Gridkor, LLC, et al. v. William Collins, et al.

Summary

The United States District Court for the Eastern District of Pennsylvania finds Jonathan Jacobs in civil contempt for knowingly aiding and facilitating violations of a preliminary injunction by defendants William Collins and Igor Gorbach. The court concludes that Jacobs requested and received $500,000 in payments despite knowing that the injunction prohibited the other defendants from dissipating assets, and that he prepared an agreement seeking additional payments. The court orders Jacobs to remit the $500,000, plus interest and reasonable attorneys’ fees.

Holdings

1. A person who knowingly aids or abets an enjoined party in violating an injunction may be held in civil contempt, even if that person is not independently subject to the injunction's operative restriction.
2. Plaintiffs proved by clear and convincing evidence that Jacobs was in civil contempt of the September 18, 2023 Preliminary Injunction Order.
3. The court may award compensatory relief consisting of the $500,000 obtained through the injunction violation, interest, and reasonable attorneys' fees incurred in enforcing the injunction.

Questions Presented

1. Whether Jacobs, a person carved out of the preliminary injunction but aware that it remained in effect as to other defendants, aided and abetted those defendants in violating the injunction by requesting and facilitating payments from them.
2. Whether Plaintiffs proved the elements of civil contempt by clear and convincing evidence.
3. What compensatory or coercive relief was appropriate for Jacobs's contempt.

Disposition

other