Bray et al v QFA Royalties

Filing 2

MOTION for Preliminary Injunction and Request for Forthwith Hearing by Plaintiffs Ali Majed, Q Food Service, Inc., Brad Fix, Jan Fix, BJ and F LLC, Richard Newkirk, Maureen Newkirk, David Newkirk, Newkirk Enterprises, Inc., R&M Enterprises LLP, Chris Bray, Hakim Abid, Allison Abid, Daniel G. Carter, Jr, Jody L. Carter, Daniel G. Carter, Sr, Madeleine Carter, Carter Group LLC, Carter Group Roseville LLC, Glenn Keane, Sabine Bray, Anne Keane, LKB LLC, David Tate, Big Little Property Investments, CTH Investments, Training Pros Inc., Jehad Majed. (llr, )

Bray et al v QFA Royalties

Doc. 2

Case 1:06-cv-02528-JLK

Document 2

Filed 12/15/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. ___________________________ CHRIS BRAY, et al. Plaintiffs, v. QFA ROYALTIES LLC, a Delaware limited liability company, Defendant. ______________________________________________________________________________ MOTION FOR PRELIMINARY INJUNCTION AND REQUEST FOR FORTHWITH HEARING ______________________________________________________________________________ COME NOW the Plaintiffs, by and through their counsel, Gregory R. Stross, and move this Court for an Order, pursuant to Fed.R.Civ.P. 65, preliminarily restraining or enjoining the defendant QFA Royalties LLC: -- from terminating the plaintiffs' franchise agreements or otherwise interfering with the continuing operations of the Plaintiffs' Quiznos restaurants based upon any acts taken by one or more plaintiffs with relation to the posting of information on the Toasted Subs Franchise Association website related to the death of Bhupinder Baber, or the solicitation of charitable contributions for the support of Bhupinder Baber's immediately family members;

Dockets.Justia.com

Case 1:06-cv-02528-JLK

Document 2

Filed 12/15/2006

Page 2 of 3

-- further that the Court enter an Order restraining or enjoining the Defendant's agents, employees, associated companies, and affiliated companies to include any mandated or designated suppliers of Quiznos' products from taking any actions that would interfere with the continued operations of Plaintiffs' Quiznos restaurants, based upon any acts taken by one or more plaintiffs in relation to the posting of information on the Toasted Subs Franchise Association website, related to the death of Bhupinder Baber, or the solicitation of charitable contributions for the support of Bhupinder Baber's immediately family members. Plaintiffs request the Court conduct a forthwith hearing on the motion. Due notice of this motion and the request for hearing has been given to Defendant by hand-delivering copies of the complaint, motion and brief in support of the motion, to Defendant's registered agent and by delivering copies of these documents by Federal Express to Defendants' counsel, Fredric A. Cohen, and by delivering copies of these documents by hand directly to Defendants' place of business at 1475 Lawrence Street, Suite 400, Denver, Colorado. DATED: December 15, 2006 Denver, Colorado

2

Case 1:06-cv-02528-JLK

Document 2

Filed 12/15/2006

Page 3 of 3

GREGORY R. STROSS ATTORNEY AT LAW By: s/Gregory R. Stross Gregory R. Stross 2940 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 Telephone [phone] Facsimile 303-572-5111 [e-mail]

3