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236-304998-18 FILED
TARRANT COUNTY
2/4/2019 11:47 AM
CAUSE NO. 236-304998-18 THOMAS A. WILDER
DISTRICT CLERK
CHARLES DOUGLAS, on behalf § IN THE DISTRICT COURT
of §
TCU PEE WEE YOUTH §
ASSOCIATION, INC. §
Plaintiff,
§
v. §
§
EARL STEWART, RAYFORD §
ROCHON, CEDRIC DORSEY SR., § 236th JUDICIAL DISTRICT
ADRIAN DORSEY, d/b/a TCU §
PEE WEE YOUTH FOOTBALL §
ASSOCIATION, §
d/b/a TCU SPORTS §
ASSOCIATION, §
d/b/a TCU PEE WEE FOOTBALL §
ASSOCIATION, and NORTH §
TEXAS FOOTBALL YOUTH §
ASSOCIATION § TARRANT COUNTY, TEXAS
Defendants. §
______________________________________________________________________________
SUMMARY OF RELIEF REQUESTED
______________________________________________________________________________
On this day, Charles Douglas, on behalf of TCU Pee Wee Youth Association,
Inc. (“Plaintiff”) presented an Application for Temporary Injunction and Order
Setting Hearing for Permanent Injunction (“Application”) against Earl Stewart,
Rayford Rochon, Cedric Dorsey Sr., Adrian Dorsey, d/b/a TCU Pee Wee Youth
Football Association, d/b/a TCU Sports Association, d/b/a TCU Pee Wee Football
Association, and North Texas Football Youth Association (“Defendants”).
Temporary Injunction Page 1 of 4
The summary of Plaintiff’s relief requested is as follows:
1. Court order Defendants to turn over all bank accounts and financial
information to TCU Pee Wee Youth Association, Treasurer, Michelle
Douglas;
2. Court order Defendants to turn over all member, vendors, and player
records to TCU Pee Wee Youth Association, Treasurer, Michelle Douglas;
3. Court order Defendants to cease the use of the d/b/a TCU Pee Wee Football
and any derivatives, including Tarrant County United Youth Sports
Association aka Youth Sports Association;
4. Court order Defendants to cease the use of any d/b/a, which induces or
attempts to induce a member of the public to use the services of TCU Pee
Wee Youth Association or its derivatives, including Tarrant County United
Youth Sports Association aka Youth Sports Association; and
5. Court order Defendants to stop operating all football teams until the
dispute is resolved.
Plaintiff requests the court make the following FINDINGS:
1. The pleadings are in the correct form and contain all the allegations
required by the law, and that all the prerequisites for the issuance of the
temporary restraining order have been met.
2. This Court bases its findings on the evidence presented in support of the
Application, including Exhibit “A” attached thereto. Based on this evidence
Plaintiff request this Court find as follows:
Temporary Injunction Page 2 of 4
3. Defendants should be enjoined from any communication, written or oral,
under the d/b/a TCU Pee Wee Football or any derivative, including Tarrant
County United Youth Sports Association aka Youth Sports Association,
which induces or attempts to induce a member of the public to use the
services of the license holder or service provider;
4. Defendants should be enjoined of the use of the d/b/a TCU Pee Wee Football
or any derivative, including Tarrant County United Youth Sports
Association aka Youth Sports Association, in any publications, radio or
television broadcasts;
5. Defendants should be enjoined from the use of the d/b/a TCU Pee Wee
Football or any and all derivatives, including Tarrant County United Youth
Sports Association aka Youth Sports Association, in any and all electronic
media including electronic mail, text messages, social networking websites,
and the internet;
6. Defendants should be enjoined from the use of the d/b/a TCU Pee Wee
Football or any derivatives, including Tarrant County United Youth Sports
Association aka Youth Sports Association on any business stationary,
business cards, signs, and billboards;
7. Defendants should be enjoined from soliciting members using the d/b/a
TCU Pee Wee Football or any derivatives, including Tarrant County United
Youth Sports Association aka Youth Sports Association;
8. Defendant should be enjoined from soliciting vendors using the d/b/a TCU
Temporary Injunction Page 3 of 4
Pee Wee Football or any derivatives, including Tarrant County United
Youth Sports Association aka Youth Sports Association;
9. Defendants should be enjoined from discussing this litigation on online or
on social media, such as Facebook, Linkedin, Twitter, or any other social
media platforms;
10. Defendants should be enjoined from the open use of Plaintiff’s marks,
colors, and collateral;
11. Defendants should be enjoined from harassing, unprofessional
communication with Plaintiffs, Plaintiffs’ family members, acquaintances,
friends and past, present, future employer or co-workers, in person or by
telephone, social media, electronic mail, postal service, parcel service or any
other form of communication or contact for the purposes of harassment of
the other party; and
12. Defendants should be enjoined from the destruction or deletion of any
documents, evidence or record, electronic or otherwise, that relates to any
of the matters implicated by this lawsuit or pertaining to Plaintiffs,
including but not limited to all hard drives, backups, archives, and other
possible sources of stored metadata or information.
Temporary Injunction Page 4 of 4
Preview
236-304998-18 FILED TARRANT COUNTY 2/4/2019 11:47 AM CAUSE NO. 236-304998-18 THOMAS A. WILDER DISTRICT CLERK CHARLES DOUGLAS, on behalf § IN THE DISTRICT COURT of § TCU PEE WEE YOUTH § ASSOCIATION, INC. § Plaintiff, § v. § § EARL STEWART, RAYFORD § ROCHON, CEDRIC DORSEY SR., § 236th JUDICIAL DISTRICT ADRIAN DORSEY, d/b/a TCU § PEE WEE YOUTH FOOTBALL § ASSOCIATION, § d/b/a TCU SPORTS § ASSOCIATION, § d/b/a TCU PEE WEE FOOTBALL § ASSOCIATION, and NORTH § TEXAS FOOTBALL YOUTH § ASSOCIATION § TARRANT COUNTY, TEXAS Defendants. § ______________________________________________________________________________ SUMMARY OF RELIEF REQUESTED ______________________________________________________________________________ On this day, Charles Douglas, on behalf of TCU Pee Wee Youth Association, Inc. (“Plaintiff”) presented an Application for Temporary Injunction and Order Setting Hearing for Permanent Injunction (“Application”) against Earl Stewart, Rayford Rochon, Cedric Dorsey Sr., Adrian Dorsey, d/b/a TCU Pee Wee Youth Football Association, d/b/a TCU Sports Association, d/b/a TCU Pee Wee Football Association, and North Texas Football Youth Association (“Defendants”). Temporary Injunction Page 1 of 4 The summary of Plaintiff’s relief requested is as follows: 1. Court order Defendants to turn over all bank accounts and financial information to TCU Pee Wee Youth Association, Treasurer, Michelle Douglas; 2. Court order Defendants to turn over all member, vendors, and player records to TCU Pee Wee Youth Association, Treasurer, Michelle Douglas; 3. Court order Defendants to cease the use of the d/b/a TCU Pee Wee Football and any derivatives, including Tarrant County United Youth Sports Association aka Youth Sports Association; 4. Court order Defendants to cease the use of any d/b/a, which induces or attempts to induce a member of the public to use the services of TCU Pee Wee Youth Association or its derivatives, including Tarrant County United Youth Sports Association aka Youth Sports Association; and 5. Court order Defendants to stop operating all football teams until the dispute is resolved. Plaintiff requests the court make the following FINDINGS: 1. The pleadings are in the correct form and contain all the allegations required by the law, and that all the prerequisites for the issuance of the temporary restraining order have been met. 2. This Court bases its findings on the evidence presented in support of the Application, including Exhibit “A” attached thereto. Based on this evidence Plaintiff request this Court find as follows: Temporary Injunction Page 2 of 4 3. Defendants should be enjoined from any communication, written or oral, under the d/b/a TCU Pee Wee Football or any derivative, including Tarrant County United Youth Sports Association aka Youth Sports Association, which induces or attempts to induce a member of the public to use the services of the license holder or service provider; 4. Defendants should be enjoined of the use of the d/b/a TCU Pee Wee Football or any derivative, including Tarrant County United Youth Sports Association aka Youth Sports Association, in any publications, radio or television broadcasts; 5. Defendants should be enjoined from the use of the d/b/a TCU Pee Wee Football or any and all derivatives, including Tarrant County United Youth Sports Association aka Youth Sports Association, in any and all electronic media including electronic mail, text messages, social networking websites, and the internet; 6. Defendants should be enjoined from the use of the d/b/a TCU Pee Wee Football or any derivatives, including Tarrant County United Youth Sports Association aka Youth Sports Association on any business stationary, business cards, signs, and billboards; 7. Defendants should be enjoined from soliciting members using the d/b/a TCU Pee Wee Football or any derivatives, including Tarrant County United Youth Sports Association aka Youth Sports Association; 8. Defendant should be enjoined from soliciting vendors using the d/b/a TCU Temporary Injunction Page 3 of 4 Pee Wee Football or any derivatives, including Tarrant County United Youth Sports Association aka Youth Sports Association; 9. Defendants should be enjoined from discussing this litigation on online or on social media, such as Facebook, Linkedin, Twitter, or any other social media platforms; 10. Defendants should be enjoined from the open use of Plaintiff’s marks, colors, and collateral; 11. Defendants should be enjoined from harassing, unprofessional communication with Plaintiffs, Plaintiffs’ family members, acquaintances, friends and past, present, future employer or co-workers, in person or by telephone, social media, electronic mail, postal service, parcel service or any other form of communication or contact for the purposes of harassment of the other party; and 12. Defendants should be enjoined from the destruction or deletion of any documents, evidence or record, electronic or otherwise, that relates to any of the matters implicated by this lawsuit or pertaining to Plaintiffs, including but not limited to all hard drives, backups, archives, and other possible sources of stored metadata or information. Temporary Injunction Page 4 of 4