Taylor Swift v. Malcolm Matthews, et al

Filing 66

MOTION to Extend Time Period and Supplement Locations Identified in Preliminary Injunction and Order of Seizure of Counterfeit Goods re 33 Order by Taylor Swift. (Attachments: # 1 Exhibit Declaration of Francisco Javier Dominguez, # 2 Proposed Order)(Rose, Natalya)

Taylor Swift v. Malcolm Matthews, et al

Doc. 66

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE IN NASHVILLE

TAYLOR SWIFT, Plaintiff v. MALCOLM MATTHEWS, et al., Defendants

Civil Action No. 3:09-0442 Judge Wiseman Magistrate Judge Griffin FILED UNDER SEAL

MOTION TO EXTEND TIME PERIOD AND SUPPLEMENT LOCATIONS IDENTIFIED IN PRELIMINARY INJUNCTION AND ORDER OF SEIZURE OF COUNTERFEIT GOODS

Plaintiff Taylor Swift ("Plaintiff"), by and through her undersigned counsel, respectfully requests that the Court extend the time period and supplement locations identified in the Preliminary Injunction and Order of Seizure of Counterfeit Goods entered by this Court on June 17, 2009 (Document 12) to encompass additional dates and venues for Plaintiff's 2009 "Fearless" Tour. As grounds for this Motion, Plaintiff submits: 1. Declaration of Mr. Dominguez made in support of this Motion (Exhibit A); 2. Proposed Order Supplementing Preliminary Injunction and Order of Seizure of Counterfeit Goods (Exhibit B); and 3. Plaintiff's Memorandum of Law, in accordance with Local Rule 7.01(a).

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Respectfully submitted, /s/ Natalya L. Rose W. Michael Milom (No. 002803) David S. Crow (No. 020699) Natalya L. Rose (No. 021701) MILOM JOYCE HORSNELL CROW PLC 3310 West End Avenue, Suite 610 Nashville, Tennessee 37203 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff Taylor Swift

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CERTIFICATE OF SERVICE I hereby certify that service of the foregoing Plaintiff's Motion to Extend Time Period and Supplement Locations Identified in Preliminary Injunction and Order of Seizure of Counterfeit Goods is being accomplished through delivery by U.S. Mail, this 2nd day of October, 2009, upon the following:

Martin D. Quattlebaum 8556 Kendrick Road Jonesboro, GA 30126 Robert Vincent Estronza 1281 Brockett Road Clarkston, GA 30021 Mervin A. Brown 1627 Carnegre St., Apt. B Columbia, SC 29204-1472 Vance William Hill 6169 Charring Cross Court Lithonia, GA 30058 Eric Lopp 153-20 123 Ave. Jamaica, NY 11434 Vernando Smith 1119 Redantrian Court Stn Mtn, GA 30088 Jeffrey Watkins 667 Westwood Drive Lexington, SC 29073-8038

/s/ Natalya L. Rose Natalya L. Rose

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