Morning Folks!!
I asked Howard yesterday to write a detailed legal opinion for me on the Oversee Release for all domainers to see. I hope you are sitting down. Don't do anything hasty. This is going to be another BARN BURNER! Howard is going to pick this apart one point at a time and I think he could go on even further with all the flaws he reveals.
From Howard:
*I, the undersigned,
individually and jointly, for myself and my successors, assigns, trustees,
partners, joint venturers, directors, officers, affiliates, associates,
managers, licensees, and for any other claiming through or under each or all of
them and for any person or entity with or for whom I may have purchased the
above mentioned names (collectively, the “Releasors”)
This means that you are signing this document to give away not
only any rights that you may have, but also the rights of others with whom you
may be associated in some way.
hereby
release and forever discharge, acquit, covenant not to sue and acknowledge
complete satisfaction
You are releasing possible claims that you may not even know you
had.
from,
SnapNames, and its past and present parent companies (including Oversee.net),
affiliates, successors, assigns, agents, attorneys, servants, representatives,
employees, independent contractors, trustees, administrators,
predecessors-in-interest, insurers, partners, joint venturers, stockholders,
members, directors, officers, parent companies, associated companies, holding
companies, subsidiaries, divisions, affiliates, associates, managers,
licensees, accountants and consultants of any of the foregoing (collectively,
the “Releasees”)
This basically releases anyone, anything or any entity in the
whole world that has had anything whatsoever to do with Snapnames, Oversee,
their stockholders (including Brady), accountants (who may have been in
collusion – see ENRON) attorneys (who may have given bad advice), affiliates
(God knows who THEY are), licensees (what do THEY have to do with this?) and
consultants (??????).
for any and all claims, actions,
arbitrations, charges, complaints, grievances, hearings, causes of action,
actions, suits, damages, costs, expenses, judgments, liabilities, demands,
inquiries, investigations, proceedings or suits of every kind and nature
whatsoever, whether known or unknown, suspected or unsuspected, previously
existing, or now existing,or hereafter arising, in law or in equity
(collectively, the “Claims”),
This means that Snapnames, Oversee and all of the aforementioned
Usual Suspects can ride roughshod over you, your domains, your auctions, or any
possible FUTURE action that you may have with IMPUNITY. The one thing that they are presently
in short supply of is TRUST. Yet,
they are saying that if you sign this document which gives away every right
that you have, you can TRUST them that they won’t screw you again. That reminds me of the currently
running Apple ad where the PC is constantly saying “TRUST ME”.
which the Releasors or any of them had, may
have had, or now has, from the beginning of time to today’s date against the
Releasees, collectively, or any of the Releasees, individually, for or by
reason of any matter whatsoever relating to the auctions for and acquisition of
the Domains, including without limitation, any Claims relating in whole or in
part to the bidding activity of the SnapNames user associated with the user
name “halvarez” (the “Released Matters”)
This somewhat contradicts the previous statement of claims
“hereafter arising” by limiting the future to “today’s date”, but it is not as
charitable as you might first believe.
While the first statement including claims in the future goes to any
claims whatsoever, this portion is limited solely to claims arising out of the
actions of “Halvarez”. Thus, while
you are giving up any rights that you may have as to the “Halvarez” matter as
of the day you sign this ludicrous document, you are still giving up ALL RIGHTS
to any action or claim that you may now have or have IN THE FUTURE concerning
any of the activities of Snapnames, Oversee, and the Seven Dwarfs.
for damages, restitution, disgorgement,
unjust enrichment, civil penalties, statutory penalties, injunctive and/or
declaratory relief, whether class, individual, representative, or otherwise in
nature, including costs, expenses, penalties, and attorneys fees.
This may be the most insidious clause of all. Not only can you not claim damages now
OR IN THE FUTURE, but you must opt out of any class action or actions that may
be brought against these culprits and forget about any costs that you may incur
to protect your interests.
Unless
the Releasor is meaningfully educated by the Releasee as to both the nature of
the release and the risk involved, the release is invalid as a matter of law in
a number of jurisdictions.
Contracts intending to release one’s self from liability must be
strictly construed against the enforcing party. The law disfavors contractual provisions by which one party
seeks to immunize himself against the consequences of his own torts. Also, releases only limit liability for
risks specifically contemplated by the release.
It would
therefore appear that this release is overly broad to the point of possibly
being at least partially invalid.
It is necessary that the express terms of the agreement be applicable to
the particular misconduct of the Releasee. If there was no misconduct on the part of Snapnames or
Oversee, then why would they need such a release?
The key to enforceability of a release is the knowledge on the part of the Releasor
of the exact nature of the agreement.
If things “known or unknown” are being intentionally hidden from the
Releasor, the agreement has no validity.
The bottom line here is not to rush into signing away your rights for a pot of
porridge. Let time reveal exactly
who the culprit or culprits are and determine where liability may lie. Then, and only then, can someone
intelligently sign a document giving away his rights for all eternity.
Thank you Howard!! This info should be invaluable in each and every domainer and illustrate in a legal way just what a mine field this agreement is and the ramifications of putting a signature on this GARBAGE! What we are witnessing is a disaster. What we are witnessing will shape how you do business for the rest of your lives. What we are witnessing is a company that is so scared to speak, that must have so many things and people to protect, they would rather implode before our very eyes than answer the questions that have been posed for days by multiple people. That is what it looks like to me in myopinion and that opinion is getting more and more common place. This is a sad day and I am at a loss. The worst handled mess I have ever seen. That's what you get with PR and Bean Counters and Lawyers running a BUSINESS. Let's have a MEETING!! For the sake of the industry and everyone in it, I beg the folks at Oversee to step forward and fix this before the point of no return. A point that I believe we are in the midst of passing. A sad day any way you look at it.Silence is deadly and being calculating is even worse when you have so many involved.
Rick Schwartz
Bob
Thanks Howard! Great legal brief on the BS ‘agreement’!
justt
Thank you Howard.
Thank you Rick.
Rick Schwartz
The way I look at signing my NAME to this contract before Howard’s legal opinion…..
I was not in any of the tainted snap auctions, but if Oversee said they would send me $100k just for signing this agreement…..NO WAY! That is how bad that agreement looked like to this”Lay” person just on the face of it.
I truly believe you have to be insane or hard up or did not actually read what you are signing to actually sign your name to this document even AFTER all the facts are out.
If I was the attorney that wrote this up, I would be spinning around and LMAO every time I got one of the contracts back with a signature.
Shortsighted domainers that sign things they don’t read and have no idea what they are promising.
I think this agreement is more like a DOMAINER MORON TEST!
Do you become an”Indentured Servant” as well? Who cares??? Just sign and get what you get.
Larry
Guys a full and final release is just that.. All releases I draft cover now and future issues, known or unknown issues and all things whatsoever, including the thing in issue, same as here.
So the release isnt the issue. The issue here is that we’ve had systemic wrongdoing…
jeff schneider
Hello Rick,
Watch your backsides everyone. Moniker is pulling the plug on 30 day grace periods to reregister domains.This is awfully suspicious timing. We should all approach Industry regulators and get a comfort level understanding of what might be happening to our holdings with them. This may be a canary in the coal mine?
David Rosenbaum
Okay, I can see that this document is pretty bad and I don’t agree with the way Oversee is going about this, however; it’s no secret that Rick and Howard despise Oversee and vise versa. Everyone should take these comments with that in mind; hatred runs deep between these two sides. I have to wonder what kind of document Howard would write (or any attorney trying to cover their ass for that matter). I think it would be fairly similar given the fact that legal documents like this are designed for the sole purpose of protection. Again, I don’t agree with Oversee’s actions but clearly the sharks are now circling.
Dave Wrixon aka Rubber Duck
It is, however, a pretty solid legal principle that legal agreements are only binding if they are lawful. Somehow, I suspect this one would get thrown straight in the bin.
Howard
If I wrote a release in this situation, I would make it as broad as possible BUT ONLY AS TO THE ACTIVITIES OF HALVAREZ. For Oversee and Snapnames to include overbroad and overreaching clauses simply because they thought that they could get away with it is absurd. Also, my so-called hatred of Oversee is absurd. First of all I never bid in a Snapnames auction and have never done business with the company. Second, I have previously had some domains at Domain Sponsor that did absolutely nothing and so I moved them to Parked.com that monetizes them much better. And third, I do a lot of business with Moniker and think that they do a great job. My analysis was not biased and was in accordance with the law as I see it.
Rick Schwartz
David,
I think you characterize things a bit extreme. While it is true we have some”History” with Oversee, we do not”Despise” them. We talk with them, we work with them, I even had planned to go to their show in January right after TRAFFIC as a surprise gesture of goodwill until this happened. I had at least a couple conversations about this at TRAFFIC. I am sure those that I talked to about this will now understand if I reconsider.
As Howard stated above, we have had a relationship with Monte for many years. And while business arrangements have been a bit strained since their merger with Oversee, we still have very warm and personal relations with Monte and those at Moniker. My domains are still at Moniker.
That makes these posts all that much harder. But more is at stake than a single company. This is as serious as it gets and the agreement is the only window we have into what seems to be nefarious intensions. That is NOT ACCEPTABLE and is an INSULT to the intelligence and business ethics of every domainer in the industry.
John Berryhill
“For Oversee and Snapnames to include overbroad and overreaching clauses simply because they thought that they could get away with it is absurd.”
I doubt Nelson Brady is singing like a canary to them, and they may not know the extent of his activities or accomplices.
If Oversee was not making any kind of offer now, they’d be crucified. So, they are offering a standard release, with a full year to accept, to anyone who wants to settle now.
If you believe the release is not legally valid, then not signing it is a dumb move.
Howard, if you hand me an unenforceable contract under which you are going to pay me ten dollars not to sue you, then I’ll be happy to take your ten dollars AND sue you.
Your legal opinion that it is invalid, contradicts the business decision to take the money if it IS invalid.
If I understand your position, then you are saying that you can get paid NOW and then still be able to sue them later.
Sounds like a win-win.
jeff schneider
Hello Rick,
I too have a lot of my holdings with Moniker, so I assure you that I can relate to having reservations about blowing a whistle.
Moniker has been after me for 10 years to use their auction platform to sell my names. The last time I requested a sales agreement copy I took one look at it and smelled a rat.
I continue to smell a rat and if sharks are circling you had better take a quick look around, because we are all in the same tank!
Gratefully, Jeff Schneider
Cartoonz
Until I see what the outcome is from some full investigation by an outside, unrelated party like an AG, I’m not going to trust anything from SnapNames at all. Oversee, maybe, but not SnapNames.
Why? Simple. Brady’s actions seriously enriched the COMPANY, not himself so much. So thinking that he acted secretly and alone, his actions completely unknown to the rest of the company is dubious, at best.
I get it that Oversee is claiming the”Lone Gunman” theory and trying to convince us all that the one bad apple – Brady- has been removed, the old adage of”follow the money” most certainly indicates a much deeper and insidious taint of the entire SnapNames company.
Just how populated is the”Grassy Knoll” anyway? THAT is what will be the turning point as far as Trust goes… if Oversee really wants to maintain that trust, all supporting characters will need to be revealed.
As long as they keep up with the”acted alone” position, Oversee is doing themselves a great disservice as the taint will then follow them for covering it all up.
Rick Schwartz
I would like to see a post defending Nelson Brady. Nobody has heard a word. We ASSUME he is the guilty party, but there ARE 2 sides and Nelson may not be going quietly. What would that defense look like and how many others could he bring down? NOW THAT is a reason to HIDE UNDER THE DESK!
Silence fuels speculation. If the news is even worse then the speculation, the jig is up and the game is over.
Howard
JB
I agree that if the agreement as I suggested is invalid, that there is no harm in signing it. However, i want to make it clear that I was not giving legal advice to anyone to either sign or not sign the agreement. I only wanted to point out the terms of the agreement that go far beyond holding Snapnames and Oversee harmless for the Brady fiasco. It is being put out there SOLELY because of the Brady fiasco, but goes far beyond what should have been presented in order to limit Oversee’s exposure. So far, you are the only spokesman for Oversee and I find that it is curious that there has been no”official” response defending Oversee’s position, nor has there been any statement indicating that a complaint against Brady has been filed by Oversee or Snapnames with the California or Oregon AG or that there is an ongoing investigation to determine whether others were involved in boosting the value of Snapnames by rigging auctions.
John Berryhill
“So far, you are the only spokesman for Oversee”
Nice. Would you care to state the implication there expressly?
I am not”a spokesman for Oversee”. I have not been engaged by any party to this mess, am not seeking engagement, and would turn down any invitation because this type of dispute not my area of professional competence.
Oversee’s communications to law enforcement agencies, if any, aren’t going to put a dime in any domainer’s pocket.
What is it that Oversee is supposed to”defend”? They’ve stated that a massive ongoing fraud was conducted, they’ve offered a settlement that was put together fairly quickly, and they hired an outside accounting firm to work out the figures (at least that’s my understanding based on stuff I read on blogs, I have no inside information).
Has anyone said to Oversee”This release seems overbroad, can we narrow it?”
If not, why not? We’ve all drafted agreements in a hurry and negotiated the terms or tightened the language later.
Or is it just full-on outrage henceforth?
Howard
“Or is it just full-on outrage henceforth?”
I am not outraged in the least. I have never done business with Snapnames and really don’t care if those who did sign the Release and get their money or not. Call it a Conspiracy theory or mystery if you like because there are some things that don’t add up. It APPEARS ( and I emphasize the word purposely) that there is more to this bidding fraud than meets the eye. Nothing has been done by the supposed victim of all this, Oversee, to indicate whether they overpaid for Snapnames due to the inflated value generated by Brady’s fraud or that others were involved in a possible cover up. They always say”follow the money” and there is a shitload of money involved here and not just from domainers. What about the VCs who put tons of money into Oversee to acquire Moniker and Snapnames? Are they really the big losers here? And what about the domain industry as a whole that Rick and I have spent the last 5 years promoting and now is getting a huge black eye from this sordid mess. There is one party who can bring this to a head – OVERSEE. And so far – nothing!
John Berryhill
I don’t dispute the validity of your questions. It just seems to be a bit early to judge.
This is like one of those spy movies where the secret enemy mole turns out to be the CIA director. I do not envy anyone charged with walking the cat back on whatever shenanigans went on.
I've been scammed
What I don’t get is that they want release from everything on the basis of giving our money back plus interest.
What a load of bollocks.
Has anyone filed a complaint with the police yet? We can prosecute the directors directly.
What gets me, is if they were overbidding on the auctions then this additional funds is split with the actual ISP that snatched the name as it dropped and Snapnames… which means Snapnames would be losing money on all these transactions…
There’s a bundle of very serious questions that need to be asked and I think far more partners of snapnames are implicated.
I also bet my bottom dollar there are far more aliases than the one pointed to…
By siging this doc you are signing away value where you have been overbid by other aliases…
John Y.
If it is determined and/or proven that Brady actually had accomplices in crime and was not a”lone gunman”… this could give a whole new meaning to”THE BRADY BUNCH” !
I've been scammed
Why aren’t snapnames paying out the overpaid monies without even needing a signed contract?
Seriously what a f’ing cheek to ask that a contract is signed to get back what is rightfully is mine. The fact that any refund is conditional on signing a contract for what is lawfully mine is wrong on every level.
If I placed a reserve bid with snapnames and then in the background with knowledge of my reserve price a fictious connected party to Snapnames bid on that auction to my reserve, then it wasn’t an auction at all.
Personally I think snapnames knew all along. I also think all there drop catching providers knew as well. Who knows, perhaps some of them knew the reserve prices or had aliases and did some shill bidding as well. Why not, if its a closed financial transaction loop.
Seriously though, Oversee buys Snapnames and probably has some earn out with the previous owners and doesn’t even do enough of a due diligence audit to assess the revenue flows.. and then has an employee continue pumping the sales revenues…
Makes you wonder….
Anunt
This reminds me of Clinton and Monica Lewinsky Scandal…the way Bill Clinton kept talking about other crap to keep people’s attention on other news stories other than his own Lewinsky scandal…same crap is going on here…stop making this snapnames crap a big deal…let’s talk about the auctions that take place at your own Traffic conference…your traffic moniker and rick latona auctions…people should have a look into your own traffic auctions…see who all is bidding…make it transparent!!!
Morgan
Thanks for posting this Rick – I still think we are only seeing a small part of what will unfold over the coming months.
Great to see Howard’s analysis and scary all at the same time.
Rick Schwartz
Innuendo as a weapon.
This is about one company doing bad things and folks always try and twist it to get others dirty as well. That being the case, if you don’t have an exact incident to point to, and then you spew some shit like Anunt who is a lowlife in general based on his comments over the years, who has never even been to a TRAFFIC event, make sure you take what they say as a reflection on them and with the proper weight.
I think Howard and Rick Latona will be commenting as well.
Stephen Douglas
I’m with David Rosenbaum on this…
Don’t you guys, powerful domain conference producers, influential domain industry players, and businessmen have some other more positive stuff to focus on?
I didn’t see any stock broker houses writing blog opinions on their competitors when they were being fried in the national media. Maybe that’s because they were smart enough to know that burning down their neighbor’s house could possibly burn down their own.
Let’s move on, it’s starting to look fanatical here, Rick. You’re fishing with a rusty hook and no bait. Oversee or Snapname’s scandal doesn’t seem to affect you or Howard in the slightest . If it did, how about telling us how?
Oh wait… I forgot about DOMAINFEST, run by Oversee, is your top competitor.
I get it now…
All due respect… see how”assumptions” can backfire?
Sc
It looks like a one sided agreement to me. I would never sign it. They are holding your refund hostage until you sign it.
Stephen Douglass misses a basic point. Thieves are not welcome among a group of folks who want to keep their reputation in good shape. Burn down the house if that is what it takes to get them to move on.
Oh yeah, don’t forget the main goal is to destroy Oversee. Thats why we set up SnapNames to get in trouble by sending in out secret agent, Nelson Brady.
LOL
Rick Schwartz
Stephen,
If you can’t figure out how this affects the entire industry and every one in it, then I am at a loss.
Minimize it, bury it, defend it, do whatever the hell you want, but it stinks like rotten fish until it is cleaned up.
As for your comparison to Wall St. they did not have to write about it, they just took them over or took all their customers.
Stephen Douglas
To Rick and Mr. Initials”SC”…
First of all, I see how this scandal”affects” our industry. I also see how the constant discussion about it, BEFORE ANY TRIAL, EVIDENCE AND LEGAL CONCLUSION IS REACHED, is creating a sweet”innuendo” attacking a major company in our industry, which just helps our detractors, paints a bad picture of domainers (reducing the value of our domains), and focuses all our energy on a situation that hasn’t had all its”innings” played out.
SC – You’re calling SNAPNAMES”thieves”, and acting like the leader of a lynch mob. Nothing has been proven about the COMPANY condoning one man’s illegal actions.
Let’s all act like you know who – the guy who runs Techcrunch, who was the main competitor for Snapnames in his own”domain dealing” operation.
All I’m saying is let’s act a little more civil, supportive of our friends at Oversee and Snapnames, and work with them to prove that our industry is a LEGITIMATE one, even if our worse fears are realized about ONE COMPANY.
Our goals aren’t to sit back on our previous successes, and blow out the image of this industry giving our detractors ammunition. Our goals are to give BACK to the industry in positive ways. I’m sure that many people will be giving apologies, or staying quiet, once it’s established that the companies of Oversee, were not a part of one Chief Engineers”alleged” nefarious activities.
Just trying to promote the fact that we’re in America, and even after GW Bush, there still should be the U.S. Consititution and the Bill of Rights in place. You’re not guilty until proven guilty by a jury of your peers.
No matter what the talking heads and public hysteria is (except no other industry has the hysteria being piped in by other players in that industry).
That’s my point. Justice and truth are more important to me than the fact I might have lost a few hundred dollars in halverez bidding on maybe 10 of my 1000 bids on Snapnames.
We’re just not ready to feed the fires, nor induce further suspicions, and get the pitchforks waving above our heads, in full view of the rest of the world media.
Domainers want to see the leaders of this industry BRING CALM to it, not do a William Hearst on us….
I've been scammed
Stephen Douglas
I don’t buy your perceived sense of fairness.
If Oversee had a shred of fairness it would simply just refund all the monies on a no admited liability basis.
Oversee it seems wants a class action against them. Otherwise they’d just pay the money and defuse the situation.
Anyway, if they are that stupid then a class action they will get. Hell, whats a few hundred dollars when I can spank a wrong doer. Take my money, but don’t rob my sense of fair play. This is about integrity, and I don’t see snapnames doing the right thing.
Rick Schwartz
“BEFORE ANY TRIAL, EVIDENCE AND LEGAL CONCLUSION IS REACHED,”
ok, Mr.Fair Play. I did not hear you give the same benefit of the doubt to Nelson Brady. Why don’t you make the same speech for him?
Right now we just have the word of a company where everyone is hiding under a desk. Last time I looked even Nelson should get equal treatment after your soap box post.
I have not heard a word from Nelson. Have you? Did he admit guilt? Did he do it with the blessing of others and then thrown under the bus? I don’t know the answer, but it is a DAMN good question and one that nobody really wants to answer or deal with.
Rick Schwartz
And for the record, if any company did what is done here, you would have seen the same response.
Example was Tucows. I had no dog in that hunt. But there was this tiny little matter of right and wrong and they were wrong then and just because a year has passed does not mean they were still not wrong for what they did and NOBODY can force me to forget about people that do things like that.
What has occurred here has done more harm to the domain industry than any other single thing I can point to? Can you point to something that has been more disruptive? Can you point to something where the fallout is so wide and ALL of us are going to be cleaning up THEIR mess? Can you?
Can you point to anyone giving a refund for wrong doing and having you sign an agreement that only an IDIOT would sign in its current form. Yes, an IDIOT. Nobody in their right mind would sign that piece of CRAP and THAT is where so much of the anger is coming.
Anyone that is not ANGRY just does not understand the gravity of what has happened and the repercussions to come.
These are all my opinions and I get to have one just like everyone else.
Jim
Rick, I’ve never liked you, in fact I can’t stand your arrogance, but you do make some good and valid points from time to time, which is why I continue to read your blog. Really hurts me to agree with you :)Oversee need a huge kick up the arse, probs cost me a fortune with shill bidding, but I cannot see any bid history on snapnames for auctions I have won. yet again TRANSPARENCY is needed.
Cartoonz
Stephen Douglas-
Do you know of some legal investigation or court proceeding currently in motion that the rest of us do not know of? The same proceeding that you pontificate that we should all be waiting for the results of before voicing our opinions?
Oh, you can’t point to one? But instead, in your usual blowhard fashion, you insist we are all wrong?
Idiot. We all want there to be a proper investigation, that is exactly what we are making so much noise about – there isn’t one!
If you’d actually look at the big picture, you realize this but that’s not your style is it? Instead, you want to make it as if we all have some ulterior motives.
Adam
Rick what’s the Tucows thing you are referring to ?
Rick Schwartz
Adam, here ya go:
http://www.thedomains.com/2008/06/21/ethics-of-domain-drop-auctions-tdnam-and-namejet-called-out-yesterday-today-we-call-out-tucows/
http://www.thedomains.com/2008/06/25/tucows-response-to-our-post-not-good-enough-and-heres-why/
I've been scammed
Rick,
Placing a name in an auction that the auction house has no legal entitlement to sell is very dubious. I guess in their T&C’s they have it as part of the registration of domains through them. ICANN needs to step in on this as it’s just like the Domain tasting BS that went on.
ICANN needs to set up a robust framework and all registrars must follow it to maintain that status. Any new innovations that might question the integrity of registrars on the whole must be approved by ICANN before being actioned otherwise ICANN can deregister that registrar (once a new rule is put in place to stop it).
Common ICANN, the domain industry has turned into SCAM land because of your slow actions and lack of professionalism (IMHO) to ensure your registrars act in accordance with decent and normal business practices.
Joe
funny how Anunt comments on the snapnames fiasco but already made a black eye on the domain industry…
look at namepros and dnforum regarding myspace tm typos
jeff schneider
Hello Rick,
I apologize for making a totally false accusation aimed at Moniker. I stated that they were discontinuing their 30 day grace period on reregistrations.
This is completely false information and I apologize to you Monte.
To Montes credit he was right on top of this with me. Again I apologize.
stewart
Hers another free opinion?
> Our File Number: FF++++-09
> Complaint About: Snapnames.com Inc.
>
>
> Thank you for the information that you sent us. Although there does not now appear to be a need for an investigation or legal action, we will keep your information on file as part of the public record.
>
> Our primary goal is to identify and eliminate the most serious marketplace violations, and many factors are considered in determining what cases we should pursue.
>
> We appreciate the time that you took to alert us to a possible problem in the marketplace. Your information may prove to be valuable in a future enforcement action.
>
> If you need to contact us about your complaint, please write to me and note your file number: FF++++-09, or contact me by phone at 503-934-4400 or e-mail at mailto:heather.j.mcfarlanemartinez@state.or.us
>
> Heather McFarlane-Martinez
> Enforcement Officer
> Financial Fraud/Consumer Protection Section
> Oregon Department of Justice