Opinion
1:23-cv-01894
06-16-2023
AMP GLOBAL STRATEGIES, LLC, a Pennsylvania limited liability company, Plaintiff, v. ASK COMMUNICATIONS LLC, a Delaware limited liability company, Defendant.
AMP GLOBAL STRATEGIES, LLC, Plaintiff Daniel J. Voelker, Esq. Voelker Litigation Group
AMP GLOBAL STRATEGIES, LLC, Plaintiff
Daniel J. Voelker, Esq.
Voelker Litigation Group
HONORABLE CHARLES P. KOCORAS
PLAINTIFF'S MOTION FOR THE ENTRY OF A MONEY JUDGMENT AGAINST DEFENDANT ASK
Plaintiff, AMP GLOBAL STRATEGIES, LLC, by and through its undersigned attorney, moves this Court pursuant to Rule 54 of the Federal Rules of Civil Procedure for the entry of a money Judgment against Defendant, ASK COMMUNICATIONS LLC, as follows:
1. On March 27, 2023, Plaintiff, AMP Global Strategies, LLC (“AMP”), filed a one-count Complaint for breach of written contract against Defendant, ASK Communications LLC (“ASK”), seeking $225,945.10 ($100,300 in Count I; and $125,645.10 in Count II) in compensatory damages.
2. On June 8, 2023, the Court entered an Order of default against Defendant, ASK.
3. Now, AMP seeks the entry of a money judgment under its Complaint against ASK.
4. In connection therewith, Plaintiff, AMP, submits the Affidavit of Brenda Pugh, Chief Executive Officer of AMP. (A true and correct copy of the Affidavit of Brenda Pugh is attached hereto as Exhibit “A” and made a part hereof).
5. In that Affidavit, Ms. Pugh sets forth the basis of the damages that AMP has sustained as a result of the breach of contract by ASK. (Affidavit of Brenda Pugh at ¶¶ 9-11).
6. The damages sustained by the non-payment of AMP's invoices total $103,000. (Affidavit of Brenda Pugh at ¶ 11).
7. The damages sustained from the breach by ASK of the non-solicitation provision of the Agreement are $43,145.10 and $82,500, for a total of $125,645.10. (Affidavit of Brenda Pugh at ¶¶ 12-18).
8. The total damages sustained by the breaches of contract by ASK total $225,945.10. (Affidavit of Brenda Pugh at ¶ 18).
9. By this Motion, AMP seeks the entry of a judgment in this case against ASK in the amount of $225,945.10, as set forth in its Complaint.
WHEREFORE, Plaintiff, AMP GLOBAL STRATEGIES, LLC, respectfully requests that this Court enter judgment in its favor and against Defendant, ASK COMMUNICATIONS LLC, in the amount of $225,945.10 and for such other and further relief as the Court deems necessary and/or appropriate under the circumstances