2021-cv-05669

COMPLAINT filed by Cecilia Granata; Filing fee $ 402, receipt number 0752-18801523.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Cecilia Granata Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Cecilia Granata by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Cecilia Granata by Yanling Jiang

ATTORNEY Appearance for Plaintiff Cecilia Granata by Yi Bu

ATTORNEY Appearance for Plaintiff Cecilia Granata by Adam Grodman

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment.

SEALED DOCUMENT by Plaintiff Cecilia Granata Amended Schedule A 2 to Complaint 1

MOTION by Plaintiff Cecilia Granata for leave to file [Certain] Documents Under Seal

MOTION by Plaintiff Cecilia Granata for leave to file excess pages

MEMORANDUM In Support of 11 Ex Parte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, Declaration of Keith Vogt

Declaration of Cecilia Granata

Exhibit 1, Declaration of Cecilia Granata

SEALED EXHIBIT by Plaintiff Cecilia Granata Sealed Exhibit 2 to the Declaration of Cecilia Granata regarding memorandum in support of motion, 12

MAILED Copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Edmond E. Chang: In this copyright-infringement case, the Plaintiff's motion 11 for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 17 U.S.C. § 504(b), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, trademark owners need only prove "the infringer's gross revenue"; the defendants must prove expenses. 15 U.S.C. §504(b). To the extent that the restraint might be too broad, the Defendant may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendants, who likely would seek to transfer the money elsewhere. The Plaintiff's motion 9 for leave to file under seal is granted in light of the asset-restraint goal. The motion 10 for extra pages is granted. By 12/06/2021, The Plaintiff shall email a redacted version of the TRO that can be entered publicly (redacting the names of Defendants and omitting Amended Schedule A). To track the case only (no appearance is required, the case will not be called), a status hearing is set for 12/08/2021 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) no later than 12/03/2021. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 11/24/2021. Emailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule "A"

NOTICE of Voluntary Dismissal by Cecilia Granata

SURETY BOND in the amount of $ 10,000.00 posted by Cecilia Granata. (Document not imaged)

MINUTE entry before the Honorable Edmond E. Chang: On review of the notice of voluntary dismissal, R. 17, the notice states, "This terminates the action." But by the notice's terms, the dismissal would not apply to the three Defendants against which the TRO was entered. The Plaintiff shall promptly file an amended notice of voluntary dismissal clarifying its intended effect. Emailed notice

NOTICE of Voluntary Dismissal by Cecilia Granata AMENDED NOTICE of Voluntary Dismissal

MINUTE entry before the Honorable Edmond E. Chang: Pursuant to the amended notice of voluntary dismissal 20, under Federal Rule of Civil Procedure 41(a)(1)(A)(i), the case is dismissed without prejudice. Tracking status hearing of 12/08/2021 is terminated. Civil case terminated. Emailed notice