UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MICHAEL STOKES, Plaintiff, Case No. 1:22-cv05253 (JLR) -against- NOTICE TO RBSB LLC d/b/a ROCK BAR, DEFENDANT Defendant. JENNIFER L. ROCHON, United States District Judge: A Lawsuit Has Been Filed Against You Plaintiff Michael Stokes has started a lawsuit against RBSB LLC, doing business as “Rock Bar.” You are receiving this notice as the Defendant. Plaintiff alleges that you copied and displayed his copyrighted photograph without permission and without his copyright watermark on your company’s Facebook account. Plaintiff is seeking damages in the tens of thousands of dollars. Plaintiff also requests an injunction, which is a legal order to stop you from using the copyrighted images without his permission or authorization. Plaintiff also claims that you have received written notice of this lawsuit. You are receiving this notice because you have not answered or otherwise responded to the Court about the Plaintiff’s allegations. If You Do Not Respond to the Lawsuit, A Judgment May Be Filed Against You Plaintiff has asked the Court to enter a default judgment in its favor against you. A default judgment is a final ruling in a case because a defendant has failed to take action. Plaintiff has asked the Court to conclude: (1) that you do not oppose Plaintiff’s allegations or disagree with its claims; and (2) that Plaintiff is entitled to damages in tens of thousands of dollars and an injunction against continued infringement of the copyright. If you continue to fail to participate, the Court may grant Plaintiff’s request and enter the default judgment against you. A judgment is a public record with significant potential consequences against you, particularly if you do not pay the judgment. Plaintiff may use the following legal tools to ensure payment of an unpaid judgment: (1) attachment (a court order seizing property), (2) imposition of a lien (giving a legal right to one’s property until a debt has been paid) or garnishment (ordering someone holding funds on behalf of a defendant, such as an employer or a bank, to pay debts directly to the plaintiff to satisfy the judgment). You May Still Respond to the Lawsuit The Court has not granted the default judgment against you yet. You still have an opportunity to respond to the lawsuit. Enclosed is an order scheduling a Hearing for February 15, 2023 at 10:00 a.m. (Eastern Time) to discuss Plaintiff’s motion asking the Court to enter default judgment against you. You may participate in the conference by dialing the toll-free number 877-336-1831 with access code 5583342. You may also have a lawyer appear for you. Corporate Defendants Defendants are cautioned that corporate entities may appear in federal court only through licensed counsel, see Lattanzio v. COMTA, 481 F.3d 137, 140 (2d Cir. 2007), and where such an entity “repeatedly fails to appear by counsel, a default judgment may be entered against it,” Grace v. Bank Leumi Tr. Co. of N.Y., 443 F.3d 180, 192 (2d Cir. 2006) (internal quotation marks omitted). Opposition Requested As stated in the related Order issued today, you are directed to promptly notify the Court. If you choose to contact the Court or file an opposition, you may state whether you received notice about the lawsuit prior to this Notice, or your factual and legal objections to Plaintiff's claims. If you did not receive a copy of the complaint, you may request one from Plaintiff's lawyer, whose information is at the end of this Notice, or the Clerk of Court. If you decide to contact the Court, you must do so by February 1, 2023. Any letter to the Court should clearly list the following case name and number: Stokes v. RBSB LLC, 22-cv-05253- JLR. You can mail or deliver the letter to: United States District Court for the Southern District of New York Attn: Clerk’s Office / Judge Rochon 500 Pearl Street New York, New York 1007 Service It is further ORDERED that Plaintiffs serve Defendants with (1) a copy of the motion for default judgment and all supporting papers; (2) a copy of this Order; and (3) a full docket Sheet within two business days of the filing of this Order. Within two business days of service, Plaintiffs must file proof of such service on the docket. Dated: January 6, 2023 New York, New York SO ORDERED. Aa L. ROCHON United States District Judge Plaintiff's Counsel: Jonathan Mark Cader Renee Jennifer Aragona Craig B. Sanders Sanders Law Group 333 Earl Ovington Boulevard Suite 402 Uniondale, NY 11553 516-203-7600