2022-cv-04387

COMPLAINT filed by Jonas Sebastian Jodicke; Filing fee $ 402, receipt number AILNDC-19755275.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Jonas Sebastian Jodicke [Amended] Schedule A to Complaint (1) and Schedule A to Complaint (2)

MOTION by Plaintiff Jonas Sebastian Jodicke for leave to file under seal

MOTION by Plaintiff Jonas Sebastian Jodicke for leave to file excess pages

MEMORANDUM in support of 11 Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Jonas Sebastian Jodicke's declaration

(Exhibit 1, of Jonas Sebastian Jodicke's declaration)

SEALED EXHIBIT by Plaintiff Jonas Sebastian Jodicke Sealed Exhibit 2, Declaration of Jonas Sebastian Jodicke regarding memorandum in support of motion, 12

Exhibit 2-1

(Exhibit 2-2)

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, as well as a redacted version on the public docket. 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, copyright owners need only prove "the infringer's gross revenue"; the defendant must prove expenses. 17 U.S.C. §504(b). To the extent that the restraint might be too broad, the Defendants 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 Plaintiff's motion 10 for extra pages is granted. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 09/09/2022 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) if appropriate no later than 09/02/2022. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 08/26/2022. Emailed notice

(Public Version) SEALED TEMPORARYRESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 08/26/2022. Emailed notice

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

SURETY BOND in the amount of $ 10,000 posted by Jonas Sebastian Jodicke. (Document not scanned)

MOTION by Plaintiff Jonas Sebastian Jodicke for preliminary injunction

MEMORANDUM by Jonas Sebastian Jodicke in support of motion for preliminary injunction 18

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

SUMMONS Returned Executed by Jonas Sebastian Jodicke as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/30/2022, answer due 9/20/2022.

(Declaration of Service)

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the facts that justified entry of the TRO, motion for preliminary injunction 18 is granted. Given the answer deadline of 09/20/2022, the tracking status hearing of 09/09/2022 is reset to 10/07/2022 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 09/26/2022. If the Defendant has not answered by the 09/26/2022 deadline, then the Defendant is deemed in default and the Plaintiff shall file a motion for default judgment on 09/28/2022. Emailed notice

(Status Report Requirements)

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 08/31/2022. Emailed notice

MOTION by Plaintiff Jonas Sebastian Jodicke for default judgment as to The Defendants Identified In [Amended] Schedule A

MEMORANDUM by Jonas Sebastian Jodicke in support of motion for default judgment 23

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

ORDER signed by the Honorable Edmond E. Chang. For the reasons stated in the Order, the motion for default judgment is granted. In light of the willfulness established by the default, a permanent injunction is entered. Statutory damages in the amount of fifteen-thousand dollars ($15,000) is awarded against each of the Defendants. A separate AO-450 judgment shall be entered. The tracking status hearing of 10/07/2022 is vacated. Civil case terminated. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 10/06/2022. Emailed notice