medecke antiSLAPP decl exhibits
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
) ) ) Case No.: 8:08-cv-02468 ) ) ) ) ) ) ) ) ) Assigned: ) Hon. Deborah K. Chasanow ) ) ) ) )
GLOBAL DIRECT SALES, LLC, PENOBSCOT INDIAN NATION, CHRISTOPHER RUSSELL, and RYAN HILL, Plaintiffs, -vAARON KROWNE, individually, and d/b/a THE MORTAGE LENDER IMPLODE-O-METER and ML-IMPLODE.COM, KROWNE CONCEPTS, INC., IMPLODE-EXPLODE HEAVY INDUSTRIES, INC. JUSTIN OWINGS, KRISTA RAILEY, STREAMLINE MARKETING, INC. and LORENA LEGGETT, Defendants.
DECLARATION OF ROBIN MEDECKE. IN SUPPORT OF DEFENDANTS’ SPECIAL MOTION TO DISMISS PURSUANT TO MARYLAND COURTS AND JUDICIAL PROCEEDINGS § 5-807
I, Robin Medecke, declare: 1.
I am over 18 years of age and competent to testify in the matters below.
2.
I make the following statements based on my personal knowledge. If called to
testify under oath in a court of law as to the matters set out herein, I could and would do so truthfully.
1
3.
I have researched and written articles criticizing seller-financed down-payment
assistance programs for the IEHI site, including an article entitled “HUD Takes Second Stab at DPA’s – Renewed Proposal Expected,” posted June 16, 2008. A true and accurate copy of the article is attached hereto as Exhibit A. 4.
It was and is the policy of the IEHI’s Mortgage Lender Implode website (“the
Website”) to not advertise firms with suspicious lending practices. 5.
On August 6, 2008, Lorena Leggett asked me to review the Grant America
Program as a potential advertiser for the Website. 6.
I reviewed the Grant America Program homepage and determined that the
program utilized seller-financed down-payment assistance. On the basis of my knowledge of down-payment assistance programs and IEHI’s policies, I told Lorena Leggett that the Website should not advertise the Grant America Program. A true and accurate copy of the electronic mail I sent Lorena Leggett directing her to refuse advertising with the site is attached hereto as Exhibit B.
I declare under penalty of perjury under the laws of the State of Maryland and the United States that the foregoing is true and correct, and that this declaration was executed on November 10, 2009 in Loveland, Ohio.
/s/ Robin Medecke /s/ Robin Medecke
2
EXHIBITS! Exhibit A HUD Takes Second Stab at DPA’s – Renewed Proposal Expected 2008-06-16.............................................................................................................
1
Exhibit B Email from Robin Medecke to Lorena Leggett, August 6, 2008 ..........................
4
A-i
Exhibit A HUD Takes Second Stab at DPA’s – Renewed Proposal Expected 2008-06-16
A-1
Exhibit B Email from Robin Medecke to Lorena Leggett, August 6, 2008 A-4
) ) ) Case No.: 8:08-cv-02468 ) ) ) ) ) ) ) ) ) Assigned: ) Hon. Deborah K. Chasanow ) ) ) ) )
GLOBAL DIRECT SALES, LLC, PENOBSCOT INDIAN NATION, CHRISTOPHER RUSSELL, and RYAN HILL, Plaintiffs, -vAARON KROWNE, individually, and d/b/a THE MORTAGE LENDER IMPLODE-O-METER and ML-IMPLODE.COM, KROWNE CONCEPTS, INC., IMPLODE-EXPLODE HEAVY INDUSTRIES, INC. JUSTIN OWINGS, KRISTA RAILEY, STREAMLINE MARKETING, INC. and LORENA LEGGETT, Defendants.
DECLARATION OF ROBIN MEDECKE. IN SUPPORT OF DEFENDANTS’ SPECIAL MOTION TO DISMISS PURSUANT TO MARYLAND COURTS AND JUDICIAL PROCEEDINGS § 5-807
I, Robin Medecke, declare: 1.
I am over 18 years of age and competent to testify in the matters below.
2.
I make the following statements based on my personal knowledge. If called to
testify under oath in a court of law as to the matters set out herein, I could and would do so truthfully.
1
3.
I have researched and written articles criticizing seller-financed down-payment
assistance programs for the IEHI site, including an article entitled “HUD Takes Second Stab at DPA’s – Renewed Proposal Expected,” posted June 16, 2008. A true and accurate copy of the article is attached hereto as Exhibit A. 4.
It was and is the policy of the IEHI’s Mortgage Lender Implode website (“the
Website”) to not advertise firms with suspicious lending practices. 5.
On August 6, 2008, Lorena Leggett asked me to review the Grant America
Program as a potential advertiser for the Website. 6.
I reviewed the Grant America Program homepage and determined that the
program utilized seller-financed down-payment assistance. On the basis of my knowledge of down-payment assistance programs and IEHI’s policies, I told Lorena Leggett that the Website should not advertise the Grant America Program. A true and accurate copy of the electronic mail I sent Lorena Leggett directing her to refuse advertising with the site is attached hereto as Exhibit B.
I declare under penalty of perjury under the laws of the State of Maryland and the United States that the foregoing is true and correct, and that this declaration was executed on November 10, 2009 in Loveland, Ohio.
/s/ Robin Medecke /s/ Robin Medecke
2
EXHIBITS! Exhibit A HUD Takes Second Stab at DPA’s – Renewed Proposal Expected 2008-06-16.............................................................................................................
1
Exhibit B Email from Robin Medecke to Lorena Leggett, August 6, 2008 ..........................
4
A-i
Exhibit A HUD Takes Second Stab at DPA’s – Renewed Proposal Expected 2008-06-16
A-1
Exhibit B Email from Robin Medecke to Lorena Leggett, August 6, 2008 A-4
