Southern California Darts Association v. Southern California Darts Association Inc et al

Filing 8

NOTICE OF MOTION AND MOTION for Preliminary Injunction re Re Trademark Infringement.. If this is filed during normal business hours, please contact the courtroom deputy assigned to the judge. If you are filing this document after 5:00 Monday through Friday, on a weekend or holiday, and need immediate judicial review, please call 213-894-2485 to advise that a Preliminary Injunction has been electronically filed. Failure to call the courtroom deputy, or the after hours filing contact number, may result in a delay of judicial review. Motion filed by PLAINTIFF Southern California Darts Association. Motion set for hearing on 4/16/2012 at 09:00 AM before Judge R. Gary Klausner. (Attachments: # 1 Memorandum, # 2 Declaration of Naomi Straus, # 3 Declaration of Matthew Canale, # 4 Declaration of L. David Irete, # 5 Exhibit of L. David Irete (Part 1 of 4), # 6 Exhibit of L. David Irete (Part 2 of 4), # 7 Exhibit of L. David Irete (Part 3 of 4), # 8 Exhibit of L. David Irete (Part 4 of 4), # 9 Appendix, # 10 Proposed Order, # 11 Proof of Service)(Kawahito, James)

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EXHIBIT P EXHIBIT Q EXHIBIT R EXHIBIT S PRESS RELEASE Contact: Publicity Department publicity@southerncaliforniadartsassociation.com FOR IMMEDIATE RELEASE August 29, 2011 Southern California Darts Association, Inc. Returns From The Dead After 34-Years GLENDALE, CALIF. August 29, 2011 — Southern California Darts Association, Inc. (“SCDA”), a California corporation, is returning from the dead, after becoming a “defunct corporation” 34-years ago. SCDA will be operating in Southern California, predominantly in Los Angeles and Orange County. League signups will commence in November 2011 and the first matches will be held in January 2012. Southern California Darts Association was organized in the early 60s and incorporated on October 19, 1966. By all accounts, the association operated as a lawful California corporation until March 1, 1977, when it was suspended by the California Franchise Tax Board. Since the first day of March in ’77, SCDA operated illegally throughout many local pubs in the Los Angeles area until the association was resurrected and brought back to legal standing on January 3, 2011, by Dino M. Zaffina, the corporation’s President and CEO. The “defunct” Southern California Darts Association, Inc. of old operated under the guise of being a nonprofit organization. Based on all relevant public records the old SCDA never established 501(c)(3) status with the Internal Revenue Service. The revived SCDA is now a legal and “for profit” corporation owned and operated by the corporation’s shareholders. Based on the new and legal Southern California Darts Association, Inc., the “illegal” SCDA will no longer be operating anywhere in the United States of America. And, the men who claim to be board members of SCDA are devoid of any power over SCDA business affairs, since none of them are board members or officers of the legal SCDA. Southern California Darts Association, Inc. will be providing dart enthusiasts with the most exciting dart leagues and tournaments ever promoted. During league matches and tournaments, the top shooters will stand to win money and prizes for their achievements. All business establishments who provide a venue for SCDA shooters, will be given the first ever opportunity to profit from league dart matches and tournaments. “Shoot well!”

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