2023-cv-01333

2023-cv-01333 General Motors LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A

Date :3/3/2023
Court :Northen District of Illinois
Law FirmGBC

#

Date

Document

1

March 3, 2023

COMPLAINT filed by General Motors LLC; Filing fee $ 402, receipt number AILNDC-20406098.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

2

March 3, 2023

EXHIBIT by Plaintiff General Motors LLC Schedule A regarding complaint 1 Modified on 4/19/2023.

3

March 3, 2023

MOTION by Plaintiff General Motors LLC for leave to file under seal

4

March 3, 2023

CIVIL Cover Sheet

5

March 3, 2023

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by General Motors LLC

6

March 3, 2023

Notice of Claims Involving Trademarks by General Motors LLC

7

March 3, 2023

ATTORNEY Appearance for Plaintiff General Motors LLC by Justin R. Gaudio

8

March 3, 2023

ATTORNEY Appearance for Plaintiff General Motors LLC by Amy Crout Ziegler

9

March 3, 2023

ATTORNEY Appearance for Plaintiff General Motors LLC by Jake Michael Christensen

10

March 3, 2023

ATTORNEY Appearance for Plaintiff General Motors LLC by Rachel S Miller

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Text entry; no document attached.)

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. (Text entry; no document attached.)

11

March 8, 2023

MOTION by Plaintiff General Motors LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

12

March 8, 2023

MEMORANDUM by General Motors LLC in support of motion for temporary restraining order 11

13

March 8, 2023

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

14

March 8, 2023

DECLARATION of Andrea Ankawi regarding memorandum in support of motion 12

(Exhibit 1)

15

March 8, 2023

EXHIBIT by Plaintiff General Motors LLC Exhibit 2 - Parts 1 - 8 regarding declaration 14 Modified on 4/19/2023.

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

Exhibit 2-7

(Exhibit 2-8)

16

March 8, 2023

MOTION by Plaintiff General Motors LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

17

March 8, 2023

MEMORANDUM by General Motors LLC in support of motion for miscellaneous relief 16

18

March 8, 2023

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

19

March 8, 2023

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 16, motion for leave to file 3, motion for temporary restraining order 11 before Honorable Jorge L. Alonso on 3/21/2023 at 09:30 AM.

20

March 20, 2023

ATTORNEY Appearance for Plaintiff General Motors LLC by Justin Tyler Joseph

21

March 20, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 3/21/23 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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.Notice mailed by Judge's staff

22

March 21, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 3 is granted. Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 11 is granted. Enter Sealed Temporary Restraining Order. The temporary restraining order will remain in effect for fourteen days. Plaintiff's motion for electronic service of process pursuant to Fed.R.Civ.P.4(f)(3) 16 is granted. Telephonic status hearing set for 4/4/23 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

23

March 21, 2023

TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 3/21/2023. Notice mailed by Judge's staff Modified on 4/19/2023.

24

March 23, 2023

SURETY BOND in the amount of $ 10,000 posted by General Motors LLC.(Document not scanned)

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

25

March 30, 2023

MOTION by Plaintiff General Motors LLC for extension of time of Temporary Restraining Order

26

March 30, 2023

MEMORANDUM by General Motors LLC in support of extension of time 25

(Declaration of Jake M. Christensen)

27

March 30, 2023

NOTICE of Motion by Jake Michael Christensen for presentment of extension of time 25 before Honorable Jorge L. Alonso on 4/4/2023 at 09:30 AM.

28

April 3, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motion to extend the temporary restraining order 25 is granted. The temporary restraining order is extended for 14 days to 4/18/23. Motion hearing previously set for 4/4/23 is stricken. Telephonic status hearing previously set for 4/4/23 is stricken and reset to 4/18/23 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

29

April 13, 2023

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

30

April 13, 2023

MOTION by Plaintiff General Motors LLC for preliminary injunction

(Exhibit A)

31

April 13, 2023

MEMORANDUM by General Motors LLC in support of motion for preliminary injunction 30

Declaration of Jake M. Christensen

(Exhibit 1)

32

April 13, 2023

NOTICE of Motion by Jake Michael Christensen for presentment of motion for preliminary injunction 30 before Honorable Jorge L. Alonso on 4/18/2023 at 09:30 AM.

(Exhibit A)

33

April 13, 2023

SUMMONS Returned Executed by General Motors LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/13/2023, answer due 5/4/2023.

Declaration of Rachel S. Miller

(Exhibit A)

34

April 18, 2023

ATTORNEY Appearance for Defendant BYS Technology by Steven G Kalberg

35

April 18, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 6/6/23 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction 30 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all previously sealed documents. Plaintiff 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 at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

36

April 18, 2023

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jorge L. Alonso on 4/18/2023. Notice mailed by Judge's staff

NEW PARTIES: Good car, good life Store, HAHHA Store, Healthy and Safe Store, Helius 777 Store, HHH Car Accessories Store, Hi Automotive supplies Store, HIGHWAY TOY Store, HM Decor Store, HUAILI Store, HUAIYU Store, huangniuniu Store, Iapetus 777 Store, iJDM Official Store, imUfer Store, INUODESIGN Store, Jennifer's car Store, Jumping in My Car Store, Kaizen-GT Official Store, LULU automobile Store, Make the car beautiful Store, Mayi Store, Miss U Store, NICESHIRT Store, NUO WAN AUTOHOME 003 Store, OFOCN Store, pku.8 Store, Prometheuss 777 Store, SevenV Car boutique Store, Shop 5 Store, Shop110000071 Store, Shop1102115835 Store, Shop1102152966 Store, Shop1102152967 Store, Shop1102154904 Store, Shop1102161942 Store, Shop1102209059 Store, Shop1102213033 Store, Shop110222000105 Store, Shop1102300a96 Store, Shop1102313989 Store, Shop1102337534 Store, Shop1102352537 Store, Shop1102377453 Store, Shop110240000108 Store, Shop1102410775 Store, Shop1102418653 Store, Shop1102422627 Store, Shop1102538135 Store, Shop1102539288 Store, Shop1102565104 Store, Shop911048118 Store, Shop911194084 Store, Shop911230002 Store, Shop911391240 Store, Tomatooffice Store, Toubu Store, t-shirt11 Store, T-SHIRT6 Store, UCW Store, WENWEN2023 Store, WithYou Store, XIAOXIAO Store, YALA car Store, YAOHU Store, Yaojun Car Products trading company Store, YS3 car accessories Store, A2740SNJBNUGUI, AHCY, BAOYUUN, BYS Technology, Changsha Yuhua District zhian Department Store, Chartina, cheikoos, chenlibaowujindian, Chu L, Coshone, dadaSupermarket, DingAnBinLiHuaShangMaoYouXianGongSi, dongfangzhiyanshangmaoyouxiangongsi, Gold Department Store, guanlia, guoyangxianmanshubaihuoyouxiangongsi, hefeishiliejiaodianzishangwuyouxiangongsi, HelenMLeal, HongSiBaiHuo, huanghuaxing, Jiaoyuyuan, kunpiaomaoyixiaopu, Lanxin qq Store, LiangBinDeXiaoDian, liangliangedqipei, linakhsdhjbegk, linxiangqufengshengzhongzhiyuan, liujiadedianpu, lixinhuanxinxinxikejiyouxiangongsi, LTingTTT123, Made in America First, MaoGe-Store, MaYongHengDHSKJJDKS, meinanzius, melodysunny, miyuebindedian, np0909, qionghaizhunheweidianzikejiyouxiangongsi., quanzhoutingyu, rewfdmjuko, Richer-yuxin231, Rosemaly, Senkuimuye, SHANGLINGSHANGMAO, songshanquyunmiaobaihuojingyingbu, taipidianzishangwuyouxianxiaodian, tangre55, Tlooong, Ucvij, UDoo82km, US Revitalizes Manufacturing Industry - Chen, WangJingwj01, WangLiLiLi, Washton store, xiangjiedianzimei, XiongQiaoXianQiPanWen, YeaWheel, yetaokj, YIZHU Store, yuanchaodedianpu, YUJINBAO, ZhenFAitems, zhijiangshipanjiaoshangmao, zihengjingpindian, 381110814zq, 6399shopping, 6399truckcar, autotruckparts, bonnilystore, carcrossover, carpartsdeals, cheerauto, chenqiuhua, che--store, col_5240, emblemofgood, gsjrtb, gzaotian, happytogogo, hejianyu, hongya-93, kunminghaomiuwangl-0, ouhaodingsheng7, ourkindnessf0, special-tailgate-letters, stickers-8, weiyu1122, yufangmiao, yuweicheng1989, AIZHIWENG, ao pan kun shang mao, Furniture Co.Ltd, HTY Co. Ltd, jia luo jue, jiaminmaoyiyouxiangongsi, pan xiao, shuo shuo da kang, xie shu, AAAUP, aiudyqkdq, BBBUP, Car Styling, DDDUP, Louis's Style, sunqihui 00852, wmshiyi and xunyun2668839971 added to case caption. (Text entry; no document attached.)

37

April 21, 2023

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

38

April 27, 2023

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

39

April 28, 2023

ATTORNEY Appearance for Defendants 6399shopping, 6399truckcar, autotruckparts, bonnilystore, carcrossover, carpartsdeals, cheerauto, emblemofgood, gzaotian, happytogogo, special-tailgate-letters by Ruoting Men

40

May 1, 2023

MOTION by Defendant BYS Technology for extension of time to file answer or otherwise respond to plaintiff's complaint (unopposed)

41

May 1, 2023

NOTICE of Motion by Steven G Kalberg for presentment of motion for extension of time to file answer 40 before Honorable Jorge L. Alonso on 5/9/2023 at 09:30 AM.

42

May 4, 2023

MOTION by Defendants 6399shopping, 6399truckcar, autotruckparts, bonnilystore, carcrossover, carpartsdeals, cheerauto, emblemofgood, gzaotian, happytogogo, special-tailgate-letters for extension of time

43

May 4, 2023

NOTICE of Motion by Ruoting Men for presentment of extension of time 42 before Honorable Jorge L. Alonso on 5/10/2023 at 09:30 AM.

44

May 8, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Defendant BYS Technology's Motion for a first extension of time to answer or otherwise respond to Plaintiff's complaint 40 is granted to 6/5/23. Motion hearing date of 5/9/23 is stricken. Notice mailed by Judge's staff

45

May 8, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Defendants 6399shopping, 6399truckcar, autotruckparts, bonnilystore, carcrossover, carpartsdeals, cheerauto, emblemofgood, gzaotian, happytogogo, special-tailgate-letters' First unopposed motion for extension of time 42 is granted to 5/25/23. Motion hearing date of 5/10/23 is stricken. Notice mailed by Judge's staff

46

May 11, 2023

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

47

May 25, 2023

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendant

48

May 25, 2023

ANSWER to Complaint by 6399shopping, 6399truckcar, autotruckparts, bonnilystore, carcrossover, carpartsdeals, cheerauto, emblemofgood, gzaotian, happytogogo, special-tailgate-letters

49

May 30, 2023

NOTICE of Voluntary Dismissal by General Motors LLC as to Certain Defendants

50

May 30, 2023

MOTION by Plaintiff General Motors LLC for entry of default, MOTION by Plaintiff General Motors LLC for default judgment as to all Defendants with the Exception of Certain Defendants

(Exhibit A)

51

May 30, 2023

MEMORANDUM by General Motors LLC in support of motion for entry of default, motion for default judgment, 50

(Exhibit 1)

52

May 30, 2023

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 51

(Exhibit 1)

53

May 30, 2023

NOTICE of Motion by Jake Michael Christensen for presentment of motion for entry of default, motion for default judgment, 50 before Honorable Jorge L. Alonso on 6/6/2023 at 09:30 AM.

(Exhibit A)

54

June 5, 2023

ANSWER to Complaint by BYS Technology

55

June 5, 2023

ATTORNEY Appearance for Defendants BYS Technology, BYS Technology by David Randolph Bennett

56

June 6, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 7/6/23 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's motion for entry of default and default judgment against all remaining Defendants, with the exception of Defendant Nos. 70, 132-133, 137-141, 148-149, and 160 50 is granted. Enter Order. The parties are directed to file a joint status report by 7/3/23. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

59

June 6, 2023

FINAL Judgment Order. Signed by the Honorable Jorge L. Alonso on 6/6/2023. Notice mailed by Judge's staff

57

June 20, 2023

MOTION by Attorney Ruoting Men to withdraw as attorney for 6399shopping, 6399truckcar, autotruckparts, bonnilystore, carcrossover, carpartsdeals, cheerauto, emblemofgood, gzaotian, happytogogo, special-tailgate-letters. New address information: Building 4, No. 111 Yingbin Road, Panyu District, Guangzhou City (1968342167@qq.com) (+86 15374036299)

(Exhibit Defendants' Contact Information)

58

June 21, 2023

STIPULATION of Dismissal

60

June 30, 2023

FULL SATISFACTION of Judgment regarding order 59 in the amount of $200,000 as to certain defendants

61

June 30, 2023

STATUS Report by General Motors LLC

63

July 6, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 8/22/23 at 9:30 a.m. No one appears on behalf of Defendants. Glacier Law's Motion to withdraw as counsel for Defendants 57 is granted. Attorney Ruoting Men is given leave to withdraw as counsel for Defendants. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

62

July 11, 2023

NOTICE of Motion by Ruoting Men for presentment of motion to withdraw as attorney, 57 before Honorable Jorge L. Alonso on 7/13/2023 at 09:30 AM.

64

Aug. 3, 2023

MOTION by Plaintiff General Motors LLC for sanctions Pursuant to Rule 37

(Exhibit A - Service Emails)

65

Aug. 3, 2023

DECLARATION of Rachel S. Miller regarding motion for sanctions 64

(Exhibit 1)

66

Aug. 3, 2023

NOTICE of Motion by Rachel S Miller for presentment of motion for sanctions 64 before Honorable Jorge L. Alonso on 8/9/2023 at 09:30 AM.

(Exhibit A - Service Emails)

67

Aug. 9, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 8/9/23 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

68

Aug. 9, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. For the reasons stated on the record, Plaintiff's Motion for sanctions pursuant to rule 37 64 is granted. Defendants 6399shopping, 6399truckcar, autotruckparts, bonnilystore, carcrossover, carpartsdeals, cheerauto, emblemofgood, gzaotian, happytogogo, special-tailgate-letters' answer 48 is stricken. Status hearing previously set for 8/22/23 is stricken and reset to 8/30/23 at 9:30 a.m. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

69

Aug. 24, 2023

MOTION by Plaintiff General Motors LLC for entry of default, MOTION by Plaintiff General Motors LLC for default judgment as to all Defendants

(Exhibit A)

70

Aug. 24, 2023

MEMORANDUM by General Motors LLC in support of motion for entry of default, motion for default judgment 69

71

Aug. 24, 2023

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 70

(Exhibit 1)

72

Aug. 24, 2023

NOTICE of Motion by Jake Michael Christensen for presentment of motion for entry of default, motion for default judgment 69 before Honorable Jorge L. Alonso on 8/30/2023 at 09:30 AM.

(Exhibit A)

73

Aug. 30, 2023

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment against all remaining Defendants 69 is granted. Enter Final Default Judgment Order. Civil case terminated. Notice mailed by Judge's staff

74

Aug. 30, 2023

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 8/30/2023. Notice mailed by Judge's staff

75

Oct. 19, 2023

FULL SATISFACTION of Judgment regarding order 59 in the amount of $200,000 as to certain defendants

76

Jan. 11, 2024

FULL SATISFACTION of Judgment regarding order 59 in the amount of $200,000 as to certain defendant

77

April 25, 2024

FULL SATISFACTION of Judgment regarding order 74 in the amount of $200,000 as to certain defendants

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