Liberty Media Holdings, LLC v. Swarm Sharing Hash File et alMOTION for Default Judgment as to Michael RapisardaD. Mass.March 28, 2012UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS LIBERTY MEDIA HOLDINGS, LLC, Plaintiff, v. SWARM SHARING HASH FILE AE3 et al., Defendants. Civil Action No. 11-cv-10802-WGY PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT AGAINST MICHAEL RAPISARDA FOR WILLFUL COPYRIGHT INFRINGEMENT Pursuant to the Notice of Default, Fed. R. Civ. P. 55, and the Court’s Standing Order, the plaintiff Liberty Media Holdings, LLC (“Liberty”) respectfully moves that the Court enter a default judgment of willful copyright infringement against defendant Michael Rapisarda (“Defendant”), and award Liberty a total of $25,000.00 in statutory damages plus $192.00 in costs and $2,690.00 in prejudgment interest. Liberty also moves for the Court to enter a permanent injunction in the form of the Proposed Order attached hereto. In support of this motion, Liberty relies on the accompanying memorandum of law, the first Declaration of Malte Dinkela, Dkt. No. 8, as well as the Declarations of Malte Dinkela and Aaron Silverstein filed herewith. Case 1:11-cv-10802-WGY Document 110 Filed 03/28/12 Page 1 of 2 2 Dated: March 28, 2012 Respectfully submitted, LIBERTY MEDIA HOLDINGS, LLC By its attorneys, /s/Aaron Silverstein Aaron Silverstein, Esq. (BBO #660716) SAUNDERS & SILVERSTEIN LLP 14 Cedar Street, Suite 224 Amesbury, MA 01913 P: 978-463-9100 F: 978-463-9109 E: asilverstein@massiplaw.com CERTIFICATE OF SERVICE I hereby certify that on March 28, 2012, the foregoing document, filed through the ECF system, will be sent electronically to the registered participants as identified on the Notice of Electronic Filing, and paper copies will be served via first-class mail to those indicated as non-registered participants. /s/Aaron Silverstein Case 1:11-cv-10802-WGY Document 110 Filed 03/28/12 Page 2 of 2
