Gordon v. Virtumundo Inc et al

Filing 106

Second DECLARATION of Robert J. Siegel filed by Plaintiff James S Gordon, Jr re 98 MOTION for Summary Judgment (Attachments: # 1)(Siegel, Robert)

Gordon v. Virtumundo Inc et al

Doc. 106

Case 2:06-cv-00204-JCC

Document 106

Filed 02/12/2007

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MERKLE SIEGEL & FRIEDRICHSEN, P.C. Robert J. Siegel 1325 Fourth Ave., Suite 940 Seattle, WA 98101 [phone]

THE HON. JOHN C. COUGHENOUR

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON, SEATTLE JAMES S. GORDON, Jr., a married individual; OMNI INNOVATIONS, LLC., a Washington limited liability company, Plaintiffs, v. VIRTUMUNDO, INC, a Delaware corporation, d/b/a ADNOWLEDGEMAIL.COM; ADKNOWLEDGE, INC., a Delaware corporation, d/b/a ADKNOWLEDGEMAIL.COM; SCOTT LYNN, an individual; and JOHN DOES, I-X, Defendants. I Robert J. Siegel state and declare as follows: 1. I am counsel of record for Plaintiffs in this matter. NO. CV06-0204JCC DECLARATION OF ROBERT J. SIEGEL IN RESPONSE TO DEFEDNANTS' MOTION FOR SUMMARY JUDGMENT [SEALED DOCUMENT]

DECLARATION OF ROBERT J. SIEGEL IN RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT GORDON v. VIRTUMUNDO GROUP, INC.
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i.Justice Law, P.C.
1325 Fourth Ave., Suite 940 Seattle, WA 98101 Phone: [phone] Fax: [phone]

Dockets.Justia.com

Case 2:06-cv-00204-JCC

Document 106

Filed 02/12/2007

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2. Attached hereto as Exhibit "A" are true and correct copies of numerous complaints by

recipients of unwanted commercial email from both Defendants Virtumundo and AdKnowledge, which copies were provided in response to Plaintiff's discovery requests. These documents were designated as "Confidential" by Defendants, and accordingly are filed under Seal. (The documents are submitted herewith in accordance with this Court's Minute Order of 12/19/06.)

I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct. SIGNED this 12th day of February, 2007, at Seattle, Washington. i.Justice Law, P.C. /s/ Robert J. Siegel_________________ ROBERT J. SIEGEL, WSBA #17312 Attorney for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on this 12th day of February, 2007, I electronically filed the DECLARATION OF ROBERT J. SIEGEL IN RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT with the Clerk of the Court using the CM/ECF System which will send notification of such filing to the following: Attorneys for Defendants: Derek A. Newman, Newman & Newman . Robert J. Siegel, WSBA WSBA #17312 ATTORNEY FOR PLAINTIFFS i.Justice Law P.C. 1325 Fourth Ave., Suite 940 Seattle, WA 98101 [e-mail]

DECLARATION OF ROBERT J. SIEGEL IN RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT GORDON v. VIRTUMUNDO GROUP, INC.
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i.Justice Law, P.C.
1325 Fourth Ave., Suite 940 Seattle, WA 98101 Phone: [phone] Fax: [phone]