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)
United States of America v. Impulse Media Group Inc
Doc. 47 Att. 4
Case 2:05-cv-01285-RSL
Document 47-5
Filed 10/14/2007
Page 1 of 3
EXHIBIT D
Dockets.Justia.com
Case 2:05-cv-01285-RSL
ImpulseMedia-FTC
Document 47-5
Filed 10/14/2007
Page 2 of 3
To: "Hash, Lauren" From: Robert Apgood Subjec t: Re: United States v. Impulse Media Group Cc : Lauren, IMG will not consent to the motion as unopposed. Regards , --Rob At 10:35 AM 10/9/2007, you wrote: 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 ----- Original Message ----From: Robert Apgood To: Hash, Lauren Sent: Tue Oct 09 11:54:39 2007 Subjec t: Re: United States v. Impulse Media Group Lauren, I have reviewed your client's motion. The language of the motion is somewhat ambiguous, but a reasonable reading of it tends to indicate that the FTCâTMs Regional Director for the Northwes t Region, Charles Harwood, is NOT empowered to bind the Federal Trade Com m is s ion to a settlement 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 Robert S. Apgood 206-624-2379 At 07:03 AM 10/9/2007, you wrote: Rob,
Printed for Robert Apgood
1
Case 2:05-cv-01285-RSL
ImpulseMedia-FTC
Document 47-5
Filed 10/14/2007
Page 3 of 3
I am writing to ask your consent to file the attached motion as unopposed. We plan to file the motion by COB on Wednesday. Sinc erely, 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
2
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