Case 4:06-cv-00685-ERW

Document 10

Filed 05/24/2006

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
DAVID ICKE and BRIDGE OF LOVE UK, )
)
Plaintiffs,
)
)
vs.
)
)
ROYAL ADAMS, an individual, BRIDGE )
OF LOVE, a registered fictitious name
)
and ROYAL PERSONNEL, INC.,
)
a Missouri corporation,
)
)
Defendants.
)

Case No.: 4-06-cv-00685-ERW

PLAINTIFFS APPLICATION FOR A TEMPORARY RESTRAINING ORDER

AND ORDER TO SHOW CAUSE RE: PRELIMINARY INJUNCTION
To:

DEFENDANTS ROYAL ADAMS, BRIDGE OF LOVE AND ROYAL PERSONNEL,

INC. AND THEIR ATTORNEY:
PLEASE TAKE NOTICE that on May 24, 2006, at the hour of 3:00 p.m., in the

Courtroom of the Honorable E. Richard Webber, United States District Judge, at the Thomas F.
Eagleton Courthouse, 111 S. 10th Street, Courtroom/Suite 12, St. Louis, Missouri 63102,
Plaintiffs David Icke and Bridge of Love UK will and do hereby apply for:
1.

A Temporary Restraining Order, pending issuance of Preliminary Injunction:

A.

Enjoining Defendants Royal Adams, Bridge of Love and Royal Personnel,

Inc., as well as any of their officers, directors, agents, servants, employees, representatives,
affiliates, subsidiaries, and all persons and entities in active concert and participation with them
who receive actual notice of this Order by personal service or otherwise, including but not
limited to Patterson Printing and Bookworld Companies (who print and distribute the
copyrighted works for sale to the public), from continuing to print, advertise, distribute, offer for
sale, sell, or otherwise alienate the copyrighted works as evidenced by the Certificates of

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Registration annexed hereto and identified thereon as David Ickes Works, or to participate or
assist in any such activity; and
B.

Directing Defendants Royal Adams, Bridge of Love and Royal Personnel,

Inc., as well as any of their officers, directors, agents, servants, employees, representatives,
affiliates, subsidiaries, and all persons and entities in active concert and participation with them
who receive actual notice of this Order by personal service or otherwise, including but not
limited to Patterson Printing and Bookworld Companies (who have printed, advertised,
distributed, offered for sale, sold or otherwise alienated the copyrighted works to the general
public), to place into an escrow account all revenues received since on or after April 10, 2006, by
any of them in connection with the printing, advertising, distributing, offering for sale, selling, or
otherwise alienating David Ickes Works.
2.

An Order To Show Cause re: Preliminary Injunction:

A. Enjoining Defendants Royal Adams, Bridge of Love and Royal Personnel,

Inc., as well as any of their officers, directors, agents, servants, employees, representatives,
affiliates, subsidiaries, and all persons and entities in active concert and participation with them
who receive actual notice of this Order by personal service or otherwise, including but not
limited to Patterson Printing and Bookworld Companies (who have printed, advertised,
distributed, offered for sale, sold or otherwise alienated the copyrighted works to the general
public), from continuing to print, advertise, distribute, offer for sale, sell, or otherwise alienate
the copyrighted works as evidenced by the Certificates of Registration annexed hereto and
identified thereon as David Ickes Works, or to participate or assist in any such activity; and
B. Ordering Defendants Royal Adams, Bridge of Love and Royal Personnel, Inc.,
as well as any of their officers, directors, agents, servants, employees, representatives, affiliates,
subsidiaries, and all persons and entities in active concert and participation with them who
receive actual notice of this Order by personal service or otherwise, including but not limited to
Patterson Printing and Bookworld Companies (who have printed, advertised, distributed, offered
for sale or sold the copyrighted works to the general public), from continuing to print, distribute,

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offer for sale, sell, or otherwise alienate the copyrighted works as evidenced by the Certificates
of Registration annexed hereto and identified thereon as David Ickes Works, to deliver
forthwith to the Clerk of this Court to be impounded during the pendency of this action, all
computer discs and materials relating to David Ickes copyright works; and
C.

Setting the preliminary injunction hearing on this matter ________, 2006,

at ___ _.m.
This motion is based on the First Amended Complaint filed herein, the accompanying
Memorandum In Support Of Plaintiffs Motion For Temporary Restraining Order And For
Preliminary Injunction, the affidavits of David Icke, Shari M. Savitt, Andre Guignon and Mary
Ann L. Wymore, matters that may be presented at the hearing and other matters of which the
Court may take notice.
Dated: May 24, 2006

Respectfully submitted,
/s/ Mary Ann L. Wymore
Mary Ann L. Wymore, E.D. Reg. # 28939
mlw@greensfelder.com
Erika M. Anderson, E.D. Reg. # 506103
ema@greensfelder.com
GREENSFELDER, HEMKER & GALE, P.C.
10 South Broadway, Suite 2000
St. Louis, Missouri 63102
Tel: (314) 241-9090
Fax: (314) 345-5466
Shari M. Savitt (upon pro hac vice application)
John J. Burke, Jr. (upon pro hac vice application)
THELEN REID & PRIEST LLP
875 Third Avenue
New York, New York 10022
Tel: (212) 603-2000
Fax: (212) 603-2001
Attorneys for Plaintiffs
David Icke and Bridge of Love UK

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