Case: 1:15-cv-00551 Document #: 19 Filed: 02/12/15 Page 1 of 2 PageID #:92

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
RIGHT FIELD ROOFTOPS, LLC,
d/b/a SKYBOX ON SHEFFIELD;
RIGHT FIELD PROPERTIES, LLC;
3633 ROOFTOP MANAGEMENT, LLC,
d/b/a LAKEVIEW BASEBALL CLUB; and
ROOFTOP ACQUISITION, LLC,
Plaintiffs,
v.
CHICAGO BASEBALL HOLDINGS, LLC;
CHICAGO CUBS BASEBALL CLUB, LLC;
WRIGLEY FIELD HOLDINGS, LLC; and
THOMAS S. RICKETTS,
Defendants.

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Case No. 15cv551
Hon. Virginia M. Kendall
Magistrate Judge Michael T. Mason

MOTION FOR TEMPORARY RESTRAINING ORDER
AND PRELIMINARY INJUNCTION
Pursuant to Rule 65 of the Federal Rules of Civil Procedure, the plaintiffs, (i) Right Field
Rooftops, LLC, d/b/a Skybox on Sheffield, (ii) Right Field Properties, LLC, (iii) 3633 Rooftop
Management, LLC, d/b/a Lakeview Baseball Club, and (iv) Rooftop Acquisition, LLC
(collectively, “Plaintiffs”), respectfully request that this Honorable Court enter a Temporary
Restraining Order and Preliminary Injunction requiring that the defendants, Chicago Baseball
Holdings, LLC, Chicago Cubs Baseball Club, LLC, Wrigley Field Holdings, LLC and Thomas
S. Ricketts (collectively, “Defendants”), immediately discontinue the installation of
“jumbotrons,” “video boards,” billboards, advertisements, and any other type of signage in front
of Plaintiffs’ properties located across from Wrigley Field, which signage will obstruct
Plaintiffs’ legally protected views into Wrigley Field.

 Case: 1:15-cv-00551 Document #: 19 Filed: 02/12/15 Page 2 of 2 PageID #:93

In support of this Motion, Plaintiffs submit the attached Memorandum of Points and
Authorities in Support of their Motion for Temporary Restraining Order and Preliminary
Injunction. A proposed order is also attached.
WHEREFORE, the plaintiffs, Right Field Rooftops, LLC, d/b/a Skybox on Sheffield,
Right Field Properties, LLC, 3633 Rooftop Management, LLC, d/b/a Lakeview Baseball Club,
and Rooftop Acquisition, LLC, respectfully request that this Honorable Court enter a Temporary
Restraining Order and Preliminary Injunction requiring that the defendants, Chicago Baseball
Holdings, LLC, Chicago Cubs Baseball Club, LLC, Wrigley Field Holdings, LLC and Thomas
S. Ricketts (collectively, “Defendants”), immediately discontinue the installation of
“jumbotrons,” “video boards,” billboards, advertisements, and any other type of signage in front
of Plaintiffs’ properties located across from Wrigley Field, which signage will obstruct
Plaintiffs’ views into Wrigley Field, and grant any additional relief deemed just and appropriate.
Respectfully Submitted,
Right Field Rooftops, LLC, d/b/a Skybox on
Sheffield, Right Field Properties, LLC, 3633
Rooftop Management, LLC, d/b/a Lakeview
Baseball Club, and Rooftop Acquisition,
LLC

/s/: Thomas M. Lombardo
By: Thomas M. Lombardo
One of their Attorneys
Thomas M. Lombardo (6279247)
Abraham Brustein (327662)
Di Monte & Lizak, LLC
216 Higgins Road
Park Ridge, IL 60068
847-698-9600 tel
847-698-9623 fax
tlombardo@dimontelaw.com
abrustein@dimontelaw.com

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