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AIA 26 2008
ohn A. Clee, kxecutve
By: Flores, Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
ROBIN SINGH EDUCATIONAL Case No. BC 330 098
SERVICES, INC., d.b.a. TestMasters, a and BC 347 174)
California corporation,
Consolidated with BC 346 066
‘ORDER TO SHOW CAUSE RE
PRELIMINARY PROHIBITORY INJUNCTION
Plaintiff, AND FOR TEMPORARY RESTRAINING ORDER
vs.
Hearing Date: August 28, 2008
BLUEPRINT TEST PREPARATION Time: 8:30 a.m.
LLC, a limited liability company, TRENT | Dept.: 307
TET, an individual, JUSTIN CAPUANO,
an individual, MATTHEW RILEY, an | Date Action Filed: March 10, 2005
individual, JODI TRIPLET, an’ ‘Trial Date: October 28, 2008
individual, COURTNEY MARTIN, an
individual, and DOES 1 through 20, Hon. William F. Highberger, Judge Presiding
inclusive,
Defendants.
AND CONSOLIDATED ACTIONS.
[PROPOSED] ORDER TO SHOW CAUSE RE PRELIMINARY PROMIBITORY INJUNCTION AND TEMPORARY
RESTRAINING ORDER||derived from TestMasters Course Materials, including without limitation, the current version of the
The Court, having considered the Ex Parte Application by Plaintiff Robin Singh Educational
Services, Inc. dba TestMasters ("Plaintiff" or "TestMasters") For Order To Show Cause Re
Preliminary Prohibitory Injunction and For Temporary Restraining Order (the “Injunction |
Application"), and having considered the evidence in favor of the Injunction Application and)
argument of counsel, the Court hereby grants Plaintifi's Injunction Application and hereby enters the
following orders against Defendants Blueprint Test Preparation LLC, Trent Teti, Justin Capuano, |
‘Matthew Riley and Jodi Triplett, and each of them (“Defendants”), as follows |
ORDER TO SHOW CAUSE
The Court orders Defendants fo show enuse shy a preliminary probibitry injunction shoud
not be entered preventing Defendants,/and their agents, servants and employees, and all persons
acting under, in concert wit, or for them (either drgtly or indirectly), from smelt doom
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from directly or indirectly engaging in any of the following conduct:
1. Using, selling, or otherwise distributing those certain LSAT test preparation course
materials (or any portion of them), developed or created by any of the Defendants based on or with
the use of any portion of the TestMasters Course Materials, or any course materials substantially
Blueprint course materials, all superseded or prior versions of the Blueprint course materials, and any |
future version of the Blueprint course materials which builds on or uses any portion of TestMasters
‘Course Materials or any earlier version of the Blueprint course materials, or any other version of such
course materials (or any portion of them) substantially derived from TestMasters Course Materials in
any form (electronic or paper) (the “Illicit Materials”) in any manner.
2. Using, selling, or otherwise distributing on the intemet or by other electronic |
communications or electronic media the Illicit Materials, defined at § 1, in any online video course or |
courses offered by Blueprint or offered by any of the Defendants, their agents, servants and
employees, and all persons acting under, in concert with, or for them (either directly or indirectly).
3. Using, selling, or otherwise distributing the Illicit Materials, defined at { 1, in ay]
Podcast or podcasts offered by Blueprint or offered by any of the Defendants, their agents, servants |
Ae
[PROPOSED] ORDER TO SHOW CAUSE RE PRELIMINARY PROHIBITORY INJUNCTION AND TEMPORARY
RESTRAINING ORDER.x
\Jand employees, and all persons acting under, in concert with, or for them (either directly or
||other downloadable method, including videotaped tutorials or classes and any “new media” not
indirectly).
4. Using, selling, or otherwise distributing the Illicit Materials, defined at 1, in PDF |
form or other electronic form able to be copied from the internet, including, without limitation, any
form that may be transmitted via a file-sharing website, by Blueprint, or by any of the Defendants,
their agents, servants and employees, and all persons acting under, in concert with, or for them (either
directly or indirectly).
5. Using, selling, or otherwise distributing the Illicit Materials, defined at 1, by any
already covered by 2, 3 and 4 above (such as online posts, emails, or other downloadable uses of
the Illicit Materials) offered by Blueprint, or by any of the Defendants, their agents, servants and
employees, and all persons acting under, in concert with, or for them (either directly or indirectly).
6. Directly or indirectly exploiting, either commercially or otherwise, the Illicit Materials |
(defined at 411 above), in any manner. cerpantonn ame, EleCom ae A
ol ‘LedetsmarnnstneeivoronDEn ve eang tech nse
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TEMPORARY RESTRAINING ORDER
Defendant Blueprint and all co-defendants except Ms. Martin are enjoined by this
Temporary Restraining Order to immediately cease providing any downloads via the
internet site or by any other electronic distribution (e.g. CD or DVD) of any course
‘material, practice tests, instruction sessions, tutorials, or anything else which has been
provided on the Blueprint website (as of August 27, 2008 or at any time in the three
months prior) or any similar instructional, training or practice materials relevant to the
LSAT test and any similar test. This TRO does not prohibit Blueprint from using its
website to continue to provide marketing and enrollment services and general
information. This is effective from August 28, 2008 4:20 p.m. through September 12,
2008, 5 p.m.