Home Life Health Care, LLC v. Dorfman

CourtDistrict Court, E.D. New York
DecidedSeptember 24, 2025
Docket2:25-cv-00526
StatusUnknown

This text of Home Life Health Care, LLC v. Dorfman (Home Life Health Care, LLC v. Dorfman) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Home Life Health Care, LLC v. Dorfman, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -----------------------------------------------------------------X HOME LIFE HEALTH CARE, LLC et al.,

Plaintiffs, MEMORANDUM v. AND ORDER 25-CV-0526-SJB-ST

IAN DORFMAN, et al.,

Defendants. -----------------------------------------------------------------X BULSARA, United States District Judge: Plaintiffs Home Life Health Care, LLC and HLHC, LLC, d/b/a Alvita Care (collectively, “Alvita”) commenced this action against Ian Dorfman and Elder Care Homecare (“Elder Care”), for violating the terms of Dorfman’s employment agreement by allegedly taking confidential information and soliciting employees and clients on Elder Care’s behalf. (Compl. dated Jan. 30, 2025 (“Compl.”), Dkt. No. 1 at 31). Alvita and Elder Care, as their names suggest, are in the business of providing home health care service for patients with Alzheimer’s and other similar conditions. Three months after starting the case, Alvita filed an Amended Complaint that added claims against Defendant Chris Tatar for violations of a similar employment agreement. (Am. Compl. dated May 8, 2025 (“Am. Compl.”), Dkt. No. 26 at 35). Alvita had previously filed two motions for preliminary injunctions that were denied. (See Order dated Apr. 15, 2025; Order dated June 5, 2025). Now pending before the Court is Alvita’s third such motion seeking relief against Dorfman, Tatar, and Elder Care (collectively, “Defendants”). (Pls.’ Mot. for Prelim. Inj. dated Aug. 2, 2025 (“Pls.’ Third PI Mot.”), Dkt. No. 50). For the reasons stated below, Alvita’s third motion is denied. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

The following alleged facts are taken from Alvita’s Amended Complaint. Alvita provides home health care services in the New York area. (Am. Compl. ¶ 18). Elder Care is an industry competitor of Alvita’s. (Id. ¶ 1). Dorfman and Tatar were previously employed by Alvita, and now both work for Elder Care. (Id. ¶¶ 2–3, 6–7). Alvita hired Dorfman on September 13, 2021. (Id. ¶ 33). By January 2023, Dorfman was the Vice President of Strategic Partnerships at Alvita, where he negotiated contracts

with Alvita’s referral sources, developed and maintained relationships with those sources and other entities on Alvita’s behalf, and supported Alvita’s sales team. (Id. ¶ 35). Dorfman resigned from Alvita on January 3, 2025. (Id. ¶ 6). Alvita alleges that Dorfman accepted an offer of employment from Elder Care on December 10, 2024, (Am. Compl. ¶ 66), and began working for it on January 6, 2025. (Id. ¶ 81). Alvita hired Tatar on June 15, 2023. (Id. ¶ 45). He worked as a Client Care Liaison, and he also developed and maintained “relationships with referral sources and

entities in the community,” advised, sold, and onboarded “clients for home care services,” and negotiated contracts with the referral sources. (Id. ¶ 47). Tatar left Alvita on March 14, 2025, (id. ¶ 96), and joined Elder Care on March 17, 2025. (Id. ¶ 7). Upon their hiring at Alvita, both Dorfman and Tatar signed employment contracts (the “Agreements”). (Am. Compl. ¶¶ 58, 59). Those Agreements contained three relevant prohibitions related to 1) confidentiality, 2) non-solicitation, and 3) return of property. The Confidentiality Clause prohibits the use or disclosure of “Confidential

Information,” defined as: information relating to Alvita’s products or services, processing, marketing, selling, client lists, patient names, referral sources (including employee names and contacts at such referral sources), trade secrets, call lists, client data, manuals, policies, memoranda, notes, records, technical data, research and development data, sources of supply and material, operating and cost data, and financial information. “Confidential Information” also includes proprietary and/or confidential information of Alvita’s clients, referral sources and trading partners (if any), including client’s financial information and patient’s health and medical information, which is protected by HIPAA[.]

(Id. ¶ 60(b)). The Confidentiality Clause is in effect “for so long as the information is not generally known to the public.” (Id. ¶ 60(c)). The Non-Solicitation Clause prohibits employees, while at Alvita and for one year following termination of employment, from employing or soliciting for employment “any person who is then, and was at any time during Employee’s employment, an employee, sales representative or agent of Alvita.” (Id. ¶ 61(a)). It also prohibits employees for the same period from soliciting: any of Alvita’s clients (including, but not limited to, patients, patients’ families, patients’ representatives, hospitals, assisted living facilities and nursing homes) or referral sources (including, but not limited to, hospitals, nursing homes, assisted living facilities, rehabilitation facilities, physicians, community centers and religious organizations) with which Employee had contact while working for Alvita, or about which Employee learned Confidential Information (the “Restricted Entities”); nor will Employee in any way, directly or indirectly, on Employee’s own behalf or on behalf of any other person, firm, corporation or entity, divert the business of, or take away, any Restricted Entities, or otherwise interfere with, disrupt or attempt to disrupt relations between Alvita and any of the Restricted Entities.

(Id. ¶ 61(b)). The Agreements also contain a Return of Property Clause that required ex- employees to return all Alvita property in their possession, including Confidential Information. (Id. ¶ 62). Alvita alleges that in the weeks between his offer of employment from Elder Care and his resignation from Alvita, Dorfman copied numerous documents onto a personal flash drive and Google Drive, and forwarded Confidential Information, including names of all of the referral sources, sales leads associated with those sources, and clients with whom he had contact within the prior year, among other items, to his personal email account. (E.g., Am. Compl. ¶¶ 67, 71, 73, 74, 76). He also set up meetings with Alvita referral sources using his personal Gmail account, while still employed by Alvita, on Elder Care’s behalf. (Id. ¶¶ 70–71). As of the filing of the

Amended Complaint, none of this property had been returned. (Id. ¶ 94).1 Besides sharing this information with Elder Care, (id. ¶ 75), Alvita also alleges that Dorfman has used this information to divert business and solicit employees away from Alvita to join Elder Care. (Id. ¶ 83). For instance, Alvita claims that on January 16, 2025, an Alvita employee “observed Dorfman with another Elder Care representative visiting Belair Nursing and Rehab, a Restricted Entity . . . [where he had] at least one

referral source with which he had contact in the weeks leading up to his departure.” (Id. ¶ 92). Alvita also claims that Dorfman “conspired with . . . Elder Care, to solicit and

1 At the hearing, the parties were, and still remain, in vigorous dispute about what was returned to Alvita and what is outstanding. recruit Tatar.” (Am. Compl. ¶ 7). Alvita alleges that Elder Care knew of the Agreements, and “substantially assisted, benefitted from, and was complicit in Dorfman’s unlawful conduct.” (Id. ¶ 112).

With respect to Tatar, Alvita alleges that Tatar has used the Confidential Information taken by Dorfman, (id. ¶ 114), and that he has also violated the Agreements by seeking business from “Thrive Senior Living at Montvale, which was an account that Dorfman and Tatar jointly signed into contract with Alvita in late November 2024.” (Id. ¶ 117). Alvita’s claims are for: 1) a violation of the Defend Trade Secrets Act, 18 U.S.C.

§ 1831, against all Defendants, (Am. Compl. ¶¶ 103–20); 2) breach of contract against Dorfman and Tatar (id. ¶¶ 121–26); 3) misappropriation of trade secrets against all Defendants, (id.

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