2025-cv-06162

COMPLAINT filed by General Motors LLC; Filing fee $ 405, receipt number AILNDC-23570159.

Exhibit 1

SEALED EXHIBIT by Plaintiff General Motors LLC Schedule A regarding complaint[1]

MOTION by Plaintiff General Motors LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by General Motors LLC

Notice of Claims Involving Trademarks by General Motors LLC

ATTORNEY Appearance for Plaintiff General Motors LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff General Motors LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff General Motors LLC by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff General Motors LLC by Lucas Allen Peterson

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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.

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EMAILED Trademark report to Patent Trademark Office, Alexandria VA

EMAILED to plaintiff(s) counsel Lanham Mediation Program materials

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

MEMORANDUM by General Motors LLC in support of motion for temporary restraining order 13

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

DECLARATION of Andrea Ankawi regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff General Motors LLC Exhibit 2 Parts 1-2 regarding declaration 16

Exhibit 2-1

(Exhibit 2-2)

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

MEMORANDUM by General Motors 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 Andrea R. Wood: Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for a telephonic motion hearing on 7/10/2025 at 9:45 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 7/10/2025. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A [2], and (2) Exhibit 2 Parts 1-2 [17]. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 8/4/2025 at 9:00 AM. [DATE AND TIME CHANGE] The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 7/21/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff General Motors LLC

Registry Deposit Information Form by General Motors LLC

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

SURETY BOND in the amount of $ 10,000 posted by General Motors LLC

MOTION by Plaintiff General Motors LLC for extension of time of Temporary Restraining Order

MEMORANDUM by General Motors LLC in support of extension of time[28]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[29]

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order [28] is granted. The Court finds good cause to extend the temporary restraining order until 8/18/2025. Telephonic status hearing set for 8/4/2025 is stricken and reset for 8/15/2025 at 9:45 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MOTION by Plaintiff General Motors LLC for preliminary injunction

Exhibit A

MEMORANDUM by General Motors LLC in support of motion for preliminary injunction[32]

Declaration of Marcella D. Slay

SUMMONS Returned Executed by General Motors LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/12/2025, answer due 9/2/2025.

Declaration of Lucas A. Peterson

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction [32] will be heard at the telephonic hearing set for 8/15/2025 at 9:45 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

ATTORNEY Appearance for Plaintiff General Motors LLC by Hannah Alexa Abes

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 8/15/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [32] is granted. By 8/22/2025, Plaintiff shall file a supplemental submission that reflects the amount of frozen funds for each defendant. Plaintiff is granted leave to file the document under seal. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A [2], (2) Exhibit 2 Parts 1-2 [17], and (3) the sealed temporary restraining order [23]. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Term inate_Instructions.pdf. Telephonic status hearing set for 9/24/2025 at 10:00 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 8/15/2025. Mailed notice

SEALED RESPONSE by General Motors LLC to order on motion for preliminary injunction, telephone conference, set/reset hearings, [38]

NOTICE of Voluntary Dismissal by General Motors LLC as to certain defendants

MOTION by Plaintiff General Motors LLC for entry of default, MOTION by Plaintiff General Motors LLC for default judgment as to all remaining Defendants

Exhibit A

MEMORANDUM by General Motors LLC in support of motion for entry of default, motion for default judgment[42]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[43]

Exhibit 1

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment as to all remaining defendants [42] will be heard at the telephonic hearing set for 9/24/2025 at 10:00 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

ATTORNEY Appearance for Plaintiff General Motors LLC by Kahlia Roe Halpern