2023-cv-03595

2023-cv-03595 Fletcher et al v. The Partnerships and Unincorporated Associations Identified on Schedule A

Date :6/7/2023
Court :Northen District of Illinois
Law FirmGBC

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Date

Document

1

June 7, 2023

COMPLAINT filed by Bryan Fletcher, Garrett Fletcher; Filing fee $ 402, receipt number AILNDC-20713481.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

2

June 7, 2023

SEALED EXHIBIT by Plaintiffs Bryan Fletcher, Garrett Fletcher Schedule A regarding complaint[1]

3

June 7, 2023

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for leave to file under seal

4

June 7, 2023

CIVIL Cover Sheet

5

June 7, 2023

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Justin R. Gaudio

6

June 7, 2023

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Amy Crout Ziegler

7

June 7, 2023

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Justin Tyler Joseph

8

June 7, 2023

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Joan H. Lefkow. Designated as Magistrate Judge the Honorable Jeffrey I. Cummings. 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.

9

June 8, 2023

MAILED copyright report to Registrar, Washington DC.

10

June 8, 2023

EXECUTIVE COMMITTEE ORDER: Case reassigned to the Honorable Franklin U. Valderrama for all further proceedings pursuant to 28:294(b). Honorable Joan H. Lefkow no longer assigned to the case. Signed by Executive Committee on 6/8/23.

11

June 9, 2023

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, Plaintiff's motion for leave to file under seal 3 is granted. Schedule A to the Complaint 2 may remain under seal, and Plaintiff may file Exhibit 2 to the Declaration of Steve Fletcher under seal. Mailed notice.

12

June 12, 2023

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

13

June 12, 2023

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for temporary restraining order[12]

14

June 12, 2023

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

15

June 12, 2023

DECLARATION of Steve Fletcher regarding memorandum in support of motion[13]

Exhibit 1

16

June 12, 2023

SEALED EXHIBIT by Plaintiffs Bryan Fletcher, Garrett Fletcher Exhibit 2 - Parts 1 - 7 regarding declaration[15]

17

June 12, 2023

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

18

June 12, 2023

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for miscellaneous relief[17]

19

June 12, 2023

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

Exhibit 1

Exhibit 2

20

June 12, 2023

MEMORANDUM by Bryan Fletcher, Garrett Fletcher Establishing that Joinder is Proper

Declaration of Justin R. Gaudio

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

21

June 13, 2023

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's ex parte motion for a temporary restraining order [12], and motion for electronic service of process [17]. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on 6/15/2023 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Emailed notice

22

June 13, 2023

SEALED TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 6/13/2023. Emailed notice

23

June 15, 2023

SURETY BOND in the amount of $ 10,000 posted by Bryan Fletcher, Garrett Fletcher. (Document not Scanned)

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

24

June 26, 2023

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for preliminary injunction as to Certain Defendants

Exhibit A

25

June 26, 2023

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for preliminary injunction[24]

Declaration of Justin T. Joseph

Exhibit 1

26

June 26, 2023

SUMMONS Returned Executed by Bryan Fletcher, Garrett Fletcher as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/26/2023, answer due 7/17/2023.

Declaration of Trevor C. Talhami

Exhibit A

27

June 27, 2023

MINUTE entry before the Honorable Franklin U. Valderrama:On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction as to certain defendants 24 is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint 2 ; (2) Exhibit 2 to the Declaration of Steve Fletcher 16 ; and (3) the TRO 22. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Emailed notice.

(Add and Terminate Parties) (axc)

28

June 27, 2023

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 6/27/2023. Emailed notice

29

July 6, 2023

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

30

July 13, 2023

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

NEW PARTIES: Changsha Qianzhi Technology Co., Ltd., Dongyang Xingyue Festival Articles Co., Ltd., Fuzhou Nice Trading Co., Ltd., Guangzhou Aoxin Trading Co., Ltd., Guangzhou Kemoli International Trading Co., Limited, Guangzhou Longcheng Ceramics Co., Limited, Jianou Ruiheyi Import& Export Trading Co., Shenzhen Goostar Handbag Co., Ltd., Shenzhen Tianchenxing Technology Co., Ltd., Shenzhen YouNeed Technology Co., Ltd, Yiwu Jingdun Trading Co.,ltd, Yiwu Juanli Daily Necessities Co., Ltd., Yiwu Lanqu Trading Company Limited, Yiwu Qianyi Trading Co., Ltd., Yiwu Yayang Trading Co., Ltd., A anime peripheral Store, Anime Jueji Store Store, BANDAI Action Toy Figures Store, Best More Dropshipping Store, Big Sharks Store, Brilliant Cheerful Life Store, Childrens Fun House Store, Cute Stuffed Toys Store, Disney Childrens House Store, Dropshiping Good Toys Store Store, Georage Store, Joy-Toy Store, Lovely Anime Toys Store, Novelty Shop Store, QM 6 Jewelry Store, Shop1100018085 Store, Shop1100037069 Store, Shop1100290105 Store, Shop1102249314 Store, Shop1102371363 Store, Shop1102457744 Store, Shop1102619071 Store, Shop1102663613 Store, Shop1102696033 Store, Shop1102718693 Store, Sosmart Store, Specially party Store, Super Funny Toys Store, Surroundings Of Anime Cosplay Store, ZHIZHI-69 Store, A1YD9Z1HOOJSW1, A34IVIVGHVBBND, A7MV63RM6IQAX, ainimoor, AIZ188XZHVAN0, Amzon ChenYue Store, Anime World(7-15 day delivery), anqingkaoleishangmaoyouxiangongsi, AO94W79AJOGMA, BAOGUO-SHOP, CaiJinHaoUS, Chaoxue Shop, chengdufengyutuchengdia, chongqingchengshengyanyimaoyiyouxiangongsi, CRAMZDT Daily Supplies, Dahuiyuan, Dakemengdirect, Dayang Shop, duanhuanshangmao, duchangxiancunmiaobaihuodian, enshishisiniaoshangmaoyouxiangongsi, ffadfad, foshanshihaochenliangkejiyouxiangongsi, geernika, GFDTRSFGXGGS, Good quality goods, GuangZhouBengGanShangMaoYouXianGongSi, guangzhouruisongshangmaoyouxiangongsi, hellorainbow, hengyangshiqiaoxuwangluokejiyouxiangongsi, hengyangshishaofuwangluokejiyouxiangongsi, huangyashan, INVINCIBLE-M, JiaChuChuUS, Jin Jin Jin, jinanshuoyangshangmaoyouxiangongsi, jinwancheng-US, Jinxing us shop, kabudaxiaobao, kunminggaowamaoyiyouxianzerengongsi, KunTaiPengQi, LAN-MEI, linshengaa, LiuBinHua ZhiYouYun, lizongyuandedian, Ljxsft, LyHdDDP18, MA-SHAOJUN, MAYAN-SHOP, MDMR, mengminkeji, MingShun, Nebula ok, Panchunyu, qinwenh, renshukangbabaihuodian, RICHFEVYFS STORE, rizhaohaomin, Roygbiv-us, sanyayinbomaoyi, ShanYuQiBoShangMao, shenzhenshiyueyuejiajuzhuangshiyouxiangongsi, Silver dike shop, SongYuLinUS, ssfgjkl, Stephen toy gifts, STROLTZZ, TunChangYuanYuTuShangMaoYouXianGongSi, wangyandebeimeidianpu, WANGYUHUA, wansgwei, WENKK, xiamengudulaoren, Xilei Baihuo, xinshengyangmaoyi, yichangjiangyanghuangdianzishangwuyouxiangongsi, yiwushihuanyingguojimaoyiyouxiangongsi, yiwushijinqindianzishangwuyouxiangongsi, yobel US, yuanguofu, YuChenLiUS, yunnanluobidianzishangwuyouxiangongsi, yunxiaoxianmoyibaihuodian, YYAJD, ZEUROUN, ZhangGuanYuUS, zhaoxingyudedianpu1, zongxuan237868, angelhometextiles, babiq03, babiq04, cfdr785, cherries, fantasy17, jinhong2022, lihaoyx, liling1985021, lkjh87, treg8702, ujh5104, us_missouri, us_ohio, youne, danzhoushifengjiesh0, fzbml520, huankan_73, liuyan-9, lxtnrs_30, oag662, simplemarts, tezha67, tongdao1688, ut5738, ylbjj697_21, Meboyz US, Natural Square and REGIS added to case caption.

31

July 14, 2023

SUMMONS Returned Executed by Garrett Fletcher, Bryan Fletcher as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/14/2023, answer due 8/4/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

32

July 17, 2023

ATTORNEY Appearance for Defendant Guangzhou Aoxin Trading Co., Ltd. by Steven G Kalberg

33

July 20, 2023

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

34

July 21, 2023

MOTION by Defendant Guangzhou Aoxin Trading Co., Ltd. for extension of time to file answer or otherwise respond to plaintiffs' complaint and to respond to plaintiffs' discovery requests (unopposed)

35

July 24, 2023

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, Defendant Guangzhou Aoxin Trading Co., Ltd.'s unopposed motion for extension of time to file answer or otherwise respond to plaintiffs' complaint and to respond to plaintiffs' discovery requests [34] is granted. Defendant Guangzhou Aoxin Trading Co., Ltd.'s answer or other responsive pleading to Plaintiff's complaint is now due by 8/16/2023. The Court advises Defendant that typically parties need not seek Court approval for extensions of time to respond to another party's discovery requests. However, given the request is unopposed, the Court grants Defendant's request for a 30-day extension of time to respond to any discovery requests. Mailed notice.

36

July 27, 2023

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

37

Aug. 10, 2023

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

38

Aug. 15, 2023

MOTION by Defendant Guangzhou Aoxin Trading Co., Ltd. for extension of time to file answer or otherwise respond to plaintiff's complaint (unopposed)

39

Aug. 16, 2023

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Defendant Guangzhou Aoxin Trading Co., Ltd.'s Unopposed Motion for a Second Extension of Time to Answer or Otherwise Respond to Plaintiffs' Complaint [38]. Defendant Guangzhou Aoxin Trading Co., Ltd.'s answer or other responsive pleading to Plaintiff's complaint is now due by 8/30/2023. Emailed notice

40

Aug. 17, 2023

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendant

41

Aug. 18, 2023

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for entry of default, MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for default judgment as to all Defendants

(Exhibit A)

42

Aug. 18, 2023

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for entry of default, motion for default judgment, 41

(Exhibit 1)

43

Aug. 18, 2023

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 42

(Exhibit 1)

44

Aug. 24, 2023

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

45

Aug. 29, 2023

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiff's Motion for Entry of Default and Default Judgment against the Defendants Identified in Schedule A 41 is granted. Enter Final Judgment Order. The ten thousand dollar ($10,000.00) surety bond posted by Greer Burns & Crain Ltd., including any interest minus the registry fee, is hereby released to Justin R. Gaudio of Greer Burns & Crain Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Justin R. Gaudio of Greer Burns & Crain Ltd., 300 South Wacker Drive, Suite 2500, Chicago, IL 60606 via certified mail. Civil case terminated. Emailed notice

46

Aug. 29, 2023

FINAL JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 8/29/2023. Emailed notice

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Bryan Fletcher and Garrett Fletcher to Justin R. Gaudio from Greer, Burns, & Crain, Ltd, 300 South Wacker Drive Suite 2500 Chicago IL. 60606 via certified mail #7019 2280 0000 0962 5575.

47

Sept. 8, 2023

MAILED copyright report with certified copy of minute order dated 8/29/2023 to Register of Copyrights, Washington, D.C.

48

Sept. 26, 2023

RETURN of U.S. Post Office Receipt, article no. 7019 2280 0000 0962 5575.

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