2025-cv-07045

EMERGENCY MOTION for Temporary Restraining Order, Seizure Order and Order to Show Cause Why A Preliminary Injunction and Seizure Order Should Not Issue. Document filed by Merch Traffic, LLC. for directions regarding promptly alerting the court to this filing.

Proposed Order for TRO, Seizure Order and Order to Show Cause Why a Preliminary

MEMORANDUM OF LAW in Support re: [6] EMERGENCY MOTION for Temporary Restraining Order, Seizure Order and Order to Show Cause Why A Preliminary Injunction and Seizure Order Should Not Issue. Document filed by Merch Traffic, LLC.

DECLARATION of Cara R. Burns (actually Certificate of Counsel Pursuant to FRCP 65 etc) in Support re: [6] EMERGENCY MOTION for Temporary Restraining Order, Seizure Order and Order to Show Cause Why A Preliminary Injunction and Seizure Order Should Not Issue. Document filed by Merch Traffic, LLC.

Exhibit A - Other SD NY Orders

Exhibit B - Other NY Orders

Exhibit C- Other Orders

DECLARATION of Emily Holt in Support re: [6] EMERGENCY MOTION for Temporary Restraining Order, Seizure Order and Order to Show Cause Why A Preliminary Injunction and Seizure Order Should Not Issue. Document filed by Merch Traffic, LLC.

Exhibit A - Tour Dates

Exhibit B - Autho Merch

Exhibit C- Bootleggers

Exhibit D - Examples Infring Merch

MOTION for Cara R. Burns to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number ANYSDC-31623025. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Merch Traffic, LLC.

Affidavit of Burns

Proposed Order for PHV Admission

Exhibit Cert of Gd Stdg

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. [11] MOTION for Cara R. Burns to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number ANYSDC-31623025. Motion and supporting papers to be reviewed by Clerk's Office staff. The document has been reviewed and there are no deficiencies.

CASHIERS OFFICE REGISTRY DEPOSIT as per [12] Order to Show Cause, Set Deadlines/Hearings, dated 08/28/2025, from Judge Vernon S. Broderick, received $10,000.00 Check from MERCH TRAFFIC, LLC Receipt Number 42794 on 09/02/2025.

TEMPORARY RESTRAINING ORDER; SEIZURE ORDER; AND AN ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION AND SEIZURE ORDER SHOULD NOT ISSUE: IT IS HEREBY ORDERED that defendants, John Does 1-100, Jane Does 1-100 and XYZ Company their true identities being unknown (collectively "Defendants), show cause before the Honorable Vernon S. Broderick, United States District Court Judge, in a telephonic hearing, accessible by dialing 1-855-244-8681 and utilizing the access code 2309 3085 835, with no attendee ID, at 9:00 a.m. on September 10, 2025 or as soon thereafter as counsel can be heard, why an order pursuant to the Lanham Act 15 U.S.C. � 1051 et. seq., Fed. R. Civ. P. Rule 65, and the All Writs Act 28 U.S.C. � 1651 should not be entered granting to Plaintiff, Merch Traffic, LLC, a preliminary injunction to enjoin Defendants from manufacturing, distributing, selling or holding for sale, any clothing, jewelry, photographs, posters and other merchandise (collectively the "Infringing Merchandise") and to seize the same bearing the trademarks, service marks, likenesses, logos and other indicia of the Artist, TATE MCRAE (collectively, the "Artists Trademarks"). AND IT IS FURTHER ORDERED that the United States Marshal for this District, the state police, local police or local deputy sheriffs, off duty officers of the same, and any person acting under their supervision, are hereby authorized to seize and impound any and all Infringing Merchandise bearing any or all of the Artists Trademarks (namely TATE MCRAE), which defendants attempt to sell or are holding for sale, including from any carton, container, vehicle, or other means of carriage in which the Infringing Merchandise is found from four (4) hours before to four (4) hours after any performance of the tour within a four (4) mile vicinity of the halls, stadiums or arenas at which the Artists tour shall be performing, except to the extent that such a radius would exceed the confines of New York County, including but not limited to in connection with the concerts to be held on Wednesday, September 3, 2025 and Thursday, September 4, 2025 at Madison Square Garden in New York, New York; AND IT IS FURTHER ORDERED that this order be and is hereby conditioned upon Plaintiff's filing with the Clerk of this Court an undertaking in the form of a bond, certified check, or cash in the amount of $ 10,000 no later than 9/2/2025, to secure the payment of such costs and damages not to exceed such sum as may be suffered or sustained by any party who is found to be wrongfully restrained hereby AND IT IS FURTHER ORDERED that Defendants' responsive papers, if any, shall be filed with the Clerk of this Court and served upon the attorneys for Plaintiff by delivering copies to its counsel on or before 9/8/2025. Any reply shall be filed by the Plaintiff and servedupon each appearing defendant or his/her counsel on or before 9/9/2025. Plaintiff isto provide copies of all other filed pleadings at the request of any identified defendant; (Responses due by 9/8/2025, Replies due by 9/9/2025., Telephone Conference set for 9/10/2025 at 09:00 AM before Judge Vernon S. Broderick.) (Signed by Judge Vernon S. Broderick on 8/28/2025) (rro) Transmission to Finance Unit (Cashiers) for processing.

NOTICE OF APPEARANCE by Mark Dana Bradford on behalf of Merch Traffic, LLC.