2025-cv-04203

COMPLAINT filed by Abraham Sandor Szomor; Filing fee $ 405, receipt number AILNDC-23362248.

(Exhibit 1)

SEALED DOCUMENT by Plaintiff Abraham Sandor Szomor Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Abraham Sandor Szomor by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Abraham Sandor Szomor by Adam Grodman

ATTORNEY Appearance for Plaintiff Abraham Sandor Szomor by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Abraham Sandor Szomor by Christopher Romero

ATTORNEY Appearance for Plaintiff Abraham Sandor Szomor by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Abraham Sandor Szomor by Yanling Jiang

ATTORNEY Appearance for Plaintiff Abraham Sandor Szomor by Yi Bu

CASE ASSIGNED to the Honorable Joan H. Lefkow. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 3). (qrtr,)

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. (qrtr,)

MOTION by Plaintiff Abraham Sandor Szomor for leave to file under seal

MOTION by Plaintiff Abraham Sandor Szomor for leave to file excess pages

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motions for leave to file under seal, 12, and for a temporary restraining order and for expedited discovery, 14 are denied. Plaintiff seeks leave to file under seal so that plaintiff may obtain a temporary restraining order freezing the defendant's assets before revealing the defendant's identity. See 12. Plaintiff also seeks expedited discovery so plaintiff may serve the requested temporary restraining order against the defendant. See 14 at 21. "The Supreme Court has made clear that courts lack the power to issue an asset freeze at the beginning of a case, unless that party is seeking equitable monetary relief." Zorro Productions, Inc. v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, No. 23-cv-5761, 2023 WL 8807254, at *4 (N.D. Ill., Dec. 20, 2023) (citing Grupo Mexicano de Desarrollo S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308 (1999)); see also Shenzhen Yihong Lighting Co., Ltd. v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 23-cv-1560, at Dkt. 15 (N.D. Ill. Nov. 22, 2023). Indeed, "[a]s a general matter [ ] prejudgment asset restraints are not proper simply to establish a fund from which a later award of money damages can be satisfied." Zorro, 2023 WL 8807254, at *4 (second alteration in original) (quoting Banister v. Firestone, No. 17-cv-8940, 2018 WL 4224444, at *9 (N.D. Ill. Sept. 5, 2018)). In Schedule A cases, plaintiffs often initially demand equitable relief in the form of an accounting of profits, but after obtaining a temporary asset freeze, plaintiffs uniformly shift their focus to demanding statutory damages. Id. at *3-4. In substance, then, if not in form, Schedule A plaintiffs seek prejudgment asset restraints to establish a fund from which money damages may be awarded. So, despite the demand in plaintiff's amended complaint that it be awarded defendant's profits, the court is not persuaded that plaintiff will actually seek or obtain such equitable relief-as opposed to statutory damages-in this case. See id. Thus, even if plaintiff's initial demand for an accounting of profits could provide this court with the power to issue a prejudgment asset freeze, see Grupo Mexicano, 527 U.S. at 333; Banister, 2018 WL 4224444, at *9, the court is not persuaded that such a freeze is warranted. Because the court denies the motion for a temporary restraining order, there is no reason to seal plaintiff's filings pending such relief. Plaintiff's motions for leave to file under seal, 12, and for a temporary restraining order for expedited discovery, 14, are therefore denied. Plaintiff's sealed exhibits, 2, 16, are stricken. If plaintiff wishes to proceed with this case, plaintiff must file its exhibits publicly on the docket by 4/29/2025.

MINUTE entry before the Honorable Martha M. Pacold: 1. Plaintiff's motion for leave to file excess pages, 13, is granted. 2. Plaintiff's motion for electronic service of process, 14, is granted. The court finds that electronic service of process is proper under Fed. R. Civ. P. 4(f)(3). Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to the defendant. To the extent that the motion requests service of process of any temporary restraining order in this case, service is not necessary because this court has already denied the motion for a TRO. 19.

SUMMONS Issued (Court Participant) as to Defendant Hanging Pictures ye

SUMMONS Returned Executed by Abraham Sandor Szomor as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/28/2025, answer due 5/19/2025.

(Declaration of Service)

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff is directed to file a status report by 6/6/2025, addressing how plaintiff seeks to proceed with this litigation.

STATUS Report Pursuant to 24 by Abraham Sandor Szomor

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff is directed to file a status report by 7/8/2025, addressing how plaintiff seeks to proceed with this litigation.

FILED IN ERROR. Modified on 6/10/2025.

NOTICE of Voluntary Dismissal by Abraham Sandor Szomor as to the Defendant(s) Identified in Amended Schedule A

MINUTE entry before the Honorable Martha M. Pacold: The court has received plaintiff's notice of voluntary dismissal, 28, which dismisses the only defendant named in the operative Schedule A, 17. This dismissal took effect without court intervention. See Fed. R. Civ. P. 41(a)(1)(A)(i); Waetzig v. Haliburton Energy Servs., 145 S. Ct. 690, 694 (2025). Civil case terminated.