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com E-ttorney at Law 35 Stillman Street, Suite 210 San Francisco, California 94107 Telephone: (415) 742-2303 Attorney for Defendant Anthony Uy
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IO GROUP, INC. d/b/a TITAN MEDIA, a California corporation, Plaintiff, v. ANTHONY UY, an individual, Defendant.
Now Comes Defendant Anthony Uy (Mr. Uy), by and through counsel, and files this Answer to the original Complaint filed by Plaintiff IO Group, INC. (IO Group) as follows:
1. Defendant denies each and every allegation of Paragraph 1 of the complaint. 2. Defendant is without knowledge or information sufficient to admit or deny the facts contained in Paragraph 2 of the complaint. 3. Defendant denies each and every allegation of Paragraph 3 of the complaint with the exception that Defendant admits he is a resident of Torrance, California. 4. Defendant admits the allegations of Paragraph 4 of the complaint.
ANSWER (No. 2:11-cv-03454-CAS-VBK)
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5. Defendant denies each and every allegation of Paragraph 5 of the complaint with the exception that Defendant admits he resides in California. 6. Defendant denies each and every allegation in paragraph 6 of the complaint with the exception that Defendant admits that Venue is proper pursuant to 28 U.S.C. 1400(a). 7. Defendant is without knowledge or information sufficient to admit or deny the facts contained in Paragraph 7 of the complaint with the exception that Defendant denies the allegations contained in the last sentence of Paragraph 7. 8. Defendant is without knowledge or information sufficient to admit or deny the facts contained in Paragraph 8 of the complaint. 9. Defendant is without knowledge or information sufficient to admit or deny the facts contained in Paragraph 9 of the complaint. 10. Defendant is without knowledge or information sufficient to admit or deny the facts contained in Paragraph 10 of the complaint. 11. Defendant denies each and every allegation of paragraph 11 of the complaint with the exception that Defendant is without knowledge or information sufficient to admit or deny the allegation that Plaintiff has at all times been the producer and owner of the audiovisual work Toolbox. 12. Defendant is without knowledge or information sufficient to admit or deny the facts contained in Paragraph 12 of the complaint. 13. Defendant denies each and every allegation of paragraph 13 of the complaint. 14. Defendant denies each and every allegation of paragraph 14 of the complaint. JURY DEMAND 15. Pursuant to Rule 28 of the Federal Rules of Civil Procedure, Defendant demands a trial by jury of all issues properly triable by a jury in this action. AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE. The complaint fails to state a claim for which relief can be granted. -2ANSWER (No. 2:11-cv-03454-CAS-VBK)
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Therefore, Defendant respectfully requests relief as follows: 4
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1. That the Court enter judgment in favor
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3 That the Court award Defendant attorneys fees and costs incurred in defending
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this action pursuant to 17 U.S.C. 505. 9
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4 That the Court grant Defendant such other and additional relief as is just and proper.
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Dated: June 3, 2011.
By,/Af~
Stewart Kellar Attorneys for Defendant Anthony Uy
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