Home Instead Inc. v. Krishnan et al

Filing 42

MOTION by Plaintiff Home Instead Inc. for judgment (Agreed) (Attachments: # 1 Exhibit A)(Rollo, Sherry)

THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
HOME INSTEAD, INC.,
Plaintiff,
v.

BIJU KRISHNAN and NORTH SHORE CARE
MANAGEMENT CORP. d/b/a QUALICARE
CHICAGO NORTH SHORE,
Defendants.

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Case No.: 15-cv-3200

STIPULATION FOR ENTRY OF
CONSENT JUDGMENT
Plaintiff Home Instead, Inc. (“Plaintiff”) and Defendants Biju Krishnan and North Shore
Care Management Corp. d/b/a Qualicare Chicago North Shore (collectively “Defendants”) have
entered into a settlement agreement and have stipulated and agreed that the Court may enter a
Consent Judgment awarding Plaintiff the sum of $2,500.00.

The Parties further stipulate and

agree to the following:
1.

The Court has proper subject matter jurisdiction over the subject matter of this

dispute, has personal jurisdiction all parties to this action, and venue is proper in this District.
2.

Plaintiff owns a valid registered copyright in the original works described in the

Complaint [Doc. No. 2].
3.

Defendants infringed Plaintiff’s copyrights in the copyrighted works.

4.

The Parties consent to entry of a final judgment in this matter against Defendants

Biju Krishnan and North Shore Care Management d/b/a Qualicare Chicago North Shore, jointly
and severally, and in favor of Home Instead, Inc. in the amount of $2,500.00.

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5.

The Parties stipulate and agree that any and all other claims made by the Parties

shall be DISMISSED with prejudice.
WHEREFORE, the Plaintiff and Defendants respectfully request that the Court enter the
proposed Consent Judgment attached as Exhibit A and simultaneously submitted to this court via
electronic mail and grant all other appropriate relief.
Respectfully submitted this 25th day of May, 2017.
Respectfully submitted:

/s/ Christopher M. Bikus___________
Christopher M. Bikus (pro hac vice)
KUTAK ROCK LLP
1650 Farnam St
Omaha, NE 68102
[e-mail]
and
Steven E. Feldman
Sherry L. Rollo
HAHN LOESER & PARKS LLP
125 S. Wacker Dr., Suite 2900
Chicago, Illinois 60606

/s/_Timothy M Murphy_________________
Timothy M. Murphy
150 North Michigan Avenue, Suite 2800
Chicago, IL 60601
Phone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Defendants Biju Krishnan and and
North Shore Care Management Corp. d/b/a
Qualicare Chicago North Shore

Attorneys for Plaintiff Home Instead, Inc.

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4825-3308-3721.1

CERTIFICATE OF SERVICE
I, the undersigned attorney for Plaintiff Home Instead, Inc., hereby certify that a true and
correct copy of the foregoing was served on all parties to this action via the Court’s CM/ECF
system:

/s/ Sherry L. Rollo
Sherry L. Rollo

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4825-3308-3721.1