IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 1:25-cv-04081-GPG-SBP
ADT, LLC, Plaintiff, v. IMPULSE ALARM LLC, and VERONICA GOLIN, Defendants.
DECLARATION OF DANIEL E. ROHNER IN SUPPORT OF ADT’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
I, Daniel E. Rohner, state and declare as follows:
1. I am an attorney licensed to practice before all of the courts of the State of Colorado, and admitted as an attorney of record in this matter for Plaintiff/Counterclaim Defendant ADT, LLC (“ADT”). Unless stated otherwise, I have personal knowledge of the facts stated in this declaration. I make this declaration in support of ADT’s Response in Opposition to Defendants’ Motion for Summary Judgment.
2. I am familiar with the documents that have been exchanged between the parties in this matter, including those attached to the pleadings and those exchanged through disclosures.
3. Attached to this Declaration as Exhibit A is a true and correct copy of relevant portions of ADT’s Dealer Guidelines (Part 4-Purchasing Program pp. 19-24) that were in place at the time of execution of the Authorized Dealer Agreement by and between ADT and Impulse Alarm, LLC that is at issue in this case.
4. Attached to this Declaration as Exhibit B is a true and correct copy of relevant portions of ADT’s Dealer Guidelines that were in place immediately prior to the termination of the Authorized Dealer Agreement on March 17, 2026.
I declare under penalty of perjury, under federal law and the laws of the State of Colorado, that the foregoing is true and correct.
Executed this 24th day of August 2024, at Denver, Colorado.
/s/ Daniel Rohner Daniel E. Rohner
Transcribed from the scanned filing (Document 36). “August 2024” appears as written in the original. Download the PDF for the original layout.