2023-cv-00762

COMPLAINT filed by Brigid Ashwood; Filing fee $ 402, receipt number AILNDC-20325642.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Brigid Ashwood Schedule A to Complaint (1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Brigid Ashwood by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Brigid Ashwood by Yanling Jiang

ATTORNEY Appearance for Plaintiff Brigid Ashwood by Yi Bu

ATTORNEY Appearance for Plaintiff Brigid Ashwood by Adam Grodman

ATTORNEY Appearance for Plaintiff Brigid Ashwood by Cameron Eugene Mcintyre

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment.

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

MAILED copyright report to Registrar, Washington DC.

MOTION by Plaintiff Brigid Ashwood for leave to file under seal

MOTION by Plaintiff Brigid Ashwood for leave to file excess pages

MINUTE entry before the Honorable Edmond E. Chang: The notice of motion for 02/15/2023 is vacated. In this copyright-infringement case, the Plaintiff's motion 13 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, 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 11 for leave to file under seal is granted in light of the asset-restraint goal. The Plaintiff's motion 12 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 03/03/2023 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) no later than 02/24/2023. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 02/14/2023. Emailed notice

(Public Version) SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 02/14/2023. 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 Brigid Ashwood. (Document not scanned).

MOTION by Plaintiff Brigid Ashwood for preliminary injunction

MEMORANDUM by Brigid Ashwood in support of motion for preliminary injunction 22

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 22 before Honorable Edmond E. Chang on 2/28/2023 at 08:30 AM.

SUMMONS Returned Executed by Brigid Ashwood as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/22/2023, answer due 3/15/2023.

(Declaration of Service)

MINUTE entry before the Honorable Edmond E. Chang: In light of the facts that justified the entry of the TRO, the motion for preliminary injunction 22 is granted. Given the answer deadline of 03/15/2023, the tracking status hearing of 03/03/2023 is reset to 04/07/2023 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 03/31/2023. If the Defendants fail to answer on time, then they will be deemed in default, and the Plaintiff shall file the motion for default judgment by 03/31/2023. The notice of motion for 02/28/2023 is vacated. The Court notes that, under the operative Seventh Amended General Order 21-0027, Local Rule 5.3(b) is suspended, so motions should not be noticed for presentment. Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 02/23/2023. Emailed notice

MOTION by Plaintiff Brigid Ashwood for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendants Identified in the [Amended] Schedule A

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion for default judgment 28 is granted in part. Statutory damages are awarded in the amount of ten-thousand dollars ($10,000). In light of the finding of willfulness, a permanent injunction shall be entered. A separate AO-450 judgment shall be entered. The tracking status hearing of 04/07/2023 is vacated. Civil case terminated. FOR FUTURE REFERENCE, UNDER THE SEVENTH AMENDED GENERAL ORDER 21-0027 (AVAILABLE ON THE DISTRICT COURT'S WEBSITE), LOCAL RULE 5.3(B) IS SUSPENDED, SO MOTIONS SHOULD NOT BE NOTICED FOR PRESENTMENT. THE NOTICE OF MOTION IS VACATED. Emailed notice

DEFAULT JUDGMNET ORDER Signed by the Honorable Edmond E. Chang on 03/20/2023. Emailed notice (mw,)

ENTERED JUDGMENT Signed by the courtroom deputy on 03/20/2023. Emailed notice