TaubmanSucks.com
WillowBendSucks.com
WillowBendMallSucks.com
ShopsAtWillowBendSucks.com
TheShopsAtWillowBendSucks.com
GiffordKrassGrohSprinkleSucks.com

[ Home Page | Condensed Version | The Movie | News | Blogs | Feedback / Mail List ]


Act 16: Taubman Tries To Kill This Site

On October 15, 2001, flush with the victory of getting the judge to issue a Preliminary Injunction against me, Ms. Greenberg filed a motion to amend the injunction to include this site.

On this and the following pages, I've reproduced the motion, the brief in support of the motion, the certificate of service, and a "Proposed Modified Order Granting Preliminary Injunction" that Ms. Greenberg thoughtfully provided to the judge, in case he was too busy to make his own decision and put it in writing. ("Just sign here, Your Honor...")

(Note: I have not included the attachments to this motion, nor have I included text versions of the "Certificate of Service" or the "Table of Authorities.")


UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

THE TAUBMAN COMPANY LIMITED
PARTNERSHIP, Plaintiff,

v. WEBFEATS and HENRY MISHKOFF,
Defendants.

Civil Action No. 01-72987
Honorable Lawrence P. Zatkoff
Magistrate Judge Komives


EXPEDITED MOTION TO AMEND PRELIMINARY INJUNCTION

ON OCTOBER 11, 2001, this Court granted Plaintiff's motion for preliminary injunction with the order attached hereto as Exhibit A, prohibiting Defendants from continuing to operate the website www.shopsatwillowbend.com. At the time the injunction was entered, Defendants' numerous additional websites incorporating various of Plaintiffs marks were not operational.

These websites are:

  • willowbendsucks.com
  • willowbendmallsucks.com
  • theshopsatwillowbendsucks.com
  • taubmansucks.com
  • shopsatwillowbendsucks.com

Since the entry of the injunction, Defendants have made these numerous sites operational, and, as promised in its previously filed brief, the sites are used to defame Plaintiff, its malls, its lawyers, and to publicize the settlement discussions that were undertaken by the parties in an attempt to resolve the dispute in this case. The first page (only) of the website is attached to this motion as Exhibit B. The full printout from the website is not attached hereto in an effort to minimize the distribution of Defendants' defamatory and confidential material, but can be accessed by the Court at any of Defendants' listed websites.

Plaintiff respectfully submits that these sites are all based on domain names incorporating Plaintiff's marks, and their use constitutes continued, unauthorized use by Defendants of the marks at issue in this case. In order to prevent this ongoing use by Defendants of Plaintiff's marks, Plaintiff requests this Court to modify the relevant language of its previously entered injunction to read all "Defendants are hereby RESTRAINED and ENJOINED from using any Internet domain name which incorporates the marks "THE SHOPS AT WILLOW BEND" or "TAUBMAN" or any other domain name incorporating elements of these marks, and to remove any related websites which use these domain names from the Internet. This order expressly applies to the following domain names:

  • www.shopsatwillowbend.com
  • www.shopsatwillowbendsucks.com
  • www.willowbendsucks.com
  • www.theshopsatwillowbendsucks.com
  • www.taubmansucks.com
  • www.willowbendmallsucks.com

In further support of this motion, Plaintiff relies on the accompanying brief.

Respectfully submitted,

Julie A. Greenberg (P38299)
GIFFORD, KRASS, GROH, SPRINKLE,
ANDERSON & CITKOWSKI, P.C.
280 N. Old Woodward Ave., Suite 400
Birmingham, Michigan 48009
(248)647-6000

Attorneys for Plaintiff

Dated: October 15, 2001

View the Original Motion (in a separate window)


Next: The Brief

[ Home Page | Condensed Version | The Movie | News | Blogs | Feedback / Mail List ]

©2001 Hank Mishkoff
All rights reserved.