Carl D. Crowell, OSB No. 982049 

email: carl@crowell-law.com 

Drew P. Taylor, OSB No. 135974 

email: drew@crowell-law.com 

CROWELL LAW 

P.O. Box923 

Salem, OR 97308 

(503) 581-1240 

Of attomeys for plaintiff 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

COBBLER NEVADA, LLC, 

Plaintiff, 

,,· < 

Case No.: 3:15-cv-01075$1' J B 

STIPULATED CONSENT JUDGMENT 

v. 

CHERISSE WATTS, 

Defendant. 

STIPULATED CONSENT JUDGMENT 

As attested to by the signatures of counsel for the parties below, this matter comes before 

the Court on the parties' joint stipulation. 

Plaintiff Cobbler Nevada, LLC has filed a Complaint against the defendant in the Oregon 

district court for copyright infringement, 17 U.S.C. §§101, et seq, for the unlicensed copying, 

promotion and distribution of plaintiffs' motion picture titled The Cobbler, registered with the 

United States Copyright Office, Reg. No. PAu 3-744-688, 2014. Voltage Pictures, LLC joins in 

this settlement to effect a full release of claims as they may relate to the parties. 

CONSENT JUDGMENT- STIPULATED Page 1of4 

Case 3:15-cv-01075-SB Document 26 Filed 03/17/16 Page 1 of 4
After initial discovery and investigation, defendant, originally identified as DOE67.168.245.223 was affirmatively identified Cherisse Watts of Clackamas, Oregon as the proper 

defendant in this matter. 

The parties and non-party Voltage Pictures LLC, after conferral and investigation, now 

appear to fully and finally resolve all claims between the them, known or unknown, arising prior 

to the date of this settlement, and whether or not the subject of the specific allegations and the 

matters presently before the Court, and have moved for entry of this Stipulated Consent 

Judgment to effect the terms of their settlement. 

WHEREFORE IT IS HEREBY STIPULATED AND ORDERED for all matters relevant to this 

case between the parties as follows: 

1. This court has jurisdiction over the parties and venue is proper. 

2. Plaintiff Cobbler Nevada, LLC has valid and enforceable copyrights in the original 

copyrighted work, The Cobbler, ("motion picture") registered with the United States 

Copyright Office, Reg. No. PAu 3-744-688, 2014. 

3. Plaintiff Voltage has valid and enforceable trademark rights in the branding associated 

with the motion picture and related promotional materials and associate rights in other 

films that may be related to this action. 

4. The signatories agree that Cherisse Watts is the proper named defendant in this case. 

5. Plaintiff and Cherisse Watts expressly consent to have a United States Magistrate Judge 

conduct any and all proceedings in this case, including entry of orders, including this 

stipulation or any other final judgment or orders arising therefrom. 

6. Cherisse Watts and counsel have fully reviewed the Complaint and the allegations of the 

CONSENT JUDGMENT- STIPULATED Page 2of 4 

Case 3:15-cv-01075-SB Document 26 Filed 03/17/16 Page 2 of 4
Complaint and specifically admit plaintiff's investigations identifying the IP address used 

by DOE-67 .168,245 .223 were accurate, in particular in accurately identifying IP address 

67.168.245.223 as the IP address used to download and distribute plaintiff's motion 

picture and other content identified with the Complaint. 

7. In addition to other tenns in a separate settlement agreement, the parties further agree and 

require pursuant to the settlement the below Permanent Injunction be entered against 

Cherisse Watts. 

PERMANENT INJUNCTION 

Cherisse Watts Is hereby PERMANENTLY ENJOINED from directly, contributorily or 

. l/1'e (nU/uJ · 

indirectly infringing plaintiffs rights in their motion picture/I Cherlsse Watts is further enjoined 

from using the internet to reproduce or copy any Voltage owned or branded motion pictures, to 

distribute any Voltage owned or branded motion pictures, or to make Voltage owned or branded 

motion pictures available for distribution to the public, except pursuant to a lawful written I 

. (See /i'<1f of V!i/fd"e,~fl!NfltrJ fi"He.r a,,-f www. v~l~J< ptG1/ur'CJ.a:'1t1;) license from Voltage. - I -f,f/e.J 

Cherisse Watts is hereby directed to immediately delete all unlicensed content in which 

{~ a,/,•"(, /iJf"). Voltage has any rights or interest, including plaintiffs motion picture~~th..any-an<htll· 

indirectly participating or fuctlitating In peer-ttr-:peerand BitTurrentf'tle~xvhange&in~violation 

CONSENT JUDGMENT - STIPULATED Page 3 of4 

Case 3:15-cv-01075-SB Document 26 Filed 03/17/16 Page 3 of 4
With entry of this consent judgment his matter is terminated. 

SO ORDERED, this day: ;Ill ittth lfi ;}p/fv.. 

{ aJ rmJi~tJ) 

So Stipulated and Respectfully Submitted: 

Defendant: 

CONSENT WDGMENT- STIPULATED 

United States Magistrate Judge 

On Behalf of Plaintiff Cobbler Nevada LLC: 

/SI Carl D. Crowell 

Carl D. Crowell, OSB # 982049 

email: carl@crowell-law.com 

Crowell Law 

P.O. Box923 

Salem. OR 97308-0923 

Phone:503-581-1240 

Of counsel for plaintiffs 

On Behalf of non-party Voltage Pictures LLC: 

Isl Carl D. Crowell 

Carl D. Crowell, OSB # 982049 

email: carl@crowell-law.com 

Crowell Law 

P.O. Box923 

Salem, OR 97308-0923 

Phone:503-581-1240 

Page 4 of 4 

Case 3:15-cv-01075-SB Document 26 Filed 03/17/16 Page 4 of 4