2024-cv-05604

COMPLAINT filed by Lucia Heffernan; Filing fee $ 405, receipt number AILNDC-22208926.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Lucia Heffernan Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Yanling Jiang

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Yi Bu

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Adam Grodman

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Christopher Romero

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 3).

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.

MOTION by Plaintiff Lucia Heffernan for leave to file under seal

MOTION by Plaintiff Lucia Heffernan for leave to file excess pages

MEMORANDUM in Support of 13 Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's Declaration

Declaration of Lucia Heffernan

(Exhibit 1, of Lucia Heffernan's Declaration)

SEALED EXHIBIT by Plaintiff Lucia Heffernan Sealed Exhibit 2, Declaration of Lucia Heffernan regarding memorandum in support of motion, 14

(Exhibit 2)

MEMORANDUM by Lucia Heffernan Establishing that Joinder is Proper

Declaration of Keith A. Vogt

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

(Exhibit 7)

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's motion for leave to file under seal 11, motion to exceed page limitation 12, and ex parte motion for a temporary restraining order 13. Provided that Plaintiff provides the security described in paragraph 10 of the temporary restraining order, the temporary restraining order shall become effective on 7/15/2024 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Mailed notice.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

MOTION by Plaintiff Lucia Heffernan for preliminary injunction

MEMORANDUM by Lucia Heffernan in support of motion for preliminary injunction 20

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's Declaration)

SUMMONS Returned Executed by Lucia Heffernan as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/16/2024, answer due 8/6/2024.

(Declaration of Service)

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction 20 is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint 2 ; (2) Exhibit 2 to the Declaration of Lucia Heffernan 15 ; and (3) the TRO 18. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 7/26/2024. Mailed notice.

NEW PARTIES: Guangtong Direct, sunaidianzishangwu, zhuodifuzhuangdian, Yixi Hangzhou, GuangZhouYiShouMaoYiYouXianGongSicdfg, suitable opportunity, zhengxuejuan666, jiaolaipanshang, Defendant No. 9, YanZhibindrfty, Talent intelligence, fujunrong1, xianjiuyuejienengkejiyouxiangongsi, Defendant No. 14, changjiawujin, KHC Shop, Defendant No. 17, GuangZhouAngSuMaoYiYouXianGongSi, linyiruxinshangmaoyouxiangongsi, dxayhfchisnvj, hubeishenglanzhouwangluokejiyouxiangongsi, gddeei, Nt Song Diep OLaLa, pham quang son dinh hoa, Luong Thi Thu Huong Thuong, Tan Tien Tran Pria, Thi Thuy Qous, ChinhHanCell, Vu Ngoc Thuy Vo Tranh, Anh Trinh Hibbi, NgCuongUSstore, Ma Kieu Minh Mie, guixiangshengweishangmao, Shijiazhuang Chisan Trading Company, xiaozhaozhunbeimaidonxi, jzhsq, Defendant No. 39, bin zhen quality poster, fengyewenrou, zhijiangshihuliushangmaoyouxiangongsi, putianshilichengqudaikaixuanmaoyiyouxiangongsi, weiweiweierart, Caiyarong Art, Zhuxinhong, LinLi Art, BEIDS, PengXiaoYu, baytrau, ShiTianHui, Jingfang Stationery store, dssdgdsgs, MENWO and wangyongqiang added to case caption.

NEW PARTIES: ppp added to case caption.

NEW PARTIES: Defendant No. 23 added to case caption.

NEW PARTIES: Defendant No. 20 added to case caption. Terminating ppp

ATTORNEY Appearance for Defendant KHC Shop by Casey Ann Hewitt

MOTION by Defendant KHC Shop to Dissolve Preliminary Injunction

MOTION by Defendant KHC Shop for extension of time UNOPPOSED

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Defendant KHC Shop's unopposed motion for extension of time to respond to the complaint [28]. Defendant's responsive pleading is now due on or before 8/20/2024. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no.46 Zhuxinhong and no. 23 Clearance Sale Save 50% YUfeng

MOTION by Plaintiff Lucia Heffernan for default judgment as to Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Lucia Heffernan in support of motion for default judgment 31

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MINUTE entry before the Honorable Franklin U. Valderrama: The Court grants Plaintiff's Motion for Entry of Default and Default Judgment 31. Statutory damages are awarded in the amount of $100,000 per each distinct Defaulting Defendant as indicated in the order. Enter Default Judgment Order. By 9/11/2024, Plaintiff is directed to file a status report as to the status of the case against the remaining defendants. To obtain release of the bond previously posted in this action, Plaintiff's counsel must file a motion for the return of the bond once the preliminary injunction no longer applies to any Defendant. Mailed notice.

DEFAULT JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 8/12/2024. Mailed notice.

MOTION by Defendant KHC Shop to withdraw motion for miscellaneous relief[26] (Motion to Dissolve PI)

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Defendant KHC SHOP's motion to withdraw its motion to dissolve the preliminary injunction [35], in which Defendant advises the Court that the parties have resolved their dispute and intend to file a stipulation of dismissal shortly. The Court commends the parties on negotiating in good faith and grants the motion [35]. KHC SHOP's motion to dissolve the preliminary injunction [26] is withdrawn and terminated as a motion. The Court strikes Defendant KHC Shop's responsive pleading deadline [29]. On or before 8/30/2024, the Court directs Plaintiff and KHC SHOP to file (i) the appropriate dismissal paperwork or (ii) a status report explaining the delay. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: Pursuant to the stipulation of dismissal 36 and under Fed. R. Civ. P. 41(a)(1)(A)(i), Defendant No. 16 KHC Shop is dismissed without prejudice and with each party to bear its own attorneys' fees, costs and expenses. Accordingly, the deadlines in the Court Minute Entry of 8/16/2024 37 are stricken. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, and with no defendants remaining in the case, the Court grants Plaintiff's motion to release surety bond 38. The ten-thousand-dollar ($10,000.00) surety bond posted by Plaintiff, including any interest minus the registry fee, is hereby released to Keith Vogt of Keith Vogt, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Keith Vogt of Keith Vogt, Ltd. at 33 West Jackson Boulevard, #2W, Chicago, Illinois 60604 via certified mail. Enter Order. Civil case terminated. Mailed notice.

ORDER: Signed by the Honorable Franklin U. Valderrama on 8/21/2024. Mailed notice.

MAILED Copyright report with certified copy of minute order dated 08/21/2024 to Registrar, Washington, D.C.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Keith Vogt of Keith Vogt, Ltd. at 33 West Jackson Boulevard, #2W, Chicago, Illinois 60604 via certified mail #9589 0710 5270 0579 7780 24.

SATISFACTION of Judgment as to defendant no. 48 BEIDS

SATISFACTION of Judgment as to defendant no.4 Yixi Hangzhou

SATISFACTION of Judgment as to defendant no.40 bin zhen quality poster

SATISFACTION of Judgment as to defendant no.15 changjiawujin and no.22 hubeishenglanzhouwangluokejiyouxiangongsi

SATISFACTION of Judgment as to defendant no.2 sunaidianzishangwu and no.8 jiaolaipanshang