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342-304998-18 FILED
TARRANT COUNTY
9/30/2021 4:20 PM
CAUSE NO. 342-304998-18 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., § 342ND 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. §
______________________________________________________________________________
ORDER ON TEMPORARY INJUNCTION
______________________________________________________________________________
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 7
The Court makes 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 injunction order have been met.
2. A hearing was held on October 1, 2021. A record of the proceeding was
made. Plaintiff appeared by and through his attorney of record, Joshua
Stewart Graham. Defendants appeared.
3. Defendants should be enjoined from any communication, written or oral,
under the d/b/a TCU Pee Wee Youth Football Association, d/b/a TCU Sports
Association, d/b/a Tarrant County United Youth Sports Association, d/b/a
North Texas Football Youth Association (hereinafter collectively called
“TCU Pee Wee Football”), or any derivative of the name, 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, 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 of the name, in any and all electronic
media including electronic mail, text messages, social networking websites,
and the internet;
Temporary Injunction Page 2 of 7
6. Defendants should be enjoined from the use of the d/b/a TCU Pee Wee
Football or any derivatives of the name, 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 of the name;
8. Defendant should be enjoined from soliciting vendors using the d/b/a TCU
Pee Wee Football or any derivatives of the name;
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, including uniforms that are the same or similar to
Plaintiffs’ uniforms;
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;
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,
Temporary Injunction Page 3 of 7
including but not limited to all hard drives, backups, archives, and other
possible sources of stored metadata or information;
13. Defendants should be enjoined from opening or maintaining any bank
account as TCU Pee Wee Football or any derivative of the name; and
14. Defendants should be enjoined from withdrawing, spending, or otherwise
distributing any money from any bank account, safety deposit box, or by
any financial instrument, money that is held in the name of d/b/a TCU Pee
Wee Football or any derivatives of the name.
The Court ORDERS and ENJOINS Defendants along with their agents,
representatives, employees, independent contractors, attorneys, and those persons in
active concert or participation with them, directly or indirectly, whether acting alone
or in conjunction with, through or for any other person, firm, association, business,
company, or corporation, whether by employment, ownership, consulting
arrangement or otherwise, from making the representations, doing the acts, and
engaging in the following practices in the pursuit and conduct of trade or commerce
within the State of Texas as follows:
1. Defendants are enjoined from any communication, written or oral, under
the d/b/a TCU Pee Wee Youth Football Association, d/b/a TCU Sports
Association, d/b/a Tarrant County United Youth Sports Association, d/b/a North
Texas Football Youth Association (hereinafter collectively called “TCU Pee Wee
Football”), which induces or attempts to induce a member of the public to
use the services of the license holder or service provider;
Temporary Injunction Page 4 of 7
2. Defendants are enjoined of the use of the d/b/a TCU Pee Wee Football or
any derivative of the name, in any publications, radio or television
broadcasts;
3. Defendants are enjoined from the use of the d/b/a TCU Pee Wee Football or
any and all derivatives of the name, in any and all electronic media
including electronic mail, text messages, social networking websites, and
the internet;
4. Defendants are enjoined from the use of the d/b/a TCU Pee Wee Football or
any derivatives of the name, on any business stationary, business cards,
signs, and billboards;
5. Defendants are enjoined from soliciting members using the d/b/a TCU Pee
Wee Football or any derivatives of the name;
6. Defendant are enjoined from soliciting vendors using the d/b/a TCU Pee
Wee Football or any derivatives of the name;
7. Defendants are enjoined from discussing this litigation on online or on
social media, such as Facebook, LinkedIn, Twitter, or any other social
media platforms;
8. Defendants are enjoined from the open use of Plaintiff’s marks, colors, and
collateral, including uniforms that are the same or similar to Plaintiffs’
uniforms;
9. Defendants are enjoined from harassing, unprofessional communication
with Plaintiffs, Plaintiffs’ family members, acquaintances, friends and past,
Temporary Injunction Page 5 of 7
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
10. Defendants are 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.
11. Defendants are enjoined enjoined from opening or maintaining any bank
account as TCU Pee Wee Football or any derivative of the name.
12. Defendants are enjoined from withdrawing, spending, or otherwise
distributing any money from any bank account, safety deposit box, or by
any financial instrument, money that is held in the name of d/b/a TCU Pee
Wee Football or any derivatives of the name.
13. The clerk of the court is directed to issue a show cause notice to Defendants
to appear at the permanent injunction hearing.
14. This Court requires Plaintiffs to post bond in the amount of $_____. The
District Clerk can accept a check or cash from Plaintiffs or Plaintiffs’
counsel or law firm as payment of the bond.
15. The clerk of the court shall issue a Temporary Injunction in conformity with
the law and terms of this order.
Temporary Injunction Page 6 of 7
This Order shall expire on ________________, 20___ at ________o’clock __.m.
Signed on _____________________, 2021 at __________o’clock __.m.
____________________________________
JUDGE PRESIDING
Temporary Injunction Page 7 of 7
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Joshua Graham on behalf of Joshua Graham
Bar No. 24080736
jsg@joshuagraham.com
Envelope ID: 57768043
Status as of 9/30/2021 4:26 PM CST
Associated Case Party: CHARLESDOUGLAS
Name BarNumber Email TimestampSubmitted Status
Joshua Graham eservice@joshuagraham.com 9/30/2021 4:20:26 PM SENT
Joshua Graham jsg@joshuagraham.com 9/30/2021 4:20:26 PM SENT
Associated Case Party: EARLSTEWART
Name BarNumber Email TimestampSubmitted Status
Earl Stewart tycozz@aol.com 9/30/2021 4:20:26 PM SENT
Associated Case Party: RAYFORDROCHON
Name BarNumber Email TimestampSubmitted Status
Rayford Rochon thedjscoobydoo2@yahoo.com 9/30/2021 4:20:26 PM SENT
Associated Case Party: CEDRIC, SRDORSEY
Name BarNumber Email TimestampSubmitted Status
Cedric Dorsey cedric.dorsey@fortworthtexas.gov 9/30/2021 4:20:26 PM SENT
Associated Case Party: ADRIANDORSEY
Name BarNumber Email TimestampSubmitted Status
Adrian Dorsey dorsey102@charter.net 9/30/2021 4:20:26 PM SENT
Associated Case Party: THENORTH TEXAS PEE WEE YOUTH LEAGUE
Name
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Joshua Graham on behalf of Joshua Graham
Bar No. 24080736
jsg@joshuagraham.com
Envelope ID: 57768043
Status as of 9/30/2021 4:26 PM CST
Associated Case Party: THENORTH TEXAS PEE WEE YOUTH LEAGUE
Anthony Chance donnettachance@gmail.com 9/30/2021 4:20:26 PM SENT
Preview
342-304998-18 FILED TARRANT COUNTY 9/30/2021 4:20 PM CAUSE NO. 342-304998-18 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., § 342ND 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. § ______________________________________________________________________________ ORDER ON TEMPORARY INJUNCTION ______________________________________________________________________________ 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 7 The Court makes 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 injunction order have been met. 2. A hearing was held on October 1, 2021. A record of the proceeding was made. Plaintiff appeared by and through his attorney of record, Joshua Stewart Graham. Defendants appeared. 3. Defendants should be enjoined from any communication, written or oral, under the d/b/a TCU Pee Wee Youth Football Association, d/b/a TCU Sports Association, d/b/a Tarrant County United Youth Sports Association, d/b/a North Texas Football Youth Association (hereinafter collectively called “TCU Pee Wee Football”), or any derivative of the name, 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, 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 of the name, in any and all electronic media including electronic mail, text messages, social networking websites, and the internet; Temporary Injunction Page 2 of 7 6. Defendants should be enjoined from the use of the d/b/a TCU Pee Wee Football or any derivatives of the name, 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 of the name; 8. Defendant should be enjoined from soliciting vendors using the d/b/a TCU Pee Wee Football or any derivatives of the name; 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, including uniforms that are the same or similar to Plaintiffs’ uniforms; 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; 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, Temporary Injunction Page 3 of 7 including but not limited to all hard drives, backups, archives, and other possible sources of stored metadata or information; 13. Defendants should be enjoined from opening or maintaining any bank account as TCU Pee Wee Football or any derivative of the name; and 14. Defendants should be enjoined from withdrawing, spending, or otherwise distributing any money from any bank account, safety deposit box, or by any financial instrument, money that is held in the name of d/b/a TCU Pee Wee Football or any derivatives of the name. The Court ORDERS and ENJOINS Defendants along with their agents, representatives, employees, independent contractors, attorneys, and those persons in active concert or participation with them, directly or indirectly, whether acting alone or in conjunction with, through or for any other person, firm, association, business, company, or corporation, whether by employment, ownership, consulting arrangement or otherwise, from making the representations, doing the acts, and engaging in the following practices in the pursuit and conduct of trade or commerce within the State of Texas as follows: 1. Defendants are enjoined from any communication, written or oral, under the d/b/a TCU Pee Wee Youth Football Association, d/b/a TCU Sports Association, d/b/a Tarrant County United Youth Sports Association, d/b/a North Texas Football Youth Association (hereinafter collectively called “TCU Pee Wee Football”), which induces or attempts to induce a member of the public to use the services of the license holder or service provider; Temporary Injunction Page 4 of 7 2. Defendants are enjoined of the use of the d/b/a TCU Pee Wee Football or any derivative of the name, in any publications, radio or television broadcasts; 3. Defendants are enjoined from the use of the d/b/a TCU Pee Wee Football or any and all derivatives of the name, in any and all electronic media including electronic mail, text messages, social networking websites, and the internet; 4. Defendants are enjoined from the use of the d/b/a TCU Pee Wee Football or any derivatives of the name, on any business stationary, business cards, signs, and billboards; 5. Defendants are enjoined from soliciting members using the d/b/a TCU Pee Wee Football or any derivatives of the name; 6. Defendant are enjoined from soliciting vendors using the d/b/a TCU Pee Wee Football or any derivatives of the name; 7. Defendants are enjoined from discussing this litigation on online or on social media, such as Facebook, LinkedIn, Twitter, or any other social media platforms; 8. Defendants are enjoined from the open use of Plaintiff’s marks, colors, and collateral, including uniforms that are the same or similar to Plaintiffs’ uniforms; 9. Defendants are enjoined from harassing, unprofessional communication with Plaintiffs, Plaintiffs’ family members, acquaintances, friends and past, Temporary Injunction Page 5 of 7 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 10. Defendants are 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. 11. Defendants are enjoined enjoined from opening or maintaining any bank account as TCU Pee Wee Football or any derivative of the name. 12. Defendants are enjoined from withdrawing, spending, or otherwise distributing any money from any bank account, safety deposit box, or by any financial instrument, money that is held in the name of d/b/a TCU Pee Wee Football or any derivatives of the name. 13. The clerk of the court is directed to issue a show cause notice to Defendants to appear at the permanent injunction hearing. 14. This Court requires Plaintiffs to post bond in the amount of $_____. The District Clerk can accept a check or cash from Plaintiffs or Plaintiffs’ counsel or law firm as payment of the bond. 15. The clerk of the court shall issue a Temporary Injunction in conformity with the law and terms of this order. Temporary Injunction Page 6 of 7 This Order shall expire on ________________, 20___ at ________o’clock __.m. Signed on _____________________, 2021 at __________o’clock __.m. ____________________________________ JUDGE PRESIDING Temporary Injunction Page 7 of 7 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Joshua Graham on behalf of Joshua Graham Bar No. 24080736 jsg@joshuagraham.com Envelope ID: 57768043 Status as of 9/30/2021 4:26 PM CST Associated Case Party: CHARLESDOUGLAS Name BarNumber Email TimestampSubmitted Status Joshua Graham eservice@joshuagraham.com 9/30/2021 4:20:26 PM SENT Joshua Graham jsg@joshuagraham.com 9/30/2021 4:20:26 PM SENT Associated Case Party: EARLSTEWART Name BarNumber Email TimestampSubmitted Status Earl Stewart tycozz@aol.com 9/30/2021 4:20:26 PM SENT Associated Case Party: RAYFORDROCHON Name BarNumber Email TimestampSubmitted Status Rayford Rochon thedjscoobydoo2@yahoo.com 9/30/2021 4:20:26 PM SENT Associated Case Party: CEDRIC, SRDORSEY Name BarNumber Email TimestampSubmitted Status Cedric Dorsey cedric.dorsey@fortworthtexas.gov 9/30/2021 4:20:26 PM SENT Associated Case Party: ADRIANDORSEY Name BarNumber Email TimestampSubmitted Status Adrian Dorsey dorsey102@charter.net 9/30/2021 4:20:26 PM SENT Associated Case Party: THENORTH TEXAS PEE WEE YOUTH LEAGUE Name Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Joshua Graham on behalf of Joshua Graham Bar No. 24080736 jsg@joshuagraham.com Envelope ID: 57768043 Status as of 9/30/2021 4:26 PM CST Associated Case Party: THENORTH TEXAS PEE WEE YOUTH LEAGUE Anthony Chance donnettachance@gmail.com 9/30/2021 4:20:26 PM SENT