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ALDEN F. ABBOTT

Acting General Counsel 

SARAH SCHROEDER, Cal. Bar No. 221528

ROBERTA TONELLI, Cal. Bar No. 278738 

EVAN ROSE, Cal. Bar No. 253478 

Federal Trade Commission

901 Market Street, Suite 570

San Francisco, CA 94103 

sschroeder@ftc.gov, rtonelli@ftc.gov, erose@ftc.gov 

Tel: (415) 848-5100; Fax: (415) 848-5184 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

OAKLAND DIVISION

FEDERAL TRADE COMMISSION, 

 Plaintiff,

 vs. 

AMERICAN FINANCIAL BENEFITS 

CENTER, a corporation, also d/b/a AFB and AF 

STUDENT SERVICES; 

AMERITECH FINANCIAL, a corporation; 

 

FINANCIAL EDUCATION BENEFITS 

CENTER, a corporation; and 

BRANDON DEMOND FRERE, individually 

and as an officer of AMERICAN FINANCIAL 

BENEFITS CENTER, AMERITECH 

FINANCIAL, and FINANCIAL EDUCATION 

BENEFITS CENTER,

 

 Defendants.

Case No. 4:18-cv-00806-SBA

Related Case: 4:17-cv-04817-SBA 

DECLARATION OF GLORIA 

HOLMES IN SUPPORT OF 

FEDERAL TRADE COMMISSION’S 

MOTION FOR PRELIMINARY 

INJUNCTION

Case 4:18-cv-00806-SBA Document 109 Filed 04/19/18 Page 1 of 3

DECLARATION OF GLORIA HOLMES IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR PRELIMINARY INJUNCTION

 4:18-CV-00806-SBA
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DECLARATION OF GLORIA HOLMES 

1. My name is Gloria Holmes and I reside in Tennessee. The following statements 

are within my personal knowledge and if called as a witness I could and would competently 

testify thereto. 

2. In early 2018, my daughter called me and said she found a strange postcard with 

my photo in our mailbox. When I got home, I examined the postcard and thought it was scary. 

The front side of the laminated postcard had my address and a small photo of me. The flip side 

had a larger photo of me in what appeared to be a personal file. The mailer included accurate 

information about my student loan amount and said I qualified for student loan forgiveness. A 

logo for “Ameritech Financial” was at the bottom of the postcard. A true and correct copy of a 

photo that I took of the postcard is attached as Holmes Attachment A. 

3. The postcard contained a photo of me that I had posted on my Facebook account 

several years ago. I selected “Private” for all my Facebook settings and do not know how 

Ameritech obtained my photo. Currently, my Facebook profile image is a photo of my grandson. 

My Facebook profile contains photos of my children and grandchildren, and I felt scared that a 

random company had gone through my Facebook account. it made me feel like I was being 

stalked. I felt like I had exposed my children and my grandson to people that could use their 

photos. 

4. I was upset when I saw my personal photo on the postcard and called the toll-free 

number at the bottom of the postcard. I spoke with someone named Scott at Ameritech 

Financial. Scott told me that I qualified for student loan forgiveness. At the time, I worked for 

the State of Tennessee. I told Scott that I did not qualify because I had not worked for a public 

entity for the right amount of time. Scott seemed frustrated and aggravated with me then started 

to try over talking me. 

5. I also told Scott that I was upset about the postcard and that Ameritech did not 

have permission to access my private photos. Scott responded, “well, we can do that.” When I 

insisted that Ameritech could not take my confidential photos, he said “everything we do is 

legal” and that I had a “beautiful family.” He was very creepy and thought it was comical. I 

Holmes Declaration - Page 1 

Case 4:18-cv-00806-SBA Document 109 Filed 04/19/18 Page 2 of 3
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asked him to stop accessing my photos and he said he was “just going to send more and he was 

his job” 

6. I have not searched for assistance with my student loan and do not know how 

Ameritech got my contact information. 

7. Based on the statements in the postcard, I thought someone was offering me loan 

forgiveness or debt relief. The top of the postcard said “STUDENT LOAN PAYMENT 

REDUCTION AND FORGIVENESS” and there was a file on me labeled “BORROWER.” I did 

not see anything that indicated Ameritech was selling a monthly membership. I would have been 

surprised to learn that this was an advertisement for a membership. 

8. I was very alarmed by the postcard. I took a photo of it and sent it to my coworker, who agreed that it was creepy and she had never received anything like it or heard of 

anyone doing that. Then I tore up the postcard and threw it away. 

9. I also visited a consumer complaint website and shared information about the 

postcard. I do not recall the name of the website. I engaged in an online chat/exchange with 

another person who received a similar postcard. He was very upset because his postcard 

included a photo of him with his daughter’s image reflected in a mirror in the background. His 

young daughter was just in her underwear. 

10. On or around January 26, 2018, I submitted the following review of Ameritech 

Financial to the Better Business Bureau: “I received a post card from them with a picture of me 

on it. It is weird and scary at the same time. I never signed up for them . . . Not sure where the 

picture came from.” 

1. I declare under penalty of perjury that the foregoing is true and correct. Executed 

on April _05_, 2018, in Tennessee. 

 ZÄÉÜ|t [ÉÄÅxá

Gloria Holmes 

Holmes Declaration - Page 2 

Case 4:18-cv-00806-SBA Document 109 Filed 04/19/18 Page 3 of 3
Holmes Attachment A

Case 4:18-cv-00806-SBA Document 109-1 Filed 04/19/18 Page 1 of 2
STUDENT LOAN PA'Olt£N1 

REDUCT\ON 1'.NO \:ORG\\J£N

B_O~ROWER 

.. "·.-:e-, -.,.; I 

Case 4:18-cv-00806-SBA Document 109-1 Filed 04/19/18 Page 2 of 2