2025-cv-02302

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-23166363.

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Schedule A regarding complaint 1

MOTION by Plaintiff Chrome Hearts LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Chrome Hearts LLC

Notice of Claims Involving Trademarks by Chrome Hearts LLC

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Luana Faria De Souza (Faria De Souza, Luana)

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

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 Trademark report to Patent Trademark Office, Alexandria VA.

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

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

MEMORANDUM by Chrome Hearts LLC in support of motion for temporary restraining order 13

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

DECLARATION of Mario Lejtman regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC regarding declaration 16

Exhibit 3-1

(Exhibit 3-2)

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

MEMORANDUM by Chrome Hearts LLC in support of motion for miscellaneous relief 18

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

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13 is granted. Plaintiff's motion for leave to file under seal 3 and motion for electronic service of process 18 are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 3/10/2025.

Registry Deposit Information Form by Chrome Hearts LLC

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ 84,000 posted by Chrome Hearts LLC. (Document not imaged, Received via Mailroom 3/17/25)

MOTION by Plaintiff Chrome Hearts LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Chrome Hearts LLC in support of extension of time 27

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 28

MINUTE entry before the Honorable Mary M. Rowland: Motion for extension of TRO 27 is granted. TRO extended to 4/7/25. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 3/20/2025. Mailed notice.

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

Exhibit A

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction[32]

Declaration of Trevor C. Talhami

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/1/2025, answer due 4/22/2025.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: Any response to the motion for preliminary injunction [32] is due by 4/16/25. Status report from Plaintiff due by 4/23/25. Mailed notice.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendant

STATUS Report Pursuant to [35] by Chrome Hearts LLC

Exhibit A

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to Certain Defendants

MOTION by Plaintiff Chrome Hearts LLC for entry of default, MOTION by Plaintiff Chrome Hearts LLC for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Chrome Hearts LLC in support of motion for entry of default, motion for default judgment 41

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

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

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [39]. Without objection, motion for preliminary injunction [32] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Any response to the motion for default [41] is due 5/15/25. Status report due 6/2/25. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 4/30/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

STATUS Report Pursuant to [45] by Chrome Hearts LLC

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report 49. The motion for default judgment 41 is granted against the remaining defendants unopposed. Enter Order. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 6/3/2025. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: The eighty-four thousand dollar ($84,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, 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 Plaintiff or its counsel. Mailed notice.