IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

DOORAGE, INC., § 

 Plaintiff, § 

 § 

VS. § CASE NO. 1:20-CV-421

 § 

BLUE CRATES, LLC § 

 Defendant. § JUDGE GARY FEINERMAN 

PLAINTIFF, DOORAGE INC.’S 

REVISED MOTION FOR INJUNCTIVE RELIEF 

 Plaintiff, DOORAGE, INC., by and through its attorneys of record, files its Revised 

Motion for a Injunctive Relief, and in support of this Motion, shows unto the Court as follows: 

A. FACTS

1. On January 19, 2020, Plaintiff, DOORAGE, INC., filed the instant case alleging 

copyright infringement against Defendant, BLUE CRATES (see Docket Entry #1). 

2. On February 5, 2020, Defendant, BLUE CRATES, LLC, was served with the 

Original Complaint by and through its Registered Agent (see Docket Entry #15). 

3. On February 18, 2020, Crum & Forster (BLUE CRATES insurance carrier) took 

on the coverage of this claim under BLUE CRATES’ policy and subsequently, hired the law firm 

of Maron Marvel to appear as counsel for BLUE CRATES (see Docket Entry #10). 

4. On June 4, 2020, BLUE CRATES filed its Answer to DOORAGE’s Original 

Complaint (see Docket Entry #32). The parties have litigated this case aggressively for 10 

months. 

5. On October 14, 2020, Crum & Forster filed Case No. 1:20-cv-06106; Crum & 

Forster vs. Blue Crates, in the United States District Court for the Northern District of Illinois, in 

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which Crum & Forster has now denied coverage of BLUE CRATES for DOORAGE’s copyright 

infringement case. 

6. On October 21, 2020, Maron Marvel withdrew as counsel for BLUE CRATES in 

this case. 

7. BLUE CRATES is now faced with two (2) federal lawsuits. BLUE CRATES 

does not have insurance coverage for its attorney fees, judgment for damages, or other losses at 

this time and may not have coverage in the future. 

8. There is a substantial likelihood that DOORAGE will prevail on the merits of this 

case based on the evidence produced to date, including BLUE CRATES production of 

documents related to the copying of DOORAGE’s copyright-protected Marketing Videos. 

9. In January 2020, BLUE CRATES had approximately $300,000 in its cash 

holdings. This amount may be the only monetary means of recovery for DOORAGE. 

10. BLUE CRATES likely has other assets used in the operation of its moving and 

storage business, including trucks, furniture, desks, trucks, moving and storage equipment, 

computers, among other items. 

11. BLUE CRATES has a number of customers with current accounts. 

12. BLUE CRATES has a Manager, RICHFIELD HOLDINGS, which is owned by 

the same owners of BLUE CRATES, Michael Walker and Matthew Walker. (See Blue Crates’ 

Answer to Interrogatory No. 16, attached hereto as Exhibit A). 

II. REQUEST FOR INJUNCTIVE RELIEF 

13. Plaintiff, DOORAGE, INC., will likely suffer irreparable injury if Defendant, 

BLUE CRATES, does not cease and/or refrain from making any withdraw, transfer, transmit or 

otherwise make any debt transactions in association with any and all of BLUE CRATES’ 

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financial assets, investments, holdings, bank accounts related to BLUE CRATES and/or its 

Manager, RICHFIELD HOLDINGS. 

14. In addition, DOORAGE will likely suffer irreparable injury if BLUE CRATES is 

not prohibited or refrained from discussing, telling, advising, or notifying its customers or the 

public of this lawsuit or the impact this litigation may have with regard to BLUE CRATES’ 

operations, business, insolvency, bankruptcy, or other termination of the customers’ contracts 

with BLUE CRATES. 

15. In addition, DOORAGE will likely suffer irreparable injury if BLUE CRATES 

does not refrain from notifying its customers of any impact this lawsuit will have with regard to 

BLUE CRATES’ business, pending bankruptcy, insolvency or other information that may 

impact the customers’ contracts with BLUE CRATES. 

16. Further, DOORAGE will likely suffer irreparable injury in the industry and to its 

reputation and business, if BLUE CRATES is not prohibited from communicating any negative 

or disparaging information related to DOORAGE to BLUE CRATES’ customers, potential 

customers, or to the public in general, by or through any means, including BLUE CRATES’ 

website and/or social media for BLUE CRATES, Michael Walker and Matthew Walker 

regarding anything relating to this lawsuit, DOORAGE’s business and/or DOORAGE’s owner, 

Sean Sandona. 

17. The harm faced by DOORAGE outweighs the harm that would be sustained by 

BLUE CRATES (if the preliminary injunction were granted) in that DOORAGE would have 

filed a lawsuit, litigated the case (including legal fees, costs and expenses) and risk no recovery 

because BLUE CRATES will eventually become insolvent and file bankruptcy. At that point, 

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there is no adequate remedy at law under which DOORAGE will recover adequate damages, 

legal fees, costs and sanctions awarded. 

18. Issuance of a preliminary injunction would not adversely affect the public interest 

as the issues involve private details, financials and business operations. 

19. DOORAGE is willing to post a bond in the amount deemed appropriate by the 

Court. 

20. DOORAGE asks the Court to grant its Motion for Injunction Relief without 

hearing due to the likelihood of harm to DOORAGE if BLUE CRATES is given time to transfer 

or withdraw finances, assets, and/or otherwise disparage DOORAGE’s business and/or its 

owner, Sean Sandona, to its customers, potential customers, and/or to the public in general. 

21. In the alternative, DOORAGE asks the Court to set its Motion for Injunctive 

Relief for hearing at the earliest possible time and, after hearing, to issue a preliminary injunction 

against Defendant, BLUE CRATES and after hearing, issue a permanent injunction against 

BLUE CRATES. 

III. PRAYER 

22. For these reasons, Plaintiff, DOORAGE, INC., asks the Court to do the following: 

a. Order that BLUE CRATES immediately cease and/or refrain from making any 

withdraw, transfer, transmit or otherwise make any debt transactions in association with 

any and all of BLUE CRATES’ financial assets, investments, holdings, bank accounts 

related to BLUE CRATES and/or its Manager, RICHFIELD HOLDINGS. 

b. Order that BLUE CRATES is immediately prohibited or refrained from 

discussing, telling, advising, or notifying its customers or the public of this lawsuit or the 

impact this litigation may have with regard to BLUE CRATES’ operations, business, 

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insolvency, bankruptcy, or other termination of the customers’ contracts with BLUE 

CRATES. 

c. Order that BLUE CRATES is immediately refrained from notifying its customers 

of any impact this lawsuit will have with regard to BLUE CRATES’ business, pending 

bankruptcy, insolvency or other information that may impact the customers’ contracts 

with BLUE CRATES. 

d. Order that BLUE CRATES is prohibited from communicating any negative 

BLUE CRATES’ customers, potential customers, or to the public in general, by or 

through any means, including BLUE CRATES’ website and/or social media for BLUE 

CRATES, Michael Walker and Matthew Walker regarding anything relating to this 

lawsuit, DOORAGE’s business and/or DOORAGE’s owner, Sean Sandona. 

e. Grant any other relief it deems appropriate. 

Respectfully submitted, 

By: /s/ Sharon K. Jackson 

SHARON K. JACKSON 

Federal Bar No. 24043986 (Texas SBN) 

12210 Clearfork Drive 

Houston, Texas 77077 

Telephone: 713/542-7491 

Email: Sharon@JacksonAttorney.net 

ATTORNEYS FOR PLAINTIFF, 

DOORAGE INC. 

 

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CERTIFICATE OF SERVICE 

 This is to certify that the foregoing Plaintiff, Doorage, Inc.’s, Revised Motion for 

Injunctive Relief was electronically filed with the Clerk of Court using the CM/ECF system and 

served upon Defendant, BLUE CRATES, by and through its office address: 

Blue Crates, LLC (via CMRRR 7017 1000 0000 6190 3216)

159 Sangamo, Suite200 

Chicago, IL 60607 

Dated: 26th day of October, 2020 

 /s/ Sharon K. Jackson \

SHARON K. JACKSON 

Attorney for Plaintiff, Doorage, Inc. 

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