T.E.N. Investments, Inc v. Jackson et al

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
T.E.N. INVESTMENTS, INC.,
Plaintiff,
v.
CHAPTER KRIS JACKSON,
ARISTOCRAT MOTORS INC.,
CHRISTOPHER ADAM JACKSON,
ARISTOCRAT MOTOR COMPANY,
INC., and SNOWY OWL LLC,
Defendants.
Case No. 25-cv-2104-TC-JBW
MEMORANDUM AND ORDER
Plaintiff T.E.N. Investments, Inc. filed a Motion to Compel Discovery Responses From
Defendants Chapter and Christopher Jackson (Dkt. 115). Plaintiff requests an order, pursuant to
Fed. R. Civ. P. 37(a), compelling pro se Defendants Chapter Jackson and Christopher Jackson
(collectively “the Jacksons”) to fully and completely respond to Plaintiff’s First Sets of
Interrogatories (“Interrogatories”) and Requests for Production (“RFPs”). The Jacksons did not
file a response opposing the motion and their March 6, 2026 deadline for doing so has passed.1 As
explained below, the motion is granted in part and denied in part.
1 Under D. Kan. Rule 7.1(c), a party opposing a motion must file a response within the applicable
deadline set in D. Kan. Rule 6.1(d). Motions to compel discovery fall under the category of “Other motions”
and therefore any response is due within 14 days after the motion is served. See D. Kan. Rule 6.1(d)(4).
Rule 7.1(c) further provides: “If a response is not filed by the applicable deadline, the court will consider
and decide the motion as an uncontested motion. Ordinarily, the court will grant the motion without further
notice.”
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 1 of 11

2
I. 	Background
Plaintiff initiated this action by filing a Complaint asserting federal and state law claims
for trademark infringement, unfair competition, false designation of origin, and related relief. The
Complaint names five defendants: two individuals—the Jacksons—and three business entities—
Aristocrat Motors, Inc., Aristocrat Motor Company, Inc., and Snowy Owl LLC (collectively the
“Entity 	Defendants”). 	Generally, 	the 	allegations 	concern 	the 	Defendants’ 	use 	of 	the
ARISTOCRAT MOTORS trademark, specifically through their alleged fraudulent filing and use
of a United States Trademark Application, the formation of sham business entities, and the
registration of fictitious business names in fall 2024. The Court entered default judgment and a
permanent injunction against the Entity Defendants on January 23, 2026. 2 Plaintiff’s claims
against the Jacksons remain pending.
On November 21, 2025, Plaintiff served 21 interrogatories (two with subparts) and 49 RFPs
on Chapter Jackson. 3 Plaintiff served 18 interrogatories (two with subparts) and 48 RFPs on
Christopher Jackson.4
2 See Order (Dkt. 114) granting Plaintiff’s Motion for Default Judgment and Permanent Injunction
Against the Entity Defendants (Dkt. 112).
3 See Pl.’s Interrogs. and RFPs to Chapter Jackson. Dkts. 115-6 and 115-8.
4 See Pl.’s Interrogs. and RFPs to Christopher Jackson. Dkts. 115-10 and 115-12.
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 2 of 11

3
On December 21, 2025, Chapter Jackson served her objections and responses to Plaintiff’s
Interrogatories and RFPs.5 Chapter Jackson objected to Interrogatories 1–6 and 8–20 but answered
Interrogatories 7 and 21. She asserted multiple objections to RFPs 1–44.
Christopher Jackson also served his objections and responses to the Interrogatories and
RFPs on December 21, 2025.6 Christopher Jackson objected to Interrogatories 1–3, 6, 9–21, but
answered Interrogatories 1–5, 7–8, and 21. Christopher Jackson objected to RFPs 16–25 as
irrelevant and overbroad. He did not object to the other RFPs but responded stating he has no
involvement in the use or intended use of Aristocrat Motors marks and possesses no documents
responsive to the RFPs.
On January 16, 2026, Plaintiff filed a motion for an extension of time to file a motion to
compel and for relief from the pre-motion conference requirement (Dkt. 113). The Court granted
the motion, extending Plaintiff’s deadline to file any discovery motion regarding the Jacksons’
objections and responses to Plaintiff’s Interrogatories and RFPs to February 20, 2026. The Court
also relieved Plaintiff’s obligation under D. Kan. Rule 37.1(a) to arrange for a pre-motion
5 See Chapter Jackson’s Resps. to Pl.’s Interrogs. (Dkt. 115-7) and Resps. and Objs. to Pl.’s RFPs
(Dkt. 115-9). Plaintiff claims the objections and responses were served one day later on December 22, 2025.
6 See Christopher Jackson’s General Objs. to Pl.’s Interrogs. (Dkt. 115-11) and Resps. and Objs.
to Pl.’s RFPs. (Dkt. 115-13). Plaintiff claims the objections and responses were served one day later on
December 22, 2025.
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 3 of 11

4
telephone conference with the Court before filing its motion.7 Plaintiff timely filed its motion to
compel on February 20, 2026. 8
II. 	Conferring Attempts
Plaintiff attaches the declaration of its counsel, Mary Hyde, detailing her attempts to confer
in good faith with the Jacksons as required by D. Kan. Rule 37.2(a). Plaintiff’s counsel states she
transmitted a golden rule letter to each of the Jacksons regarding their deficient objections and
responses to Plaintiff’s discovery requests on January 9, 2026. 9 The Jacksons were offered
substantial windows of availability on January 14, 15 and 16, 2026 for a call to discuss the
discovery deficiencies.10 On January 14, 2026, Defendant Christopher Jackson emailed they were
available on January 19, 2026, and a phone call was scheduled for that day.11 Counsel describes
the phone call that ensued:
At the outset of the call, Chapter Jackson interrupted me and asked if I was
recording the call, and I confirmed that counsel for Plaintiff were not recording.
Chapter then announced she was being videotaped and that she could not stop the
recording. I asked her how the recording was occurring and why she could not stop
the recording, but she simply said that she could not stop the recording and then
dropped from the call approximately four minutes after it began. At 11:04 AM
(CST) I emailed her to ask her to rejoin the meeting and asked Defendant
Christopher Jackson to try to get in touch with her as well, and he said that he texted
her. At 12:23 PM (CST) Chapter Jackson responded acknowledging that she hung
7 See Text Order (Dkt. 117).
8 The certificate of service for Plaintiff’s Motion indicates a copy was served by electronic filing
on Christopher Jackson and served by U.S. mail and electronic mail on Chapter Jackson. Dkt. 115 at 7.
9 Hyde Decl. (Dkt. 115-2) at ¶ 7.
10 Id.
11 Id. at ¶ 8.
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 4 of 11

5
up and left the call intentionally.12
Christopher Jackson remained on the January 19, 2026 call after Chapter Jackson
dropped from the call. I asked him if his position on any of the discovery
responses/objections had changed, and he started to launch into a discussion about
his views of the case and alleged the Court does not have jurisdiction. Patric Linden
stated that lack of jurisdiction was not raised in their responses, so that objection is
waived. Christopher Jackson then raised his voice and appeared to get upset, saying
he had nothing to say to Mr. Linden and calling Mr. Linden offensive names. I tried
to cut in a number of times to try to get him to calm down, but he continued his
rant, making a number of threats of additional litigation against Plaintiff and/or its
counsel for malicious prosecution. Then he too disconnected from the call. I copied
Christopher Jackson on my email at 11:04 AM (CST) to Defendant Chapter
Jackson. At 12:27 PM (CST) Christopher Jackson responded acknowledging that
he hung up and left the call intentionally.13
Based upon counsel’s reported exchanges with the Jacksons and subsequent email
correspondence, the Court finds further efforts to confer with the Jacksons would likely be futile.
Plaintiff has shown it made reasonable efforts to confer prior to filing its motion as required by D.
Kan. Rule 37.2.
III. 	Discovery Requests Plaintiff Seeks to Compel From the Jacksons
Plaintiff requests the Court overrule the Jacksons’ objections and order them to provide
full and complete responses to certain written discovery requests within fourteen days of the
Court’s order. Plaintiff requests both Jacksons be compelled to produce documents responsive to
Plaintiff’s RFPs 1–4, 6, 8–10, 13–15, 17–19, 29, and 31–44. It requests that Chapter Jackson be
compelled to serve answers fully responding to Plaintiff’s Interrogatories 1–3, 7–10, and 12–20
12 Id. at ¶ 9.
13 Id. at ¶ 10.
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 5 of 11

6
served upon her. Plaintiff requests Christopher Jackson be compelled to serve answers fully
responding to Interrogatories 1–3 and 7–17 served upon him.
Federal Rule of Civil Procedure 37(a)(3)(B) permits a party to move for an order
compelling a discovery response. Specifically, the party seeking the discovery may file a motion
to compel if the responding party fails to answer an interrogatory submitted under Rule 33 or fails
to produce documents as requested under Rule 34. 14 In response to a motion to compel, the
responding party has an opportunity to reassert and offer support for objections made in the
discovery responses themselves.15 “Any objection the responding party does not reassert in its
response to a motion to compel is deemed abandoned.” 16
In this case, the Jacksons failed to file a response in opposition to Plaintiff’s motion to
compel that supports the objections they asserted in their respective interrogatory and RFP
responses. The Court could deem those objections abandoned. However, the Court notes that the
Jacksons are proceeding as pro se defendants in this trademark infringement case and Plaintiff has
served approximately 50 RFPs and 25 interrogatories (counting subparts) on each of the Jacksons.
Plaintiff’s motion seeks to compel on more than half of these RFPs and interrogatories. The Court
14 Fed. R. Civ. P. 37(a)(3)(B)(iii)–(iv).
15 Mercado v. Arrow Truck Sales, Inc., No. 23-2052-HLT-ADM, 2024 WL 1557539, at *2 (D.
Kan. Apr. 10, 2024).
16 Id.; See also Kannaday v. Ball, 292 F.R.D. 640, 644 (D. Kan. 2013) (“[O]bjections initially
raised but not supported in the objecting party's response to the motion to compel are deemed abandoned.”);
Firestone v. Hawker Beechcraft Int'l Serv. Co., No. 10-1404, 2011 WL 13233153, at *2 (D. Kan. Sept. 28,
2011) (“Objections initially raised but not relied upon in response to the motion to compel will be deemed
abandoned.”).
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 6 of 11

7
therefore will not deem the Jacksons’ objections abandoned simply by their failure to file a
response but instead will consider them in ruling on Plaintiff’s motion.
A. 	RFPs and Interrogatories Served Upon Chapter Jackson at Issue
Plaintiff seeks an order compelling Chapter Jackson to produce documents responsive to
RFPs 1–4, 6, 8–10, 13–15, 17–19, 29, and 31–44. Chapter Jackson asserted multiple objections to
the RFPs at issue, including overly broad, unduly burdensome, not proportional, duplicative, seek
documents equally available to Plaintiff and documents not in her personal possession or control.
The Court has reviewed the objections asserted to each specific RFP at issue and overrules all the
objections. Although some of the RFPs arguably request documents that do not exist or Ms.
Jackson does not have in her possession, custody, or control, it is not evident from Ms. Jackson’s
responses asserting objections whether she is withholding responsive documents on the basis of
her objections. Fed. R. Civ. P. 34(b)(2)(C) requires a party objecting to requests of production to
“state whether any responsive materials are being withheld on the basis of that objection.” Ms.
Jackson’s RFP objections thus fail to comply with Rule 34(b)(2)(C). To the extent she is
withholding responsive documents based upon her objections, those objections are overruled and
Ms. Jackson is ordered to produce all documents responsive to RFPs 1–4, 6, 8–10, 13–15, 17–19,
29, and 31–44. If there are no responsive documents to any of these RFPs, then Ms. Jackson shall
serve supplemental responses stating, without objection, she has no responsive documents.
Plaintiff also seeks to compel Chapter Jackson to serve supplemental responses fully
answering Interrogatories 1–3, 7–10 and 12–20. Chapter Jackson objected without answering any
of the Interrogatories at issue except Interrogatory 7. Although she did not object to Interrogatory
7, Ms. Jackson’s response stating her legal name does not fully answer the interrogatory and she
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 7 of 11

8
is ordered to serve a supplemental response fully responding to it. Ms. Jackson objected without
answering the other Interrogatories at issue as overly broad and unduly burdensome, assuming
facts and requiring her to adopt third-party knowledge, and argumentative. The Court has reviewed
the objections Ms. Jackson asserted to each specific Interrogatory at issue and overrules all her
objections to Interrogatories 1–3, 8–10, and 12–20. Ms. Jackson is ordered to serve supplemental
responses that fully answer Interrogatories 1–3, 7–10, and 12–20 without objection.
Chapter Jackson also asserted objections based upon her vision impairment to nearly every
Interrogatory and RFP at issue stating she is unable to personally review or identify responsive
documents due to her vision impairment. In her “preliminary statement[s] regarding disability”
prefacing her discovery responses, she states:
she suffers from a severe vision impairment, glaucoma and other medical
conditions that substantially limit her ability to read, review, identify, sort, or
produce documents, including electronically stored information. She also states she
currently does not have access to a reader, assistive technology, or other reasonable
accommodation necessary to review the RFPs or to review documents for purposes
of production and to gather said documents.
Ms. Jackson reasserts her vision impairment in nearly all her interrogatory and RFP
responses, purportedly as a reason why she cannot independently review records, or identify or
produce documents necessary to confirm the information requested. Ms. Jackson’s vision
impairment is not a valid objection to responding to the interrogatories or producing documents
responsive to Plaintiff’s RFPs. To the extent she is arguing Plaintiff is required to provide some
type of accommodation for her vision impairment, she provides no legal authority for this
argument and the Court is not otherwise aware of any such authority imposing such obligation
upon a party serving discovery requests.
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 8 of 11

9
Plaintiff’s Motion to Compel is granted as to the RFPs and Interrogatories served upon
Chapter Jackson. Ms. Jackson is ordered to produce documents responsive to RFPs 1–4, 6, 8–10,
13–15, 17–19, 29, and 31–44, and serve supplemental responses that fully answer Interrogatories
1–3, 7–10, and 12–20. The Court will give Chapter Jackson thirty (30) days, which is more time
than the fourteen days requested by Plaintiff, to serve all responsive documents and supplemental
responses or answers as ordered herein.
B. 	RFPs and Interrogatories Served Upon Christopher Jackson at Issue
Plaintiff seeks an order compelling Christopher Jackson to produce documents responsive
to the same RFPs at issue as co-defendant Chapter Jackson (RFPs 1–4, 6, 8–10, 13–15, 17–19, 29,
and 31–44). Of the RFPs at issue in Plaintiff’s motion, Christopher Jackson only objected to RFPs
17–19 as irrelevant and overbroad. He did not object to any of the other RFPs at issue but
responded with statements he has no involvement in the use or intended use of Aristocrat Motors
marks and possesses no documents responsive to the RFPs. The Court has reviewed the responses
and objections Mr. Jackson asserted to RFPs 17–19 and overrules those objections. However, since
his responses also state he has no responsive documents to the RFPs 17–19,17 the Court will not
compel supplemental production or responses for the RFPs at issue absent some showing Mr.
Jackson actually has documents responsive to the RFPs at issue in his possession, custody, or
control that have not been produced. Plaintiff’s Motion to Compel is denied as to the RFPs served
upon Christopher Jackson.
17 Christopher Jackson’s response to RFPs 16–25 objects on relevance and overbreadth grounds
but then states “he has no documents responsive to these Requests as they relate to alleged trademark use
or infringement.” Dkt. 115-13 at 4.
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 9 of 11

10
Plaintiff also seeks to compel Christopher Jackson to serve supplemental responses fully
answering Interrogatories 1–3 and 7–17. For the Interrogatories at issue, Christopher Jackson
objected to all but Interrogatories 7 and 8. For the other Interrogatories at issue (1–3 and 9–17),
Christopher Jackson objected and then answered subject to those objections. The Court has
reviewed the objections Mr. Jackson asserted to the specific Interrogatories at issue and overrules
those objections. For example, Interrogatory 1 asked Mr. Jackson to “[i]dentify each product or
service in connection with which the Defendant ARISTOCRAT MOTORS Marks have been used
by you or any of the other Defendants.”18 He objected to it as “vague, overly broad, and assuming
facts not admitted.” While the Court agrees with Mr. Jackson that Interrogatory 1 is confusing in
its wording, the information sought by the interrogatory is obvious and the Court overrules the
objection. Mr. Jackson’s subsequent response (after objecting) to Interrogatory 1 also does not
fully answer it. His statement “he has not personally sold products or services under the trademark
in a manner constituting commercial trademark use under the Lanham Act” limits the answer to
him and does not identify products or service in which the mark was used by the other Defendants.
Mr. Jackson’s responses after objecting to the other Interrogatories at issue similarly fail to fully
answer those Interrogatories. Christopher Jackson’s objections to Interrogatories 1–3 and 9–17 are
overruled, and he is ordered to serve supplemental responses that fully answer these interrogatories
without objection.
Although Mr. Jackson did not object to Interrogatories 7 and 8 and simply answered, the
Court finds Christopher Jackson’s answers are not sufficient. His answer to Interrogatory 7 (stating
18 Pl.’s Interrogs. to Christopher Jackson (Dkt. 115-10) at 5.
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 10 of 11

11
his “legal name”) does not fully answer the interrogatory asking for all names, aliases and
nicknames he has been known by. Likewise, his answer to Interrogatory 8 (stating “Chapter
Jackson is a separate individual”) does not answer the interrogatory asking him to describe the
nature of their relationship. 19 Plaintiff’s Motion to Compel is granted as to the Interrogatories
served upon Christopher Jackson and he is ordered to serve supplemental responses that fully
answer Interrogatories 1–3 and 7–17 without objection.
IT IS THEREFORE ORDERED that Plaintiff’s Motion to Compel Discovery Responses
From Defendants Chapter and Christopher Jackson (Dkt. 115) is granted in part and denied in
part. Defendant Chapter Jackson is ordered to produce documents responsive to Plaintiff’s First
RFPs 1–4, 6, 8–10, 13–15, 17–19, 29, and 31–44 and serve answers fully responding to Plaintiff’s
First Interrogatories 1–3, 7–10, and 12–20 served upon her. Defendant Christopher Jackson is
ordered to serve answers fully responding to Plaintiff’s Interrogatories 1–3 and 7–17 served upon
him. Defendants Chapter and Christopher Jackson shall serve all documents and supplemental
responses or answers ordered above within 30 days of the date of this Order.
Copies of this Order shall be sent to pro se defendant Chapter Jackson by regular mail and
to pro se defendant Christopher Adam Jackson by email ECF notification.
IT IS SO ORDERED.
Dated April 15, 2026, at Kansas City, Kansas.
19 Pl.’s Interrogs. to Christopher Jackson (Dkt. 115-10) at 8 and Christopher Jackson’s Interrog.
Resps. (Dkt. 115-11) at 3.
Jennifer B. Wieland
U. S. Magistrate Judge
Case 2:25-cv-02104-TC-JBW Document 121 Filed 04/15/26 Page 11 of 11