13 4 15 16 7 18 19 20 a 2 2B 24 25 26 Page 1 = JUN 23 2019 FILED IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MARION IN THE MATTER OF: CaseNo. 15CV16018 HENRY CRICKET GROUP, LLC; MAXIMILLIAN, INC; LIBERTY PUBLISHERS SERVICE, INC; ORBITAL PUBLISHING GROUP, INC.; EXPRESS ASSURANCE OF VOLUNTARY PUBLISHERS SERVICE, INC; ASSOCIATED| COMPLIANCE PUBLISHERS NETWORK, INC. UNITED PUBLISHERS NETWORK; ADEPT MANAGEMENT, INC.; CUSTOMER ACCESS| SERVICES, INC.; CONSOLIDATED. PUBLISHERS EXCHANGE, INC; MAGAZINE CLEARING EXCHANGE, INC; SUBSCRIPTION HOUSE AGENCY, INC.; MAGAZINE LINK, INC; PUBLISHERS | PAYMENT PROCESSING, INC; ANCHOR PUBLISHING GROUP, INC; CLARITY GROUP, INC.; WINEOCEROS WINE CLUB, INC, CPC SOLUTIONS, INC. REALITY KATS, LLC; HOYAL & ASSOCIATES, INC. LAURA LOVRIEN; COLLEEN M, KAYLOR; SHANNON R. BACON; LYDIA J. PUGSLEY; NOEL PARDUC INDA BABB; WILLIAM STRICKLER; RACHEL WORCESTER: JEFFREY HOYAL; DENNIS SIMPSON Respondents, 1 This Assurance of Voluntary Compliance (AVC) is offered by each of the following Respondents, to the Oregon Department of Justice (DOJ), acting pursuant to ORS 646.632: 591482 HENRY CRICKET GROUP, LLC; MAXIMILLIAN, INC. LIBERTY PUBLISHERS SERVICE, IN ORBITAL PUBLISHING GROUP, INC. EXPRESS PUBLISHERS SERVICE, IN( ASSOCIATED PUBLISHERS NETWORK, INC.; UNITED PUBLISHERS NETWORK; ASSURANCE OF VOLUNTARY COMPLIANCE, DEPARTMENT OF JUSTICE > "2 Caon Sse NE Salon, OR 9701-4096 (st oats FAN (55) 378-5017 [STATE OF OREGON. [Marion County Circuit Courta 2 23 4 2% 26 ADEPT MANAGEMENT, INC. CUSTOMER ACCESS SERVICES, INC.; CONSOLIDATED PUBLISHERS EXCHANGE, IN MAGAZINE CLEARING EXCHANGE, INC.; SUBSCRIPTION HOUSE AGENCY, INC MAGAZINE LINK, INC.; PUBLISHERS PAYMENT PROCESSING, INC. ANCHOR PUBLISHING GROUP, IN CLARITY GROUP, INC; WINEOCEROS WINE CLUB, INC CPC SOLUTIONS, INC.; REALITY KATS, LLC; HOYAL & ASSOCIATES, INC.; LAURA LOVRIEN; COLLEEN M. KAYLOR; SHANNON R. BACO! LYDIA.J. PUGSLE NOEL PARDUCCI; LINDA BABB: ‘WILLIAM STRICKLER; RACHEL WORCESTER; JEPFREY HOYAL; DENNIS SIMPSON A This AVC is a settlement of a dispnted matter, set forth more fully in the records and files of, State v, Henry Cricket Group, LLC, et. al., Marion County-Circuit Court No. 1SCVOT765 (“Lavisuit”). Respondents expressly deny any and all of the allegations set forth in ‘the records and files of the Lawsuit. Nothing in this document shall be construed to be an admission of fact or law by any Respondent. Respondents and DOJ agree that no provision of this AVC operates as a penalty, forfeinure, or punishment under the Constitution of the United States, under the Constitution of the State of Oregon, or under any other provision of law. 3. Respondents and the Oregon Departinent of Justice hereby release and discharge each other of and fiom any and all mown or unkown or unforeseen actions, claims, liabilities, injury, losses, rights of contribution or indemnity, and damages without limitation, to include ‘but not Himited to those which are alleged or which may develop which are in any way connected with or based upon the transactions described in the records and files of the Lawsuit. Page 2- ASSURANCE OF VOLUNTARY COMPLIANCE, 5591482 DEPARTMENT OF JUSTICE 162 Cout Seat NE Salem, OF 9701-4056 (605) 93-4400 FAX: 03) 378-5017n 2 B 4 15 16 a 18 19 20 a 22 2B 24 25 26 This release includes all claims that were brought, or could have been brought, by the Attomey General on behalf ofthe State of Oregon, tothe full extent of the power of the Oregon Attorney General. This release also includes all claims which Respondent has or might have against the State of Oregon as a result of the investigation or prosecution of this matter. 4 Respondents expressly acknowledge and agree that nothing herein shall be construed to limit the rights of any district attorney, or of any other State, or of the United States, or of any individual Oregon consumer, or of classes of consumers, from bringing charges, claims or causes of action which arise, or which may arise, from the transactions or business practices alleged in the Complaint and the records and files of the Lawsuit. 5 Respondents acknowledge receipt of notice from the State of Oregon pursuant to ORS 646.632(2), or waive such notice of the alleged unlawful trade practice and the relief to be sought 6. Respondents understand and agree this AVC applies to each Respondent, any entity a Respondent owns, operates or controls, the officers, directors, agents, employees, representatives, successors and assigns of such entities, jointly and severally, while acting, personally, or through any corporation of other business entities, whose acts, practices or policies are directed, formulated or controlled by a Respondent. 7 ‘Respondents understand and agree that if this AVC is accepted by DOI, it will be submitted to the Circuit Court of the State of Oregon for Mation County for approval, and, if approved, will be filed with the Court pursuant to ORS 646.6322). w Ww Page 3- ASSURANCE OF VOLUNTARY COMPLIANCE, 591482 DEPARIMENT OF JUSTICE 2 Cows Start NE Sale, OR 97301-4095 3) 934-1400 AX: (60) 378.50072 3 4 10 u 2 13 4 15 16 7 18 19 20 21 22 23 24 25 26 8. Bach Respondent waives any further notice of submission to and filing with the Court of this AVC, Each Respondent agrees to accept service of a conformed or court cerlified copy by prepaid first class mail sent to Respondents? attomeys, William F. Gary, Shaton A. Rudnick, or David Lennon, 8. Respondents understand thet, in addition to any other sanctions which may be imposed under this AVC or under the law, violation of any of the terms of this AVC may result in contempt of court proceedings, civil penalties of up to $25,000 for each violation, and such. further relief as the court may deem appropriate, ORS 646.632(4), ORS 646.642(1) and ORS 646.6422) 10. The parties acknowledge that no other promises, representations or agreements of any nature have been made or entered into by the parties. The parties further acknowledge that this AVC constitutes a single and entire agreement that is not severable or divisible, except that if any provision herein is found to be legally insufficient or unenforceable, the remaining provisions shall continue in full foree and effect 11 Respondents shall not represent or imply that DOJ acquiesces or approves of Respondent's past business practices, current efforts to reform their practices, or any fixture practices which Respondent may adopt or consider adopting, DOJ's decision to setle this matter or to otherwise unilaterally limit current of future enforcement action does not constitute approval or imply authorization for any past, present, or future business practice. " a “a Page4- ASSURANCE OF VOLUNTARY COMPLIANCE 591482 DEPARTMENT OF JUSTICE Te2 Coun Set NE Salem, S730 4096 (5 gato PAX (503) 378-50171 PROHIBITED CONDUCT. : Buch Reon i peer eid fm engaging in ayo al ofthe {allowing 4 conduct: 5 a) From using the United States Mails, the intent, telephone systems, or private 6 couriers to engage in any activity prohibited by this AVC; z ') From conspiring with any other person or entity to violate this AVC; ‘ ) From engaging in the magazine or newspaper subscription business. This includes . the sale of newspaper or magazine subscriptions, conducting business as a bu subscription clearing house, and using, purchasing renting, ot leasing any castomer a list for amy third party B MANDATORY CONDUCT — RESTITUTION “4 1B 18 Respondents shall pay Restitution according to the terms of this AVC. ‘The restitution 16 ni shall be administered by an Administentor chosen after he execution of his AVC and q deemed mtually acceptable by Respondents and the State. The Administrator shall be paid 1g om the Restitution Fund established herein. 20 4 21 ‘Within seven days oftheir execution ofthis AVC, Respondents shall tender to the 22 Administrator the sum of $250,000, which the Administrator will deposit into an account from 23 which he or she will pay claims relating to the restitution program. If, duting the course of the 4. 24 sestitution program, the balance of these fimds drops below $150,000, Respondents, within 25 seven days of receiving written notice from the Administrator, shall tender such additional sums 26 Page 5- ASSURANCE OF VOLUNTARY COMPLIANCE 5591482 DEPARTMENT OF.1USTICE ea course Ne Sale, OR 973014096 (603) 95444007 FAX: (50) 3701710 in 12 13 4 15 16 7 18 19 20 a 2 B 24 25 26 as may be necessary to maintain the restitution fund at the level of $250,000 — but in no event shall Respondents be responsible for paying more than $500,000 into the fund. Money from the fund shall be used by the Administrator to pay consumer restitution, and to pay the costs of ‘administering the restitution program. Any unused balance in the consumer fund account, as of the closure of the restitution program, shall be retumed to Respondents so the funds may be made available for use in other restitution programs as may be agreed upon by Respondents and other States. 1s. ‘The Respondents shall cooperate with all reasonable requests for information as made by the Department or by the Administrator, which information is reasonably related to identifying consumers who are eligible for refunds, or for determining the amounts of refunds. 16. Restitution will be provided to “eligible consumers” who, between January 1, 2010 and August 1, 2015, met the following eriteria, based on the electronic records and files maintained by defendants, and upon consumer complaints received by the Oregon Department of Justice: a) The consumer lived in Oregon; b) The consumer ordered newspaper or magazine subscriptions from one or more of the Respondents; ) The consumer paid money for the newspaper or magazine subscriptions; 4) The consumer makes a claim in writing for restitution within 120-days after the Department or the Administrator fitst provides the consumer with written notice of the restitution program; and, Page 6~ ASSURANCE OF VOLUNTARY COMPLIANCE, e914. DEPARTMENT OF 1USTICE 1162 Cour suect NE Sule, OR 97301-4096 (60 94007 FAX 3) 3785017€) Restitution eligible persons also include Oregonians who, since January 1, 2010, 22. money those consumers paid for subscriptions or renewals during the time referenced in the 1 . hhave made past complaints to the Oregon Department of Justice which, to date, have 3 not been the subject of full refunds from Respondents | ‘ 1. 5 Eligible consumers shall be classified as follows, for purposes ofthe restitution : program: ’ a) Category A consumers: those who were 65 years of age or older atthe time ; they purchased subscriptions ftom one or more Respondents, which called for 0 the delivery of the publications beyond 3 years from the date of the consumer's ry order; i n ) Category B consumers: those who purchased subscriptions, but did not receive | 13 delivery of the publications, or they received delivery of a “substitute” | ts publication not explicitly requested by the consumer; | ® ©) Category C consumers: those who purchased subscriptions, despite that the | = publication was a free benefit to members of consumer organizations (for | 8 example, Trout Unlimited); and, | 19 4) Category D consumers: the remaining consumers who purchased subscriptions ' | 18, 2 Category A, B and C consumers shall be paid restitution in an amount equal to all | | 73 consumer's claim for restitution. Category D consumers shall be paid restitution in an amount | 74 alto the money paid by the consumer, less amounts previously refunded to the consumer by | 7 Respondents, less the newsstand price for magazines tht the consumer received antl did not Page7- ASSURANCE OF VOLUNTARY COMPLIANCE | oso DEPARTMENT OF JUSTICE, 1162 Cont Stet NE Salem, OR 97301-4096, (608) 9-10 FAX: 50H 3785017So) oo) 1 10 iW 2 13 4 15 16 7 18 19 20 2 22 23 24 28 26 return before cancellation, Ifa consumer was previously paid a partial refund, but Respondents withheld a service fee (e.g, a $20 service fee), then the consumer shall be refunded the service fee previously withheld. MANDATORY CONDUCT — PAYMENT TO CP&E REVOLVING ACCOUNT 19. Within seven days of executing this AVC, Respondents shall tendcr to the Department ‘the sum of Three Million Dollars ($3.0 million), for deposit into the Consumer Protection and Education Revolving Account established by ORS 180.095, to be used as Oregon law may provide. RESPONDENTS” SIGNATURES AND ACKNOWLEDGMENTS: I, NOEL PARDUCCT, have read and understand this Assurance of Voluntary ‘Compliance, and each of its terms, and Thave conferred with my attomeys tegarding it. I agree ‘to each and every term, on behalf of myself, personally, and on bebalf of the following corporations: Henry Cricket Group, LLC, Maximillian, Inc., Liberty Publishers Service, Ine., Orbital Publishing Group, Inc., Express Publishers Service, Ine. Associated Publishers Network, Inc., and United Publjshers Net SUBSCRIBED AND SWORN to before me this (E day of June, 2015. Notary ca art Naat or u Page 8- ASSURANCE OF VOLUNTARY COMPLIANCE, ‘eso1see [DBPARTMENT OF JUSTICE Vee Cour svete Soke, OR 973014056 (03) 934-180/ BAX: (03)78-50171 L, LYDIA PUGSLEY, have read and understand this Assurance of Voluntary Compliance, and each of its terms, and Thave conferred with my attomeys regarding it. I agree 2 toeach and every term, on behalf of myself, personally, and on behalf of Adept Management, ine... SUBSCRIBED AND SWORN to before me tis Cay of June, 205. cise Magis Ntedics — bic for Oregon 1, COLLEEN KAYLOR, have sead and understand this Assurance of Voluntary 11 Compliance, and each of its terms, and I have conferred with my attomeys regarding it.I agree ‘0 each and every term, on behalf of myself, personally, and on behalf of Customer Access 12 Services, Inc., Magazine Clearing Exchange, Inc., Magazine Link, Inc., and, CPC 19. [PRVECRssON EXPIRES FEBRUARY 25,2018 J, SHANNON BACON, have read and understand this Assurance of Voluntary 20 Compliance, and each of its terms, and I have conferred with my attorneys regarding it. Tagree to each and every term, on behalf of myself, personally, and on behalf of Subscription House 21 Agency, Inc., Publishers Payment Processing, Inc., and Clarity Group, Inc., Consolidated Publishers Exchange, Inc. Solutions, Inc.. cE 14 Sighatire Natl Oraeeeeeeeee 15 ined Name | its, | 16 SUBSCRIBED AND SWORN to before me this (day of me, 2015. ' (eB, | epee ac | sR) sera ome sto Oregon [ ara anyon Eacort ee 25 7 Subserrbed and Swern bo before mre thes (tt deay of Sune, dog 6 Suave. Morvio SeaeS - Setory Public ofR Page9- ASSURANCE OF VOLUNTARY COMPLIANCE, ‘esoudez DEPARTAONNT OF JUSTICE 112 Coan Suet NE Seem, O8 9701-406 (som) 954.000 FAX (509 3780171 LINDA BABB, have read and understand this Assurance of Voluntary Compliance, and each of its terms, and I have conferred with my attorneys regarding it.I agree 2 toeach and every term, on behalf of myself, personally, and on behalf of Anchor Publishing, Group, Inc., vida "4 ie TBsbb eae ee SUBSCRIBED AND SWORN to before nth Zhy of June, 2015, CFFICIAL STAM RONDA Ml KENNEDY NOTARY PUBLIC-OREGON COMMISSION NO. 838170 MY COMMISSION EXPIRES MAY 18,200] tary Public for Oregon Seo el 1 I, WILLIAM STRICKLER, have read and understand this Assurance of Voluntary 11 Compliance, and each of its terms, and [ have conferred with my attorneys regarding it, Lagree 1p Sealand every em, on behalf of mysef, personally, and on behalf of Wineoceres Wine lub, Tne. 13 Signawre “4 a rink 15 6 SUBSCRIBED AND SWORN to before me this__day of June, 2015. 7 1 Notary Public for Oregon 19 1, DENNIS SIMPSON, have read and understand this Assurance of Voluntary 20° Compliance, and cach ofits tonns, and J have conferred with my attomeys regarding it, Tagree to each and every term, on behalf of myself, personally, and on behalf of Reality Kats, LLC.. a Rn ‘Signature 3B Printed Name m SUBSCRIBED AND SWORN to before me this__day of June, 2015. 25 2% ‘Notary Public Tor Oregon Page 10- ASSURANCE OF VOLUNTARY COMPLIANCE sous DEPARTMENT OF JUSTICE Naz coun suet Siem, OR S301-2086 (51393444007 FAX: G0 37-501796/22/2018 eee 10 ML 12 13 a 15 16 wv 18 19 20 at 2 23 eo 25, 26 12:14 895--364-3962 FEDEX OFFICE 0283, J, LIND, have read and understand this Ass of Vol Colne en ach oie ees Te en een Vola ft, Tagree ‘yeah tld every term, on bel of mye personally, and on behalf of Anchor Palishing Group, Sigma Name SUBSCRIBED AND SWORN tu before this__dsy of June, 2015, (otary Public for Oregon 2, WHLUIAM STRICKLER; have read and understand this Assurance of Voluxtary ‘Compllanep, and each ofits tems, and Ihave conferred with my atiomeys regarding it agiee tgicach and every tex, om bel of myself personally, and on behalf of Wineoeeres Wine Club, Inc. to i SE f 5 (AUAM STRY ck lee Printed Name. SUBSCRIBED AND SWORN to before methis day of June, 2015, ed ‘Notary Public: CAL Faeni 1, DENNIS SIMPSON, have read sod understand this Assurance of Volugtary i ey tan en bend Hare confoie wihny tomeyt anc it J gree t0 cach and Gvery ter, on behalf of myself, personally, and on behalf oft Kats, LLC. ‘oats ‘Printed Name SUBSCRIBED AND SWORN to before me this__day of Tune, 2015, ‘Notary Publis fir Oregoa— Page 10 - ASSURANCE OF VOLUNTARY COMPLIANCE, exoiens DEFARIAENE OF oSrICE WOCoan Sera OR ersonaans sty eseatb Be eas sre)86/22/2015 12:14 895--964~3962 FEDEX CFFICE 0283 PAGE 92 SURAT WITH AFFIANT STATEMENT GOVERNMENT CODE § 6202 4a Document (Notary to cross out lines 1-6 below) Ent Below (Lines 1-6 to be completed only by document signeris}, not Notary) en ‘Sianafure of Document Signer No. 7 “Signature of Bacument Signer No. 2 ifeny) 7 neta ple or eke ofcer completing tis carta vrfies any tho ionty ofthe nv wo sige the aoa a nthe caren attached nd not the rufus, aonuracy,ovady of at eocumant ‘State of nie ‘Subscribed an sworn to (or affirmed) before me 13 ni othe on this tell day of JUNE 21S, by Oe Month Year 0 fand d E WARE EEET MS A Namefsf of Signertat S get gaostzer 2 prARe pum. cauroraey proved to me on the basis of satisfactory evidence he aoe Bain Oe nT to be the persone who appeared before me. Signature. Seal Place Notary Seal Above Though t Descriptios Title or Type Number of weve (22014 Nati} OPTIONAL is section is optional, completing this information can deter alteration of the document or fraudulent reatiachinent of this form to an unintended document, of Attached Dooument Campion “ of Document: MK Document Date: _L¢ {22/15 |2_- signer(s) Other Than Named Ab nok ial Notary Association « www NatlonalNotay.org * 1-800-US NOTARY (1-800-876-6827) them #59101 1, LINDA BABB, have read and understand this Assurance of Voluntary Compliance, and each of its terms, and I have conferred with my attomieys regarding it. agree to each and every term, on behalf of myself, personally, and on bebaif of Anchor Publishing. | Group, inc.. 4 Siguate 3 Pri as 6 SUBSCRIBED AND SWORN to before me this__ day of June, 2015. : : ‘Nola Public for Oregon ~ 1 1, WILLIAM STRICKLER, have read and understand this Assurance of Voluntary 11 Compliance, and each of its rms, and I have conferred with my attorneys regarding it, T agree 1a (easand every tem, on behalf Of myself, personlly, and om behalf of Wineveeras Wine Club, Ine. B Snare 4 a Primed Nae 1s 16 SUBSCRIBED AND SWORN to before me this _ day of June, 2015. 7 Is 19 1, DENNIS SIMPSON, have read and understand this Assurance of Voluntary 20 Gompliance, and each ofits terms, and Ihave conferred with myattomey’s regarding it. agree focuth and every tem, on behal of myself prsonally-ane of behalf of Reality Kats, LLC. 2 persons od 2 23 Prise Same m4 SUBSCRIBED AND SWORN to before me this, day of June, 2015 25 26 Notary Piblic for Om gon" - Faye 10~ ASSURANCE OF VOLUNTARY COMPLIANCE ssa DBRARESUENT OF JUSTICE se Cout Seet Sie OR PSH 09 (403 set 7 FAX 30) 378- 5077(CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT CIVIL CODE § 1169 ‘A notary public o athe offcercomplating this certificate verifes only the entity ofthe Individual who signed the ‘document to which this ceticate is attached, and not the tuthuness, accuracy, of valdtyof that document. State of California, ) County of _Ssan Dig « ) on Scie 22". 2015 before me, Seantfer- Bhim, Rasta public Date Here insert Name and Title of the Officer personally appeared QENNTS £ . SitiPson, ‘Name(s) of Signer(s) who proved t me on the basi of easactoy evidence to be the panont whose nampa (ore foscrbed to the within instrument and acknowledged fo me that fsisnefey executed the cae in {afer autores capacities), and thet by.his/hertnr signature) on the instrument the persone), frectted the instrument "oer under PENALTY OF PERJURY under te avs of tho Sate of Celforio tat the forego paragrah B tne and eomoct WITNESS my hand and official sel. ‘he entity upon behalf of which the persont OFFAL SEAL AENMFEREEINL = as SIC CALIFORNIA NOTA no. ao2e7ah Signature _ a 2 patie hfe: a Sun 1 SB) 0) Soin Hav 27 sor} ‘Signature of Notary Public Place Notary Seal Above OPTIONAL ‘Though this section is optional, completing this information can deter alteration of the document or fraudulent reattachment of this form to an unintended document. Description of Attached Document posunens. of VdUeeny Compton cay Title or Type of Document: Giegen. wou Document Date: Number of Pages: Signer) Other Than Named Above: _™ Capacity(ies) Claimed by Signer(s) Signer's Name: __ Signer's Name: Di Gorporate Officer — Tite Corporate Officer — Tite): (Partner — [iLimited © General Partner — Ci Limited General Tilndividual ~~ [1 Attomey in Fact Individual ‘Attorney in Fact (Trustee (iGuarcian or Conservator “Trustee Guardian or Conservator Other: _ 2 Other: _ Signer ls Representing: Signer Is Representing: - (©2014 Nationat Notary Association + wivw.NationalNotary.org* 1-800-US NOTARY (1-800-876-6827) tem #590726 1, JEFFREY HOYAL, have read and understand this Assurance ‘Compliance, and each of its tenms, and I have conferred with iy attomeys regardinpit. I agree to each and every term, on behalf of myself, personallyrand on behalf Ine. Sma Merk Hera inted Name SUBSCRIBED AND SWORN to before me snist¢|thay of June, 2015. orrcuL svaiP ‘TESCAMARIALANDIS A 26 ry exe t ila 7] ONSEN ea ‘Stary Pablic for Orego! AV COMMISSION EXPRES FEBRLAAY 23,2019 1, RACHEL WORCESTER, have read and understand this Assurance of Voluntary Compliance, and each of its terms, and [have conferred with my attomeys regarding it. 1 agree to each and every term, on behalf of myself, personally, and on behalf of Associated Publisher Network, Inc.. Signature Printed Name SUBSCRIBED AND SWORN to before me this __ day of June, 2015. ue mw Ww ut ut Ww “we Page 11 - ASSURANCE OF VOLUNTARY COMPLIANCE, 94482 DEPARTMENT OF JUSTICE, Me2 Coa Set NE Salem, ORS73OL-A096 (601) 934-40 7 FAX 645) 378-901726 J, JEFFREY HOYAL, have read and understand this Assurance of Volum ‘Compliance, and each of its terms, and Uhave conferred with-miy attomey: ‘to each and every term, on behalf of myself, personal]yrtind on Ine. i. Lagree ociates, reporr 8 OMISSION EXPIRES FEBRUARY 2,208 1, RACHEL WORCESTER, have read and understand this Assurance of Voluniary Compliance, and each of its terms, and I have conferred with my attorneys regarding it. Tagree to each and every term, on behalf of mysel&-peiSonally, and on bebalf of Associated Publisher Network, Ine. ¢ ie @ SBSEA REE Lind pened MY COMMISSION PRES su C208 Wy Page 11- ASSURANCE OF VOLUNTARY COMPLIANCE ‘ss91402 DERARTAREYT OF JUSTICE HE Ce Sect Eiken, OR EOACIS ese GO TENT1], LAURA LOVRIEN, have read and understand this Assurance of Voluntary Compliance, and each of its terms, and I have conferred with my attomeys regarding it. l agree to each and every 2 term, on behalf of myself, personally. 3 . =) i Do 2S Signature ~ 2 ie _ Loven) Printed 6 7 SUBSCRIBED AND SWORN to before me sis lay of June, 2015. —————— 2 i OFFICIAL STAMP LL if 2 || RONDA M KENNEDY (a ett lh L ah NOTARY PUBLICOREGON \ 4 CouMSSION NO. s88170 My COMMISION XPRES 1 29 CA _ CEPTANCE OF DOJ 2 Accepted this 2 day of June, 2015. 13 (REESE ROSENBLUM 4 {Attorney Neeal | 15 \ Z Wil SAN LE LK AR 16 odes ISB #80290 Senior Assistaht Attomey General 7 Department of Justice 7 OF Attomeys for State of Oregon 19 APPROVAL BY COURT + 20 APPROVED FOR FILING and SO ORDERED this@3 day of June, 2015. a 2 2B Cireuit Court Judge a 25 26 Page 12 - ASSURANCE OF VOLUNTARY COMPLIANCE 6soraer DEPARTMENT OF JUSTICE 2 Cou Stet NE Salem, OR 97301-1096 (603) 954-1400 FAX: 803) 3788017STATE OF OREGON) County of Marion ‘The foregoing copy has been compared and is certified by me as afl, true and Correct copy of the original on file in my office and in my custody. tn Testimony Whereot, have hereunto set im hand and affixed the sel ofthe Gourton; A 25 IS TRIAL COURT ADMINISTRATOR Gye