Export Development Canada v. Marquis Solar Frame Works, Inc. et al

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Case: 3:25-cv-00751-wmc Document#: 64 _ Filed: 12/30/25 Page 1of3

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WISCONSIN

EXPORT DEVELOPMENT CANADA,
AMENDED TEMPORARY
Plaintiff, RESTRAINING ORDER

Vv. 25-cv-75 l-wmc

MARQUIS SOLAR FRAME WORKS, INC.,
and MARQUIS STAR HOLDING, INC.,

Defendants.

Upon review of the additional evidence supporting plaintiff's motion for a
temporary restraining order (dkts. ##57-61), including defendant Marquis Solar Frame
Works, Inc., and Marquis Star Holding, Inc.’s recent asset transfers and the suspicious
timing of recent offers to sell real estate assets held by it in this state, and good cause having
been found for equitable relief pending the possible issuance of a preliminary injunction,

IT IS ORDERED that defendants Marquis Solar Frame Works, Inc. and Marquis
Star Holding, Inc. (the “Defendants”) are temporarily restrained from causing or
participating in the disposition or dilution of any ownership, possessory, security, or equity
interest they hold, directly or indirectly, in the real property at: (1) 1100 Biscayne Blvd.,
Unit 6307, Miami, FL 33132; (2) 205 Industrial Circle, Stoughton, WI 53589; and (3)
1600 Williams Drive, Stoughton, WI 53589, absent immediate escrowing of all net
proceeds after payment to any lenders or lienors holding mortgages or security interests in

that real property provided those persons are not (and never have been) directly or

Case: 3:25-cv-00751-wmc Document#:64_ Filed: 12/30/25 Page 2 of 3

indirectly employed, owned, or controlled, in whole or in part, by the defendants or any of
their current or former officers, employees, or direct or indirect owners.

IT IS FURTHER ORDERED that the defendants may consummate a transaction
that would otherwise be prohibited by this amended TRO provided: (1) they believe in
good faith it is for fair market value; (2) it is with a person or entity with whom they have
no direct or indirect (past or present) personal, familial, financial, employment, or business
relationship; (3) at least seven days in advance of the closing the sales documents are shared
with plaintiff's counsel; and (4) the proceeds are held in escrow net of closing expenses
_ payable to persons or entities who are not (and never have been) directly or indirectly
employed, owned, or controlled, in whole or in part, by the defendants or any of their
current or former officers, employees, or direct or indirect owners.

IT IS FURTHER ORDERED that defendants are prohibited from: (1) drawing on
the Perfect Gateway loans (dkts. ##60-3, 60-4) other than as excepted in (4) below; (2)
allowing additional liens to be recorded against Marquis Star or Marquis Solar’s assets
without EDC’s consent or the court’s approval; (3) transferring additional assets to
nonparties in which Mr. Zhong Li, a/k/a John Lee, has a direct or indirect beneficial interest,
including his Canadian companies; or (4) otherwise causing or participating in the
disposition or dilution of any ownership, possessory, security, or equity interest in any
other assets of defendants except for payments or transfers made to employees, customers,
suppliers, or arms’-length lenders with whom the defendants contracted before the entering
of this amended TRO, consistent with established business practices that are necessary for

the defendants’ ongoing and normal business operations.

Case: 3:25-cv-00751-wmc Document#: 64 _ Filed: 12/30/25 Page 3 of3

IT IS FURTHER ORDERED that the briefing schedule shall remain as previously
ordered, and any opposition to the plaintiff's motion for a preliminary injunction shall be
filed with the court on or before January 9, 2026, including any response to plaintiff's
supplemental statement of proposed facts (Dkt. #59), and any reply shall be filed on or
before January 16, 2026, with a hearing to be held on that motion in this courthouse at
9:30 am, January 21, 2026, if necessary.

IT IS FURTHER ORDERED that pursuant to Fed. R. Civ. P. 65(c), plaintiff shall
not be required to post a bond at this time and may again enter this order as a lien on the
properties specified.

Entered this 30th day of December, 2025.

BY THE COURT: