The defection of three insurance brokers from Polk & Sullivan for a rival firm has prompted a lawsuit in District Court.

At issue in the complaint from Polk & Sullivan parent First Horizon Insurance Group are non-compete agreements the company claims the bolting brokers violated.

According to the filing, brokers Chadwick Willoughby, John Tomlinson, both insurance sales agents, and account manager Connie O’Loughlin all tendered their resignation from Polk & Sullivan on March 27. All three accepted employment with the local office of Louisville-based competitor Neace Lukens.

Polk & Sullivan lobs accusations at the three for a variety of actions. Willoughby the company claims solicited clients of Polk & Sullivan to “become client(s) of defendant Willoughby at Neace Lukens.” According to the filing, both he and Tomlinson “solicited employees of plaintiff to become employed by or otherwise affiliated with Neace Lukens.” Tomlinson and O’Loughlin, the filing further asserts, forwarded information “from plaintiffs secure and protected computer system to [their own] personal email.”

Those alleged actions constitute a breach of the confidentiality agreements that the three signed as part of their employment with Polk & Sullivan. Further, their knowledge of the company’s accounts, pricing and methodology, among other things, constitute “protectable business interests.”

As such, Polk & Sullivan along with parent First Horizon are seeking a preliminary injunction barring the defendants from sharing any of the information they have. Additionally, the plaintiffs ask that the three return any of the confidential information they might have obtained during their employment.

Filing the lawsuit are Memphis attorneys Thomas L. Henderson and Jeremy A. Ireland of Ogletree Deakins Nash Smoak & Stewart.