2022-cv-04819

COMPLAINT filed by Toyota Motor Sales, U.S.A., Inc.; Filing fee $ 402, receipt number AILNDC-19818032.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Toyota Motor Sales, U.S.A., Inc.

Notice of Claims Involving Trademarks by Toyota Motor Sales, U.S.A., Inc.

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Jake Michael Christensen

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Kahlia Roe Halpern

CASE ASSIGNED to the Honorable Sara L. Ellis. Designated as Magistrate Judge the Honorable Jeffrey Cummings. Case assignment: Random assignment.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

((List of Trademarks Exhibit 1))

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for temporary restraining order[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Teena Bohi regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Toyota Motor Sales, U.S.A., Inc. Exhibit 3 - Parts 1-6 regarding declaration[16]

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc.for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[13], motion for leave to file[3], motion for miscellaneous relief[18] before Honorable Sara L. Ellis on 9/20/2022 at 09:45 AM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motions for entry of a temporary restraining order 13, for leave to file under seal 3, and for electronic service of process 18. The Court sets a status date for 10/11/2022 at 9:30 a.m. Plaintiff should file any motion for preliminary injunction and notice it for presentment at the next status date. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (866) 434-5269 and the access code is 8087837. Counsel of record will receive an email with instructions to join the call. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Sara L. Ellis on 9/22/2022

BOND in the amount of $ 10,000.00 check, Receipt No. 4624277241, posted by Toyota Motor Sales, U.S.A., Inc.

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of extension of time[24]

Declaration of Jake M. Christensen

NOTICE of Motion by Jake Michael Christensen for presentment of extension of time[24] before Honorable Robert M. Dow Jr. on 10/6/2022 at 09:00 AM.

MINUTE entry before the Honorable Robert M. Dow, Jr: Plaintiff's motion to extend TRO [24] will be heard telephonically on 10/6/2022 at 9:00 a.m. by Judge Dow as Emergency Judge. Participants should use the Court's toll-free, call-in number 877-336-1829, passcode is 6963747. Mailed notice

ATTORNEY Appearance for Plaintiff Toyota Motor Sales, U.S.A., Inc. by Justin Tyler Joseph

MINUTE entry before the Honorable Robert M. Dow, Jr: Motion hearing held telephonically before Judge Dow as the emergency judge. Plaintiff's ex parte motion to extend the temporary restraining order until 10/20/2022 24 is granted. Emailed notice

MINUTE entry before the Honorable Sara L. Ellis: The Court strikes the status date set for 10/11/2022 and resets it to 10/20/2022 at 1:30 p.m. Plaintiff should file and notice for presentment at the next status date any motion for preliminary injunction. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (866) 434-5269 and the access code is 8087837. Counsel of record will receive an email with instructions to join the call. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for preliminary injunction[31]

Declaration of Justin T. Joseph

Exhibit 1

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction[31] before Honorable Sara L. Ellis on 10/20/2022 at 01:45 PM.

Exhibit A

SUMMONS Returned Executed by Toyota Motor Sales, U.S.A., Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/17/2022, answer due 11/7/2022.

Declaration of Kahlia R. Halpern

Exhibit A

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for preliminary injunction [31]. The Law Firm of Greer, Burns & Crain is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the Court's website located at www.ilnd.uscourts.gov/instructions. The Court strikes the status date set for 10/20/2022 and resets it to 11/17/2022 at 1:30 p.m. Plaintiff should file and notice for presentment any motion for default judgment to the next status date. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (866) 434-5269 and the access code is 8087837. Counsel of record will receive an email with instructions to join the call. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

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NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Sara L. Ellis on 10/27/2022:Mailed notice

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Toyota Motor Sales, U.S.A., Inc. as to a Certain Defendant

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for entry of default, MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Toyota Motor Sales, U.S.A., Inc. in support of motion for entry of default, motion for default judgment 40

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 41

(Exhibit 1)

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for entry of default, motion for default judgment 40 before Honorable Sara L. Ellis on 11/17/2022 at 01:30 PM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for default judgment as to all Defendants 40. The Court enters default judgment in favor of Plaintiff and against all Defendants on Amended Schedule A. Civil case terminated. Mailed notice

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, terminated case, 44 in the amount of $100,000 as to certain defendants

DEFAULT JUDGMENT ORDER signed by the Honorable Sara L. Ellis on 12/20/2022. Mailed notice.

FULL SATISFACTION of Judgment regarding order 46 in the amount of $100,000 as to certain defendants

MOTION by Plaintiff Toyota Motor Sales, U.S.A., Inc. to amend/correct order[46]

NOTICE of Motion by Justin Tyler Joseph for presentment of motion to amend/correct[48] before Honorable Sara L. Ellis on 1/17/2023 at 09:45 AM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion to amend the default judgment order 48. The Court corrects the default judgment order in paragraph 9 of the Default Judgment Order 46 to reflect that the ten thousand dollar ($10,000) cash bond posted by Plaintiff should be released to Toyota or its counsel. Mailed notice

AMENDED DEFAULT JUDGMENT ORDER. Signed by the Honorable Sara L. Ellis on 1/26/2023:Mailed notice

FULL SATISFACTION of Judgment regarding order 46 in the amount of $100,000 as to certain defendant