 24, 2017, Heidrick sent Bell a memorandum confirming her contractual repayment obligations under the Letter Agreement. Enclosed with the memorandum was a detailed calculation and breakdown of the amounts Bell was required to repay to Heidrick, in accordance with Paragraph 6 of the Letter Agreement, and a repayment schedule with monthly payments in the amount of -5-

Case 1:17-cv-03261-ELR Document 1 Filed 08/28/17 Page 6 of 9 $10,919 beginning in June 2017 and ending in November 2018. (A copy of Heidrick s April 24, 2017 memorandum is attached as Exhibit B). In total, the Letter Agreement required Bell to repay Heidrick $196,545. 21. On May 9, 2017, Heidrick sent Bell s attorney a letter re-affirming Bell s contractual repayment obligations under the Letter Agreement and demanding that Bell repay the full amount owed, in accordance with the repayment schedule Heidrick previously provided to Bell on April 24, 2017. 22. To date, Bell has repaid to Heidrick the total sum of $16,667, representing only the portion of the Sign-On Bonus as demanded by Heidrick, leaving a remaining balance owed by Bell of $179,879. Bell has not repaid any portion of either the 2015 Bonus or the 2016 Bonus. competitors. 23. Bell currently works for Korn Ferry, one of Heidrick s direct COUNT I (Breach of Contract Letter Agreement) 24. Heidrick realleges Paragraphs 1 through 23 as though these Paragraphs were set forth fully herein. contract. Agreement. 25. Bell s Letter Agreement with Heidrick is a valid and enforceable 26. Heidrick has performed all of its obligations under the Letter -6-

Case 1:17-cv-03261-ELR Document 1 Filed 08/28/17 Page 7 of 9 27. Bell has breached the terms of the Letter Agreement by: (1) refusing to repay $74,004 of the 2015 Bonus; and (2) refusing to repay $105,875 of the 2016 Bonus Payment. 28. As a direct result of Bell s breach of the terms of the Letter Agreement, Heidrick has sustained damages in an amount not less than $179,879. Further, Heidrick has incurred and will continue to incur costs and fees in attempting to recover the repayment amounts owed by Bell, including but not limited to court costs and attorneys fees. 29. Heidrick is entitled to an award of damages resulting from Bell s breach of the Letter Agreement. PRAYER FOR RELIEF WHEREFORE, Heidrick respectfully requests that this Court enter judgment in its favor and against Bell and enter an order: (a) (b) (c) ordering Bell to pay Heidrick its damages, together with pre-judgment interest, in an amount not less than $179,879; ordering Bell to reimburse Heidrick for its costs and attorneys fees incurred in connection with attempting to recover the repayment amounts owed by Bell; and granting Heidrick any such other and further relief that this Court deems just and proper. -7-

Case 1:17-cv-03261-ELR Document 1 Filed 08/28/17 Page 8 of 9 Dated: August 28, 2017 ROGERS & HARDIN LLP 2700 International Tower 229 Peachtree Street NE Atlanta, GA 30303 Phone: 404-522-4700 Facsimile: 404-525-2224 jgunnemann@rh-law.com croberts@rh-law.com NEAL, GERBER & EISENBERG LLP Two North LaSalle Street, Suite 1700 Chicago, Illinois 60602-3801 Telephone: (312) 269-8000 Facsimile: (312) 269-1747 srosenberg@nge.com dweldon@nge.com /s/ Joshua P. Gunnemann Joshua P. Gunnemann Ga. Bar No. 152250 Cameron B. Roberts Ga. Bar No. 599839 Sonya Rosenberg (pro hac vice forthcoming) David G. Weldon (pro hac vice forthcoming) Counsel for HEIDRICK & STRUGGLES, INC -8-

Case 1:17-cv-03261-ELR Document 1 Filed 08/28/17 Page 9 of 9 CERTIFICATION OF COMPLIANCE WITH L.R. 5.1B I hereby certify that the foregoing has been computer processed with 14 point New Times Roman font in compliance with the United States District Court for the Northern District of Georgia Local Rule 5.1B. Dated: August 28, 2017 /s/ Joshua P. Gunnemann Joshua P. Gunnemann Ga. Bar No. 152250-9-