2025-cv-21362

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18310772, filed by Berluti SA.

Civil Cover Sheet

Exhibit 1 to Complaint - Certificates of Registration for the Berluti Trademarks

Clerks Notice of Judge Assignment to Judge William P. Dimitrouleas. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Ellen F. D'Angelo is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

Complaint and Exhibit

Plaintiff's Corporate Disclosure Statement by Berluti SA identifying Corporate Parent LVMH Moet Hennessy Louis Vuitton, SE for Berluti SA

Plaintiff's MOTION to Seal per Local Rule 5.4 by Berluti SA.

Text of Proposed Order

ORDER REQUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT. Signed by Judge William P. Dimitrouleas on 3/26/2025. See attached document for full details.

ORDER granting [5] Motion to File Under Seal. Schedule "A" to Plaintiff's Complaint and the Summonses shall be filed under seal and shall remain under seal until further order from this Court. Signed by Judge William P. Dimitrouleas on 3/26/2025. See attached document for full details.

Order

NOTICE of Filing Bond by Berluti SA.

Order

Plaintiff's MOTION to Unseal Document by Berluti SA. Responses due by 4/29/2025.

Text of Proposed Order

Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): berlutiparis.com, femikasali.shop, joseatxamiquelez.shop, karenmilano.shop, lisaneveitt.shop, matildabibby.shop, nielspahlad.shop, ralfbacker.shop, sujungkim.shop, tomescumihaela.shop and victorbell.shop.

ORDER granting [16] Plaintiff's Motion to Unseal. The Clerk of the Court is hereby DIRECTED to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge William P. Dimitrouleas on 4/16/2025. See attached document for full details.

CLERK'S NOTICE of Compliance by unsealing documents pursuant to 18 Order.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Berluti SA re [10] Order on Ex Parte Motion, [1] Complaint, [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law In Support Thereof

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Berluti SA re [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [7] Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law In Support Thereof, [10] Order on Ex Parte Motion, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [3] Form AO 120/121, [14] Sealed Document, [1] Complaint, [11] Order on Ex Parte Motion, [9] Order on Motion to Seal, [13] Notice (Other), [2] Clerks Notice of Judge Assignment, [8] Order Requiring Joint Scheduling Report, [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law In Support Thereof, [12] Sealed Document upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Berluti SA. berlutiparis.com served on 4/14/2025, response/answer due 5/5/2025; femikasali.shop served on 4/14/2025, response/answer due 5/5/2025; joseatxamiquelez.shop served on 4/14/2025, response/answer due 5/5/2025; karenmilano.shop served on 4/14/2025, response/answer due 5/5/2025; lisaneveitt.shop served on 4/14/2025, response/answer due 5/5/2025; matildabibby.shop served on 4/14/2025, response/answer due 5/5/2025; nielspahlad.shop served on 4/14/2025, response/answer due 5/5/2025; ralfbacker.shop served on 4/14/2025, response/answer due 5/5/2025; sujungkim.shop served on 4/14/2025, response/answer due 5/5/2025; tomescumihaela.shop served on 4/14/2025, response/answer due 5/5/2025; victorbell.shop served on 4/14/2025, response/answer due 5/5/2025.

Affidavit of Service

Affidavit of Service

Plaintiff's MOTION for Discovery for Order Authorizing Plaintiff to Initiate Discovery by Berluti SA. Responses due by 5/14/2025.

Declaration of Virgilio Gigante in Support Thereof

Text of Proposed Order

ORDER REFERRING MOTION AND DISCOVERY. Magistrate Judge Ellen F. D'Angelo for Discovery Matters. REFERRING [23] Plaintiff's MOTION for Discovery for Order Authorizing Plaintiff to Initiate Discovery filed by Berluti SA. Motions referred to Judge Ellen F. D'Angelo. Signed by Judge William P. Dimitrouleas on 5/1/2025. See attached document for full details.

ORDER SETTING DISCOVERY PROCEDURES. Signed by Magistrate Judge Ellen F. D'Angelo on 5/01/2025. See attached document for full details. (co00)

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Preliminary Injunction Hearing held on 5/2/2025. Total time in court: 5 minutes. Attorney Appearance(s): Virgilio Gigante, Court Reporter: Patricia Bailey-Entin, 305-523-5635 / Patricia_BaileyEntin@flsd.uscourts.gov.

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION re DE [6] Ex Parte Motion for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets. Signed by Judge William P. Dimitrouleas on 5/2/2025. See attached document for full details.

ORDER granting 23 Plaintiff Berluti SA's Motion for Order Authorizing Plaintiff to Initiate Discovery. Signed by Magistrate Judge Ellen F. D'Angelo on 5/07/2025. See attached document for full details. (co00)

Plaintiff's MOTION for Clerk's Entry of Default as to THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, berlutiparis.com, femikasali.shop, joseatxamiquelez.shop, karenmilano.shop, lisaneveitt.shop, matildabibby.shop, nielspahlad.shop, ralfbacker.shop, sujungkim.shop, tomescumihaela.shop, victorbell.shop by Berluti SA.

Affidavit Declaration of Stephen M. Gaffigan in Support of Request for Clerk&#03

Text of Proposed Order

Clerk's Entry of Default as to joseatxamiquelez.shop, karenmilano.shop, lisaneveitt.shop, matildabibby.shop, nielspahlad.shop, ralfbacker.shop, sujungkim.shop, tomescumihaela.shop, victorbell.shop, berlutiparis.com, femikasali.shop - Motions Terminated: 29 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 5/30/2025.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION. Show Cause Response due by 6/30/2025. Signed by Judge William P. Dimitrouleas on 6/23/2025. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Berluti SA.

Declaration of Hadrien Huet in Support Thereof

Exhibit 1 to the Declaration of Hadrien Huet

Declaration of Virgilio Gigante in Support Thereof

Text of Proposed Order Granting Motion for Default Final Judgment

Text of Proposed Order Granting Default Final Judgment and Permanent Injunction

ORDER TO SHOW CAUSE WHY COURT SHOULD NOT GRANT MOTION FOR DEFAULT FINAL JUDGMENT. Show Cause Response due by 7/14/2025. Signed by Judge William P. Dimitrouleas on 7/1/2025. See attached document for full details.

CERTIFICATE OF SERVICE by Berluti SA re [33] Order to Show Cause upon Defendants via Electronic Mail and via Website Posting

ORDER GRANTING MOTION FOR DEFAULT FINAL JUDGMENT re [32] Motion for Default Judgment. Signed by Judge William P. Dimitrouleas on 7/15/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of Berluti SA against THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, berlutiparis.com, femikasali.shop, joseatxamiquelez.shop, karenmilano.shop, lisaneveitt.shop, matildabibby.shop, nielspahlad.shop, ralfbacker.shop, sujungkim.shop, tomescumihaela.shop, PERMANENT INJUNCTION Closing Case. Signed by Judge William P. Dimitrouleas on 7/15/2025. See attached document for full details.