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Brown Paper Tickets Refunds $9M To Customers
Brown Paper Tickets Refunds $9M To Customers
7 STATE OF WASHINGTON
KING COUNTY SUPERIOR COURT
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STATE OF WASHINGTON, NO. 20-2-14549-1 SEA
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Plaintiff, CONSENT DECREE
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v. [CLERK’S ACTION REQUIRED]
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BROWN PAPER TICKETS, LLC,
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Defendant.
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14 I. JUDGMENT SUMMARY
15 1.1 Judgment Creditor State of Washington
16 1.2 Judgment Debtor Brown Paper Tickets, LLC
21 1.6 Attorneys for Judgment Debtor: Darwin Roberts and Christopher Huck
Goldfarb & Huck Roth Riojas, PLLC
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1.7 Plaintiff State of Washington (Washington), having conducted an investigation
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and commenced this action pursuant to RCW 19.86, the Consumer Protection Act (CPA); and
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4 Attorneys General; and Defendant, appearing by and through its attorneys Darwin Roberts and
6 1.9 Washington and Defendant having agreed on a basis for the settlement of the
7 matters alleged in the Complaint and to the entry of this Consent Decree against Defendant
8 without the need for trial or adjudication of any issue of law or fact; and
9 1.10 Defendant Brown Paper Tickets, by entering into this Consent Decree, stating
10 that it does not admit the allegations of the Complaint other than those solely as necessary to
11 establish the jurisdiction of this Court; and Plaintiff acknowledging that Brown Paper Tickets
12 has fully cooperated in efforts to resolve this matter, and that Brown Paper Tickets has been
13 making payments to some Event Organizers and providing refunds to some Ticket Buyers,
14 including any and all Brown Paper Tickets service fees, prior to entry of this Consent
15 Decree; and
16 1.11 Washington and Defendant having agreed this Consent Decree does not
17 constitute evidence or an admission regarding the existence or non-existence of any issue, fact,
19 1.12 Defendant recognizing and stating this Consent Decree is entered into voluntarily
20 and that no promises, representations, or threats have been made by the Attorney General’s
21 Office or any member, officer, agent, or representative thereof to induce it to enter into this
22 Consent Decree, except for the promises and representations provided herein; and
23 1.13 Defendant waiving any right it may have to appeal from this Consent Decree or
25 1.14 Defendant further agreeing this Court shall retain jurisdiction of this action and
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26 specified therein, Brown Paper Tickets shall immediately notify the Attorney General’s Office
8 determined by Washington’s sole discretion, shall be considered a breach of this Consent Decree,
9 subject only to the election of Washington, in its sole discretion, to extend the period for
10 completing Consumer payments. Prior to the Attorney General’s Office declaring a material
11 breach of the Consent Decree under this paragraph 3.5, Brown Paper Tickets shall be notified of
12 such determination by the Attorney General’s Office, and shall have five (5) business days to
13 take appropriate steps to investigate and attempt to remedy such asserted breach, such five (5)
14 day period to be in addition to any previous five (5) day period provided for in this paragraph.
15 3.6 Order of Payments: Brown Paper Tickets shall prioritize payments and refunds
16 as set forth in this paragraph 3.6. Brown Paper Tickets shall, to the greatest extent possible,
17 prioritize making payments to Event Organizers whose events were completed before making
18 payments to Event Organizers and issuing refunds to Ticket Buyers for cancelled events.
19 (a) Completed Events: For completed events, Brown Paper Tickets shall
20 prioritize payments to Event Organizers whose principal place of business is in the State of
21 Washington, with the sole exception of previously identified pre-existing judgments or payment
22 agreements entered into by Brown Paper Tickets prior to the date of execution of this Consent
23 Decree.
24 (b) Cancelled Events: For cancelled events, Brown Paper Tickets shall, to the
25 greatest extent possible, prioritize payments to Washington Event Organizers and refunds to
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THE HONORABLE MARY ROBERTS
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