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Confessions of Judgement in Kyko Global Inc vs Madhavi Vuppalapati & Prithvi Info Solutions Ltd

Confessions of Judgement in Kyko Global Inc vs Madhavi Vuppalapati & Prithvi Info Solutions Ltd

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Published by Megan Finley
The judgement was passed in favour of Plaintiffs Kyko Global Inc. Confessions of Judgement in Kyko Global Inc vs Madhavi Vuppalapati & Prithvi Info Solutions Ltd
The judgement was passed in favour of Plaintiffs Kyko Global Inc. Confessions of Judgement in Kyko Global Inc vs Madhavi Vuppalapati & Prithvi Info Solutions Ltd

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Published by: Megan Finley on Apr 04, 2014
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04/16/2014

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PAGE 1 – PLAINTIFFS’ MOTION FOR ISSUANCE OF JUDGMENTIN AMOUNT AGAINST CERTAIN DEFENDANTSPURSUANT TO CONFESSIONS OF JUDGMENTCase No. 2:13-CV-1034-MJP
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TANFORD
601 Union Street, Suite 4400Seattle, WA 98101 p. 206-237-0020; f. 503.417.4250
The Honorable Marsha J. Pechman
UNITED STATES DISTRICT COURTWESTERN DISTRICT OF WASHINGTONAT SEATTLEKYKO GLOBAL, INC., a Canadiancorporation, and KYKO GLOBAL GMBH, aBahamian corporation,Plaintiffs,v.PRITHVI INFORMATION SOLUTIONS,LTD., a Pennsylvania corporation, PRITHVICATALYTIC, INC., a Delaware corporation,PRITHVI SOLUTIONS, INC., a Delawarecorporation, PRITHVI INFORMATIONSOLUTIONS INTERNATIONAL, LLC, aPennsylvania limited liability company,INALYTIX, INC., a Nevada corporation,INTERNATIONAL BUSINESSSOLUTIONS, INC., a North Carolina,corporation, AVANI INVESTMENTS, INC., aDelaware corporation, ANANYA CAPITALINC., a Delaware corporation, MADHAVIVUPPALAPATI AND ANANDHANJAGARAMAN, husband and wife and themarital community composed thereof, GURUPANDYAR AND JANE DOE PANDYAR,husband and wife and the marital communitycomposed thereof, and SRINIVAS SISTAAND JOHN DOE SISTA, husband and wifeand the marital community composed thereof,DCGS, INC., a Pennsylvania company, EPP,Case No. 2:13-CV-1034 MJP
PLAINTIFFS’ MOTION FOR ISSUANCE OF JUDGMENT INAMOUNT AGAINST CERTAINDEFENDANTS PURSUANT TOCONFESSIONS OF JUDGMENTNOTE ON MOTION CALENDAR:AUGUST 9, 2013[CLERK’S ACTION REQUIRED]
Case 2:13-cv-01034-MJP Document 41 Filed 08/08/13 Page 1 of 5
 
PAGE 2 – PLAINTIFFS’ MOTION FOR ISSUANCE OF JUDGMENTIN AMOUNT AGAINST CERTAIN DEFENDANTSPURSUANT TO CONFESSIONS OF JUDGMENTCase No. 2:13-CV-1034-MJP
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601 Union Street, Suite 4400Seattle, WA 98101 p. 206-237-0020; f. 503.417.4250
INC., a Washington corporation, FINANCIALOXYGEN, INC., a Washington corporation,HUAWEI LATIN AMERICAN SOLUTIONS,INC., a Florida corporation, L3C, INC., aWashington corporation.Defendants.
I. INTRODUCTION
Pursuant to Fed. R. Civ. P. 58(b), Plaintiffs seek entry of judgment against theDefendants, with the exception of Defendants International Business Solutions, Inc., GuruPandyar, and Srinivas Sista (who did not sign Confessions of Judgment). Each and every other named Defendant in this case signed a Confession of Judgment, which has now been filed withthe Court. Defendants have duly executed Confessions of Judgment in the amount of $18million as required under RCW 4.60.010
 et seq
. Since the date of the Confessions of Judgmentsigned by those Defendants, Plaintiffs have received payments of $161,470 towards the totalamount owed of $18 million. Defendants confessed unconditionally and irrevocably to theamount of $18 million in the Confessions of Judgment.Plaintiffs reserve the right to file a subsequent motion with the Court seeking to amendthe judgment for additional accruing interest, costs and attorneys fees, but now seek entry of immediate judgment for an amount certain against Defendants in the total amount of $17,838,530 as confessed to by the Defendants under the Washington statutory procedure setforth under RCW 4.60.010
 et seq.
 and as further outlined below.
II. EVIDENCE RELIED UPON
Defendants Prithvi Information Solutions, Ltd.; Prithvi Information SolutionsInternational, LLC; Prithvi Catalytic, Inc.; Prithvi Solutions, Inc.; Inalytix, Inc.; AvaniInvestments, Inc.; Ananya Capital, Inc.; Madhavi Vuppalapati; DCGS, Inc.; EPP, Inc.; Financial
Case 2:13-cv-01034-MJP Document 41 Filed 08/08/13 Page 2 of 5
 
PAGE 3 – PLAINTIFFS’ MOTION FOR ISSUANCE OF JUDGMENTIN AMOUNT AGAINST CERTAIN DEFENDANTSPURSUANT TO CONFESSIONS OF JUDGMENTCase No. 2:13-CV-1034-MJP
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601 Union Street, Suite 4400Seattle, WA 98101 p. 206-237-0020; f. 503.417.4250
Oxygen, Inc.; Huawei Latin American Solutions, Inc.; and L3C, Inc. separately executedConfessions of Judgment on or about July 16-17, 2013, which have now been filed with theCourt.The Declaration of Kiran Kulkarni filed herewith sets forth the amounts paid to date inthe amount of $161,470.
III. LEGAL ANALYSIS
Confessions of Judgment are defined under Washington law by statute. “On theconfession of the defendant, with the assent of the plaintiff or his or her attorney, judgment may be given against the defendant in any action before or after answer, for any amount or relief notexceeding or different from that demanded in the complaint.” RCW 4.60.010. “The confessionand assent thereto shall be in writing and subscribed by the parties making the same, andacknowledged by each before some officer authorized to take acknowledgments of deeds.”RCW 4.60.040. “A judgment by confession may be entered without action, either for money dueor to become due, or to secure any person against contingent liability on behalf of the defendant,or both, in the manner prescribed by this chapter.” RCW 4.60.050. “The statement must be presented to the superior court or a judge thereof, and if the same be found sufficient, the court or  judge shall indorse thereon an order that judgment be entered by the clerk; whereupon it may befiled in the office of the clerk, who shall enter a judgment for the amount confessed, with costs.Execution may be issued and enforced thereon in the same manner as upon judgments in other cases.” RCW 4.60.070.Plaintiffs have filed with the Court the Confessions of Judgment against Defendants inthe amount of $18 million executed in the manner prescribed by RCW 4.60.040 and adeclaration of Kiran Kulkarni setting forth the amounts paid to date against the total amount
Case 2:13-cv-01034-MJP Document 41 Filed 08/08/13 Page 3 of 5

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