2024-cv-60669

2024-cv-60669 Apple Corps Limited v. The Individual, Business Entity, or Unincorporated Association Identified On Schedule A

Date :4/23/2024
Court :Southern District of Florida
Law FirmSMG

#

Date

Document

1

April 23, 2024

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17470427, filed by Apple Corps Limited.

Civil Cover Sheet

(Exhibit 1 to Complaint - Certificates of Registration for the Beatles Trademarks)

2

April 23, 2024

Clerks Notice of Judge Assignment to Judge Rodney Smith. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Patrick M. Hunt is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent.

3

April 23, 2024

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

(Complaint & Exhibits) (nwn)

4

April 24, 2024

Corporate Disclosure Statement by Apple Corps Limited

5

April 24, 2024

Plaintiff's MOTION to Seal per Local Rule 5.4 by Apple Corps Limited.

(Text of Proposed Order) (Wiborg-Rodriguez, T.)

6

April 25, 2024

ORDER granting 5 Motion to Seal. Signed by Judge Rodney Smith on 4/25/2024. See attached document for full details.

7

April 25, 2024

Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof by Apple Corps Limited.

Declaration of Paul Cole in Support Thereof

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Exhibit 1 to the Declaration of T. Raquel Wiborg-Rodriguez

Declaration of Eric Rosaler in Support Thereof

Exhibit 1to the Declaration of Eric Rosaler

Text of Proposed Order) (Wiborg-Rodriguez, T.) Modified to Unseal Entry on 5/3/2024 PER DE#

(cds)

8

April 25, 2024

Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law in Support Thereof by Apple Corps Limited.

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Exhibit 1 to the Declaration of T. Raquel Wiborg-Rodriguez

Text of Proposed Order) (Wiborg-Rodriguez, T.) Modified to Unseal Entry on 5/3/2024 PER DE#

(cds)

9

April 25, 2024

Sealed Document Notice of Filing re DE# 6 Order on Motion to Seal by Apple Corps Limited.

Schedule A to the Complaint) (Wiborg-Rodriguez, T.) Modified to Unseal Entry on 5/3/2024 PER DE#

(cds)

10

April 26, 2024

Sealed Document Notice of Filing re DE# 6 Order on Motion to Seal by Apple Corps Limited.

Proposed Summons) (Wiborg-Rodriguez, T.) Modified to Unseal Entry on 5/3/2024 PER DE#

(cds)

11

April 26, 2024

(Duplicate no PDF Attached) Summons Issued as to THE INDIVIDUAL, BUSINESS ENTITY, OR UNINCORPORATED ASSOCIATION IDENTIFIED ON SCHEDULE A. (cds) Modified Text on 4/26/2024 (cds). (SEE DE# 12 for Image) Modified to Unseal Entry on 5/3/2024 PER DE# 17

12

April 26, 2024

Summons Issued as to THE INDIVIDUAL, BUSINESS ENTITY, OR UNINCORPORATED ASSOCIATION IDENTIFIED ON SCHEDULE A. (cds) Modified to Unseal Entry on 5/3/2024 PER DE# 17

13

April 30, 2024

ORDER Granting 7 Ex Parte Application for Entry of Temporary Restraining Order. Telephonic Preliminary Injunction Hearing set for 5/14/2024 11:10 AM in Fort Lauderdale Division before Judge Rodney Smith. Responses due by 5/7/2024. Replies due by 5/9/2024. Signed by Judge Rodney Smith on 4/30/2024. See attached document for full details. (cds)Modified to Unseal Entry on 5/3/2024 PER DE# 17

14

April 30, 2024

ORDER Granting 8 Ex Parte Motion for Order Authorizing Alternate Service of Process. Signed by Judge Rodney Smith on 4/30/2024. See attached document for full details. (cds) Modified to Unseal Entry on 5/3/2024 PER DE# 17

15

May 1, 2024

Surety BOND in the amount of $10,000 posted by Apple Corps Limited Approved by Judge Rodney Smith

16

May 2, 2024

Plaintiff's MOTION to Unseal Document Docket Entries 7 - 14 by Apple Corps Limited. Responses due by 5/16/2024.

(Text of Proposed Order)(Wiborg-Rodriguez, T.) Modified Relief on 5/3/2024 (cds)

17

May 3, 2024

ORDER Granting 16 Motion to Unseal. Signed by Judge Rodney Smith on 5/3/2024. See attached document for full details.

18

May 3, 2024

NOTICE of Compliance (All Docket Entries in this Case have Been Unsealed) re 17 Order on Motion to Unseal

19

May 3, 2024

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Apple Corps Limited.

(Exhibit 1 to Amended Complaint - Certificates of Registration for the Beatles Trademarks)

20

May 9, 2024

Plaintiff's NOTICE upon Defendant via Electronic Mail by Apple Corps Limited re 1 Complaint, 13 Order on Ex Parte Motion

(Exhibit Certificate of Sevice)

21

May 9, 2024

CERTIFICATE OF SERVICE by Apple Corps Limited re 14 Order on Ex Parte Motion, 16 Motion to Unseal Case, 7 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, 9 Sealed Document, 4 Certificate of Other Affiliates/Corporate Disclosure Statement, 3 Form AO 120/121, 6 Order on Motion to Seal, 8 Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law in Support Thereof, 1 Complaint, 10 Sealed Document, 13 Order on Ex Parte Motion, 5 Plaintiff's MOTION to Seal per Local Rule 5.4, 2 Clerks Notice of Judge Assignment, upon Defendants via website posting

22

May 14, 2024

PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Miscellaneous Hearing held on 5/14/2024, 11:10-11:15am. Preliminary Injunction to be entered. Attorney Appearance(s): Virgilio Gigante, Court Reporter: Patricia Bailey-Entin, 305-523-5635 / Patricia_BaileyEntin@flsd.uscourts.gov.

23

May 14, 2024

ORDER GRANTING MOTION FOR ENTRY OF PRELIMINARY INJUNCTION re 7 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof filed by Apple Corps Limited Signed by Judge Rodney Smith on 5/14/2024. See attached document for full details.

24

May 31, 2024

SUMMONS (Affidavit) Returned Executed on 19 Amended Complaint/Amended Notice of Removal, 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Apple Corps Limited. SHESHOW.COM served on 5/3/2024, response/answer due 5/24/2024.

Affidavit of Service

(Affidavit of Service)

25

May 31, 2024

Plaintiff's NOTICE upon Defendant via Electronic Mail by Apple Corps Limited re 23 Order

(Exhibit Certificate of Sevice)

26

May 31, 2024

CERTIFICATE OF SERVICE by Apple Corps Limited re 23 Order, upon Defendant via website posting

27

May 31, 2024

Plaintiff's MOTION for Clerk's Entry of Default as to SHESHOW.COM, THE INDIVIDUAL, BUSINESS ENTITY, OR UNINCORPORATED ASSOCIATION IDENTIFIED ON SCHEDULE A by Apple Corps Limited.

Exhibit Declaration of Stephen M. Gaffigan in Support of Request for Clerk's Entry of Default

(Text of Proposed Order)

28

June 3, 2024

Clerk's Entry of Default as to SHESHOW.COM, THE INDIVIDUAL, BUSINESS ENTITY, OR UNINCORPORATED ASSOCIATION IDENTIFIED ON SCHEDULE A - Motions Terminated: 27 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 6/3/2024.

29

July 3, 2024

Plaintiff's MOTION to Approve Consent Judgment (Responses due by 7/17/2024.), MOTION for Permanent Injunction as to Defendant by Apple Corps Limited.

Exhibit 1 - Consent Final Judgment and Permanent Injunction as to Defendant

Exhibit 2 - Statement of Consent as to Defendant

30

Nov. 5, 2024

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT Closing Case. Signed by Judge Rodney Smith on 11/5/2024. See attached document for full details.

31

Nov. 6, 2024

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

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