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Motion for Ex Parte TRO and Preliminary Injunction

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Marc J. Randazza, AZ Bar No.: 27861

Ronald D. Green (Pro Hac Vice) RANDAZZA LEGAL GROUP, PLLC

3625 S. Town Center Drive, Suite 150

Las Vegas, NV 89135

Telephone: 702-420-2001

Facsimile: 305-437-7662

ecf@randazza.com

Attorneys for Plaintiff,

AMA Multimedia LLC

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

AMA MULTIMEDIA LLC, 

a Nevada limited liability company,

Plaintiff,

vs.

John Does 1-25, and

Roe Corporations 26-50

Defendants.

Case No. 2:15-cv-01674-ROS 

MOTION FOR EX PARTE

TEMPORARY RESTRAINING 

ORDER AND PRELIMINARY 

INJUNCTION

Plaintiff AMA MULTIMEDIA, LLC (“AMA”) hereby requests that this 

Court issue an ex parte Temporary Restraining Order and, subsequently, a 

preliminary injunction restraining Defendants’ assets from the websites 

located at <eporner.com>, <epornergay.com>, and <eprncdn.com> 

pursuant to 17 U.S.C. § 502 and Rule 65 of the Federal Rules of Civil 

Procedure. If Defendant’s operations are not frozen, they will dissipate 

those assets and/or transfer them outside the jurisdiction of this Court (and 

likely outside the United States), leaving Plaintiff with no adequate remedy 

at law. Plaintiff can show likelihood of success on its copyright and 
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Motion for Ex Parte TRO and Preliminary Injunction

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trademark claims, irreparable harm from Defendants’ infringement, and 

the public interest would not be disserved by issuance of an injunctive 

order. 

MEMORANDUM OF POINTS AND AUTHORITIES

1.0 INTRODUCTION

Plaintiff AMA is a producer and distributor of adult entertainment 

online. Defendants are owners and operators of websites located at the 

<eporner.com>, <epornergay.com>, and <eprncdn.com>, which 

unlawfully display the copyrighted content and registered trademarks 

without permission of the owners, including Plaintiff. Defendants profit from 

stolen content uploaded by themselves and their users, and thereby have 

irreparably and irreversibly harmed AMA by decreasing the value of its 

content in the marketplace.

Failure to enjoin Defendants and freeze their operations would 

permit Defendants to dissipate their assets or transfer their operations, or 

otherwise destroy or hide evidence of their widespread, intentional 

intellectual property infringement. This would leave Plaintiff AMA with no 

adequate remedy at law and necessitates equitable relief. Plaintiff 

requests this Court issue an ex parte temporary restraining order, which 

should be converted into a preliminary injunction until AMA obtains a 

judgment and permanent injunction at the conclusion of this case.

2.0 STATEMENT OF RELEVANT FACTS

2.1 Plaintiff AMA Multimedia

Plaintiff AMA Multimedia is a Nevada Limited Liability Company that 

produces high quality audiovisual erotic adult entertainment and 

distributes those works online to paid subscribers of its websites. (See

Declaration of Adam Silverman, attached hereto as Exhibit 1, at ¶¶2-3.) 
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Motion for Ex Parte TRO and Preliminary Injunction

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AMA’s subscription-based websites issue login ID and passwords to paid 

subscribers after confirming that they are over 18 years of age. (See id. at 

¶¶4-5.) Subscribers are then able to access secure portions of AMA’s 

websites to view adult entertainment materials. (See id. at ¶5.) AMA owns 

online properties and brands protected by common law and federally 

registered trademarks including “Passion-HD” and “Massage Creep,” 

among others. AMA maintains federally registered trademark rights in the 

marks:

a. PASSION-HD.COM (registration number 4,190,291)

b. PASSION-HD (registration number 4,251,457)

c. PORNPROS (registration number 4,081,017)

d. PORNPROS (registration number 3,566,875)

e. PURE MATURE (registration number 4,453,271)

f. POVD INNOVATIVE. CUTTING EDGE. A NEW PORN EXPERIENCE. 

(registration number 4,576,025)

g. TINY4K.COM (registration number 4,678,642)

h. FANTASYHD (registration number 4,591,117)

i. EXOTIC4K.COM YOUNG EXOTIC GIRLS 4K ULTRA-DEF (serial number 

86,425,774)

(See USPTO Registrations and corresponding assignments, attached 

hereto as Composite Exhibit 2).

Many of Plaintiff’s audiovisual works have appeared on 

Defendants’ websites without Plaintiff’s permission. Such infringing works 

displayed on Defendants’ websites additionally contain AMA’s watermark 

wrongfully suggesting Plaintiff’s endorsement of Defendants’ website. (See

Exhibit 3, Declaration of Trey Rothell, at Exhibit A, Representative Example 

of Plaintiff Video on EPorner Website).
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Motion for Ex Parte TRO and Preliminary Injunction

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2.2 Doe Defendants & Roe Corporations 

Defendants are the registrants of the domain names 

<eporner.com>, <epornergay.com>, and <eprncdn.com>, and the 

owners of the EPorner website accessible through each of the domain 

names. (See Exhibit 3 at Exhibit B, Front Page of EPorner Website). 

Defendants registered <eporner.com> on or about April 8, 2008. (See 

Whois Information for <eporner.com>, attached hereto as Exhibit 4.) The 

current registrar of <eporner.com> is Key-Systems GmbH, located in Sankt 

Ingber, Germany. (See id.) Defendants registered <epornergay.com> on 

or about August 27, 2013. (See Whois Information for <epornergay.com>, 

attached hereto as Exhibit 5.) The current registrar for <epornergay.com> 

is GoDaddy.com, LLC, located in Scottsdale, Arizona. (See id.) Finally, 

Defendants registered <eprncdn.com> on or about November 5, 2013, 

using domain name registrar GoDaddy.com, LLC, located in Scottsdale, 

Arizona. (See Whois Information for <eprncdn.com>, attached hereto as 

Exhibit 6.)

Defendants are aware they are using each domain name to 

infringe upon Plaintiff’s rights and the rights of other content produces. 

Therefore, they have taken affirmative steps to hide both their identities 

and locations from the world, including but not limited to using privacy 

services for the registrations of the domain names. The <eporner.com> 

domain name is registered to Whoisproxy.com in Auckland, New Zealand, 

and <epornergay.com> is registered to Domains by Proxy in Scottsdale, 

Arizona. (See Exhibits 4, 5, & 6.) The <eprncdn.com> domain name is 

hosted by Leaseweb, headquartered in Amsterdam, Netherlands, with an 

office in Manassas, Virginia. 
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Motion for Ex Parte TRO and Preliminary Injunction

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The EPorner website operates as an adult entertainment theater 

displaying audiovisual content created by Plaintiff and other content 

producers to its users free of charge and with no compensation to Plaintiff. 

(See EPorner Homepage, Exhibit 3 at Exhibit B.) Defendants’ profits and 

their website’s popularity are specifically the result of the infringing 

content found on the site, including content belonging to Plaintiff. Videos 

displayed on the EPorner site bear the watermark of the content owner, 

including Plaintiff, side-by-side with EPorner’s own watermark, improperly 

inferring that Plaintiff and other content owners endorse or are affiliated 

with EPorner. (See Video Screenshot, Exhibit 3 at Exhibit A.)

Finally, EPorner, like many adult and non-adult websites, encourages 

its users to upload material to the site, similar to how YouTube operates. 

Most websites that permit user uploads require users to create an account 

and provide some type of personal information prior to uploading 

content.1 Among other things, this assists the site in identifying users who 

are uploading infringing content. However, EPorner explicitly encourages 

its users to upload infringing material by advertising that users may upload 

and/or access content anonymously. (See EPorner Upload Page, Exhibit 3

at Exhibit F.) With no fear of reprisals from intellectual property owners, 

EPorner and its users have transformed the site into a digital haven for 

infringers.

/ / /

/ / /

 1 See e.g. Upload, YouTube, youtube.com/# (last visited Sept. 3, 2015) (requires gmail.com login 

and creation of youtube account/google+ profile); XVideos, 

upload.xvideos.com/account/uploads/new (last visited Sept. 3, 2015) (requires xvidos.com 

account); Vimeo, vimeo.com/help/uploading (last visited Sept. 3, 2015) (requires login before 

uploading). (Exhibit 3 at Exhibits C, D, and E.) See also, Flickr, www.flickr.com (last visited Aug. 19, 

2015) (click Upload, log in to Yahoo!); CNN, ireport.cnn.com (last visited Aug. 19, 2015). 
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3.0 LEGAL ARGUMENT

3.1 Standard of Review

A temporary restraining order or preliminary injunction should be 

entered where plaintiff establishes: (1) likelihood of success on the merits;

(2) a likelihood of irreparable harm; (3) the balance of equities is in 

plaintiff’s favor; and (4) the public interest would not be disserved by the 

issuance of a preliminary injunction. (See Alliance for the Wild Rockies v. 

Cottrell, 632 F.3d 1127, 1131 (9th Cir. 2011).)

Pursuant to the U.S. Copyright Act, aggrieved copyright owners are 

entitled to, inter alia, the equitable relief of a seizure of the infringing 

defendant’s profits and injunctive relief to prevent or restrain further 

infringement by the defendant. (See 17 U.S.C. §§ 502, 504.) Doman names 

are commonly proper objects of injunctive seizure. (See Kremen v. Cohen, 

337 F.3d 1024, 1030 (9th Cir. 2003); see also Office Depot, Inc. v. Zuccarini, 

596 F.3d 696, 701 (9th Cir. 2010).) In this instance, a temporary restraining 

order and/or preliminary injunction are necessary to stop Defendants’ 

infringement, to stop Defendants from dissipating or moving their assets 

out of the Court’s jurisdiction, and to prevent them from destroying any 

incriminating evidence after receiving notice of this lawsuit.

3.2 Plaintiff Is Likely to Succeed on the Merits of Its Claims 

Plaintiff is likely to succeed on the Merits of its relevant claims for 

Copyright infringement under 17 U.S.C. §501, Contributory Copyright 

Infringement, Vicarious Copyright Infringement, Trademark infringement 

under 15 U.S.C. § 1114, and Unfair Competition under 15 U.S.C. § 1125(a). 

Plaintiff only need demonstrate likelihood of success on one relevant 

claim to be entitled to relief in the form of a Temporary Restraining Order 

and/or Preliminary Injunction.
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3.2.1 Copyright Infringement

To prevail on a copyright infringement claim, plaintiff must show 

that: (1) it owns a copyright in the allegedly infringed work, and (2) the 

defendant copied with work without authorization. (See Feist Pul’ns Inc. v. 

Rural Tel. Serv. Co., Inc., 499 U.S. 340, 361 (1991); see also Shaw v. 

Lindheim, 919 F.2d 1351, 1356 (9th Cir. 1990).)

Plaintiff AMA is the owner of registered copyrights on 22 works 

available on Defendants’ website. (See List of Infringing Works, attached 

hereto as Exhibit 7.) Plaintiff has never given Defendants permission to use 

or provide access to those works on Defendants’ website or anywhere 

else, nor has Plaintiff granted Defendants permission to copy these works.

Once plaintiff has established ownership of materials that have 

been copied or distributed without permission, plaintiff has established a 

prima facie case for copyright infringement. (See 17 U.S.C. §106; see also

Feist Publ’ns Inc., 499 U.S. at 361.) Because of the clear evidence Plaintiff 

AMA has provided showing copyright ownership and Defendant’s 

unauthorized use and copying, Plaintiff has established a likelihood of 

success on their Copyright infringement claim.

3.2.2 Contributory and Vicarious Copyright Infringement

Defendants’ are further liable for vicarious and contributory 

copyright infringement since Defendants have not designated a DMCA 

agent for service of process and therefore can be liable as an Internet 

service provider. (See 17 U.S.C. § 512(c)(2) (stating the limitations on 

liability permitted under the DMCA apply to service providers only if the 

service provider has a designated agent to receive service notifications of 

claimed infringements).) Defendants permit unidentified users to upload 

videos onto the EPorner website and thus should be aware that copyright 
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protected works, including Plaintiff’s, would end up on their site. Absent 

DMCA protection, Defendants are liable for contributory copyright 

infringement based on the unauthorized uploads by their users. (See

Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913, 930 (2005) 

(holding “[o]ne infringes contributorily by intentionally inducing or 

encouraging direct infringement.”))

Furthermore, Defendants have the capability to take steps to 

prevent or diminish the uploading of infringing videos on the EPorner 

website but failed to do so. Defendants’ profited off user infringement, 

including infringement of Plaintiff’s works, and are thus liable for vicarious 

copyright infringement. (See Grokster, 545 U.S. at 914 (holding one liable 

for vicarious copyright infringement where they profit “from direct 

infringement while declining to exercise the right to stop or limit it.”))

Plaintiff is likely to succeed on the merits of its claim against 

Defendants for contributory and vicarious copyright infringement and thus 

injunctive relief should issue.

3.2.3 Trademark Infringement

Defendants will be found liable for Trademark Infringement where 

plaintiff can show (a) goods or services are involved; (b) interstate 

commerce is affected; and (c) there is a likelihood of confusion to current 

or potential consumers due to Defendants’ infringement. (See 15 U.S.C. §§ 

1444 & 1125(a).) Irreparable harm is presumed if Plaintiff demonstrates a 

likelihood of confusion. (See Vision Sports, Inc. v. Melville Corp., 888 F.2d 

609, 612 (9th Cir. 1989).)

Defendants have profited off of the use of Plaintiff’s copyrights and 

created consumer confusion by leaving Plaintiff’s watermark with its 

trademarked logos on the infringing videos, available to its users. 
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Therefore a user would likely believe that Plaintiff endorsed Defendants 

use of their copyrighted works and in turn Defendants’ website itself. 

Courts determine likelihood of confusion by looking to certain 

factors including: (1) strength of plaintiff’s trademarks; (2) proximity of the 

goods; (3) similarity of the marks; (4) evidence of actual confusion; (5) 

marketing channels; (6) types of goods and consumer’s degree of care;

(7) defendants’ intent; and (8) likelihood of expansion into the area of 

goods. (See AMF Inc. v. Sleekcraft Boats, 599 F.2d 341 (9th Cir. 1979).)

Plaintiff’s federal registrations constitute prima facie evidence of the 

validity and exclusive right to use the marks in commerce in connection 

with certain goods and services. (See Coca-Cola Co v. Overland Inc., 692 

F.2d 506, 509 (9th Cir. 1969).) Plaintiff uses its trademarks in connection with 

providing adult entertainment, in the form of their copyrighted videos, 

online. Defendants have used those same trademarks in congruence with 

distribution of the same goods. The marks Defendant has used are the 

exact marks belonging to Plaintiff. For these reasons and Defendant’s 

blatant intention to use Plaintiff’s trademarks and copyrighted works 

without permission constitutes Plaintiff’s entitlement to injunctive relief.

3.2.4 Unfair Competition

The Lanham Act protection against unfair competition by “mak[ing] 

actionable the deceptive and misleading use of marks.” Two Pesos, Inc. v. 

Taco Cabana, 505 U.S. 763, 768 (1992). Plaintiffs registered marks enjoy 

“presumed source association . . . [and] qualify for protection under 

§41(a) without proof of secondary meaning.” Id. at 772. Likelihood of 

confusion for a Lanham Act claim of unfair competition is the same for 

trademark infringement. (See 15 U.S.C. §1125 & 1127.) Accordingly, 

Plaintiff is likely to succeed on its claim.
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3.3 Plaintiff Will Suffer Irreparable Harm Absent Equitable Relief

Irreparable harm exists where a plaintiff will suffer an injury that 

cannot be adequately redressed after the completion of a trial either 

legally or equitably. (See Bethesda Softworks, LLC v. Interplay Entm’t 

Corp., 452 App’x 351, 353 (4th Cir. 2011).) A company’s loss of reputation, 

good will, and business opportunities amounts to irreparable harm. (See

Otsuka Pharm. Co. v. Burwell, 2015 U.S. Dist. LEXIS 56344, *29 (D. Md. Apr. 

29,2015).) While monetary damages may be available at law in copyright 

and trademark cases, equity compels a refusal to permit defendant from 

continuing infringing activities. (See 17 U.S.C. §504.)

Irreparable harm cannot be categorically presumed in intellectual 

property cases. (See eBay Inc. v. MercExchange, 547 U.S. 388 (2006).)

Therefore Plaintiff shows irreparable harm whereby Plaintiff’s property 

interest in its copyrighted works is compromised by Defendants’ actions, 

and the possibility of market confusion amongst current and potential 

customers constitutes irreparable harm. (See Perfect 10, Inc. v. Cybernet 

Ventures, Inc., 213 F.Supp.2d 1146, 1190–91 (C.D. Ca. 2002).) Additionally, 

irreparable harm is satisfied because it is “notoriously difficult” to quantify 

potential lost sales as a result of infringement. (See Omega Importing 

Corp. v. Petri-Kine Camera Co., 451 F.2d 1190, 1195 (2d Cir. 1971); see also

Country Kids ‘N City Slicks, Inc. v. Sheen, 77 F.3d 1280, 1288 (10th Cir. 

1991).) Where copyrighted materials are “central to the essence of 

plaintiff’s operations,” their infringement enhances the irreparable nature 

of a plaintiff’s harm. (See Apple Computer, Inc. v. Franklin Computer 

Corp., 714 F.2d at 1254; see also Educational Testing Services v. Katzman, 

793 F.2d 533, 544 (3d Cir. 1986).)
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Because Defendants’ blatant infringement of Plaintiff’s copyrighted 

works via unauthorized copying, distribution, and public display has 

caused irreparable harm to AMA this Court should issue injunctive relief.

3.4 The Balance of Equities Favors Injunctive Relief

This requested temporary restraining order is limited in scope. It 

merely prohibits Defendants from continuing use of the domain names 

<eporner.com>, <epornergay.com>, and <eprncdn.com>, and any 

associated websites to profit from infringement of Plaintiff’s copyrighted 

works. Because Defendants’ identities are unknown the only way to 

ensure that infringement ceases for the pendency of this action is to 

freeze any and all assets and domain names of any and all Defendants 

pending the outcome of this case.

Freezing Defendants’ <eporner.com>, <epornergay.com>, and 

<eprncdn.com> domain names to prevent their transfer to another 

registrar or to a different registrant is also essential for Plaintiff to receive 

relief. Additionally, the preliminary injunction sought restrains Defendants 

from making further unauthorized copies of Plaintiff’s works and from 

further distributing such pirated materials. 

The requested injunctive relief seeks to require Defendants to 

comply with the U.S. Copyright Act, cease infringing upon Plaintiff’s 

copyrighted materials, and to preserve the status quo throughout the 

pendency of this case. An imposition this may cause to Defendants’ 

legitimate business activities (if any) is minimal and short-lived. Plaintiff’s 

injury, and Defendants’ continued infringement and potential to destroy 

evidence outweigh any possible damage caused to Defendants upon 

issuing injunctive relief. 

/ / /
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3.5 The Requested Relief Is In the Public Interest

Courts balance two competing public interests in deciding whether 

to issue a preliminary injunction in a copyright case: “the rights of users 

and the public interest in the broad accessibility of creative works, and 

the rights of copyright owners and the public interest in rewarding and 

incentivizing creative efforts.” WPIX, Inc. v. IVI, Inc., 691 F.3d 275, 287 (2d 

Cir. 2012). There is a significant public interest in upholding copyright 

protections and preliminary injunctions serve that purpose. (See Autoskill, 

Inc. v. Nat’l Educ. Support Sys., Inc., 994 F.2d 1476, 1499 (10th Cir. 1993);

see also Perfect 10, Inc. v. Cybernet Ventures, Inc. 213 F.Supp.2d 

1146,1191 (C.D. Ca. 2002).)

Federal copyright law furthers the public’s interest in protecting 

business investment and intellectual property, and fostering creativity. 

There is no predominating public interested promoted by Defendants’ 

infringement of AMA’s copyrighted works. 

3.6 Ex Parte Relief Is Essential

Federal Rule of Civil Procedure 65 permits issuance of a temporary 

restraining order without prior notice to Defendants. An ex parte order 

preserves the status quo and prevents irreparable harm. (See Granny 

Goose Foods, Inc. v. Brotherhood of Teamsters, 415 U.S. 423, 439 (1974).)

Courts grant temporary restraining orders when: (a) immediate and 

irreparable injury, loss, or damage will result to the applicant before the 

adverse party can be heard in opposition; and (b) the applicant 

sufficiently demonstrates the reasons notice should not be required. (See 

FRCP 65(b)(1).) Courts often recognize the need for ex parte temporary 

restraining orders in intellectual property cases, especially in cases where 

defendants are unidentifiable at the time. (See e.g. Bridals v. P’ships & 
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Unincorporated Ass’ns, 2015 U.S. Dist. LEXIS 72511, *4 (W.D.N.C. June 3, 

2015); In re Vuitton Et Fils S.A., 606 F.2d 1 (2d Cir. 1979); see also

Guggenheim Capital v. Birnbaum, 722 F.3d 444, 447 (2d Cir. 2013); NBA 

Properties v. Various John Does, 113 F.3d 1246 (10th Cir. 1997); and see

American Can Company v. Mansukkhani, 742 F.2d 314, 321 (7th Cir. 1984) 

(holding Rule 65 “expressly contemplates the issuance of ex parte 

temporary restraining orders”).)

To obtain ex parte relief, a “Plaintiff need not show that a particular 

Defendant would not adhere to a temporary restraining order, but rather 

only that someone like the defendant would be likely to hide or destroy 

the evidence of his infringing activity.” Century Home Entertainment, Inc. 

v. Laser Beat, Inc., 859 F. Supp. 636, 638 (E.D.N.Y. 1994); see also First 

Technology Safety Systems, Inc. v. Depinet, 11 F.3d 641, 651 (6th Cir. 1998); 

In re Estate of Ferdinand Marcos, 25 F.3d 1467 (9th Cir. 1994).

Plaintiff has substantiated equitable remedies available under 17 

U.S.C. §§ 502–505. Remedial and legal relief, however, will be unavailable 

if Defendants remove all property subject to Plaintiff’s recovery beyond 

the reach of the Court. Prior notice would “render fruitless further 

prosecution of the action.” Vuitton, 606 F.2d at 5. 

Defendants’ willful infringement of Plaintiff’s copyrighted works make 

it critical that the Court order injunctive relief before Defendants have the 

opportunity to prevent Plaintiff’s relief. Additionally, where danger of 

destruction or hiding evidence exists, the federal rules permit issuance of 

ex parte seizures and impoundment orders under cases such as this. (See

Laser Beat, 859 F. Supp. at 638.)

/ / /
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3.7 Plaintiff Will Provide Adequate Security if Defendants 

Demonstrate Hardship

In the event that Defendants should prove hardship, they may 

propose a bond. “[T]he district court has the discretion to set the bond 

amount in such a sum as the court deems proper.” Hoechst Diafoil Co. v. 

Nan Ya Plastics Corp., 174 F.3d 411, 421 (4th Cir. 1999). However, if there is 

no evidence that the enjoined or restrained party will suffer material harm 

as a result of the injunction the court may set the bond amount at zero. 

(See Connecticut General Life Ins. v. New Images of Beverly Hills, 321 F.3d 

878, 882 (9th Cir. 2003).)

Defendants are unlikely to show any hardship suffered by issuance 

of an injunction. Injunctive relief would merely prevent Defendants from 

continuing illegal infringement activities. Additionally, “copyright 

infringement must not be allowed to serve as the cornerstone of a 

profitable business.” Playboy Enterprises, Inc. v. Webbworld, Inc., 991 F. 

Supp. 543, 561 (N.D. Tex. 1997), affirmed without opinion, 168 F.3d 486 (5th 

Cir. 1999). Should the Court have trouble assessing the proper amount to 

which to set bond, it should hold an evidentiary hearing wherein 

Defendants are required to meet their evidentiary burden to prove 

hardship. A mere request for bond without sworn testimony specifically 

articulating alleged harm and an opportunity to cross-examine witnesses, 

should not be entertained. 

4.0 DEFENDANTS SHOULD BE REQUIRED TO SHOW CAUSE

The requirements for a preliminary injunction are the same for a 

Temporary Restraining Order. (See Walczak v. EPL Prolong. Inc., 198 F.3d 

725, 731 (9th Cir. 1999).) Plaintiffs have overcome the burden to meet 

these standards. This Court should issue a show-cause order requiring 
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Defendants to demonstrate any countervailing argument as to why the 

Court should not issue a preliminary injunction continuing the relief 

granted in the TRO.

5.0 CONCLUSION

Defendants illegally copies, distributed, and publicly displayed copies 

of Plaintiff’s copyrighted material for profit. Defendants additionally 

created a potential for consumer confusion as to their authority to display 

Plaintiff’s works by infringing on Plaintiff’s registered trademarks. 

Defendants’ conduct is patently indefensible. These actions immediately 

and irreparably harm Plaintiff. Therefore the Court should grant Plaintiff’s 

motions for a temporary restraining order and order to show cause. 

Plaintiff requests the Court grant these motions ex parte and without 

advance notice to Defendants to preserve the status quo and permit the 

Court to execute effective relief at trial. 

Dated: September 3, 2015

Respectfully Submitted,

/s/ Marc J. Randazza

Marc J. Randazza, AZ Bar No. 27861

Ronald D. Green, Pro Hac Vice

Randazza Legal Group, PLLC

3625 S. Town Center Drive, Suite 150

Las Vegas, NV 89135

Attorneys for Plaintiff,

AMA Multimedia, LLC