Home Instead Inc. v. Krishnan et al

Filing 42

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

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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. ) ) ) ) ) ) ) ) ) ) ) ) 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. 4825-3308-3721.1 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 Chris.bikus@kutakrock.com 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: (312) 857-8461 Facsimile: (866) 781-6175 tim@timmurphylaw.com 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. 2 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 3 4825-3308-3721.1

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