govinfo:USCOURTS-ctd-3_26-cv-00052-0

UNITED STATES DISTRICT COURT 
DISTRICT OF CONNECTICUT 
UNITED RENTALS, INC., and 
UNITED RENTALS (NORTH 
AMERICA), INC., 
Plaintiffs, 
v. 
SCOTT MORGAN, 
Defendant. 
: 
: 
: 
: 
: 
: 
: 
: 
: 
: 
: 
Civil Action No. 
3:26-cv-00052 (SFR) 
STIPULATED PERMANENT INJUNCTION ORDER 
WHEREAS, this action came before the Court by Complaint dated January 12, 
2026; 
WHEREAS, the Prayer for Relief filed by the Plaintiffs, United Rentals, Inc., and 
United Rentals (North America), Inc. (collectively, “Plaintiffs” or “United”), seeks among 
other things, an Order including “[t]emporary, preliminary and permanent injunctive 
relief”; 
WHEREAS, the parties desire to resolve this matter by way of this Stipulated 
Permanent Injunction and pursuant to a separate settlement agreement (the 
“Settlement Agreement”), compliance with which is a condition of the parties’ mutual 
resolution; 
WHEREAS, to facilitate such a resolution, Plaintiffs and Defendant (with the 
assistance, advice and consent of counsel) consent and stipulate to the entry of a 

Permanent Injunction against Defendant, and in favor of the Plaintiffs, as more fully set 
forth below. 
IT IS ORDERED that the Defendant, Scott Morgan, is enjoined as follows and therefore 
SHALL NOT: 
(a) perform any business or sales activities on behalf of Bitting Electric, Inc.
(“Bitting”) within 100 miles of United’s PHVAC branch in Raleigh, North
Carolina through January 15, 2027. (Nothing herein shall restrict Defendant
from working out of his home to perform business or sales activities outside of
the 100 miles of United’s PHVAC branch in Raleigh, North Carolina.)
(b) through January 15, 2027 , be employed or retained by or provide services to
any other competitor of United, within a 100 mile radius from United’s PHVAC
branch in Raleigh, North Carolina;
(c) through January 15, 2027, solicit or accept the business of, call upon, contact,
or communicate with any person or entity, or affiliate of any such person or
entity, who or which is or was a customer, business prospect or other person
who had a business relationship with United resulting in and/or for the purpose
of providing or obtaining any product or service reasonably deemed competitive
with any product or service then offered by United; provided, however, that this
limitation shall apply only with respect to persons or entities with whom Morgan
had a business relationship, with whom Morgan communicated, with whom
Morgan transacted business, or about whom Morgan had Confidential
Information while employed by United;

(d) through January 15, 2027 , (i) approve, solicit or retain, or discuss the
employment or retention (whether as an employee, consultant or otherwise) of
any person who was an employee of United at any time during the one year
period preceding the termination of Morgan’s employment by United, and/or (ii)
solicit or encourage any person to leave the employ of United;
(e) use or disclose United’s trade secrets and/or Confidential Information; and/or
(f) continue to possess or retain United data and/or property.
Without any intended limitation of the foregoing, but for purposes of clarity, 
Paragraph (a), above, prohibits Defendant from, among other things: (i) personally 
engaging in rental or sales activities vis-à-vis customers and/or job sites within a 100 mile 
radius from United’s PHVAC branch in Raleigh, North Carolina, and (ii) reporting to and/or 
working out of any Bitting facility (or facility of any other competitor) located within a 100 
mile radius from United’s PHVAC branch in Raleigh, North Carolina. 
IT IS FURTHER ORDERED that no bond is required. 
Date: May 18, 2026
Time: 9:00 AM
So Ordered: 
Hon. Sarah F. Russell 
United States District Judge 
/s/ Sarah F. Russell 

Approved as to form and substance: 
THE PLAINTIFFS, 
UNITED RENTALS, INC. and 
UNITED RENTALS (NORTH AMERICA), 
INC. 
By: /s/ Gerald C. Pia, Jr._______ 
Brian C. Roche, Esq. (ct 17975) 
Gerald C. Pia, Esq. (ct 21296) 
Roche Pia LLC 
4 Research Drive, Suite 402 
PMB #543-85 
Shelton, CT 06484 
Phone: (203) 944-0235 
Fax: (203) 567-8033 
Email: broche@rochepia.com 
Email: gpia@rochepia.com 
Date: _________________ 
THE DEFENDANT, 
SCOTT MORGAN 
By: /s/ Sarah S. Healey_______ 
Sarah S. Healey (ct27952) 
Carmody Torrance Sandak & 
Hennessy LLP 
195 Church Street 
P.O. Box 1950 
New Haven, CT 06509 
Phone: 203-777-5501 
Fax: 203-784-3199 
Email: shealey@carmodylaw.com; 
Date: ___________________ 

Passage view · GavelSight