August Image, LLC v. Holistic Heights, LLC et al.
- Denise Cote
- 1:25-cv-04198
- U.S. District Court · Southern District of New York
- 2
In August Image v. Holistic Heights, Judge Wang ordered a damages inquest after defendants’ default, requiring written proof from the parties.
August Image, LLC and the defaulting defendants, Holistic Heights, LLC et al.; the order concerns the evidence and procedures for determining damages, attorney’s fees, and costs.
What happened
In August Image, LLC v. Holistic Heights, LLC et al., the court said the case had been referred for an inquest after the defendants’ default. The opinion does not state the underlying claims or enter a damages award.
The court ordered August Image to submit proposed factual findings, legal conclusions, evidence supporting its requested damages, and documentation for attorney’s fees and costs by December 19, 2025. August Image must serve those materials on the defaulting defendants and file proof of service by December 21, 2025.
The court said it may decide the damages inquiry using written submissions alone. Any party seeking a hearing had to request one in its papers and explain why it was needed and what additional evidence would be presented. Magistrate Judge Ona T. Wang issued the order.
The detailed version
- August Image, LLC v. Holistic Heights, LLC et al. · No. 1:25-cv-04198
- Denise Cote
- Nov. 17, 2025
Background
The matter was referred to Magistrate Judge Ona T. Wang for an inquest following a default by the defendants. An inquest is a proceeding to determine the amount of damages and any related fees or costs after a defendant has defaulted. The opinion does not describe August Image’s underlying claims or state that the court had entered a final damages judgment.
Court’s instructions
The court ordered August Image to file, by December 19, 2025:
- proposed findings of fact and conclusions of law; and - an inquest memorandum explaining and supporting its damages request.
The proposed damages figures had to be supported by documents and/or one or more affidavits. August Image also had to provide documentation supporting its requested attorney’s fees and costs.
August Image was required to serve these materials on the defaulting defendants and file proof of service on the docket by December 21, 2025. The opinion states that any opposition papers from the defendants were due January 9, 2025.
Hearing and disposition
The court notified the parties that it might conduct the damages inquest solely through written submissions. A party seeking an evidentiary hearing had to request one in its papers, explain why the hearing was necessary, and identify the additional evidence that would be presented.
Judge Wang therefore set procedures for determining damages, fees, and costs after the default. The order did not determine the amount owed and did not state that a hearing would occur.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.