First MOTION for Order to Show Cause with Proposed Temporary Restraining Order by Bufete MF & CO., RAMON FONSECA, JURGEN MOSSACK, MOSSACK FONSECA & CO., S.A.. (Seeger, Stephan)
No tags have been applied so far. Sign in to add some.
Page 1 UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
MOSSACK FONSECA & CO., S.A, BUFETE
MF & CO., JÜRGEN MOSSACK and
RAMÓN FONSECA
:
:
:
:
:
:
:
:
:
Plaintiffs
v.
NETFLIX INC.
Defendant
CIVIL ACTION NO:
OCTOBER 15, 2019
ORDER TO SHOW CAUSE & [PROPOSED]
TEMPORARY RESTRAINING ORDER
Upon the Verified Complaint herein, Application for Temporary Restraining Order,
Affidavit of Arthur Ventura Jr., and Memorandum of Law in Support thereof, it is hereby:
ORDERED that the Defendants show cause before this Court on the
October, 2019, at
o’clock
th day of
, why an Order should not be entered pursuant to Rule 65 of the Federal Rules of Civil Procedure, enjoining the Defendants, their agents, servants,
employees, and assigns, pending further order of this Court as provided by the Federal Rules of
Civil Procedure, as requested by the Plaintiff. Briefs in support of the motion for preliminary
injunction and/or in opposition thereto shall be filed and served by the parties as follows:
Plaintiffs on or before
, 2019, at
Defendant on or before
pm.
, 2019, at
pm.
AND WHEREAS, it appearing from the facts alleged in the Verified Complaint and the
Memorandum of Law in Support of the Temporary Restraining Order, that immediate and
irreparable injury, loss, or damage will result to the Plaintiff before a hearing can be held upon
Plaintiff’s motion for Preliminary Injunction, the following Proposed Order is submitted Page 2 TEMPORARY RESTRAINING ORDER
IT IS ORDERED that a Temporary Restraining Order hereby issue without the necessity
of Plaintiffs’ posting a bond, the same continuing in full force and effect as against the
Defendant, NETFLIX INC., pending the outcome of a Preliminary Injunction hearing pursuant
to FRCP Rule 65, enjoining said Defendant, from releasing, publishing, showing, airing,
broadcasting, disseminating and/or otherwise communicating its film “The Laundromat” in
theatres and/or via its streaming platform to subscribers, using the real names of the Plaintiffs, or
any of them, absent a disclaimer and/or written acknowledgement displayed on-screen to
potential viewers confirming that Plaintiffs have never been convicted of money laundering, tax
evasion or any financial crime or conspiracy to commit such crime, and that views expressed or
implied in the movie “The Laundromat do not, and are not, meant or intended by NETFLIX
INC., to constitute proof to the contrary.
IT IS FURTHER ORDERED that a Temporary Restraining Order hereby issue without
the necessity of Plaintiffs posting a bond, the same continuing in full force and effect as against
the Defendant, NETFLIX INC., pending the outcome of a Preliminary Injunction hearing,
pursuant to FRCP Rule 65, enjoining said Defendant from using Mossack Fonseca & Co., S.A.’s
trademarked and protected logo(s), in the movie “The Laundromat,” and/or any promotional,
informational, advertising, or other material, related to “The Laundromat,” in any Member States
of the 1929 General Inter American Convention for Trademark and Commercial Protection, to
wit: the United States and/or Peru, Bolivia, Paraguay, Ecuador, Uruguay, Dominican Republic,
Chile, Panama, Venezuela, Costa Rica, Cuba, Guatemala, Haiti, Colombia, Brazil, Mexico,
Nicaragua, or Honduras. Page 3 IT IS FURTHER ORDERED that, pursuant to FRCP Rule 4(f)(3), service via e-mail
and Federal Express of a copy of this Order and the papers upon which it is granted, made upon
the Defendant , NETFLIX, or its Counsel, on or before ________________ , 2019, shall be
deemed good and sufficient service and notice thereof.
IT IS FURTHER ORDERED,
Dated at,
, Connecticut, this
day of
, 2019.
BY: ____________________________________
UNITED STATES DISTRICT COURT JUDGE
PDF Page 1
PlainSite Cover Page
PDF Page 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
MOSSACK FONSECA & CO., S.A, BUFETE
MF & CO., JÜRGEN MOSSACK and
RAMÓN FONSECA
:
:
:
:
:
:
:
:
:
Plaintiffs
v.
NETFLIX INC.
Defendant
CIVIL ACTION NO:
OCTOBER 15, 2019
ORDER TO SHOW CAUSE & [PROPOSED]
TEMPORARY RESTRAINING ORDER
Upon the Verified Complaint herein, Application for Temporary Restraining Order,
Affidavit of Arthur Ventura Jr., and Memorandum of Law in Support thereof, it is hereby:
ORDERED that the Defendants show cause before this Court on the
October, 2019, at
o’clock
th day of
, why an Order should not be entered pursuant to
Rule 65 of the Federal Rules of Civil Procedure, enjoining the Defendants, their agents, servants,
employees, and assigns, pending further order of this Court as provided by the Federal Rules of
Civil Procedure, as requested by the Plaintiff. Briefs in support of the motion for preliminary
injunction and/or in opposition thereto shall be filed and served by the parties as follows:
Plaintiffs on or before
, 2019, at
Defendant on or before
pm.
, 2019, at
pm.
AND WHEREAS, it appearing from the facts alleged in the Verified Complaint and the
Memorandum of Law in Support of the Temporary Restraining Order, that immediate and
irreparable injury, loss, or damage will result to the Plaintiff before a hearing can be held upon
Plaintiff’s motion for Preliminary Injunction, the following Proposed Order is submitted
1
PDF Page 3
TEMPORARY RESTRAINING ORDER
IT IS ORDERED that a Temporary Restraining Order hereby issue without the necessity
of Plaintiffs’ posting a bond, the same continuing in full force and effect as against the
Defendant, NETFLIX INC., pending the outcome of a Preliminary Injunction hearing pursuant
to FRCP Rule 65, enjoining said Defendant, from releasing, publishing, showing, airing,
broadcasting, disseminating and/or otherwise communicating its film “The Laundromat” in
theatres and/or via its streaming platform to subscribers, using the real names of the Plaintiffs, or
any of them, absent a disclaimer and/or written acknowledgement displayed on-screen to
potential viewers confirming that Plaintiffs have never been convicted of money laundering, tax
evasion or any financial crime or conspiracy to commit such crime, and that views expressed or
implied in the movie “The Laundromat do not, and are not, meant or intended by NETFLIX
INC., to constitute proof to the contrary.
IT IS FURTHER ORDERED that a Temporary Restraining Order hereby issue without
the necessity of Plaintiffs posting a bond, the same continuing in full force and effect as against
the Defendant, NETFLIX INC., pending the outcome of a Preliminary Injunction hearing,
pursuant to FRCP Rule 65, enjoining said Defendant from using Mossack Fonseca & Co., S.A.’s
trademarked and protected logo(s), in the movie “The Laundromat,” and/or any promotional,
informational, advertising, or other material, related to “The Laundromat,” in any Member States
of the 1929 General Inter American Convention for Trademark and Commercial Protection, to
wit: the United States and/or Peru, Bolivia, Paraguay, Ecuador, Uruguay, Dominican Republic,
Chile, Panama, Venezuela, Costa Rica, Cuba, Guatemala, Haiti, Colombia, Brazil, Mexico,
Nicaragua, or Honduras.
2
PDF Page 4
IT IS FURTHER ORDERED that, pursuant to FRCP Rule 4(f)(3), service via e-mail
and Federal Express of a copy of this Order and the papers upon which it is granted, made upon
the Defendant , NETFLIX, or its Counsel, on or before ________________ , 2019, shall be
deemed good and sufficient service and notice thereof.
IT IS FURTHER ORDERED,
Dated at,
, Connecticut, this
day of
, 2019.
BY: ____________________________________
UNITED STATES DISTRICT COURT JUDGE
3
Back to 
