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King Vision Pay Per View, Ltd. v. Cuello

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS Eastern Division


August 25, 2008

KING VISION PAY PER VIEW, LTD., PLAINTIFF,
v.
EDMUNDO CUELLO, INDIVIDUALLY AND D/B/A THE COCKTAIL BAR, INC., D/B/A FUGGEDABOUDIT AND THE COCKTAIL BAR, INC., D/B/A FUGGEDABOUDIT DEFENDANTS.

I.D. 06184818

File No. 3900-029

PLAINTIFF'S MOTION FOR PROVE-UP

COMES NOW the Plaintiff, KING VISION PAY PER VIEW, LTD., by and through its attorneys, ZANE D. SMITH & ASSOCIATES, LTD. and moves this Honorable Court for the entry of a Prove-up Order against EDMUNDO CUELLO, individually and THE COCKTAIL BAR, INC., d/b/a FUGGEDABOUDIT and in support thereof, states as follows:

1. That on July 22, 2008 this Honorable Court entered default judgment against the Defendants and set this matter for prove up.

2. That this matter is brought pursuant to the Communications Act of 1934, 47 U.S.C. § 151 et seq. as amended by the Cable Communications Policy Act of 1984, 47 U.S.C. § 521 et seq and the Copyright Act of 1976, 17 U.S.C. §§ 101 et seq.;

. That the aforesaid Act provides for statutory liquidated damages to wit:

a) Sixty Thousand ($60,000.00) Dollars for each violation of Section 553 of the Cable Communications Act;

b) One Hundred Ten Thousand ($110,000.00) Dollars for each violation of Section 6504 of the Copyright Act:

3. That in the instant matter, there were one (1) violation of the aforesaid provisions of the Cable Communication Act; See the Affidavit of the Investigator, attached hereto and made a part hereof, marked "Plaintiff's Exhibit A;"

4. That Plaintiff is therefore entitled to One Hundred Seventy Thousand and No/100 ($170,000.00) Dollars as Statutory liquidated damages.

5. That Plaintiff is further entitled to Two Thousand Five Hundred Eight One and 25/100 ($2,581.25 ) Dollars for attorney's fees and costs; See Affidavit of Plaintiff's Counsel, Zane D. Smith, attached hereto and made a part hereof, marked "Plaintiff's Exhibit B."

8. That Plaintiff is entitled to statutory damages, in the amount of $170,000.00 plus attorneys and fees and costs of $2,581.25 totaling $172,581.25.

WHEREFORE, the Plaintiff, KING VISION PAY PER VIEW, LTD., respectfully prays this Honorable Court for the entry of an Order in Plaintiff's favor and against the defendants, EDMUNDO CUELLO, individually and THE COCKTAIL BAR, INC., d/b/a FUGGEDABOUDIT in the amount of amount of $172,581.25 and for such other relief as this Court deems just and right.

20080825

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