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ALDEN F. ABBOTT

General Counsel

KATHERINE WHITE

VA Bar No. 68779; kwhite@ftc.gov

Tel: (202) 326-2878

ELISA JILLSON

DC Bar No. 989763; ejillson@ftc.gov

Federal Trade Commission

600 Pennsylvania Ave. NW, CC-8232

Washington, DC 20580

Fax: (202) 326-3062

Local Counsel

KENNETH ABBE

CA Bar No. 172416; kabbe@ftc.gov

Federal Trade Commission

10990 Wilshire Boulevard, Suite 400 

Los Angeles, CA 90024

Tel: (310) 824-4313 / Fax: (310) 824-4380

Attorneys for Plaintiff 

Federal Trade Commission

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA

_______________________________

FEDERAL TRADE COMMISSION, ) 

) 

Plaintiff, ) 

) 

v. )

)

Case No. _5:18-CV-1960-MWF-SP

STIPULATED ORDER FOR 

PERMANENT INJUNCTION 

AND MONETARY JUDGMENT 

KATRINA MOORE, )

individually and also d/b/a ) 

Innovative Paycheck Solutions ) 

______________________________ )

_____________________________

 ) 

and FakePayStubOnline.com, ) 

Case 5:18-cv-01960-MWF-SP Document 8 Filed 09/17/18 Page 1 of 14 Page ID #:52
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 )

 )

Defendant. )

______________________________ )

Plaintiff the Federal Trade Commission (“Commission”), filed its Complaint 

for Permanent Injunction and Monetary Judgement ( “Complaint”), pursuant to 

Section 13(b) of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. 

§ 53(b). The Commission and Defendant stipulate to the entry of this Stipulated 

Order for Permanent Injunction and Other Equitable Relief (“Order”) to resolve all 

matters in dispute in this action between them.

THEREFORE, IT IS ORDERED as follows:

FINDINGS

1. This Court has jurisdiction over this matter.

2. The Complaint charges that Defendant participated in unfair and deceptive 

acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45, in 

connection with the Defendant’s marketing and sale of fake pay stubs, fake bank 

statements, fake tax forms, and a service for falsifying real bank statements. 

3. Defendant neither admits nor denies any of the allegations in the Complaint, 

except as specifically stated in this Order. Only for purposes of this action, 

Defendant admits the facts necessary to establish jurisdiction. 

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4. Defendant waives any claims that she may have under the Equal Access to 

Justice Act, 28 U.S.C. § 2412, concerning the prosecution of this action through 

the date of this Order, and agrees to bear her own costs and attorney fees.

5. Defendant and the Commission waive all rights to appeal or otherwise 

challenge or contest the validity of this Order.

DEFINITIONS

For the purpose of this Order, the following definitions apply:

A. “Defendant” means Katrina Moore, individually and doing business as 

Innovative Paycheck Solutions and FakePayStubOnline.com.

B. “Fake Document” means any document, in paper or electronic form, that

misrepresents any person’s identity, residency, finances, taxes, or employment, or 

otherwise misrepresents the document’s source, provenance, authenticity, or 

accuracy.

ORDER

I. PROHIBITION AGAINST FAKE DOCUMENTS

IT IS ORDERED that Defendant is permanently restrained and enjoined 

from advertising, marketing, promoting, or offering for sale, or assisting in the 

advertising, marketing, promoting, or offering for sale any Fake Document or any 

service, template, or mechanism for creating any Fake Document.

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II. PROHIBITION AGAINST PROVIDING THE MEANS AND 

INSTRUMENTALITIES TO DECEIVE CONSUMERS

IT IS FURTHER ORDERED that Defendant, Defendant’s officers, agents, 

employees and attorneys, and all other persons in active concert or participation 

with any of them, who receive actual notice of this Order, whether acting directly 

or indirectly, are permanently restrained and enjoined from providing to others the 

means and instrumentalities with which to make, expressly or by implication, any 

statement or representation of material fact that misrepresents:

A. any person’s identity, residency, finances, taxes, or employment; or

B. the source, provenance, authenticity, or accuracy of any document related 

to identity, residency, finances, taxes, or employment.

III. MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of one hundred sixty-nine thousand Dollars 

($169,000) is entered in favor of the Commission against Defendant as equitable 

monetary relief.

B. The judgment is suspended subject to the Subsections below.

C. The Commission’s agreement to the suspension of the judgment is expressly 

premised upon the truthfulness, accuracy, and completeness of Defendants’ sworn 

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financial statements and related documents (collectively, “financial 

representations”) submitted to the Commission, namely: 

1. the Financial Statement of Defendant Katrina Moore signed on April 1, 

2018, including the attachments; and

2. the additional documentation submitted by Defendant’s counsel Eric 

Anderson, which is described in the April 12, 2018, letter from Commission 

counsel Katherine White to Defendant’s counsel Eric Anderson. 

D. The suspension of the judgment will be lifted as to Defendant if, upon 

motion by the Commission, the Court finds that Defendant failed to disclose any

material asset, materially misstated the value of any asset, or made any other 

material misstatement or omission in the financial representations identified above.

E. If the suspension of the judgment is lifted, the judgment becomes 

immediately due as to Defendant in the amount specified in Subsection A. above 

(which the parties stipulate only for purposes of this Section represents the unjust 

enrichment alleged in the Complaint), less any payment previously made pursuant 

to this Section, plus interest computed from the date of entry of this Order.

IV. ADDITIONAL MONETARY PROVISIONS

IT IS FURTHER ORDERED that: 

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A. Defendant relinquishes dominion and all legal and equitable right, title, and 

interest in all assets transferred pursuant to this Order and may not seek the return 

of any assets.

B. The facts alleged in the Complaint will be taken as true, without further 

proof, in any subsequent civil litigation by or on behalf of the Commission, 

including in a proceeding to enforce its rights to any payment or monetary 

judgment pursuant to this Order, such as a nondischargeability complaint in any 

bankruptcy case.

C. The facts alleged in the Complaint establish all elements necessary to sustain 

and action by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy 

Code, 11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effect 

for such purposes.

D. Defendant acknowledges that her Taxpayer Identification Numbers (Social 

Security Numbers or Employer Identification Numbers), which Defendant 

previously submitted to the Commission, may be used for collecting and reporting 

on any delinquent amount arising out of this Order, in accordance with 31 U.S.C. 

§7701.

E. All money paid to the Commission pursuant to this Order may be deposited 

into a fund administered by the Commission or its designee to be used for 

equitable relief, including consumer redress and any attendant expenses for the 

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administration of any redress fund. If a representative of the Commission decides 

that direct redress to consumers is wholly or partially impracticable or money 

remains after redress is completed, the Commission may apply any remaining 

money for such other equitable relief (including consumer information remedies) 

as it determines to be reasonably related to Defendant’s practices alleged in the 

Complaint. Any money not used for such equitable relief is to be deposited to the 

U.S. Treasury as disgorgement. Defendant has no right to challenge any actions 

the Commission or its representatives may take pursuant to this Subsection.

V. ORDER ACKNOWLEDGMENTS

IT IS FURTHER ORDERED that Defendant obtains acknowledgments of 

receipt of this Order:

A. Defendant, within 7 days of entry of this Order, must submit to the 

Commission an acknowledgment of receipt of this Order sworn under penalty of 

perjury.

B. For 5 years after entry of this Order, Defendant for any business that 

Defendant is the majority owner or controls directly or indirectly, must deliver a 

copy of this Order to: (1) all principals, officers, directors, and LLC managers and 

members; (2) all employees having managerial responsibilities for conduct related 

to the subject matter of the Order and all agents and representatives who participate 

in conduct related to the subject matter of the Order; and (3) any business entity 

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resulting from any change in structure as set forth in the Section titled Compliance 

Reporting. Delivery must occur within 7 days of entry of this Order for current 

personnel. For all others, delivery must occur before they assume their 

responsibilities.

C. From each individual or entity to which Defendant delivered a copy of this 

Order, Defendant must obtain, within 30 days, a signed and dated acknowledgment 

of receipt of this Order.

VI. COMPLIANCE REPORTING

IT IS FURTHER ORDERED that Defendant make timely submissions to 

the Commission:

A. One year after entry of this Order, Defendant must submit a compliance 

report, sworn under penalty of perjury, Defendant must:

1. identify all telephone numbers and all physical, postal, email and Internet 

addresses, including all residences; 

2. identify all business activities, including any business for which Defendant 

performs services whether as an employee or otherwise and any entity in which 

Defendant has any ownership interest;

3. describe in detail Defendant’s involvement in each such business, including 

title, role, responsibilities, participation, authority, control, and any ownership; 

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4. identify the primary physical, postal, and email address and telephone 

number, as designated points of contact, which representatives of the Commission 

may use to communicate with Defendant; 

5. identify all of Defendant’s businesses by all of their names, telephone 

numbers, and physical, postal, email, and Internet addresses; 

6. describe the activities of each business, including the goods and services 

offered, the means of advertising, marketing, and sales; 

7. describe in detail whether and how Defendant is in compliance with each 

Section of this Order; and 

8. provide a copy of each Order Acknowledgment obtained pursuant to this 

Order, unless previously submitted to the Commission. 

B. For 20 years after entry of this Order, Defendant must submit a compliance 

notice, sworn under penalty of perjury, within 14 days of any change in the 

following: 

1. name, including aliases or fictitious name, or residence address;

2. title or role in any business activity, including any business for which 

Defendant performs services whether as an employee or otherwise and any entity 

in which Defendant has any ownership interest, and identify the name, physical 

address, and any Internet address of the business or entity; 

3. any designated point of contact; or

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4. the structure of any entity that Defendant has any ownership interest in or 

controls directly or indirectly that may affect compliance obligations arising under 

this Order, including: creation, merger, sale, or dissolution of the entity or any 

subsidiary, parent, or affiliate that engages in any acts or practices subject to this 

Order.

C. Defendant must submit to the Commission notice of the filing of any 

bankruptcy petition, insolvency proceeding, or similar proceeding by or against 

Defendant within 14 days of its filing.

D. Any submission to the Commission required by this Order to be sworn under 

penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746, 

such as by concluding: “I declare under penalty of perjury under the laws of the 

United States of America that the foregoing is true and correct. Executed on: 

_____” and supplying the date, signatory’s full name, title (if applicable), and 

signature.

E. Unless otherwise directed by a Commission representative in writing, all 

submissions to the Commission pursuant to this Order must be emailed to 

DEbrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to: 

Associate Director for Enforcement, Bureau of Consumer Protection, Federal 

Trade Commission, 600 Pennsylvania Avenue N.W., Washington, DC 20580. The 

subject line must begin: FTC v. Katrina Moore, FTC Matter No. 1723111.

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VII. RECORDKEEPING

IT IS FURTHER ORDERED that Defendant must create certain records for 

20 years after entry of the Order, and retain each such record for 5 years. 

Specifically, Defendant for any business that Defendant is a majority owner or 

controls directly or indirectly, must create and retain the following records:

A. accounting records showing the revenues from all goods or services sold;

B. personnel records showing, for each person providing services, whether as 

an employee or otherwise, that person’s: name; addresses; telephone numbers; job 

title or position; dates of service; and (if applicable) the reason for termination;

C. records of all consumer complaints and refund requests, whether received 

directly or indirectly, such as through a third party, and any response; and

D. all records necessary to demonstrate full compliance with each provision of 

this Order, including all submissions to the Commission.

VIII. COMPLIANCE MONITORING

IT IS FURTHER ORDERED that, for the purpose of monitoring 

Defendant’s compliance with this Order:

A. Within 14 days of receipt of a written request from a representative of the 

Commission, Defendant must: submit additional compliance reports or other 

requested information, which must be sworn under penalty of perjury; appear for 

depositions; and produce documents for inspection and copying. The Commission 

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is also authorized to obtain discovery, without further leave of court, using any of 

the procedures prescribed by Federal Rules of Civil Procedure 29, 30 (including 

telephonic depositions), 31, 33, 34, 36, 45, and 69.

B. For matters concerning this Order, the Commission is authorized to 

communicate directly with Defendant. Defendant must permit representatives of 

the Commission to interview any employee or other person affiliated with 

Defendant who has agreed to such an interview. The person interviewed may have 

counsel present.

C. The Commission may use all other lawful means, including posing, through 

its representatives as consumers, suppliers, or other individuals or entities, to 

Defendant or any individual or entity affiliated with Defendants, without the 

necessity of identification or prior notice. Nothing in this Order limits the 

Commission’s lawful use of compulsory process, pursuant to Sections 9 and 20 of 

the FTC Act, 15 U.S.C. §§ 49, 57b-1.

D. Upon written request from a representative of the Commission, any 

consumer reporting agency must furnish consumer reports concerning Defendant, 

pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 U.S.C. 

§1681b(a)(1).

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IX. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this 

matter for purposes of construction, modification, and enforcement of this Order. 

so STIPULATED AND AGREED: 

OR PLAINTIFF: 

FEDERAL TRADE COMMISSION 

Date: 7/Js//8 

KATHERINE WHITE, VA Bar No. 68779 

Email: kwhite@ftc.gov 

Tel: (202) 326-2878 

ELISA JILLSON, DC Bar No. 989763 

Tel: (202) 326-3001 

Federal Trade Commission 

600 Pennsylvania Ave. N.W., CC-8232 

Washington, DC 20580 

Fax: (202) 326-3062 

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STIPULATED ORDER PAGE 13 
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Local Counsel 

KENNETH ABBE, CA Bar No. 172416 

Email: kabbe@ftc.gov 

Federal Trade Commission 

10990 Wilshire Boulevard, Suite 400 

Los Angeles, CA 90024 

Tel: (310) 824-4313 /Fax: (310) 824-4380 

Date: ( d 1- /P 

ERIC D. ANDERSON, CA Bar No. 243797 

Email: ericanderson@edalaw.com 

ERIC D. ANDERSON LAW 

300 E. State Street, Suite 520 

Redlands, CA 923 73 

Tel: (909) 283-5494 / Fax: (909) 801-7204 

!COUNSEL 

DEFENDANT: 

Date: 6 · J- Y·-/ if 

TRINA MOORE, individually 

and also d/b/a Innovative Paycheck Solutions 

land FakePayStubOnline.com 

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STIPULATED ORDER PAGE 14 
Stipulation 

5:18-cv-01960-MWF-SP Federal Trade Commission v. Katrina Moore

ACCO,(SPx),DISCOVERY,MANADR

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Notice of Electronic Filing

The following transaction was entered by Abbe, Kenneth on 9/17/2018 at 11:23 AM PDT and filed on 

9/17/2018 

Case Name: Federal Trade Commission v. Katrina Moore

Case Number: 5:18-cv-01960-MWF-SP

Filer: Federal Trade Commission

Document Number: 8

Docket Text:

STIPULATION for Permanent Injunction as to defendant filed by plaintiff Federal Trade 

Commission. (Attachments: # (1) Proposed Order)(Abbe, Kenneth) 

5:18-cv-01960-MWF-SP Notice has been electronically mailed to: 

Kenneth H Abbe kabbe@ftc.gov 

5:18-cv-01960-MWF-SP Notice has been delivered by First Class U. S. Mail or by other means BY 

THE FILER to : 

The following document(s) are associated with this transaction:

Document description:Main Document 

Original filename:C:\fakepath\CAC.EC18CV01960.KA.StipOrder.pdf

Electronic document Stamp:

[STAMP cacdStamp_ID=1020290914 [Date=9/17/2018] [FileNumber=26278232-0

] [3ea3a7a4efb3ea29a340857ab3472c5223fc12a9b5d09cc9f6a998c4688208501d6

7ae6a672fa484944ff964ed3b9d09c9ebd38891ab7dd611043c0b770dec25]]

Document description:Proposed Order 

Original filename:C:\fakepath\CAC.ED.18CV01960.KA.PropoedOrder.pdf

Electronic document Stamp:

[STAMP cacdStamp_ID=1020290914 [Date=9/17/2018] [FileNumber=26278232-1

] [3ca4b3c84b3579d557d8452c086562e09831e2cee76edc1f425f7ed396cb8ec0ae8

3d44d43e0c25b9a1fa3c573b579b95ccef4fa8f90214a841ce081443c90de]]

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