Silva Cover Page AWS
Case 3:17-cv-00391-HZ
Document 6-2
Filed 03/21/17
Page 1 of 3
UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION
VICKY SILVA, a consumer residing in Oregon, individually and on behalf of all others similarly situated,
Case No. 3:17-cv-00391-HZ COVER PAGE
Plaintiff, v. UNIQUE BEVERAGE COMPANY, LLC, a foreign corporation, Defendant.
Exhibit 3 Defendant’s March 14 letter
COVER PAGE
Case 3:17-cv-00391-HZ
Document 6-2
Filed 03/21/17
4580 Klahanie Drive S.E., Suite 165 Sammamish, WA 98029
Page 2 of 3
(425) 392-1548 FAX (425) 526-5791 [email protected]
ADMITTED IN WASHINGTON, OREGON AND ARIZONA
March 14, 2017 VIA EMAIL ONLY [email protected] [email protected] [email protected] [email protected] [email protected] Mark Geragos Ben Meiselas Geragos & Geragos 644 S. Figueroa Street Los Angeles, CA 90017-3411 Michael Fuller Rex Daines Olsen Daines PC 111 S.W. 5th Avenue, Suite 3150 Portland, OR 97204 Re:
Silva v. Unique Beverage Company, LLC U.S. District Court for the District of Oregon Case No. 3:17-cv-391 (Defendant Unique’s Representation by Counsel)
Dear Mark, Ben, Michael and Rex, My law firm and I represent Unique Beverage Company, LLC (“Unique”). We received a copy of the Complaint that you filed against Unique on behalf of Vicky Silva. Neither a Summons nor the Complaint have been served on Unique. It has come to our attention that your law firms have already violated Oregon Rule of Professional Conduct (“ORCP”) 3.6(a) by issuing press releases and/or making public statements to media outlets regarding this frivolous lawsuit. For those of you who are also California attorneys, it appears that your conduct likewise violates California Rule of Professional Conduct 5-120(A). There is no question that your intention in doing so was to prejudice Unique’s ability to defend against your unfounded allegations. Frankly, it’s not a noble way for you to begin this lawsuit in Oregon.
Silva Exhibit 3 – Page 1 of 2
Case 3:17-cv-00391-HZ
Document 6-2
Filed 03/21/17
Page 3 of 3
HOCHMAN LEGAL GROUP, PLLC
Mark Geragos Ben Meiselas Michael Fuller Rex Daines March 14, 2017 Page 2 We take your actions and ethical violations seriously. As such, we will pursue all necessary and ethical measures to ensure that our client’s rights are protected and that your unethical conduct receives the appropriate consequences. You, your co-counsel and your respective staff are not authorized to communicate with Unique or any of its personnel at any time. Rather, you are instructed to direct all communications regarding this lawsuit and/or Unique, except original service of process, to only my attention. Our law firm’s mailing address is: Hochman Legal Group PLLC, Attn.: Joe Hochman, 4580 Klahanie Drive S.E., Suite 165, Sammamish, WA 98029. You are welcome to contact me with any questions. My telephone number is (425) 3921548. My email address is [email protected]. Sincerely, HOCHMAN LEGAL GROUP, PLLC
By: Joe Hochman, Managing Attorney cc:
Unique Beverage Company, LLC
Silva Exhibit 3 – Page 2 of 2
Document 6-2
Filed 03/21/17
Page 1 of 3
UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION
VICKY SILVA, a consumer residing in Oregon, individually and on behalf of all others similarly situated,
Case No. 3:17-cv-00391-HZ COVER PAGE
Plaintiff, v. UNIQUE BEVERAGE COMPANY, LLC, a foreign corporation, Defendant.
Exhibit 3 Defendant’s March 14 letter
COVER PAGE
Case 3:17-cv-00391-HZ
Document 6-2
Filed 03/21/17
4580 Klahanie Drive S.E., Suite 165 Sammamish, WA 98029
Page 2 of 3
(425) 392-1548 FAX (425) 526-5791 [email protected]
ADMITTED IN WASHINGTON, OREGON AND ARIZONA
March 14, 2017 VIA EMAIL ONLY [email protected] [email protected] [email protected] [email protected] [email protected] Mark Geragos Ben Meiselas Geragos & Geragos 644 S. Figueroa Street Los Angeles, CA 90017-3411 Michael Fuller Rex Daines Olsen Daines PC 111 S.W. 5th Avenue, Suite 3150 Portland, OR 97204 Re:
Silva v. Unique Beverage Company, LLC U.S. District Court for the District of Oregon Case No. 3:17-cv-391 (Defendant Unique’s Representation by Counsel)
Dear Mark, Ben, Michael and Rex, My law firm and I represent Unique Beverage Company, LLC (“Unique”). We received a copy of the Complaint that you filed against Unique on behalf of Vicky Silva. Neither a Summons nor the Complaint have been served on Unique. It has come to our attention that your law firms have already violated Oregon Rule of Professional Conduct (“ORCP”) 3.6(a) by issuing press releases and/or making public statements to media outlets regarding this frivolous lawsuit. For those of you who are also California attorneys, it appears that your conduct likewise violates California Rule of Professional Conduct 5-120(A). There is no question that your intention in doing so was to prejudice Unique’s ability to defend against your unfounded allegations. Frankly, it’s not a noble way for you to begin this lawsuit in Oregon.
Silva Exhibit 3 – Page 1 of 2
Case 3:17-cv-00391-HZ
Document 6-2
Filed 03/21/17
Page 3 of 3
HOCHMAN LEGAL GROUP, PLLC
Mark Geragos Ben Meiselas Michael Fuller Rex Daines March 14, 2017 Page 2 We take your actions and ethical violations seriously. As such, we will pursue all necessary and ethical measures to ensure that our client’s rights are protected and that your unethical conduct receives the appropriate consequences. You, your co-counsel and your respective staff are not authorized to communicate with Unique or any of its personnel at any time. Rather, you are instructed to direct all communications regarding this lawsuit and/or Unique, except original service of process, to only my attention. Our law firm’s mailing address is: Hochman Legal Group PLLC, Attn.: Joe Hochman, 4580 Klahanie Drive S.E., Suite 165, Sammamish, WA 98029. You are welcome to contact me with any questions. My telephone number is (425) 3921548. My email address is [email protected]. Sincerely, HOCHMAN LEGAL GROUP, PLLC
By: Joe Hochman, Managing Attorney cc:
Unique Beverage Company, LLC
Silva Exhibit 3 – Page 2 of 2
