TIN 15/08:
The Court has entered judgment in plaintiff’s favor in the amount of $550,000. At the same time, the Court ordered that the assets of Defendant FF Magnat Limited, d/b/a Oron.com (“Oron”) remain “frozen, in order to satisfy any fee award which may be sought by Plaintiff.” Plaintiff has requested $199,821.50 in attorneys’ fees and costs.
Oron respectfully requests that the Court “unfreeze” all of Oron’s assets over and above the amount necessary to satisfy plaintiff’s judgment and pay all attorneys’ fees and costs that the plaintiff has requested and may be awarded.1 Thus, Oron requests an order specifying that all of its assets are unfrozen except for $749,821.50, which will remain frozen in Oron’s PayPal account in the United States. A proposed form of order is attached hereto. There is no reason for any additional assets to be frozen.
Oron desires to file a post-judgment motion or motions in this Court, and if necessary an appeal in the Ninth Circuit. Oron requests that the Court stay execution on its judgment until after Oron’s post-judgment motions can be decided and after Oron has the opportunity to ask the Ninth Circuit to stay execution on the judgment. Plaintiff’s judgment will be adequately protected by the $550,000 which will remain frozen in Oron’s PayPal account. If the Court is unwilling to unfreeze all of Oron’s assets over and above the amount of the judgment and requested attorneys’ fees, Oron requests in the alternative that the Court allow the disbursement of additional funds now frozen by this Court for (1) payment of attorneys’ fees to allow the filing of post-judgment motions in this Court and/or an appeal of this Court’s judgment to the Ninth Circuit, and (2) posting a bond for purposes of appealing the Court’s judgment.
Finally, Oron requests that the Court order that plaintiff cease its efforts to enforce the Court’s judgment until the fourteen-day automatic stay on enforcement in FRCP 62(a) expires.