Case 3:19-cv-00933-VAB *SEALED* Document 33 Filed 06/18/19 Page 1 of 24 

IN THE 'UNITED ST ATES DISTRICT COURT 

FOR THE DISTRICT OF CONNECTJCU T 

FEDERAL TRADE COM.MJSSION, 

Plaintiff, 

v. 

GRAND TETON PROFESSIONALS, LLC, et 

al., 

Defendants, 

l<'ILED UNDER SEAIJ 

Case No. 

EX PARTE TEMPORARY RESTRAINL~G ORDER WITH ASSET FREEZE, 

AND OTHER EQUITABLE RELIEF, AND ORDER TO SHOW CAUSE WHY A 

PRELIMINARY INJUNCTION SHOULD NOT ISSUE 

Plaintiff, the Federal Trade Commission ("FTC"), has filed its Complaint for Permanent 

Injunction and Other Equitable Relief pursuant to Sections 13(b) and 19 of the FTC Act, 15 

U.S.C. §§ 53(b) and 57b, Section 410(b) oftbe Credit Repair Organizations Act ("CROA''), 15 

U.S.C. § J 679h(b), SecJfon 6(b) of the Telemarketing and Consumer Fraud and Abuse 

Prevention Act, 15 U.S.C. § 6105(b), the Consumer Review Fairness Act ("CRFA"), 15 U.S.C. § 

45b, Section 108(c) of the Truth in Lending Act ("TILA"), 15 U.S.C. § 1607(c), Section 918(c) 

of the Electronic Fund Transfe.rs Act ("EFTA"), 15 U.S.C. § 1693o(c), and has moved, pursuant 

to Fed. R. Civ. P. 65(b), for a temporary restraining order, asset freeze, other equitable relief, and 

an order to show cause why a preliminary injunction should nol issue against Defendants Grand 

Teton Professionals, LLC, 99'" Floor, LLC, Mait Management Inc., Demand Dynamics LLC, 

Atomium Corps Inc. (Wyoming), Atomium Corps Inc. (Colorado), Startup Masters NJ Inc. 

(Wyoming), Startup Masters NJ Inc. (New Jersey), First Incorporation Services Inc. (Wyoming), 

First Incoporation Services Il)c. (Florida), Douglas Filter, and Marcie G. Anckade. 

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FINDINGS OF FACT 

The Court, having considered the Complaint, the ex parte Motion for a Temporary 

Restraining Order, declarations, exh:bits, and the memorandum of points and authorities filed in 

support thereof, and being otherwise advised, finds that: 

A. This Court has jurisdiction over the subject matter of this case, and there is good cause to 

believe that it will have jurisdiction over all parties hereto and that venue in this district is 

proper. 

B. There is good cause to believe that Defendants Grand Teton Professionals, LLC, 99th Floor, 

LLC, Mait Management Inc., Demand Dynamics LLC, Atomium Corps Inc. (Wyoming), 

Atomium Corps Inc. (Colorado), Startup Masters NJ Inc. (Wyoming), Stanup Masters NJ 

Inc. (New Jersey), First Incorporation Services Inc. (Wyoming), Firnt lncoporation Services 

Inc. (Florida), Douglas Filter, and Marcio G. Andrade have engaged in and are likely to 

engage i11 acts or practices that violate Section 5 oftbe FTC Act, JS U.S.C. § 45, multiple 

provisions of CROA, 15 U.S.C. §§ 1679-16791, multiple provisions of the FTC's 

Telemarketing Sales Rule ("TSR"), 16 C.F.R. Part 3 I 0, the CRFA, 15 U.S.C. § 45b, TILA, 

15 U.S.C. §§ 1601-1666j, and its implementing Re1:,>ulation Z, 12 C.F.R. Part 1026, and 

Section 907(a) of EFT A, 15 U.S.C .. § 1693e(a) and its implementing Regulation E, 12 C.F.R. 

Part 1005, and that the FTC is therefore likely to prevail on the merits of this action. 

C. There is good cause to believe that Defendants are violating or are about to violate the FfC 

A<-i, CROA, the TSR, the CRFA, TJLA and Regulation Z, and EFTA and Regulation E. 

D. There is good cause to believe that immediate and irreparable harm will result from 

Defendants' ongoing violations ofLlie FTC Act, CROA, the TSR, the CRFA, TILA and 

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Regulation Z, and EFTA and Regulation E unless Defendants are restrained and enjoined by 

order of this Court. 

E. 1l1ere is good cause to believe that Defendants have caused consumer ham1 of at least 

$6,242,745. 

F. There is good cause to believe tl1at immediate and irreparable damage to fue Court's abi lity 

to grant effective final relief for consumers-including monetary restitution, rescission, 

disgorgement or refunds- will occur from the sale, transfer, destruction or other disposition 

or concealment by Defendants of their assets or records, unless Defendants are immediately 

restrained and enjoined by order of this Court; and that, in accordance with Fed. R. Civ. P. 

65(b ), the interests of justice require that this Order be granted without prior notice to 

Defendants. Thus, there is good cause for relieving the FTC of the duty to provide 

Defendants with prior notice of its Motion for a Temporary Restraining Order. 

G. Good cause exists for freezing Defendants' assets, disabling Defendants' Internet websites, 

pennitting the FTC immediate access to the Defendants' business premises, and permitting 

the FTC to take expedited discovery. 

H. Weighing the equities and considering the FTC's likelihood of ultimate success on the 

merits, a temporary restraining order with an asset freeze, immediate access to business 

premises, expedited discovery, and other equitable relief is in the public interest. 

I. This Court has authority to issue this Order pursuant to Section l 3(b) of the FTC Act, 15 

U.S.C. § 53(b); Federal Rule of Civil P1·ocedure 65; and the All Writs Act, 28 U.S.C. § 1651. 

J. No security is required of any agency of the United States for issuance of a temporary 

rcstraioing order. Fed. R. Civ. P. 65(c). 

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DEflNITIONS 

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

A. "Asset" means any legal or equitable interest in, right to, or claim to, any property, wherever 

located and by whomever held. 

B. "ConsllJ!ler" means any Person. 

C. "Corporate Defendants" means Grand Teton Professionals, LLC, 99th Floor, LLC, Mait 

Management Inc., Demand Dynamics LLC, Atomium Corps Inc. (a Wyoming company), 

Atomiwn Corps Inc. (a Colorado company}, Starrup Masters NJ Inc. (a Wyoming company), 

Startup Masters NJ Inc. (a New Jersey company}, First Incorporation Services Jnc. (a 

Wyoming company), First Jncoporation Services Inc. (a Florida company}, and each of their 

subsidiaries, affiliates, successors, and assigns. 

D. ''Credit Repair Service" means any service, in return for payment of money or other 

valuable consideration, for the express or implied purpose of: (1) improving any consumer's 

credit report, credit record, credit history, credit profile, credit score, or credit rating; or (2) 

providing advice or assistance to any consumer with regard to any activity or service the 

purpose of which is to improve a consumer's credit report, credit record, credit history, credit 

profile, credit score, or credit rating. 

E. "Defendants" means Corporate Defendants and Individual Defendants, individually, 

collectively, or in any combination. 

F. "Document" is synonymous in meaning and equal .in scope to the usage of "document" and 

"electronically stored infonnation" in Federal Rule of Civil Procedure 34(a), Fed. R. Civ. P. 

34(a}, and includes writings, drawings, graphs, charts, photographs, sound and video 

recordings, images, lutemet sites, web pages, websites, electronic correspondence, including 

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e-mail and instant messages, contracts, accounting data, advertisements, FTP Logs, Server 

Access Logs, books, written or printed records, handwritten notes, telephone logs, telephone 

scripts, receipt books, ledgers, personal and business canceled checks and check registers, 

bank statements, appointment books, computer records, customer or sales databases and any 

other electronically stored infonnation, including Documents located on remote servers or 

cloud computing systems, and other data or data compilations from which information can be 

obtained directly or, ifnec<::Ssary, after trai1slation into a reasonably usable fonn. A draft or 

non-identical copy is a separate document within the meaning of the term. 

G. "Electronic Data Hosf' means any person or entity in the business of storing, hosting, or 

otherwise maintaining electronically stored information. This includes, but is not limited to, 

any entity hosting a website or server, and any entity providing "cloud based" electronic 

storage. 

H. "Individual Defendants" means Douglas Filter and Marcio G. Andrade, individually, 

collectively, or in any combination. 

I. "Person" means a natural person, an organization or other legal entity, including a 

corporation, partnership, sole proprietorship, limited liability company, association, 

cooperative, or any other group or combination acting as an entity. 

ORDER 

PROHIBITED CREDIT REPAIR ACTIVITIES 

I. IT IS THEREFORE ORDERED that Defendants, Defendants' officers, agents, employees, 

and attorneys, and all other persons in active concert or participation with them, who receive 

actual uotice of this Order by personal service or otherwise, wheiher acting directly or 

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if!direcUy, in connection with the adve,tising, marketing, promoting, or offering for sale of 

any Credit Repair Service, are te:nporarily restrained and enjoined from: 

A. Misrepresenting or assisting others in misrepresenting, expressly or by implication: 

1. That any Person can remove negative information or hard inquiries from any Person's 

credit report, c.redit record, credit history, credit profile; 

2. That any Person will add any Person as an additional authorized user to any other 

Person's credit card or line of credit account; 

3. That any Person can sub;tantially-improve aoy Person's credit score or credit rating; 

4. That aoy Person is or was a victim of identity theft; 

5. That any Person is an additional authorized user on any other Person's credit card or 

line of credit account; or 

6. Any other fact material to consumers concerning any Credit Repair Service, such as 

the total costs; any material restrictions, limitations, or conditions; or any material 

aspect of its perfonnance, efficacy, nature, or central characteristics; 

B. Charging or receiving money or other valuable co_nsideration for the performance of any 

Credit Repair Service before such servi~ is fully perfonned; 

C. Failing to provide any Person with a written statement of "Con.sumer Credit File Rights 

Under State and Federal Law," in the fom1 and manner required by Section 405(a) of 

CROA, 15 U.S.C. § J679c(a}; 

D. Failing to include in contracts for any Credit Repair Service the foJiowiJJg required ten.us 

and conditions: ( a) a full and detailed description of the services to be perfonned for the 

consumer, including all guarantees of perfomlance and an estimate of the date by which 

the perfonnance of the services (to be perfonned by Defendants or any other Person) will 

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case 3:19-cv-00933-VAB *SEALED* Document 33 Filed 06/18/19 Page 7 of 24 

be complete or the length of the period necessary to perform such services, and (b) the 

specific conspicuous statement in bold face type, in immediate proximity to the space 

reserved for the consumer's signature on the contract, regarding the consumers' right to 

cancel the contracts without penalty or obligation at any time before the third business 

day after the date on which consumers signed the contracts; 

£ . Failing to provide any Person with a separate form with the heading "Notice of 

Cancellation,'' in the fonn and 1nanner required by Section 407(b) of CROA, 15 U.S.C. § 

1679e(b); and 

F. Failing to provide any Person with a copy of a completed contract and all disclosures 

required under CROA and a copy of any other document such Person is required to sii,'ll. 

PROHIBITED BUSINESS ACTIVITIES 

II. IT IS THEREFORE ORDERED that Defendants, Defendants' officers, agents, employees, 

and attorneys, and all other persons in active concert or participation with them, who receive 

actual notice of this Order by personal service or otherwise, whether acting directly or 

indirectly, in connection with the advertising, marketing, promoting, or offering for sale of 

any good or service, are temporarily restrained and enjoined from: 

A. Prohibiting any Person from speaking or publishing any truthful or non-defamatory 

negative comment or review about any other Person or their services, including, but not 

limited to, by imposing or threatening to impose a penalty or fee for speaking or 

publishing any truthful or non-defamatory negative comment or review about any other 

Person or their services; 

B. Including any provision in a fonn contract that (a) prohibits or restricts the ability of any 

Person who is a party to the form contract to make any written, oral, or pictorial review, 

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performance assessment of, or other similar analysis of, including by electronic means, 

tbe goods, services, or conduct of any other Person, or (b) imposes a penalty or fee 

against any Person for making any written, oral, or pictorial review, perfomiance 

assessment of, or other similar analysis of, i11cluding by electronic means, the goods, 

services, or conduct of any other Person; 

C. Prohibiting any Person from exercising their rights under any statute, rule, or agreement 

to dispute a charge placed on their credit or debit card or withdrawal from their bank 

account, including, but not limited to, by imposing or threatening to impose a penalty or 

fee for exercising any right under any statute, rule, or agreement to dispute a charge 

p!aceu on their credit or debit card or withdrawal from their bank account; 

D. Creating or causing to be created, directly or indirectly, a remotely created payment order 

as payment for any good or service offered or sold through telemarketing; 

E. Failing to disclose clearly and conspicuously in any advertisement for closed-end credit 

the amount or percentage of any downpayment, the terms of repayment (including the 

number of payments or period of repayment and the amount of any payment), the amount 

of any finance charge, and the annual percentage rate; 

F. Failing to obtain a written authorization signed or similarly authenticated from any 

Person before debiting such Person's bank account on a recurring basis; and 

G. Failing to provide a copy of a written autl1ori.zatioo signed or similarly authenticated from 

any Person before debiting such Pe~son's bank account on a recurring basis. 

DJSABLEMENT OF INTERN.ET WEBSITES 

III. IT IS FURTHER ORDERED that, immediately upon service of the Order upon them and 

pending determination of the FTC's request for a preliminary injunction, (1) any person 

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hosting any Internet website for, or on behalf of, any Defendant, and (2) Defendants, their 

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 by personal service or 

otherwise, whether acting directly or indirectly, shall: 

A. Immediately do whatever is necessary to ensure that any Internet website used by 

Defendants for the advertising, marketing, promotion, offering for sale, sale, Qr provision 

of any Credit Repair Service, or otherwise containing statements or representations 

prohibited by Section I of this Order, cannot be accessed by the public; 

R Prevent the destruction or erasure of any Internet website used by Defendants for the 

adveitising, marketing, promotion, offering for sale, sale, or provision of any Credit 

Repair Service, by preserving such website in the fol'lllat in which they are maintained 

cwrcntly; and 

C. Immediately notify in writing counsel for the FTC of any other Internet website operated 

or controlled by any Defendant not listed in Section II.A or B above. 

SUSPENSION OF INTERNET DOMAIN NAMES 

IV. JT IS FURTHER ORDERED that, pending detennination oftheFTC's request for a 

preliminary injunction, any domain name registrar shall suspend the registration of any 

lntemet website used by Defendants for the advertising, marketing, promotion, offering for 

sale, sale, or provision of any Credit Repair Service, or otherwise containing statements or 

representations prohibited by Section I of this Order, and provide immediate notice to 

counsel for the FTC of any other Internet domain names registered by Defendants, their 

officers, agents, employees, and attorneys, and all other persons in active concert or 

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participation with any of them who receive act\lal notice of this Order by personal service or 

otherwise, whether acting directly or indirectly. 

PROHIBITION ON RELEASE OF CUSTOMER INFORMATION 

V. IT JS 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 hereby 

temporarily restrained and enjoined from; 

A. Selling, renting, leasing, transfen:ing, or otherwise disclosing, the name, address, birth 

date, telephone number, email address, credit card number, bank account number, Social 

Security number, or other financial or identifying information of any person that any 

Defendant obtained in connection with any activity that pertains to the subject matter of 

this Order; and 

B. Benefitting from or using the name, address, birth date, telephone number, email address, 

credit card number, bank account number, Social Security number, or other financial or 

identifying infonnation of any person that any Defendant obtained in connection with any 

activity that pertains to the subject matter of this Order. 

C. Provided, however, that Defendants may disclose such identifying information to a Jaw 

enforcement agency, to their attorneys as required for their defense, as required by any 

law, regulation, or court order, or in any filings, pleadings or discovery in this action in 

the manner required by the Federal Rules of Civil Procedure and by any protective order 

in the case. 

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ASSET FREEZE 

VI. JT IS FURTHER ORDERED that Defondants and their officers, agents, employees, and 

attorneys, and all other persons in active concert or participation with any of them, who 

receive actual notice oftJ1is Order, whether acting directly or indirectly, are hereby 

temporarily restrained and enjoined from: 

A. Transferring, liquidating, converting, encurnbe1ing, pledging, loaning, seUing, 

concealing, dissipating, disbursing, assigning, relinquishing, spending, withdrawing, 

granting a Hen or security interest or other interest in, or otherwise disposing of any 

Assets that are: 

I. owned or controlled, directly or indirectly, by any Defendant; 

2. held, in part or in whole, for the benefit of any Defendant; 

3. in the actual or constructive possession of any Defendant; or 

4. owned or controlled by, in the actual-or constructive possession of, or otherwise held 

for the benefit of, any corporation, partnership, asset protection trust, or other entity 

that is directly . or indirectly . owned, managed or controlled by any Defendant. 

B. Opening or causing to be opened any safe deposit boxes, commercial mail boxes, or 

storage facilities titled in the name of any Defendant or subject to access by any 

Defendant; 

C. Incurring charges or cash advances on any credit, debit, or ATM card issued in the name, 

individually or jointly, of any Corporate Defendant or any corporation, partnership, ot 

other entity directly or indirectly owned, managed, or controlled by any Defendant or of 

which any Defendant is an officer, director, member, or manager. This includes any 

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corporate bankcard or corporate credit card account for which any Defendru1t is, or was 

on the date that this Order was signed, an authorized signor; or 

D. Cashing any checks or depositing any money orders or cash received from consumers, 

clients, or customers of any Defendant. 

E. Tiie Assets affected by this Sc~tion shall include: (!} all Assets of Defendants as of the 

time this Order is entered; and (2) Assets obtained by Defendants after this Order is 

entered if those Assets are derived from any activity that is the subject of the Complaint 

in this matter or that is prohibited by this Order. This Section does not prohibit any 

repatriation of foreign Assets specifically required by this order. 

DUTIES OF ASSET HOLDERS AND OTHER THIRD PARTIES 

VU. IT IS FURTHER ORDERED that any financial or brokerage institution, Electronic Data 

Host, credit card processor, payment processor, merchant bank, acquiring bank, independent 

sales organization, third party processor, payment gateway, insurance company, business 

entity, or person who receives actual .notice of this Order (by service or otherwise) that: (a) 

has held, controlled, or maintained custody, through an account or otherwise, of any 

Document on beh~Jf of any Defendant or any Asset that has been owned or controlled, 

directly or indirectly, by any Defendant; held, in part or in whole, for the benefit of any 

Defendant; in the actual or constructive possession of any Defendant; or owned or controlled 

by, in the actual or constructive possession of, or otherwise held for the benefit of, any 

corporation, partnership, asset protection trust, or other entity that is directly or indirectly 

owned, managed or controlled by any Defendant; (b) has held, controlled, or maintained 

custody, through an account or otherwise, of any Document or Asset associated with credits, 

debits, or charges made on behalf of any Defendant, including reserve funds held by payment 

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processors, credit card pr<>cessors, merchant banks, acquiring banks, independent sales 

organizations, third party processors, payment gateways, insurance companies, or other 

entities; or ( c) has extended credit to any Defendant, including through a credit card account, 

shall: 

A. Hold, preserve, and retain within its control and prohibit the withdrawal, removal, 

alteration, as_sigiunent, transfer, pledge, encumbrance, disbursement, dissipation, 

relinquishment, conversion, sale, or other disposal of any such Document or Asset, as 

well as all Documents or other property related to such Assets, except by further order of 

this Court; provided, however, that this provision docs not prohibit an lndi vi dual 

Defendant from incuning <;hargcs on a personal cre<lit card established prior to entry of 

this Order, up to tl1e pre-existing credit limit; 

B. Deny any person access to any safe deposit box, commercial mail box, or storage facility 

that is titled in the name of any Defendant, either individually or jointly, or otherwise 

subject to access by any Defendant; 

C. Provide FTC, within three (3) days of receiving a copy of this Order, a sworn statement 

setting forth, for each Asset or account covered by this Section: 

1. The identification number of each such account or Asset; 

2. The balance of each such account; oi a description of the nature and value of each 

such Asset as of the close ofbusiness ou the day on which this Order is served, and, if 

the account or other Asset has been closed or removed, the date closed or removed, 

the total funds removed in order to close the account, and the name of the person or 

entity to whom such account or other Asset was remitted; and 

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3. The identification of any safe deposit box, commercial mail box, or storage facility 

that is either titled in the name, individually or jointly, of any Defendant, or is 

otherwise subject to access by any Defendant; and 

D. Upon the request of FTC counsel, promptly provide FTC counsel with copies of all 

records or other Documents pe_rtaining to any account covered by tl1is Section or Asset, 

including originals or copies of account applications, account statements, signature cards, 

checks, drafts, deposit tickets, transfers to and from the accounts, including wire transfers 

and wire transfer instructions, all other debit and credit instruments or slips, currency 

transaction reports, I 099 forms, and all Jogs and recorlls pertaining to safe deposit boxes, 

commercial mail boxes, and storage facilities. 

E. Provided, however, that this Section does not prohibit any repatriation of foreign Assets 

specifically required by this order. 

FINANCIAL DISCLOSURES AND ACCOUNTING 

vm. IT JS FURTHER ORDERED that each Defendant, within five (5) days of service of this 

Order upon them, shall prepare and deliver to FTC counsel: 

A. Completed financial statements on the forms attached to this Order as Attachment A 

(Financial Statement of Individual Defendant) for eacl1 Individual Defendant, and 

Attachment B (Financial Statement of ColJ)Orate Defendant) for each Corporate 

Defendant; 

B. Completed Attachment C (IRS Form 4506, Request for Copy of a Tax Return) for each 

Individual and Corporate Defendant; and 

C. A detailed accounting of: (I) each product advertised, marketed, promoted, offered for 

sale, distributed, or sold by or on behalf of Defendants since [date], including a brief 

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description of each product; (2) gross revenues and net profits (in U.S. dollars) obtained 

fro,n the adve11ising, marketing, or sale of each product identified in response to section 

(I) above, from inception of the advertising, marketing, or sale of that product ihrough 

the date of entry of this Order; and (3) the name, address, telephone number, e-mail 

address, website address, and contact person of each entity that: (i) supplied 

manufactured, fommlated, or created each product identified in response to subsection 

(I) above; (ii) paid Defendants, whether directly or indirectly, related to Defendants' 

advertisement of any products; or (iii) disseminated o.r published an advertisement on 

behalf of Defendants or received payment from Defendants for arrangi11g in or assisting 

in such dissemination or publication. 

FOREIGN ASSET REPATRIATION 

IX. IT JS FURTHER ORDERED that within five (5) days following the service of this Order, 

each Defendant shall: 

A. Provide FTC counsel with a full accounting, verified under oath and accurate as of the 

date of this Order, of all Assets, Documents, and accounts outside of the United States 

which arc: (I) titled in the name, individually or jointly, of any Defendant; (2) held by 

any person or entity for the benefit of any Defendant or for the benefit of, any 

corporation, partnership, asset protection trust, or other entity that is directly or indirectly 

owned, managed or controlled by any Defendant; or (3) under the direct or indirect 

control, whether jointly or singly, of any Defendant; 

B. Take all steps necessary to provide FTC COWlsel access to all Documents and records that 

may be held by third parties located outside of the territorial United States of America, 

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Case 3:19-cv-00933-VAB *SEALED* Document 33 Filed 06/18/19 Page 16 of 24 

including signing the Consent to Release of Financial Records appended to this Order as 

Attachment D. 

C. Transfer to the te1Titory of the United States and all Documents and Assets located in 

foreign countries which arc: (1) titled in the name, individually or jointly, of any 

Defendant; (2) held by any person or entity for the benefit of any Defendant or for the 

benefit of, any corporation, partnership, asset protection-trust, or other entity that is 

directly or indirectly owned, .managed or controlled by any Defendant; or (3) under the 

direct or indirect control, whether jointly or singly, of any Defendant; and 

D. The same business day as any repatriation, (1) notify FTC counsel of the name and 

location of the financial institution or other entity that is .the recipient of such Documents 

or Assets; and (2) serve this Order on any such financial institution or other entity. 

NON-INTERFERENCE WITH REPATRIATION 

X. 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 hereby 

temporarily restrained and enjoined from taking any action, diredly or indirectly, which may 

re.sult in the encumbrance or dissipation of foreign Assets, or in the hindrance ofthc 

repatriation required by this Order, including, but not limited to: 

A. Sending any communication er engaging in any other act, directly or indirectly, that 

results in a detennination by a foreign trustee or other entity that a "duress'' event has 

occurred under the terms of a foreign trust agreement until such time that a!J Defendants' 

Assets have been fully repatriated pursuant to this Order; or 

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B. Notifying any trustee, protector or other agent of any foreign trust or other related entities 

of either the existence of this Order, or of the fact that repatriation is required pursuant to 

a court order, untiJ such time that all Defendants' Assets have been fully repatriated 

pursuant to this Order. 

CONSUMER CREDIT REPORTS 

XI. IT IS FURTHER ORDERED that the FTC may obtain credit reports conceming any 

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

l68lb(a)(l), and that, upon written request, any credit reporting agency from which such 

reports are requested shaU provide them to the FTC. 

PRESERVATION OF RECORDS 

XII. IT JS 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 hereby 

temporarily restrained and enjoined from: 

A. Destroying, erasing, falsifying, writing over, mutilating, concealing, altering, transferring, 

or otherwise disposing of, in any manner, directly or indirectly, Documents that relate to: 

(!) the business, business practices, Assets, or business or personal finances of any 

Defendant; (2) the business practices or finances of entities directly or indirC\:IIY under 

the control of any Defendant; or (3) the business practices or finances of entities directly 

or indirectly under common control with any other Defendant; and 

B. Failing to create and maintain Documents that, in reasonable detail, accurately, fairly, and 

completely reflect Defendants' incomes, disbursements, trru1sactions, and use of 

Defendants' Assets. 

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REPORT OF :NEW BUSINESS ACTIVITY 

XIII. 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 hereby 

temporarily restrained and enjoined from creating, operating, or exercising any control over 

any business entity, whether newly formed or previously inactive, including any partnership, 

limited partnership,joint venture, sole proprietorship, or corporation, without first providing 

FTC counsel with a written statement disclosing: (1) the name of the business entity; (2) the 

address and telephone number of the business entity; (3) the names of the business entity's 

officers, directors, principals, managers, and employees; and (4) a detailed description of the 

business entity's intended activities. 

IMMEDIATE ACCESS TO BUSU-ESS PREMISES AND RECORDS 

XIV. IT TS FURTHER ORDERED that: 

A. In ord~r to allow the FTC to preserve Assets and evidence relevant to this action and to 

expedite <!iscovery, the FTC, and its representatives, agents, contractors, and assistants, 

shall have immediate access to any business premises or storage facilities, owned, 

controlled, or used by the Defendants. 

B. The FTC, and its representatives, agents, contractors, and assistants, are authorized to 

remove Documents from Defendants' business premises in order that they may be 

inspected, inventoried, and copied. The FTC shall return aoy removed materials to 

Defendants within five (5) business days of compleiing inventorying and copying, or 

such time as is agreed upon by the FTC; 

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Case 3:19-cv-00933-VAB *SEALED* Document 33 Filed 06/18/19 Page 19 of 24 

C. The FTC's access to Defendants' documents pursuant to th is Section shall not provide 

grounds for any Defendant to object to any subsequent request for documents served by 

the FTC. 

D. The FTC, and its representatives, agents, contractors, and assistants, are authorized to 

obtain the assistance of federal, state and local law enforcement officers as they deem 

necessary to effect service and to implement peacefully the provisions of this Order; 

E. lf any Documents, computers, or electronic s_torage devices containing infonnation 

related to the business practices or finances of Defendants are l(,}Cated in the personal 

residence(s) of any Defendant, then, immediately upon receiving notice of this order, 

Defendants shall produce to the FTC all such Documents, computers, and e!ecironic 

storage devices, along with any codes or passwords needed for access. ln order to 

prevent the destruction of computer data, upon service of this Order, any such computers 

or electronic storage devices shall be powered down in the normal course of the operating 

system used on such devices and shall not be powered up or used until produced for 

copying and inspection. The FTC shall return any removed materials to Defendants 

within five (5) business days of completing inventorying and copying, or such time as is 

agreed upon by the FTC; and 

F. If any communications or records of any Defendant are stored with an Electronic Data 

Host, such Defendant shall, immediately upon receiving notice of this order or upon 

request of FTC counsel, take all steps necessary to provide FTC counsel access to such 

communications or records, which may include signing a consent for disclosure of 

communications or records in the form appended to this Order as Attachment E, 

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Case 3:19-cv-00933-VAB *SEALED* Document 33 Filed 06/18/19 Page 20 of 24 

DISTRIBUTION OF ORDER BY DEFENDANTS 

XV. IT IS FURTHER ORDERED that Defendants shall immediately provide a copy of this 

Order to each affiliate, telemarketer, marketer, sales entity, successor, assign, member, 

officer, director, employee, agent, independent contractor, client, attorney, spouse, 

subsidiary, division, and representative of any Defendant, and shall, within ten (10) days 

from the date of entry oft.his Order, and provide the FTC with a sworn statement that this 

provision of the Order has been saiisfied, which statement shall include the names, physical 

addresses, phone number, and cmeil addresses of each such person or entity who received a 

copy of the Order. Furthermore, Defendants shall not take any action that would encoμrage 

officers, agents, members, directors, employees, salespersons, independent contractors, 

attorneys, subsidiaries, affiliates, successors, assigns or other persons or entities in active 

concert or participation with them to disregard this Order or believe that they are not bound 

by its provisions. 

EXPEDITED DISCOVERY 

XVI. IT IS FURTHER ORDERED that, notwithstanding the provisions of the Fed. R. Civ. P. 

26(d) and (f) and 30(a)(2)(A)(iii), and pursuant to Fed. R. Civ. P. 30(a); 34, and 45, the FTC 

is granted leave, at any time after service of this Order, to conduct limited expedited 

discovery for the purpose of discovering: (1) the nature, location, status, and extent of 

Defendants' Assets; (2) the nature, location, and extent of Defendants' business transactions 

and operations; (3) Documents reflecting Defendants' business transactions and operations; 

or (4) compliance with this Order. The limited expedited discovery set forth in this Section 

shall proceed as follows: 

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Case 3:19-cv-00933-VAB ' SEALED* Document 33 Filed 06/18/19 Page 21 of 24 

A. The FTC may take the deposition of parties <\lld non-parties. Forty-eight (48) hours' 

notice shall be sufficient notice for such depositions. The limitations and conditions set 

forth in Rules 30(a)(2)(B) and 31 (a)(2)(B) ofthe Federal Rules of Civil Procedure 

regarding subsequent depositions of an individual shall not apply to depositions taken 

pursuant to this Section. Any such deposition taken pursuant to this Section shall not be 

counted towards the deposition limit set forth in Rules 30(a)(2)(A) and 3 l (a)(2)(A) and 

depositions may be taken by telephone or other remote electronic means; 

B. The FTC may serve upon parties requests for production· of Documents or inspection that 

require production or inspection within five (5) days of service, provided, however, that 

three (3) days of notice shall be deemed sufficient for the production of any such 

Documents that arc maintained or stored only in an electronic fonnat. 

C. The FTC may serve upon parties interrogatories that require response within five (5) days 

after the FTC serves such interrogatories; 

D. The FTC may serve subpoenas upon non-parties that direct production or inspection 

within five (5) days of service. 

E. Service of discove(y·upon a party to this action, taken pursuant to this Section, shall be 

sufficient if made by facsimile, email, or by overnight delivery. 

F. Any expedited discovery taken pursuant to this Section is in addition to, and is not 

subject to, the limits on discovery set forth in the Federal R\1les of Civil Procedure and 

the 1-ocal Rules of this Court. Tbe expedited discovery permitted by this Section does 

not require a meeting or conference of the parties, pursuant to Rules 26( d) & (f) of the 

Federal Rules of Civil Procedure. 

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Case 3:19-cv-00933-VAB *SEALED* Document 33 Filed 06/18/19 Page 22 of 24 

SERVICE OF THIS ORDER 

XVH. IT IS FURTHER ORDERED that copies of this Order as well as the Motion for Temporary 

Restraining Order and all other pleadings, DocumenLs, and exhibits filed contemporaneously 

with that Motion (other than the complaint and summons), may be served by any means, 

including facsimile transmission, electronic mail or other electronic messaging, personal or 

overnight delivery, U.S. Mail or FedEx, by agents and employees of the FTC, by any law 

enforcement agency, or by private process server, upon any Defendant or any person 

(including any financial institution) that may have possession, custody or control of any 

Asset or Document of any Defendant, or that may be subject to any provision of this Order 

pursuant lo Rule 65( d)(2) of the Federal Rules of Civil Procedure. For purposes of this 

Section, service upon any branch, subsidiary, affiliate or office of any entity shall effect 

service upon the entire entity. 

CORRESPONDENCE Al\'D SERVICE ON THE FTC 

XVIII. IT IS FURTHER ORDERED that, for the purpose of this Order, all correspondence and 

service of pleadings on the FTC shall be address.eel to: Gregory A. Ashe and Ioana R. 

Gorecki, Federal Trade Commission, 600 Pennsylvania Avenue NW, Room CC-10232, 

Washington, D.C. 20580, email: ·gashe@ftc.gov and igore<llo@ftc.gov. 

PRELIMIIXARY INJUNCTION HEARING 

XIX. IT IS FURTHER ORDERED that, pursuant to Fed. R. Civ. P. 65(b), Defendants shall 

appear before this Court on the 28th day of June 2019, at 

915 Lafayette Blvd., 

I l :30 , at the United States Courthouse, Courtroom __ 2_, .:::B.:.:ric::d,,_ge::<pc::o.:.rt=------' 

Co1mecticut, to show ca\lse, if there is any, why this Court should not enter a preliminary 

injunction, pending final ruling on the Complaint against Defendants, enjoining the 

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Case 3:19-cv-00933-VAB *SEALED* Document 33 Filed 06/18/19 Page 23 of 24 

violations of the law alleged in the Complaint, continuing the freeze of their Assets, and 

imposing such additional relief as may be appropriate. 

BRIEFS AND AFFIDAVITS CONCERNING PRELIMINARY INJUNCTION 

XX. IT IS FURTHER ORDERED that: 

A. Defendants shall file with the Court and serve on FTC counsel any answering pleadings, 

affidavits, motions, expert reports or declarations, or legal memoranda no later than two 

(2) days prior to the order to show cause hearing scheduled pursuant to this Order. The 

FTC may fit~ responsive or supplemental pleadings, materials, affidavits, or memoranda 

with the Court and serve the same on counsel for Defendants no later than one (l) day 

prior to the order to show Cause hearing. Provided that such affidavits, pleadings, 

motions, expert reports, declarations, legal memoranda or oppositions must be served by 

personal or overnight delivery, facsimile or ernail, and be received by the other party or 

parties no later than 5:00 p.m. (Eastern Daylight Time) on the appropriate dates set forth 

in this Section. 

B. An evidentiary hearing on the FTC's request for a preliminary injunction is not necessary 

unless Defendants demonstrate that they have, and intend to introduce, evidence that 

raises a genuine and material factual iss,ie. The question of whether this Court should 

enter a preliminary inj unction shall be resolved on the pleadings, declarations, exhibits, 

and memoranda filed by, and oral argument of, the parties. Live testimony shall be heard 

only on further order of this Court. Any motion to permit such testimony shall be filed 

witb the Court and served on counsel for the other parties at least five (5) days prior to 

the preliminary injunction heating in this matter. Such motion shall set forth the name, 

address, and telephone number of each proposed witness, a detailed summary or affidavit 

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case 3:19-cv-00933-VAB *SEALED* Document 33 Filed 06/18/19 Page 24 of 24 

revealing the substance of each proposed witness's expected testimony, and an 

explanation of why the taking of live testimony would be helpful to this Court. Any 

papers opposing a timely motion to present live testimony or to present live testimony in 

response to another party's timely motion to present live testimony shall be filed with this 

Court and served on the other parties ~t least three (3) days prior to the order to show 

cause hearing. Provided, however, that service shall be performed by personal or 

overnight delivery, facsimile or email, and Documents shall be delivered so that they 

shall be received by the other parties no later than 5:00 p.m. (Eastern Daylight Time) on 

the appropriate dates provided in this Section. 

DUR<\TION OF THE ORDER 

XXI. IT IS FURTHER ORDERED that this Order shall expire folllteen (14) days from the date 

of entry noted below, unless within such time, the Order is extended for an additional period 

pursuant to Fed. R. Civ. P. 65(b)(2). 

RETENTION OF JURISDICTION 

XXII. IT IS FURTHER ORDERED that this Court shall retain jurisdiction of this matter for all 

purposes. 

SO ORDERED, this 18th day of June, 2019, at-'--9:..:..00.:..... __ ,.J!_.m. 

/s/ Victor A. Bolden, USDJ 

UNITED STATES DISTRICT JUDGE 

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