2024-cv-04333

2024-cv-04333 Holly Denise Simental v. The Partnerships and Unincorporated Associations Identified On Schedule A

Date :5/28/2024
Court :Northen District of Illinois
Law FirmKeith

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Date

Document

1

May 28, 2024

COMPLAINT filed by Holly Denise Simental; Filing fee $ 405, receipt number AILNDC-22024735.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

2

May 28, 2024

DOCUMENT by Plaintiff Holly Denise Simental Schedule A to Complaint 1 Modified on 6/24/2024.

3

May 28, 2024

ATTORNEY Appearance for Plaintiff Holly Denise Simental by Keith A. Vogt

4

May 28, 2024

CIVIL Cover Sheet

5

May 28, 2024

ATTORNEY Appearance for Plaintiff Holly Denise Simental by Adam Grodman

6

May 28, 2024

ATTORNEY Appearance for Plaintiff Holly Denise Simental by Cameron Eugene Mcintyre

7

May 28, 2024

ATTORNEY Appearance for Plaintiff Holly Denise Simental by Christopher Romero

8

May 28, 2024

ATTORNEY Appearance for Plaintiff Holly Denise Simental by Monica Rita Martin

9

May 28, 2024

ATTORNEY Appearance for Plaintiff Holly Denise Simental by Yanling Jiang

10

May 28, 2024

ATTORNEY Appearance for Plaintiff Holly Denise Simental by Yi Bu

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category Three).

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.

11

May 28, 2024

MOTION by Plaintiff Holly Denise Simental for leave to file under seal

12

May 28, 2024

MOTION by Plaintiff Holly Denise Simental for leave to file excess pages

14

May 28, 2024

MEMORANDUM in Support of 13 Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's Declaration

Declaration of Holly Denise Simental

(Exhibit 1, of Holly Denise Simental's Declaration)

15

May 28, 2024

EXHIBIT by Plaintiff Holly Denise Simental Sealed Exhibit 2, Declaration of Holly Denise Simental regarding memorandum in support of motion, 14 Modified on 6/24/2024.

(Exhibit 2)

16

May 28, 2024

Presentment for Exparte Motion 13 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 12, motion for leave to file 11 before Honorable Manish S. Shah on 6/4/2024 at 09:45 AM.

17

June 3, 2024

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 11 12 13 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $10,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices Mailed.

18

June 3, 2024

TEMPORARY RESTRAINING ORDER. Signed b y the Honorable Manish S. Shah on 6/3/2024. Notices Mailed. Modified on 6/24/2024.

SUMMONS Issued as to wangjinhuanbaihuolingshouchaoshi and all other Defendants identified in the Complaint

19

June 5, 2024

INJUNCTION BOND in the amount of $ 10,000.00 posted by Holly Denise Simental. (Document not Scanned).

20

June 10, 2024

MOTION by Plaintiff Holly Denise Simental for preliminary injunction

21

June 10, 2024

MEMORANDUM by Holly Denise Simental in support of motion for preliminary injunction 20

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's Declaration)

22

June 10, 2024

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 20 before Honorable Manish S. Shah on 6/13/2024 at 09:45 AM.

23

June 10, 2024

SUMMONS Returned Executed by Holly Denise Simental as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/10/2024, answer due 7/1/2024.

(Declaration of Service)

24

June 13, 2024

TRANSCRIPT OF PROCEEDINGS held on 06/13/2024 before the Honorable Manish S. Shah. Motion Hearing. Order Number: 49044. Court Reporter Contact Information: Colleen_Conway@ilnd.uscourts.gov or 312.435.5594. 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 7/4/2024. Redacted Transcript Deadline set for 7/15/2024. Release of Transcript Restriction set for 9/11/2024.

25

June 13, 2024

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 20 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

26

June 13, 2024

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 6/13/2024. Notices Mailed.

27

July 11, 2024

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

28

July 11, 2024

MOTION by Plaintiff Holly Denise Simental for default judgment as to The Defendants Identified In First Amended Schedule A

29

July 11, 2024

MEMORANDUM by Holly Denise Simental in support of motion for default judgment 28

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

30

July 11, 2024

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 28 before Honorable Manish S. Shah on 7/18/2024 at 09:45 AM.

31

July 18, 2024

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for default judgment 28 is granted. Enter Default Judgment Order. Civil case terminated. Notices Mailed.

32

July 18, 2024

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 7/18/2024. Notices Mailed.

33

Sept. 13, 2024

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 21 lin lin Rain poster

34

Oct. 6, 2024

SATISFACTION of Judgment as to Defendant no. 56 Petty Boy

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