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Counterfeit Product Cases

Plaintiffs in cases alleging counterfeit products and joining many defendants (also known as Schedule A cases) should use the template proposed orders linked below to assist the Court in reviewing motions for: (1) temporary restraining orders; (2) preliminary injunctions; and (3) default judgments. Plaintiffs should create a redline comparison of their proposed order against the relevant template and submit that redline comparison along with their proposed order to the Court's proposed-order email box. A proposed order's conformity with the template does not imply that the associated motion will be granted. Plaintiffs should be prepared to explain any differences between their proposed orders and the templates.

Judge Alonso will presumptively require a bond of $1,000 per defendant. Plaintiffs should inform the Court of any circumstances that make such a bond inappropriate.

Temporary Restraining Order Template
Preliminary Injunction Template
Default Judgment Template