Carreon v. Inman et al

Filing 20

Ex Parte Application For Temporary Restraining Order and Order to Shaw Cause Re Preliminary Injunction filed by Charles Carreon. (Attachments: # 1 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION, # 2 Declaration OF CHARLES CARREON IN SUPPORT OF EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION, # 3 Exhibit (S) A - K TO THE DECLARATION OF CHARLES CARREON IN SUPPORT OF EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION, # 4 Proposed Order EX PARTE TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUCNTION)(Carreon, Charles) (Filed on 6/30/2012)

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1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 NORTHERN DISTRICT OF CALIFORNIA 8 9 10 11 12 13 14 15 16 17 18 CHARLES CARREON ) ) Plaintiff, ) ) vs. ) ) MATTHEW INMAN, INDIEGOGO, INC., ) NATIONAL WILDLIFE FEDERATION, ) AND AMERICAN CANCER SOCIETY, ) and Does 1 – 100, ) ) Defendants, ) ) and ) ) KAMALA HARRIS, Attorney General of the ) State of California, ) ) A Person To Be Joined If ) Feasible Under F.R.Civ.P. 19. ) ) Case No.: CV-12-3112-EMC [PROPOSED] EX PARTE TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION 19 ORDER 20 21 TO DEFENDANTS INDIEGOGO, INC. AND MATTHEW INMAN: 22 YOU ARE EACH ORDERED TO SHOW CAUSE at ____.m., on July __, 2012, 23 or as soon thereafter as counsel may be heard, in Courtroom ____, at the United 24 States Courthouse, 450 Golden Gate Avenue, San Francisco, California 25 _____________________, why (1) Indiegogo, Inc. (“Indiegogo”) should not be 26 restrained and enjoined pending trial from transferring the $220,014 now in the 27 possession of Indiegogo, Inc. (the “Charitable Fund”) to Matthew Inman (“Inman”), or to 28 any other person or entity, (2) a constructive charitable trust should not be imposed upon ______________________________________________ _______________________________ [PROPOSED] TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION, Page 1 of 2 1 the Charitable Fund, and (3) the Charitable Fund should not be deposited in a blocked 2 account pending distribution of the Charitable Fund to the designated beneficiaries of the 3 Bear Love campaign, to wit, the defendants, the American Cancer Society, and the 4 National Wildlife Federation. 5 PENDING HEARING on the above Order to Show Cause, Indiegogo is HEREBY 6 RESTRAINED AND ENJOINED from disbursing the Charitable Fund, or any portion 7 thereof to Inman. 8 9 10 IT IS FURTHER ORDERED that this Order shall be served on Indiegogo no later than ____ days before the day set for hearing, with proof of service to be filed no later than ____ days before the date set for the hearing. 11 12 IT IS SO ORDERED. 13 14 Dated: July __, 2012 Hon. Edward M. Chen UNITED STATES DISTRICT COURT JUDGE 15 16 17 18 19 20 21 22 Respectfully submitted this 28th day of June, 2012, by: s/Charles Carreon CHARLES CARREON, ESQ. (127139) 2165 S. Avenida Planeta Tucson, Arizona 85710 Tel: 520-841-0835 Fax: 520-843-2083 Email: chas@charlescarreon.com 23 Attorney for Plaintiff Pro Se 24 25 26 27 28 ______________________________________________ _______________________________ [PROPOSED] TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE PRELIMINARY INJUNCTION, Page 2 of 2

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