United States of America v. Impulse Media Group Inc

Filing 47

DECLARATION of Robert S. Apgood filed by Defendant Impulse Media Group Inc re 45 MOTION for Relief Request Regarding Attendance at Court Ordered Settlement (Attachments: # 1 Exhibit A - EMail request by Plaintiff for Defendant to agree to filing of Plaintiff's Request Regarding Attendance unopposed# 2 Exhibit B - Proposed Order Plaintiff provided when seeking Defendant's agreement to allow to be filed unopposed# 3 Exhibit C - EMail messages between counsel clarifying terms in proposed motion# 4 Exhibit D - EMail from Defendant's counsel to Plaintiff's counsel declining to agree to filing of motion as unopposed)(Apgood, Robert)

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United States of America v. Impulse Media Group Inc Doc. 47 Att. 3 Case 2:05-cv-01285-RSL Document 47-4 Filed 10/14/2007 Page 1 of 4 EXHIBIT C Dockets.Justia.com Case 2:05-cv-01285-RSL ImpulseMedia-FTC Document 47-4 Filed 10/14/2007 Page 2 of 4 To: "Hash, Lauren" From: Robert Apgood Subjec t: Re: United States v. Impulse Media Group Cc : Lauren, I have reviewed your client's motion. The language of the motion is somewhat ambiguous, but a reas onable reading of it tends to indicate that the FTC's Regional Director for the Northwest Region, Charles Harwood, is NOT empowered to bind the Federal Trade Commission to a s ettlem ent on its behalf. If this is an accurate reading of the motion, the defendant, Impulse Media Group, does not consent to the motion as unopposed. Regards , CarpeLaw PLLC R o b e rt S. Apgood 206-624-2379 At 07:03 AM 10/9/2007, you wrote: Rob, I am writing to ask your consent to file the attached motion as unopposed. We plan to file the motion by COB on Wednesday. Sincerely, Lauren Hash United States Department of Justice O ffic e of Consumer Litigation P.O. Box 386 W as hington, DC 20044 lauren.has h@us doj.gov 202-353-1991 Printed for Robert Apgood 1 Case 2:05-cv-01285-RSL ImpulseMedia-FTC Document 47-4 Filed 10/14/2007 Page 3 of 4 Subject: Re: United States v. Impulse Media Group From: "Hash, Lauren" To: Rob, It is an accurate reading >From : Robert Apgood >To: Hash, Lauren >Sent: Tue Oct 09 11:54:39 2007 >Subjec t: Re: United States v. Impulse Media Group ...s nip... > O ffic e of Consumer Litigation > P.O. Box 386 > W as hington, DC 20044 > lauren.has h@us doj.gov > 202-353-1991 Printed for Robert Apgood 1 Case 2:05-cv-01285-RSL ImpulseMedia-FTC Document 47-4 Filed 10/14/2007 Page 4 of 4 Subject: Re: United States v. Impulse Media Group From: "Hash, Lauren" To: Rob, My last email was cut off. It is an accurate reading that Charles Harwood Is not empowered to bind the FTC. To be clear, IMG will not consent to this motion as unoppos ed? Thank you, Lauren Hash >From : Robert Apgood >To: Hash, Lauren >Sent: Tue Oct 09 11:54:39 2007 >Subjec t: Re: United States v. Impulse Media Group ...s nip... > O ffic e of Consumer Litigation > P.O. Box 386 > W as hington, DC 20044 > lauren.has h@us doj.gov > 202-353-1991 Printed for Robert Apgood 1