Free Application for Writ of Garnishment - District Court of Connecticut - Connecticut

Case 3:02-cv-02009-TPS

Document 25

Filed 03/04/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ____________________________________ JOHN W. BLASSINGAME, JR. ADMINISTRATOR OF THE ESTATE OF JOHN W. BLASSINGAME Plaintiff, : : : : : V. : : YALE UNIVERSITY : Defendant. : ____________________________________

CIVIL ACTION NO.: 302CV02009(CFD) MARCH 3, 2004

APPLICATION FOR TEMPORARY INJUNCTION The plaintiff respectfully represents to this Court: 1He is the plaintiff in the above-captioned case requesting this Court to enjoin the defendant Yale University from selling and distributing any of The Frederick Douglass Papers and that all proceeds from any and all sales shall be held in escrow pending the resolution of the case, and to refrain from negotiating with any and all entities and individuals to continue work on the project, and to refrain from using the "John W. Blassingame" name in all publishing. 2The defendant, Yale University, through Yale University Press has engaged in copyright infringement and failed to pay royalties and recognize the rights of the decedent's heirs, and improperly retained the royalties generated by the sale of "The Frederick Douglass Papers." The defendant continues to engage in these actions. 3The defendant, Yale University's actions are wrong, illegal and in violation of Federal law. 4The defendant, Yale University's aforementioned actions, if not restrained will cause serious irreparable harm to the plaintiff John W. Blassingame,

Case 3:02-cv-02009-TPS

Document 25

Filed 03/04/2004

Page 2 of 2

Jr., causing him and the estate incalculable damages and/or cannot be compensated in a monetary way. WHEREFORE, the plaintiff, John W. Blassingame, Jr. requests and moves this Court to issue a temporary injunction, restraining and enjoining the defendant from selling and distributing any of The Frederick Douglass Papers, from granting any permission for the use of The Frederick Douglass Papers and that all proceeds from any and all sales shall be held in escrow pending the resolution of the case, and to refrain from negotiating with any entities or individuals to continue work on the project, and to refrain from using the "John W. Blassingame" name in all publishing. THE PLAINTIFF JOHN W. BLASSINGAME, JR.

BY: IKECHUKWU UMEUGO HIS ATTORNEY UMEUGO & ASSOCIATES, P.C. 620 BOSTON POST ROAD WEST HAVEN, CT 06516 (203)931-2680; FED.BAR#Ct04536 CERTIFICATION This is to certify that a copy of the foregoing was mailed, postage prepaid, on the abovewritten date, to: Patrick M. Noonan, Esq. Delaney, Zemetis, Donahue, Durham & Noonan, P.C. 741 Boston Post Road Guilford, CT 06437