Free Motion for Default Judgment - District Court of Connecticut - Connecticut

. Case 3:03-cv-00955SRU Document 8 Filed 12/Og/2)OO3 Page 1 of 4
UNITED STATES DISTRICT COURT I I
DISTRICT OF CONNECTICUT I
DIRECTV, INC., ) Case N0.: 303Cq?®}»7U§IRUI`I A qI LI I
Piamarr, i 1>LA1Nri1t`gis';M_oT1oN I
Plaintiff, I DEFAULT JUDGMENT
vs_ > I
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Michael Braun I
Defendant )
Plaintiff hereby moves this Court for a Judgment by Default in the above-entitled actio
against the Defendant. The Plaintiff also requests that this Court assess non—Liquidated Damage
after considering the Plaintiffs filings made herewith. The Plaintiff contends that because th I
plaintiff is seeking only the statutory minimum the Court should be able to assess statutor I
damages in this action based upon the facts as determined through the Defendant's default all i I
accordance with Fed. R. Civ. P. 55(b)(2). ‘ I
In support of this Motion, Plaintiff submits: I
l. That a Default was entered against the Defendant on September 26, 2003. I
2. That the Defendant has still failed to reply or otherwise defend the claims set fort
in Plaintiffs complaint;
3. That the Defendant is not an infant or incompetent; I
4. That the Defendant is not in the military service; and,
5. That the Plaintiff is entitled to damages and other civil remedies as set forth belo I
because damages are liquidated in this case as they are based on a minim
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statutory award of $30,000.00 due to Defendant’s conduct as alleged i I
DIRECTV’s Complaint.
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, ’ Case 3:03-cv-OO9@Z)SRU Document 8 Filed 12/O@O3 Page 2 of 4 \
In further support of this Motion, please see: I
1. Memorandum of Law in Support of Plaintiffs Motion for Default Judgment.
2. Affidavit of Attorney John M. McLaughlin.
3. Proposed Order of Default.
WHEREFORE Plaintiff respectfully requests that this Court enter Default Judgment in
favor of the Plaintiff and against the Defendant for the reasons set forth above (and as further
articulated in it’s Memorandum of Law in Support of Plaintiffs Motion for Default Judgment),
DIRECTV respectfully requests that this Court award to DIRECTV:
(1) Full statutory damages in the amount of $30,000.00;
(2) Full costs in the amount of $203.50;
(3) Attorneys’ fees in the amount of $729.00
(4) Permanently enjoin Defendant from committing or assisting in the commission of any
violation of`47 U.S.C. § 605 or 18 U.S.C. § 2511; and
(5) Grant DIRECTV such other and further relief as this court deems equitable, just and i
proper.
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_ ‘ Case 3:03-cv-OO9€‘i>§FlU Document 8 Filed 12/O@O3 Page 3 of 4 I
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Respectfully Submitted for the Plaintiff, I
DIRECT , Inc.
By Its 0 ey _,.: I I
Diate I I J _ . McL ughli (B O: 556328)
AUG IN ACKS, LLC 3%
3:1 Trumbull Road &é I Ci I
`I orthampton, MA 01060
(413) 586—0865
Local Address Pursuant to
D. Conn. L. Civ. R. 2(c):
Palumbo, Palumbo & Carrington, P.C.
193 Grand Street
P.O. Box 2518 I
Waterbury, CT 06732-2518 E
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r Case 3:03-cv-OOQQKSRU Document 8 Filed 12/04:*2003 Page 4 of 4
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CERTIFICATE OF SERVICE i
I, John M. McLaughlin, attorney for the Plaintiff, hereby certify that on December 3,
2003 I served a copy of the foregoing Motion for Default Judgment, Memorandum of Law
Proposed Judgment and Affidavit of John M. McLaughlin were sent via first class mail, postag
pre—paid to:
Michael Braun
7 Countryside Lane Unit 6
Middletown, CT 06457
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