Paramon Nevzorov previously worked at iHiker as a software engineer. Three months after signing a confidentiality agreement and non-competition agreement, Paramon Nevzorov tendered his resignation effectively immediately. The iHiker general counsel, Miguel Rodriguez, has now learned that Paramon Nevzorov is now working for a competing software company. After an investigation, Miguel has also learned that Paramon Nevzorov sent a number of emails with attachments from his company email address to his personal email address and that a company laptop with confidentiality information is now missing.

In this scenario, you are working as a paralegal or legal assistant for iHiker and your immediate supervisor is Miguel Rodriguez, the general counsel of iHiker. Your supervising attorney has asked you to draft a cease-and-desist letter from Miguel Rodriguez to Paramon Nevzorov, the former employee. In the cease-and-desist letter you should allege misappropriation of trade secrets, breach of the confidentiality agreement, and breach of the non-competition agreement with a demand for return of the iHiker company laptop. In the letter, discuss the potential remedies that iHiker could obtain in a legal action against the former employee. Use business letter format for the cease-and-cease letter.