2024-cv-00012

2024-cv-00012 Harley-Davidson Motor Company, Inc. v. The Partnerships and Unincorporated Associations Identified on Schedule A

Date :1/2/2024
Court :Northen District of Illinois
Law FirmGBC

#

Date

Document

1

Jan. 2, 2024

COMPLAINT filed by Harley-Davidson Motor Company, Inc.; Filing fee $ 405, receipt number AILNDC-21477697.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

2

Jan. 2, 2024

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Schedule A regarding complaint 1

3

Jan. 2, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for leave to file under Seal

4

Jan. 2, 2024

CIVIL Cover Sheet

5

Jan. 2, 2024

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Harley-Davidson Motor Company, Inc.

6

Jan. 2, 2024

Notice of Claims involving Trademarks by Harley-Davidson Motor Company, Inc.

7

Jan. 2, 2024

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Justin R. Gaudio

8

Jan. 2, 2024

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Amy Crout Ziegler

9

Jan. 2, 2024

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Marcella Deshonda Slay

10

Jan. 2, 2024

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Virginia M. Kendall. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2). (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

Jan. 3, 2024

MAILED trademark report to Patent Trademark Office, Alexandria VA.

12

Jan. 3, 2024

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

13

Jan. 3, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

14

Jan. 3, 2024

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for temporary restraining order 13

15

Jan. 3, 2024

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

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

16

Jan. 3, 2024

DECLARATION of Adraea M. Brown regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

17

Jan. 3, 2024

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Exhibit 3 - Parts 1-10 regarding declaration 16

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

Exhibit 3-8

Exhibit 3-9

(Exhibit 3-10)

18

Jan. 3, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

19

Jan. 3, 2024

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for miscellaneous relief 18

20

Jan. 3, 2024

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

Exhibit 1

(Exhibit 2)

21

Jan. 3, 2024

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order 13, motion for miscellaneous relief 18, motion for leave to file 3 before Honorable Virginia M. Kendall on 1/9/2024 at 09:00 AM.

22

Jan. 9, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 1/9/2024. Plaintiff's Sealed Motion for Temporary Restraining Order 13 is granted and shall remain in effect up to and including 1/23/2024. Sealed Order to follow. Plaintiff's Motion for leave to file under seal 3 and Motion for electronic service of process are granted. Status hearing set for 1/23/2024 at 9:00 AM. Mailed notice

23

Jan. 9, 2024

SEALED Temporary Restraining Order signed by the Honorable Virginia M. Kendall on 1/9/2024. Mailed notice

24

Jan. 11, 2024

INJUNCTION BOND in the amount of $ 10,000.00 posted by Harley-Davidson Motor Company, Inc. (Document not scanned).

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

25

Jan. 18, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for extension of time of Temporary Restraining Order

26

Jan. 18, 2024

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of extension of time 25

(Declaration of Marcella D. Slay)

27

Jan. 18, 2024

NOTICE of Motion by Marcella Deshonda Slay for presentment of extension of time 25 before Honorable Virginia M. Kendall on 1/23/2024 at 09:00 AM.

28

Jan. 19, 2024

MINUTE entry before the Honorable Virginia M. Kendall: Plaintiff's Ex Parte Motion To Extend The Temporary Restraining Order 25 is granted. Temporary Restraining Order 23 shall remain in effect up to and including 2/6/2024. Motion presentment hearing is stricken. Status hearing is reset to 2/6/2024 at 9:00 AM. Mailed notice

29

Jan. 26, 2024

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

30

Feb. 1, 2024

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to Certain Defendants

31

Feb. 1, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for preliminary injunction

(Exhibit A)

32

Feb. 1, 2024

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for preliminary injunction 31

Declaration of Marcella D. Slay

(Exhibit 1)

33

Feb. 1, 2024

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction 31 before Honorable Virginia M. Kendall on 2/6/2024 at 09:00 AM.

(Exhibit A)

34

Feb. 1, 2024

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/1/2024, answer due 2/22/2024.

Declaration of Trevor C. Talhami

(Exhibit A)

35

Feb. 5, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Status and Motion hearing set for 2/6/2024 is reset for 9:30 AM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

36

Feb. 6, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 2/6/2024. Plaintiff's Motion for Preliminary Injunction 31 is granted. Order to follow. Status hearing set for 3/26/2024 at 9:00 AM. Mailed notice

37

Feb. 6, 2024

PRELIMINARY Injunction Order signed by the Honorable Virginia M. Kendall on 2/6/2024. Mailed notice

NEW PARTIES: Foshan Yu Jun Jewelry Company Limited, Guangzhou Haitai Automobile Products Co., Ltd., Hefei Drifting Rabbit E-Commerce Co., Ltd., Nantong Diashi Textile Technology Co., Ltd., Quanzhou Heige Trading Co., Ltd., Shandong Xinhuizhan Trade Co., Ltd., Shenzhen Dingbiao Technology Co., Ltd., Shenzhen Suoleikesi Technology Co., Ltd., Wenzhou Joyful Promotions Co., Ltd., Yiwu Beidifu Jewelry Co., Ltd., Yiwu Jinjie Arts & Crafts Co., Ltd., Yiwu Shichen Trading Co., Ltd., Zhongshan Illusionneon Lighting Technology Co., Ltd., A1L4R1O3A3N3D5, ATHEON STUDIO, Beauty Word, bgfsnhgthtfxh, bufangjia, ChroX, DFJCDDD, dghuasen, Evano US, GKmow-Auto-US, guangzhouhaifashangmaoyouxiangongsi, guxing-us, haichengwangluokeji, HaiTingYingMaoYi, HDUS Store, hezemudanquhaiyiriyongbaihuoxiaoshouyxzrgs, Hua Mi Shang WuSHOP, HuQiaoLifhgjk, Jiajia Shop, keerqinqufeihengbaihuodian, Lan & You, LiHanQianUS, ling-rui, liujiexiaodianpu, love xiao, Matare US, MCZ Pro Flag, MeiYiDuo, MENZOM SHOP, Merican, PALAMEDE-US, peimingbaihuodian example 1, Shuangtaizi, Sprise, Sumu department store, suzhouhuanshuojidiangongchengyouxiangongsi, suzhouliangyanwangluokejiyouxiangongsi, taiyuanshiliufuguangshangmaoyouxiangongsi, tiankaiamz, Tom's Wheezes, US - Boutique Discount Store, Vu Thi Thanh Thao 123, WELOVE SHOP, wmj1124, XiaoLong ShangMao, XinQJY, xuechengxiaodianSHOP, YIWANYINHANG US, YOUNGIE, zhanghualangnannvzhuang, Zhaoyj shop, big_box, brand_style, daye09, daye10, gaosx, hello03, huo10, iceyyoung, lin56707, lin5679, look_at_mee, look_for_mee, mhck, necklace_womens, ren10, sunglasses_cc, sunglasses_k, sunglasses1977, xing10, ytdzsw308, zhong09, cnsqmc_motoshop, delong27, good-auto, hoxua_55, mrptolemy, nuoaida, Car Decoration Sticker Direct, Fancool, FIONA SIGN, Miss Meng Jewelry, Wqppk, WSYB, haomai, azkvrysdp, gutianyu8601, Mens Hat, zhanghongli9695, affozi.com, angelprinter.com, dopethug.com, gearhead.bike, leesinstores.com, pediclothing.com, storeedyta.com, teewix.com, waltdreamtee.com, yoteeus.com, hddaytona.com, bootharleydavidson.com, motorcyclehd.com, harleysdavidson.shop, storeretailtherapy.com, harley-davidsonsale.com and harley-merch.com added to case caption. (Text entry; no document attached.)

Terminating Fancool, MeiYiDuo, Tom's Wheezes, Wqppk, YOUNGIE, bufangjia, cnsqmc_motoshop, Evano US and FIONA SIGN (Text entry; no document attached.)

38

Feb. 8, 2024

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

39

Feb. 15, 2024

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

40

Feb. 19, 2024

ATTORNEY Appearance for Defendant GKmow-Auto-US by Christopher Paul Keleher

41

Feb. 19, 2024

MOTION by Defendant GKmow-Auto-US for extension of time to file answer regarding complaint 1

42

Feb. 19, 2024

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer 41 before Honorable Virginia M. Kendall on 2/26/2024 at 09:00 AM.

43

Feb. 20, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Defendant GKmow-Auto-US'sMotion for extension of time to answer or otherwise plead 41 is granted. Answer shall be filed by 3/11/2024. Motion hearing set for 2/26/2024 is stricken. Mailed notice

44

Feb. 22, 2024

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

45

Feb. 27, 2024

ATTORNEY Appearance for Defendant Shandong Xinhuizhan Trade Co., Ltd. by Weisun Rao

46

Feb. 27, 2024

MOTION by Defendant Shandong Xinhuizhan Trade Co., Ltd. to dismiss for lack of jurisdiction

Exhibit A - Declaration of Dong Zhou

Exhibit B - Copy of Court's Order in Prior Case

(Exhibit C - Copy of Court's Order in Another Prior Case)

47

Feb. 28, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Briefing schedule set as to Defendant Shandong Xinhuizhan Trade Co., Ltd's Motion to Dismiss 46. Response due by 3/13/2024; Reply due by 3/20/2024. Mailed notice

48

Feb. 29, 2024

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

49

March 4, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for sanctions Pursuant to Fed. R. Civ. P. 37 for Failure to Respond to Discovery Requests

Declaration of Trevor C. Talhami

Exhibit 1

(Exhibit 2)

50

March 4, 2024

NOTICE of Motion by Justin R. Gaudio for presentment of motion for sanctions, 49 before Honorable Virginia M. Kendall on 3/18/2024 at 09:00 AM.

51

March 4, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. to Extend or Stay Briefing Schedule 47 for Defendant's Motion to Dismiss

52

March 4, 2024

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 51 before Honorable Virginia M. Kendall on 3/18/2024 at 09:00 AM.

53

March 7, 2024

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

54

March 11, 2024

NOTICE by Shandong Xinhuizhan Trade Co., Ltd. re MOTION by Defendant Shandong Xinhuizhan Trade Co., Ltd. to dismiss for lack of jurisdiction 46 Notice of Withdrawal of Motion

55

March 11, 2024

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain Defendants

56

March 11, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for entry of default, MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for default judgment as to all Defendants with the exception of a certain Defendant

(Exhibit A)

57

March 11, 2024

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for entry of default, motion for default judgment, 56

(Exhibit 1)

58

March 11, 2024

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 57

(Exhibit 1)

59

March 11, 2024

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment, 56 before Honorable Virginia M. Kendall on 3/18/2024 at 09:00 AM.

(Exhibit A)

60

March 13, 2024

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 3/18/2024 is reset for 3/26/2024 at 9:00 AM. Mailed notice

61

March 25, 2024

ATTORNEY Appearance for Defendant dopethug.com by Ge Lei

62

March 25, 2024

MOTION by Defendant dopethug.com for leave to file an Answer to Plaintiff's Complaint

63

March 25, 2024

ANSWER to Complaint by dopethug.com

64

March 25, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. to strike Defendant dopethug.com's Answer [63]

65

March 25, 2024

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion to strike[64] before Honorable Virginia M. Kendall on 3/28/2024 at 09:00 AM.

66

March 25, 2024

ANSWER to Complaint by Shandong Xinhuizhan Trade Co., Ltd.

67

March 26, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing set for 3/28/2024 is stricken. Mailed notice

68

March 26, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 3/26/2024. Defendant Shandong Xinhuizhan Trade Co., Ltd's Motion to Dismiss [46] is withdrawn pursuant to Notice of Withdrawal [54]. Plaintiff's Motion for Sanctions and Motion to extend briefing [51] are stricken as moot due to Defendant Shandong Xinhuizhan Trade Co., Ltd's withdrawal of Motion to Dismiss. Plaintiff's Motion for entry of Default and Default Judgment as to all Defendants with the exception of Defendants Shandong Xinhuizhan Trade Co., Ltd. and dopethug.com [56] is granted. Order to follow. Defendant dopethug.com's Motion to file Answer [62] is granted. Plaintiff's Motion to Strike Answer [64] is denied. Status hearing set for 4/16/2024 at 9:00 AM. Mailed notice

69

March 26, 2024

FINAL Judgment Order signed by the Honorable Virginia M. Kendall on 3/26/2024. Mailed notice

70

March 29, 2024

MOTION by Defendant dopethug.com to Modify Preliminary Injunction Order

Declaration

Exhibit

Exhibit

Exhibit

71

March 29, 2024

NOTICE of Motion by Ge Lei for presentment of motion for miscellaneous relief[70] before Honorable Virginia M. Kendall on 4/3/2024 at 09:00 AM.

72

April 2, 2024

RESPONSE by Harley-Davidson Motor Company, Inc.in Opposition to MOTION by Defendant dopethug.com to Modify Preliminary Injunction Order [70]

Declaration of Trevor C. Talhami

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

73

April 2, 2024

REPLY by dopethug.com to response in opposition to motion, [72]

Exhibit

Exhibit

74

April 2, 2024

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by dopethug.com

75

April 3, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 4/3/2024. Oral argument heard regarding Defendant dopethug.com's Motion to Modify Preliminary Injunction Order [70]. Motion to Modify Preliminary Injunction [70] is taken under advisement. Defendant is to provide Plaintiff with Discovery. Status hearing set for 4/17/2024 at 9:00 AM. Mailed notice

76

April 8, 2024

TRANSCRIPT OF PROCEEDINGS held on 04/03/2024 before the Honorable Virginia M. Kendall. Motion Hearing. Order Number: 48410. Court Reporter Contact Information: Gayle A. McGuigan, CSR, RMR, CRR, Gayle_McGuigan@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 4/29/2024. Redacted Transcript Deadline set for 5/9/2024. Release of Transcript Restriction set for 7/8/2024.

77

April 16, 2024

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Berel Yonathan Lakovitsky

78

April 16, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing set for 4/17/2024 is stricken. Mailed notice

79

April 16, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing held on 4/16/2024. The Court grants Defendant dopethug.com's Motion to Modify Preliminary Injunction Order [70]. Preliminary Injunction Order is modified to reduce the asset restraint of Defendant dopethug.com to $10,000. Mailed notice

80

April 16, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for reconsideration Regarding The Court's Decision To Limit The Scope Of The Asset Restraint.

81

April 16, 2024

Plaintiff's NOTICE of Motion by Justin R. Gaudio for presentment of motion for reconsideration[80] before Honorable Virginia M. Kendall on 4/18/2024 at 09:00 AM.

82

April 17, 2024

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 4/18/2024 is reset for 9:15 AM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

83

April 17, 2024

RESPONSE by dopethug.comin Opposition to MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for reconsideration Regarding The Court's Decision To Limit The Scope Of The Asset Restraint. [80]

Exhibit Exhibit A

Exhibit Exhibit B

Exhibit Exhibit C

84

April 18, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 4/18/2024. Oral argument heard regarding Motion for Reconsideration [80]. The Court takes Motion for Reconsideration [80] under advisement. Mailed notice

85

April 19, 2024

TRANSCRIPT OF PROCEEDINGS held on 04/16/2024 before the Honorable Virginia M. Kendall. Motion Hearing. Order Number: 48527. Court Reporter Contact Information: Gayle A. McGuigan, CSR, RMR, CRR, Gayle_McGuigan@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 5/10/2024. Redacted Transcript Deadline set for 5/20/2024. Release of Transcript Restriction set for 7/18/2024.

86

April 23, 2024

MINUTE entry before the Honorable Virginia M. Kendall. In January 2024, this Court granted Plaintiff Harley-Davidson's motion for a temporary restraining order and temporary asset restraint against Defendant dopethug.com. (Dkt. [23]). A few weeks later, the Court entered a preliminary injunction order which, in pertinent part, extended the temporary asset restraint as against all $98,629.20 in dopethug.com's PayPal account. (Dkt. [37]). On Defendant's motion, (Dkt. [70]), and after hearing oral argument on the issue, this Court modified the asset restraint to $10,000. (Dkt. [79]). Harley-Davidson now moves this Court to reconsider its Order limiting the scope of the asset restraint. (Dkt. [80]). Harley-Davidson contends that "[t]o exempt assets from an asset freeze, the burden is on the party seeking relief to present documentary proof that particular assets are not the proceeds of counterfeiting activities" and the defendant here has not met its burden. Johnson & Johnson v. Advanced Inventory Mgmt., Inc., 2020 WL 8262230, at *1 (N.D. Ill. Oct. 19, 2020) (cleaned up). At this time, dopethug.com has not provided proof that the assets at issue are not the proceeds of counterfeiting activity, but Court will not reimplement the full asset restraint without more evidence of the sources of revenue in dopethug.com's PayPal account. Accordingly, Harley-Davidson's motion [80] is granted in part and denied in part. The Order limiting the scope of the asset freeze (Dkt. [79]) is stayed and the parties are directed to appear on 5/1/2024 at 10:00 AM for an evidentiary hearing. Mailed notice

87

April 30, 2024

Exhibit List for Evidentiary Hearing by Harley-Davidson Motor Company, Inc.

Declaration of Trevor C. Talhami

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

88

May 1, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Due to clerical error, it was incorrectly noted that evidentiary hearing would proceed on 5/1/2024. Evidentiary hearing will proceed on 5/2/2024 at 10:00 AM. Mailed notice

89

May 1, 2024

Exhibit List for Evidentiary Hearing [88] by dopethug.com.

Declaration

Declaration

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

90

May 2, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Evidentiary hearing held on 5/2/2024. Oral argument heard regarding Plaintiff Harley-Davidson's Motion to Reconsider [80] the Court's Order limiting the scope of the asset freeze. Plaintiff's Motion [80] remains granted in part and denied in part. The Order [86] staying the limit on the scope of Defendant dopethug.com's asset freeze stands. Defendant's assets will remain frozen in accordance with the Preliminary Injunction Order [37]. Mailed notice

91

June 5, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing set for 7/17/2024 at 9:30 AM. Mailed notice

92

June 5, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. to compel Defendant Shandong Xinhuizhan Trade Co., Ltd.

93

June 5, 2024

DECLARATION of Justin R. Gaudio regarding motion to compel[92]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

94

June 5, 2024

NOTICE of Motion by Justin R. Gaudio for presentment of motion to compel[92] before Honorable Virginia M. Kendall on 6/10/2024 at 09:00 AM.

95

June 6, 2024

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 6/10/2024 is reset for 9:30 AM (PLEASE NOTE TIME CHANGE ONLY). Mailed notice

96

June 7, 2024

MOTION by Attorney Weisun Rao to withdraw as attorney for Shandong Xinhuizhan Trade Co., Ltd. No party information provided

Notification of Party Contact Information

97

June 10, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 6/10/2024. Attorney Weisun Rao's Motion to withdraw as Attorney for Defendant Shandong Xinhuizhan Trade Co., Ltd. 96 is granted. Plaintiff's Motion to Compel 92 is moot based upon Attorney's Rao's withdrawal as Counsel for Defendant Shandong Xinhuizhan Trade Co., Ltd. Mailed notice

98

June 18, 2024

STIPULATION of Dismissal as to Defendant dopethug.com (Joint)

99

June 19, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for sanctions Pursuant to Rule 37 of the Federal Rules of Civil Procedure

100

June 19, 2024

DECLARATION of Justin R. Gaudio regarding motion for sanctions 99

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

Exhibit 9

(Exhibit 10)

101

June 19, 2024

NOTICE of Motion by Justin R. Gaudio for presentment of motion for sanctions 99 before Honorable Virginia M. Kendall on 6/27/2024 at 09:00 AM.

102

June 24, 2024

TRANSCRIPT OF PROCEEDINGS held on June 10, 2024, before the Honorable Virginia M. Kendall. Order Number: 49027. Court Reporter Contact Information: Laura LaCien, laura_lacien@ilnd.uscourts.gov, 312-408-5032. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 7/15/2024. Redacted Transcript Deadline set for 7/25/2024. Release of Transcript Restriction set for 9/23/2024.

103

June 27, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 6/27/2024. Plaintiff's Motion for Sanctions 99 will be held in abeyance until Defendant Shandong Xinhuizhan Trade Co., Ltd. retains new Counsel. Defendant's new Counsel is directed to file an appearance on or before 7/5/2024. Defendant Shandong Xinhuizhan Trade Co., Ltd. is reminded that an entity may not represent itself. Mailed notice

104

July 11, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing held on 7/11/2024. Plaintiff's Counsel advised that they have received no response from Defendant Shandong Xinhuizhan Trade Co., Ltd. Mailed notice

105

July 12, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. to strike answer to complaint 66

106

July 12, 2024

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for entry of default, MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for default judgment as to Defendant Shandong Xinhuizhan Trade Co., Ltd.

107

July 12, 2024

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for entry of default, motion for default judgment, 106

108

July 12, 2024

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 107

(Exhibit 1)

109

July 12, 2024

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment, 106, motion to strike 105 before Honorable Virginia M. Kendall on 7/17/2024 at 09:30 AM.

110

July 17, 2024

MINUTE entry before the Honorable Virginia M. Kendall. Status and Motion hearing held on 7/17/2024. Plaintiff's Motion for entry of Default and Default Judgment against Defendant Shandong Xinhuizhan Trade Co., Ltd. Enter Order of Default as to Defendant Shandong Xinhuizhan Trade Co., Ltd. Default Judgment Order to follow. Plaintiff's Motion to Strike Answer 105 is granted. Motion for Sanctions 99 is dismissed as moot. Mailed notice

111

July 17, 2024

FINAL Judgment Order signed by the Honorable Virginia M. Kendall on 7/17/2024. Mailed notice

112

Jan. 23, 2025

FULL SATISFACTION of Judgment regarding order, terminated case 111 in the amount of $150,000 as to certain defendant

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