Arista Records LLC et al v. Lime Wire LLC et al

Filing 242

MOTION for Preliminary Injunction Freezing Defendants' Assets. Document filed by Capitol Records, Inc., Elektra Entertainment Group, Inc., Interscope Records, Laface Records LLC, Motown Record Company, L.P., Arista Records LLC, Priority Records LLC, Sony BMG Music Entertainment, UMG Recordings, Inc., Virgin Records America, Inc., Warner Bros. Records Inc., Atlantic Recording Corporation, BMG Music.(Klaus, Kelly)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ARISTA RECORDS LLC; ATLANTIC RECORDING CORPORATION; BMG MUSIC; CAPITOL RECORDS, INC.; ELEKTRA ENTERTAINMENT GROUP INC.; INTERSCOPE RECORDS; LAFACE RECORDS LLC; MOTOWN RECORD COMPANY, L.P.; PRIORITY RECORDS LLC; SONY BMG MUSIC ENTERTAINMENT; UMG RECORDINGS, INC.; VIRGIN RECORDS AMERICA, INC.; and WARNER BROS. RECORDS INC., Plaintiffs, v. LIME WIRE LLC; LIME GROUP LLC; MARK GORTON; GREG BILDSON; and M.J.G. LIME WIRE FAMILY LIMITED PARTNERSHIP, Defendants. TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that as soon as counsel may be heard before the Honorable Kimba M. Wood in Courtroom 15B, United States Courthouse, 500 Pearl Street, New York, New York, all Plaintiffs in Case No. 06 Civ. 05936 ("Plaintiffs") will and hereby do move the Court pursuant to Federal Rule of Civil Procedure Rules 64 and 65 for entry of a preliminary injunction enjoining Defendants, and anyone acting in concert with them, from transferring or otherwise disposing of any existing or future assets in their possession, custody, or control, as described in greater detail in the Proposed Order submitted concurrently herewith. PLEASE TAKE FURTHER NOTICE that this Motion is based on the Notice of Motion, Motion and the accompanying Memorandum of Points and Authorities, the Declaration of Kelly M. Klaus, and any Reply Memorandum in support, the court records and files (including the 06 Civ. 05936 (KMW) ECF CASE NOTICE OF MOTION AND MOTION OF PLAINTIFFS FOR PRELIMINARY INJUNCTION FREEZING DEFENDANTS' ASSETS -1- Court's Amended Order on the parties' summary judgment motions dated May 25, 2010), and upon such other evidence and argument that may be offered at the hearing on the Motion. Dated: June 7, 2010 Los Angeles, CA Respectfully submitted /s/ Kelly M. Klaus Kelly M. Klaus (pro hac vice) Attorney for Plaintiffs Munger, Tolles & Olson LLP 355 South Grand Avenue, 35th Floor Los Angeles, CA 90071-1560 (213) 683-9100 (213) 687-3702 (Fax) -2-