STIPULATED ORDER-1 

Katherine White, (VA Bar No. 68779)

Elisa Jillson (DC Bar No. 989763)

kwhite@ftc.gov; ejillson@ftc.gov

Federal Trade Commission

600 Pennsylvania Ave. N.W.

Washington, DC 20580

Tel: (202) 326-2878; -3001

Attorneys for Plaintiff Federal Trade Commission

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

INTEGRATED FLIGHT SOLUTIONS

LLC, a limited liability company, also

d/b/a NoveltyExcuses.com; and

STEVEN SIMMONS, individually and

also d/b/a AB Productions, Inc., A.B. 

Pro., and NoveltyExcuses.com, and as

an officer of INTEGRATED FLIGHT 

SOLUTIONS LLC, 

Defendants. 

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

for Permanent Injunction and Other Equitable Relief ( “Complaint”), pursuant to 

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

Case No. 3:18-cv-1658

STIPULATED ORDER FOR

PERMANENT INJUNCTION AND 

MONETARY JUDGMENT

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STIPULATED ORDER-2

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

Order for Permanent Injunction and Monetary Judgment (“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 Defendants participated in unfair acts or 

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

with the Defendants’ marketing and sale of fake pay stubs, fake bank statements, 

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

3. Defendants neither admit nor deny any of the allegations in the Complaint, 

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

Defendants admit the facts necessary to establish jurisdiction. 

4. Defendants waive any claims that they 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 their own costs and attorney fees.

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

challenge or contest the validity of this Order.

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STIPULATED ORDER-3

DEFINITIONS

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

A. “Defendants” means Individual Defendant and the Corporate Defendant, 

individually, collectively, or in any combination.

B. “Corporate Defendant” means Integrated Flight Solutions LLC, also d/b/a 

NoveltyExcuses.com, and its successors and assigns.

C. “Individual Defendant” means Steven Simmons, individually and doing 

business as AB Productions, Inc., A.B. Pro., and Novelty Excuses.com.

D. “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 Defendants are 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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STIPULATED ORDER-4

II. PROHIBITION AGAINST PROVIDING THE MEANS AND 

INSTRUMENTALITIES TO DECEIVE CONSUMERS

IT IS FURTHER ORDERED that Defendants, Defendants’ 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 AND SUSPENSION

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Fifteen Thousand Dollars ($15,000) is entered in 

favor of the Commission against Defendants, jointly and severally, 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 premised 

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STIPULATED ORDER-5

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

statements and related documents (collectively, “financial representations”) 

submitted to the Commission, namely:

1. The Financial Statement of Individual Defendant Steven Simmons signed on 

February 19, 2018, including the attachments;

2. The Financial Statement of Corporate Defendant Integrated Flight Solutions 

LLC signed by Steven Simmons, Owner and CEO, on February 16, 2018, including 

the attachments.

D. The suspension of the judgment will be lifted as to any 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 that 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), plus interested computed from the date 

of entry of this Order.

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STIPULATED ORDER-6

IV. ADDITIONAL MONETARY PROVISIONS

IT IS FURTHER ORDERED that: 

A. Defendants relinquish 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. Defendants acknowledge that their Taxpayer Identification Numbers (Social 

Security Numbers or Employer Identification Numbers), which Defendants

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.

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STIPULATED ORDER-7

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 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 Defendants’ practices alleged in the Complaint. Any 

money not used for such equitable relief is to be deposited to the U.S. Treasury as 

disgorgement. Defendants have 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 Defendants obtain acknowledgments of 

receipt of this Order:

A. Each 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, each Individual Defendant for any 

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STIPULATED ORDER-8

business that such Defendant, individually or collectively with any other 

Defendants, is the majority owner or controls directly or indirectly, and each 

Corporate Defendant, 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 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 a Defendant delivered a copy of this 

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

acknowledgment of receipt of this Order.

VI. COMPLIANCE REPORTING

IT IS FURTHER ORDERED that Defendants make timely submissions to 

the Commission:

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

report, sworn under penalty of perjury:

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STIPULATED ORDER-9

1. Each Defendant must: (a) 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; (b) 

identify all of that Defendant’s businesses by all of their names, telephone numbers, 

and physical, postal, email, and Internet addresses; (c) describe the activities of 

each business, including the goods and services offered, the means of advertising, 

marketing, and sales, and the involvement of any other Defendant (which 

Individual Defendants must describe if they know or should know due to their own 

involvement); (d) describe in detail whether and how that Defendant is in 

compliance with each Section of this Order; and (e) provide a copy of each Order 

Acknowledgment obtained pursuant to this Order, unless previously submitted to 

the Commission.

2. Additionally, each Individual Defendant must: (a) identify all telephone 

numbers and all physical, postal, email and Internet addresses, including all 

residences; (b) identify all business activities, including any business for which 

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

entity in which such Defendant has any ownership interest; and (c)describe in detail 

Defendant’s involvement in each such business, including title, role, 

responsibilities, participation, authority, control, and any ownership.

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STIPULATED ORDER-10

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

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

the following: 

1. Each Defendant must report any change in: (a) any designated point of 

contact; or (b) the structure of any Corporate Defendant or 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.

2. Additionally, each Individual Defendant must report any change in: (a) name, 

including aliases of fictitious name or residence address; or (b) title or role in any 

business activity, including any business for which such Defendant performs 

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

Defendant has any ownership interest, and identify the name, physical address, and 

any Internet address of the business or entity.

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

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

such Defendant within 14 days of its filing.

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

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STIPULATED ORDER-11

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. Integrated Flight Solutions, LLC, FTC Matter No. 

1723151.

VII. RECORDKEEPING

IT IS FURTHER ORDERED that Defendants must create certain records for 

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

Specifically, Corporate Defendant, in connection with the 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 

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STIPULATED ORDER-12

mechanism for creating any Fake Document, and each Individual Defendant for any 

business that such Defendant, individually or collectively with any other 

Defendants, 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 Defendants’

compliance with this Order:

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

Commission, each Defendant must: submit additional compliance reports or other 

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

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STIPULATED ORDER-13

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

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 each Defendant. Defendant must permit representatives 

of the Commission to interview any employee or other person affiliated with any 

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 

Defendants 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 Individual Defendant, 

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

§1681b(a)(1).

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STIPULATED ORDER-14

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 ORDERED this day of , 2018. 

_______________________________

UNITED STATES DISTRICT JUDGE

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Case 3:18-cv-01658-MO Document 2 Filed 09/13/18 Page 15 of 16

SO STIPULATED AND AGREED: 

FOR PLAINTIFF: 

FEDERAL TRADE COMl\fJSSION 

iatherine White, (VA Bar No. 68779) 

Elisa Jillson (DC Bar No. 989763) 

k•vhite~i:;-fie.gov; eiillson(a)ftc .goY 

Federal Trade Commission 

600 Pennsylvania Ave. N.W. 

Washington, DC 20580 

Tel: (202) 326-2878; -3001 

Attorneys for Plaintiff Federal Trade Commission 

FOR DEFENDANTS: 

Date: 

iki L :::i Date: b}ltl/2018 

Ste~(, Individually and as an officer 

of Integrated Flight Solutions LLC, also d/b/a 

Novelty Excuses.com 

STIPULATED ORDER-15 
CERTIFICATE OF SERVICE

I, Katherine White, certify that on September 13, 2018, the foregoing document to 

be filed with the Clerk of the Court via the Court’s CM/ECF electronic filing 

system. I further certify that on this same date, a true and correct copy of the 

foregoing was served, via email and Federal Express, to the following:

Steven Simmons

13137 Southwest Carr St

Beaverton, OR 97008

Email: nevetspdx@aol.com

/s/ Katherine White

Katherine White

Attorney for Plaintiff

FEDERAL TRADE COMMISSION

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