Omni Innovations LLC v. Ascentive LLC et al

Filing 15

DECLARATION of Floyd E. Ivey filed by Defendant Ascentive LLC re 3 MOTION to Disqualify Floyd E. Ivey (Ivey, Floyd)

Omni Innovations LLC v. Ascentive LLC et al

Doc. 15

Case 2:06-cv-01284-JCC

Document 15

Filed 10/20/2006

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Floyd E. Ivey Liebler, Ivey, Connor, Berry & St. Hilaire 3 1141 N. Edison, Suite C P.O. Box 6125 4 Kennewick, WA 99336 Telephone [phone] Fax [phone] Attorneys for Defendant
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Hon. Judge Zilly

DOUGLAS E. MCKINLEY, JR. Attorney At Law P.O. Box 202 Richland, Washington 99352 8 509-628-0809 Fax [phone] Attorney for Plaintiff
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DeclarationIvey Motion Opposing Plaintiff's Motion to Disqualify 1.
Z:\IPClient\Ascentive LLC v. Gordon\Ascentive v. Omni Innovations\Motions\MotionDisqualify\Motion toDisqualify.DECIVEY.061020.wpd

ROBERT J. SIEGEL 1325 4th Ave Ste 940 Seattle, WA 98101-2509

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON ) ) ) Plaintiffs ) ) ASCENTIVE, LLC ) a Delaware Limited Liability Company; ) ADAM SCHRAN, individually and as part ) of his marital community; JOHN DOES, I-X) Defendants ) ) ___________________________________ ) LLC in this matter on October 20, 2006. I have separately moved for the Rescheduling or Striking of Plaintiffs' Motion to Disqualify. I have reviewed the Declaration of Mr. James Gordon in Support of Disqualification. Mr. Gordon alleges that I have provided assistance to Mr.
LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE Attorneys at Law P.O. Box 6125 Kennewick, Washington 99336-0125 [phone]

OMNI INNOVATIONS LLC et al

NO. CV-06-01284-TSZ DECLARATION OF FLOYD E. IVEY IN RESPONSE TO PLAINTIFFS' MOTION TO DISQUALIFY COUNSEL FLOYD E. IVEY

Floyd E. Ivey now declares that I have appeared for Defendant Ascentive,

Dockets.Justia.com

Case 2:06-cv-01284-JCC

Document 15

Filed 10/20/2006

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Gordon regarding Omni Innovations LLC. I find no record of having consulted with or having undertaken any work relative to Omni Innovations LLC. I have had, in years past, minimal contact with Mr. Gordon. That prior contact is fully addressed in the Exhibits and Memorandum which is identified as Exhibits to the Defendants' Memorandum Opposing Plaintiff's Motion to Disqualify. The Exhibits annexed to Mr. Gordon's Declaration, in this present matter, were previously considered in a like Motion to Disqualify brought in a like case by Mr. Gordon's wife in the Eastern District. I find no file, no memos, notes or any evidence that assistance was provided to Mr. Gordon relative to Omni Innovations LLC. However, it is with certainty that I have not engaged in any effort regarding Omni Innovations LLC and any issue in the case of Omni Innovations LLC. Any contact by Mr. Gordon with this office relative to his intent to pursue violations of RCW 19.190 are documented in the email annexed to Mrs. Gordon's Declaration in the Eastern District matter of Gordon v. Impulse Marketing Group. DATED this 20th day of October, 2006 LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE By s/ FLOYD E. IVEY FLOYD E. IVEY, WSBA #6888 Counsel for Defendant 1141 N. Edison, Suite C Kennewick, WA 99336

I hereby certify that on October 20, 2006, I electronically filed Declaration of Floyd E. Ivey Opposing Motion to Disqualify with the Clerk of the Court using the CM/ECF System which will send notification of such filing to Plaintiffs' 24 counsel Robert J. Siegel and Douglas McKinley. S/ FLOYD E. IVEY FLOYD E. IVEY 25
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DeclarationIvey Motion Opposing Plaintiff's Motion to Disqualify 2.
Z:\IPClient\Ascentive LLC v. Gordon\Ascentive v. Omni Innovations\Motions\MotionDisqualify\Motion toDisqualify.DECIVEY.061020.wpd

LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE Attorneys at Law P.O. Box 6125 Kennewick, Washington 99336-0125 [phone]