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1
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2022-11-22 |
COMPLAINT filed by Sassan Filsoof; Filing fee $ 402, receipt number AILNDC-20071849. |
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Exhibit 1 |
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Exhibit 2 |
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Exhibit 3 |
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(Exhibit 4) |
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2
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2022-11-22 |
SEALED DOCUMENT by Plaintiff Sassan Filsoof Schedule A to Complaint (1) |
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3
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2022-11-22 |
CIVIL Cover Sheet |
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4
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2022-11-22 |
ATTORNEY Appearance for Plaintiff Sassan Filsoof by Keith A. Vogt |
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5
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2022-11-22 |
ATTORNEY Appearance for Plaintiff Sassan Filsoof by Yanling Jiang |
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6
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2022-11-22 |
ATTORNEY Appearance for Plaintiff Sassan Filsoof by Yi Bu |
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7
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2022-11-22 |
ATTORNEY Appearance for Plaintiff Sassan Filsoof by Adam Grodman |
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CASE ASSIGNED to the Honorable John F. Kness. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. |
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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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8
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2022-11-22 |
MOTION by Plaintiff Sassan Filsoof for leave to file under seal |
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9
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2022-11-22 |
MOTION by Plaintiff Sassan Filsoof for leave to file excess pages |
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11
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2022-11-22 |
MEMORANDUM in support of 10 Exparte motion |
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Declaration of Keith A. Vogt |
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Exhibit 1-4, of Keith A. Vogt's declaration |
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Declaration of Sassan Filsoof |
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(Exhibit 1, of Sassan Filsoof's declaration) |
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12
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2022-11-22 |
SEALED EXHIBIT by Plaintiff Sassan Filsoof Sealed Exhibit 2, Declaration of Sassan Filsoof regarding memorandum in support of motion, 11 |
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Exhibit 2-1 |
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(Exhibit 2-2) |
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13
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2022-12-29 |
ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/29/2022: Mailed notice. |
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14
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2023-03-07 |
MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for leave to file under seal 8, motion for leave to file excess pages 9, and ex parte motion for a temporary restraining order and other relief 10 are granted. Plaintiff's submissions establish that, were Defendants to learn of these proceedings before the execution of Plaintiff's requested preliminary injunctive relief, there is a significant risk that Defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, Plaintiff may for now file under seal the documents identified in the motion to seal and appearing at docket entries 2, 10, and 12. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, Plaintiff's filings support proceeding (for the time being) on an ex parte basis. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, it is likely assets and websites would be redirected, thus defeating Plaintiff's interests in identifying defendants, stopping Defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by Plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by infringing goods, and there is no countervailing harm to defendants from an order directing them to stop infringement. 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 Defendants. As other judges in this District have noted, there may be reason to question both the propriety of the joinder of all Defendants in this one action and whether Plaintiff will pursue an accounting (which Plaintiff asserts as justification for an asset freeze), but at this preliminary stage, the court is persuaded that Plaintiff has provided sufficient evidence of coordinated activity and the prospect of an accounting to justify the requested relief as to all Defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. If any defendant appears and objects, the court will revisit the asset freeze and joinder. Enter Sealed Temporary Restraining Order. Mailed notice |
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15
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2023-03-07 |
SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable John F. Kness on 3/7/2023. Mailed notice |
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SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A |
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16
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2023-03-14 |
SURETY BOND in the amount of $10,000.00 posted by Sassan Filsoof (Document not scanned) |
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17
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2023-03-17 |
MOTION by Plaintiff Sassan Filsoof for extension of time for Temporary Restraining Order |
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18
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2023-03-21 |
MOTION by Plaintiff Sassan Filsoof for preliminary injunction |
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19
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2023-03-21 |
MEMORANDUM by Sassan Filsoof in support of motion for preliminary injunction 18 |
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Declaration of Keith A. Vogt |
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(Exhibit 1, Declaration of Keith Vogt) |
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ALIAS Summons Issued as to Defendant chenxibaihuodian123 and all other Defendants identified in the Complaint |
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20
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2023-03-21 |
MINUTE entry before the Honorable John F. Kness: Plaintiff's Motion for extension of time 17 is granted. Enter separate order. Mailed notice |
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21
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2023-03-21 |
ORDER ON MOTION FOR EXTENSION OF TEMPORARY RESTRAINING ORDER signed by the Honorable John F. Kness on 3/21/2023. Mailed notice |
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22
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2023-03-21 |
SUMMONS Returned Executed by Sassan Filsoof as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/21/2023, answer due 4/11/2023. |
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(Declaration of Service) |
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23
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2023-03-24 |
MINUTE entry before the Honorable John F. Kness: Before the Court is Plaintiff's motion 18 for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects on or before 3/30/2023." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice |
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24
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2023-03-24 |
CERTIFICATE of Service by Plaintiff Sassan Filsoof regarding order on motion for preliminary injunction, terminate deadlines and hearings, terminate motion and R&R deadlines/hearings, set motion and R&R deadlines/hearings, 23 |
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25
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2023-04-03 |
MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for a preliminary injunction 18 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established 24 that it provided electronic notice to Defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any Defendant. Enter preliminary injunction order. Plaintiff's counsel is directed to ensure that all Defendants listed on Schedule A are added to the Court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. Mailed notice |
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26
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2023-04-03 |
PRELIMINARY INJUNCTION ORDER signed by the Honorable John F. Kness on 4/3/2023. Mailed notice |
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NEW PARTIES: chenxibaihuodian123, Libobo, P04.RASOJICK, liugang-us, Houseware1, shaoyanmaoyiyouxiangongsi, jianerbaihuo, lizhengu, CHUDY, Adam Sheivare, Nguyenlck, Puzzles Home, Thahdemo Store, Thanh van, BeXoaiCute, YSDBJ, fanzihan, guoxiulin, liujinyuw, weizuozhuan, nanningweiweimaoyiyouxiangongsi, vintage corner and sss566 added to case caption. |
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NEW PARTIES: Max Guy, lijinyourt, Theresa Prints, zhuoyi art shop, weiyungui, suizhoushizhengbowangluokejiyouxiangongsi, emily chen, HTX SHOP, yangsizhan789, chunfanmaoyi, LEADERSHIP TRADING LIMITED, Fun Cloud Metal Sign, Reyno_Orediy, Eugene Race, xuexinyu, JINRONGBUYI, XiaoChangBaiHuo, WTGTYHS2IOJSFAAD, chongqingyihaoyixinxijishuyouxiangongsi, KingofPosters, PuTianShiLiChengQuChenHaoZhaoMaoYiYouXianGongSi, LXJPAOSHOP, hejianbinkeji, yangzilindianzishangwuyouxiangongsi, yuanxinqia, Tinhvanshop, LalisaW, THUTRANGTRAN66TN, putianshilichengquzhouxiangliumaoyiyouxianGongsi, HelenUS, putianshilichengqulongmieweimaoyiyouxiangongsi, BFDKJLHLSDFD1FDSFD, lilililli, jinhun-US, TongShanXianPanSuYunShangMaoYouXianGongSi, xixixiaj, iweijipilinfuzhuangyouxiango, putianshilichengqushuangfangjiaomaoyiyouxiangongsi, xinchengdahai, guyunhaokeji, ibeipawolifuzhuangyouxiango, hiruiziwangluokejiyoux, PLOKIJHFE5UJINHWS, kuangxuan, Poster Collector, PuTianShiChengXiangQuYeMieLinMaoYiYouXianGongSi, Gaoxinquxinshiqutangshanluxingergecanyindian, liuyangshiyeliangdianzishangmaoyouxiangongsi, DGJHGKDFG, LINHUIHUAYI, nanningdongbaomaoyiyouxiangongsi, heFeichaileiwangluokejiyouxiangongsi, wegtaerhg, Nguyen thuy linh, FrankDeBoe Store, It All boutique, The Mrk Store, Canvas painting decoration, Artwork Decor Sign, haikoutinglimeimaoyi and amaliuuwanling718 added to case caption. |
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NEW PARTIES: TalynShop, TRETee, MCZZFDM, FRHGKG, ZHANGLINGMWJHSHOP, huangyanguandedian, aanxi Rong Xie Yuan Trading Co., Lt, MrRobert Store, doanhdoanh, ZUILING POSTER, Flower Tx Store, Michael Philp Store, Dastan Kasmaliev Shop, MMDLQPPP, LiuYangShiLinHeMaoYiYouXianGongSi, Brumwell, ZXMMY, lijianyangkeji, changfengxianchikaishangmaoyouxiangongsi, Beijingguoyikangzhongyiyiyuan, DTTHStore, Guardian of the Lucky Star, sishaobozxmbcsjafhge, Poster Cave, chendonglan, haikoupengliuadianzishangwu, fish cc, Ad Store-US, WEnTiAn, hefeicoushengdianzishangwuyouxiangongsi, Nanningzengjimaoyiyouxiangongsi, zhengliqinhaibao and milanta Store added to case caption. |
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NEW PARTIES: Art Deco Wood Sign, chenpanus, GaoXinQuHuShuGuanZhenWeiHaoZhongMuJuJingYingBu, Gil Elvgren, MNBDFKHGDFS1DFGJHLKF, danzhoushihaozhuchencheng, nanninghexiangmaoyiyouxiangongsi, CASDASMGKLMLKSADMKLASMLGMA, weijianhuishop, hefeishiyingwushangwenshangmaoyouxiangongsi, Bee Family Gift, nanjinglianshengyuegongyipinmaoyiyouxiangongsi, Steven Lotis Store, xxstasmyxg, wenchangxuzhihaoshangmaoyouxiangongsi82, GOOD BAI Store, Gekerarge, fuhaijundedianpu, gedeyumaoyiyouxianzerengongsi, MEIGUANGYAOSTORE, Putianshichengxiangqunongjunwumaoyiyouxiangongsi, WJQ Shop, ChengDuTongJieLiaoShangMaoYouXianGongSi, shanxilaicaiqiyeguanliyouxiangongsi, YueFaShangMaoBaiHuo, liurenyiasfsdf, US-wjdpt, tongshie100, liujianbin1234, wanghuimin19961120, aiyukun2619, qiluyao520, Christos Caplanis43, liuqiangll66, yaomingfan, If the heart is in fhe dream, Dona laciura45, jiangjiajun8974, mengfanlong6019, shenxinxing0828, luorenbin8888, gaojuncong6334, lliken, Kexiangying, Jared Wike and mngzxkzozhlvvrpe added to case caption. |
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NEW PARTIES: Sheenpal coats, Aymima, Lg Petif, Wondlandy Magic, DioVaiip, ledgen, haungxiaoqiong Store, Xinme, Haijanto, Uiosli36, gulizhi37364, liujianghuai123, LIUp1994CFadd, Wangdongshuai, majingrui62, zhouxiongbing11452, hulingyan06288, konglingju8164, guozhe1389665, zoucuiwen8325, hehao65399405, liuyumeng1314, liuyan5206, fxnxfjcbxcvdbxf and majiangshan4508 added to case caption. |
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27
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2023-04-12 |
MOTION by Plaintiff Sassan Filsoof for default judgment as to The Defendants Identified In The First Amended Schedule A |
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28
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2023-04-12 |
MEMORANDUM by Sassan Filsoof in support of motion for default judgment 27 |
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Exhibit 1 |
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Exhibit 2 |
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(Declaration of Keith A. Vogt) |
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29
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2023-04-13 |
MINUTE entry before the Honorable John F. Kness: Before the Court is Plaintiff's motion 27 for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before 4/21/2023. If no objections are filed by that date, the court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice |
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30
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2023-04-13 |
CERTIFICATE of Service by Plaintiff Sassan Filsoof regarding text entry, 29 |
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31
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2023-04-18 |
NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] Defendants |
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32
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2023-04-24 |
NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no.33 HTX SHOP |
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33
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2023-04-24 |
ORDER signed by the Honorable John F. Kness on 4/24/2023: Plaintiff's motion for entry of default judgment 27 is granted. The ten thousand dollar ($10,000) surety bond posted by Sassan Filsoof is released to Sassan Filsoof or Plaintiff's counsel, 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 A. Vogt of Keith Vogt, Ltd., 33 West Jackson Boulevard, #2W Chicago, Illinois 60604 via certified mail. Civil case terminated. Mailed notice |
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34
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2023-04-24 |
DEFAULT JUDGMENT ORDER signed by the Honorable John F. Kness on 4/24/2023. Mailed notice |
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MAILED original ten-thousand-dollar ($10,000) surety bond posted by posted by Sassan Filsoof, Keith A. Vogt of Keith Vogt, Ltd., 33 West Jackson Boulevard #2W, Chicago, Illinois 60604 via certified mail # 7008 1830 0000 4138 9004. |
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35
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2023-04-25 |
MAILED copyright report to Registrar, Washington DC (jk2,) |
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36
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2023-05-01 |
RETURN of U.S. Post Office Receipt, article no. 7008 1830 0000 4138 9004. |
