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STEPHEN T. FAIRCHILD

WA Bar No. 41214; sfairchild@ftc.gov

RICHARD MCKEWEN

WA Bar No. 45041; rmckewen@ftc.gov

FEDERAL TRADE COMMISSION

915 Second Avenue, Suite 2896

Seattle, WA 98174

Tel.: (206) 220-6350; Fax: (206) 220-6366

ROBERT J. QUIGLEY, Local Counsel

CA Bar No. 302879; rquigley@ftc.gov

FEDERAL TRADE COMMISSION

10990 Wilshire Boulevard, Suite 400

Los Angeles, CA 90024

Tel.: (310) 824-4300; Fax: (310) 824-4380

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

FEDERAL TRADE COMMISSION,

 Plaintiff,

 v.

AMERICAN FINANCIAL SUPPORT 

SERVICES INC., et al.,

 Defendants.

Civ. No. 8:19-cv-02109-JWH (ADSx)

[Proposed] STIPULATED ORDER 

FOR PERMANENT INJUNCTION 

AND MONETARY JUDGMENT AS 

TO DEFENDANTS AMERICAN 

FINANCIAL SUPPORT SERVICES 

INC., US FINANCIAL FREEDOM 

CENTER, INC., AND JAY SINGH

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

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

Complaint for Permanent Injunction and Other Equitable Relief ( “Complaint”) in 

this matter, pursuant to Sections 13(b) and 19 of the Federal Trade Commission 

Act (“FTC Act”), 15 U.S.C. §§ 53(b), 57b. The Commission and Defendants 

American Financial Support Services Inc., US Financial Freedom Center, Inc., and 

Jay Singh (each a “Stipulating Defendant,” and collectively, “Stipulating 

Defendants”) stipulate to the entry of this Stipulated Order for Permanent 

Injunction and Monetary Judgment as to Defendants American Financial Support 

Services Inc., US Financial Freedom Center, Inc., and Jay Singh (“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 Stipulating Defendants participated in deceptive

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

Telemarketing Sales Rule, 16 C.F.R. pt. 310, in the marketing and sale of student 

loan debt relief services. 

3. Stipulating 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, Stipulating Defendants admit the facts necessary to establish jurisdiction. 

4. Stipulating Defendants waive any claim 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 agree to bear their own costs and attorney fees.

Furthermore, Stipulating Defendants waive and release any claims that they may 

have against the Commission, the Receiver, and their agents that relate to this 

action. 

5. Stipulating 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 FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 2

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DEFINITIONS

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

A. “Assisting Others” includes:

1. performing customer service functions, including receiving or 

responding to consumer complaints; 

2. formulating or providing, or arranging for the formulation or 

provision of, any advertising or marketing material, including any telephone 

sales script, direct mail solicitation, or the design, text, or use of images of 

any Internet website, email, or other electronic communication; 

3. formulating or providing, or arranging for the formulation or 

provision of, any marketing support material or service, including web or 

Internet Protocol addresses or domain name registration for any Internet 

websites, affiliate marketing services, or media placement services;

4. providing names of, or assisting in the generation of, potential 

customers; or

5. performing marketing, billing, or payment services of any kind.

B. “Debt Relief Product or Service” means: 

1. With respect to any mortgage, loan, debt, or obligation between a 

Person and one or more secured or unsecured creditors or debt collectors, 

any Product or Service represented, expressly or by implication, to:

a. stop, prevent, or postpone any mortgage or deed of foreclosure 

sale for a Person’s dwelling, any other sale of collateral, any 

repossession of a Person’s dwelling or other collateral, or otherwise 

save a Person’s dwelling or other collateral from foreclosure or 

repossession;

b. negotiate, obtain, or arrange a modification, or renegotiate, 

settle, or in any way alter any terms of the mortgage, loan, debt, or 

obligation, including a reduction in the amount of interest, principal 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

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balance, monthly payments, or fees owed by a Person to a secured or 

unsecured creditor or debt collector;

c. obtain any forbearance or modification in the timing of 

payments from any secured or unsecured holder or servicer of any 

mortgage, loan, debt, or obligation;

d. negotiate, obtain, or arrange any extension of the period of time 

within which a Person may (i) cure his or her default on the mortgage, 

loan, debt, or obligation, (ii) reinstate his or her mortgage, loan, debt, 

or obligation, (iii) redeem a dwelling or other collateral, or (iv) 

exercise any right to reinstate the mortgage, loan, debt, or obligation 

or redeem a dwelling or other collateral;

e. obtain any waiver of an acceleration clause or balloon payment 

contained in any promissory note or contract secured by any dwelling 

or other collateral; or

f. negotiate, obtain, or arrange (i) a short sale of a dwelling or 

other collateral, (ii) a deed-in-lieu of foreclosure, or (iii) any other 

disposition of a mortgage, loan, debt, or obligation other than a sale to 

a third party that is not the secured or unsecured loan holder.

The foregoing shall include any manner of claimed assistance, including 

auditing or examining a Person’s application for the mortgage, loan, debt, or

obligation.

2. With respect to any loan, debt, or obligation between a Person and one 

or more unsecured creditors or debt collectors, any Product or Service 

represented, expressly or by implication, to: 

a. repay one or more unsecured loans, debts, or obligations; or

b. combine unsecured loans, debts, or obligations into one or more 

new loans, debts, or obligations.

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 4

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C. “Corporate Defendants” means Defendants American Financial Support 

Services Inc. and US Financial Freedom Center, Inc., individually, collectively, or 

in any combination.

D. “Individual Defendant” means Defendant Jay Singh.

E. “Person” means any individual, group, unincorporated association, limited 

or general partnership, corporation, or other business entity.

F. “Product or Service” means any good or service, including any plan or 

program.

ORDER

I. BAN ON DEBT RELIEF PRODUCTS AND SERVICES

IT IS ORDERED that Stipulating Defendants are permanently restrained and 

enjoined, whether acting directly or through an intermediary, from advertising, 

marketing, promoting, offering for sale, or selling, or Assisting Others in the 

advertising, marketing, promoting, offering for sale, or selling, of any Debt Relief 

Product or Service.

II. PROHIBITION AGAINST MISREPRESENTATIONS

IT IS FURTHER ORDERED that Stipulating Defendants, Stipulating

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, in connection with the advertising, 

marketing, promoting, offering for sale, or selling of any Product or Service, are 

permanently restrained and enjoined from misrepresenting, or Assisting Others in 

misrepresenting, expressly or by implication:

A. any material aspect of the nature or terms of any refund, cancellation, 

exchange, or repurchase policy, including the likelihood of a consumer obtaining a 

full or partial refund, or the circumstances in which a full or partial refund will be 

granted to the consumer;

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 5

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B. that any Person is affiliated with, endorsed or approved by, or otherwise 

connected to any other Person; government entity; public, non-profit, or other noncommercial program; or any other program;

C. the nature, expertise, position, or job title of any Person who provides any 

Product or Service;

D. the Person who will provide any Product or Service to any consumer;

E. that any Person providing a testimonial has purchased, received, or used the 

Product or Service;

F. that the experience represented in a testimonial of the Product or Service 

represents the Person’s actual experience resulting from the use of the Product or 

Service under the circumstances depicted in the advertisement; or

G. any other fact material to consumers concerning any Product or Service, 

such as: the total costs; any material restrictions, limitations, or conditions; or any 

material aspect of its performance, efficacy, nature, or central characteristics.

III. PROHIBITION AGAINST UNSUBSTANTIATED CLAIMS

IT IS FURTHER ORDERED that Stipulating Defendants, Stipulating

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, in connection with the promoting or

offering for sale of any Product or Service, are permanently restrained and

enjoined from making any representation or Assisting Others in making any

representation, expressly or by implication, about the benefits, performance, or

efficacy of any Product or Service, unless the representation is non-misleading,

including that, at the time such representation is made, they possess and rely upon

competent and reliable evidence that is sufficient in quality and quantity based on

standards generally accepted in the relevant fields, when considered in light of the

entire body of relevant and reliable evidence, to substantiate that the representation

is true. 

Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 6 of 44 Page ID #:4455
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 6

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IV. INJUNCTION RELATING TO TELEMARKETING

IT IS FURTHER ORDERED that Stipulating Defendants, Stipulating

Defendants’ officers, agents, and employees, 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, in connection with telemarketing, advertising,

marketing, promoting, offering for sale, or selling of any Product or Service, are

hereby permanently restrained and enjoined from:

A. Misrepresenting, directly or by implication, in the sale of goods or services

any material aspect of the performance, efficacy, nature, or central characteristics

of goods or services that are the subject of a sales offer; and

B. Violating the FTC’s Telemarketing Sales Rule, 16 C.F.R. pt. 310, a copy of

which is attached as Attachment A. 

V. MONETARY JUDGMENT AND PARTIAL SUSPENSION

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Seven Million Five Hundred Fifty-Seven 

Thousand One Dollars and Ten Cents ($7,557,001.10) is entered in favor of the 

Commission against Stipulating Defendants, jointly and severally, as monetary 

relief.

B. In partial satisfaction of the judgment imposed by Subsection A, Individual 

Defendant Jay Singh is ordered to pay to the Commission $743,386.00, which, as 

Individual Defendant stipulates, his counsel will hold in escrow for no purpose 

other than payment to the Commission. Such payment must be made within 7 days

of entry of this Order by electronic fund transfer in accordance with instructions 

previously provided by a representative of the Commission. Upon such payment, 

the remainder of the judgment is suspended, subject to the Subsections below.

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

expressly premised upon the truthfulness, accuracy, and completeness of 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 7

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Stipulating Defendants’ sworn financial statements and related documents 

(collectively, “Financial Attestations”) submitted to the Commission, namely: 

1. the Financial Statement of Individual Defendant Jay Singh signed on 

November 14, 2019;

2. the Amended Financial Statement of Individual Defendant Jay Singh 

signed on October 9, 2020;

3. the sworn declaration of Individual Defendant Jay Singh signed on 

January 20, 2021;

4. the Financial Statement of Corporate Defendant American Financial 

Support Services Inc. signed by Jay Singh on November 13, 2019, including 

the attachments; and

5. the Financial Statement of Corporate Defendant US Financial 

Freedom Center, Inc. signed by Jay Singh on November 13, 2019, including 

the attachments.

D. The suspension of the judgment will be lifted as to any Stipulating 

Defendant if, upon motion by the Commission, the Court finds that Stipulating 

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 Stipulating Defendant in the amount specified in 

Subsection A above (which the parties stipulate only for purposes of this Section 

represents the consumer injury alleged in the Complaint), less any payment 

previously made pursuant to this Section, plus interest computed from the date of 

entry of this Order.

VI. ADDITIONAL MONETARY PROVISIONS

IT IS FURTHER ORDERED that: 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 8

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A. Stipulating 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 

an 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. Stipulating Defendants acknowledge that their Taxpayer Identification 

Numbers (Social Security Numbers or Employer Identification Numbers), which 

Stipulating 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.

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 

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 relief 

(including consumer information remedies) as it determines to be reasonably 

related to Stipulating Defendants’ practices alleged in the Complaint. Any money 

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

disgorgement. Stipulating Defendants have no right to challenge any actions the 

Commission or its representatives may take pursuant to this Subsection.

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 9

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F. The asset freeze imposed by the preliminary injunction order entered on

December 17, 2019 (Doc. 79), is modified to permit the payments identified in

Section V.B. The asset freeze shall otherwise remain in full force and effect until 

the completion of all such payments, after which the asset freeze shall be dissolved 

as to the Stipulating Defendants.

VII. CUSTOMER INFORMATION

IT IS FURTHER ORDERED that Stipulating 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, whether

acting directly or indirectly, in connection with the advertising, marketing,

promoting, offering for sale, or selling of any Product or Service, are permanently 

restrained and enjoined from directly or indirectly: 

A. failing to provide sufficient customer information to enable the Commission 

to efficiently administer consumer redress. If a representative of the Commission 

requests in writing any information related to redress, Stipulating Defendants must 

provide it, in the form prescribed by the Commission, within 14 days.

B. disclosing, using, or benefitting from customer information, including the 

name, address, telephone number, email address, social security number, other 

identifying information, or any data that enables access to a customer’s account 

(including a credit card, bank account, or other financial account), that any 

Defendant obtained prior to entry of this Order in connection with the sale and 

marketing of student loan debt relief services; and

C. failing to destroy such customer information in all forms in their possession, 

custody, or control within 30 days after receipt of written direction to do so from a 

representative of the Commission. 

Provided, however, that customer information need not be disposed of, and 

may be disclosed, to the extent requested by a government agency or required by 

law, regulation, or court order. 

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DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

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VIII. COOPERATION

IT IS FURTHER ORDERED that Stipulating Defendants must fully 

cooperate with representatives of the Commission and the Receiver in this case and 

in any investigation related to or associated with the transactions or the 

occurrences that are the subject of the Complaint. Stipulating Defendants must 

provide truthful and complete information, evidence, and testimony. Individual 

Defendant Jay Singh must appear and Corporate Defendants must cause their

officers, employees, representatives, or agents to appear for interviews, discovery, 

hearings, trials, and any other proceedings that a Commission or Receiver’s

representative may reasonably request upon 5 days written notice, or other 

reasonable notice, at such places and times as a Commission or Receiver’s

representative may designate, without the service of a subpoena.

IX. RECEIVERSHIP TERMINATION

IT IS FURTHER ORDERED that, within 120 days after entry of this Order, 

the Receiver must file with the Court and serve on the parties a final accounting, 

report, and request for compensation with respect to Corporate Defendants. Any 

party or the Receiver may request that the Court extend this deadline for good 

cause. After the Court has approved the Receiver’s final request for compensation, 

the Receiver shall transfer to the Commission all dominion, title, and control of the 

Corporate Defendants’ remaining monetary assets, in partial satisfaction of the 

monetary judgment contained in Section V.A of this Order. Payment to the 

Commission of said assets, if any, shall be made by the holder of the assets by 

electronic fund transfer in accordance with instructions provided to the holder of 

the assets by a representative of the Commission. Corporate Defendants waive and 

release any rights to claims to their funds in possession of the Receiver remaining 

after payment of the fees authorized by the Court to the Receiver. After the 

Receiver has transferred the Corporate Defendants’ remaining monetary assets to 

the Commission, the Receiver shall return Stipulating Defendants’ remaining nonCase 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 11 of 44 Page ID

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monetary assets in the Receiver’s possession to counsel for Stipulating 

Defendants. The Receiver shall provide counsel for the Commission with a written 

inventory of the non-monetary assets returned to Stipulating Defendants pursuant 

to this Section.

No later than 60 days after the Receiver has transferred the Corporate 

Defendants’ remaining monetary assets to the Commission, the Receiver shall 

dissolve and complete all remaining duties with respect to the Corporate 

Defendants, and the receivership shall terminate and the Receiver shall be 

discharged with respect to the Corporate Defendants.

X. ORDER ACKNOWLEDGMENTS

IT IS FURTHER ORDERED that Stipulating Defendants obtain 

acknowledgments of receipt of this Order:

A. Each Stipulating 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 10 years after entry of this Order, Individual Defendant for any business 

that such Individual Defendant, individually or collectively with any other 

defendant in this action, 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 

the conduct specified in Section IV and all agents and representatives who 

participate in the conduct specified in Section IV; (3) any payment processor or 

lead broker or generator used by the business; and (4) 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.

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C. From each individual or entity to which a Stipulating Defendant delivered a 

copy of this Order, that Stipulating Defendant must obtain and deliver to the 

Commission, within 30 days, a signed and dated acknowledgment of receipt of this 

Order, in the form attached to this Order.

XI. COMPLIANCE REPORTING

IT IS FURTHER ORDERED that Stipulating Defendants make timely 

submissions to the Commission:

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

compliance report, sworn under penalty of perjury:

1. Each Stipulating 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 Stipulating Defendant; (b) identify all of that Stipulating Defendant’s 

businesses by all of their names, telephone numbers, and physical, postal, 

email, and Internet addresses; (c) describe in detail 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 

Stipulating Defendants must describe if they know or should know due to 

their own involvement); (d) describe in detail whether and how that 

Stipulating 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, 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 Individual Defendant performs services whether as an employee or 

otherwise and any entity in which Individual Defendant has any ownership 

interest; and (c) describe in detail Individual Defendant’s involvement in 

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each such business, including title, role, responsibilities, participation, 

authority, control, and any ownership.

B. For 10 years after entry of this Order, each Stipulating Defendant must 

submit a compliance notice, sworn under penalty of perjury, within 14 days of any 

change in the following: 

1. Each Stipulating Defendant must report any change in: (a) any 

designated point of contact; or (b) the structure of any entity that Stipulating

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 Stipulating Defendant must report any change in: 

(a) name, including aliases or fictitious name, or residence address; or (b) 

title or role in any business activity, including any business for which such

Stipulating Defendant performs services whether as an employee or 

otherwise and any entity in which such Stipulating Defendant has any 

ownership interest, and identify the name, physical address, and any Internet 

address of the business or entity.

C. Each Stipulating Defendant must submit to the Commission notice of the 

filing of any bankruptcy petition, insolvency proceeding, or similar proceeding by 

or against such Stipulating 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.

Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 14 of 44 Page ID

#:4463
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 14

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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 NW, Washington, DC 20580. The 

subject line must begin: FTC v. American Financial Support Services Inc., et al., 

X200005.

XII. RECORDKEEPING

IT IS FURTHER ORDERED that Stipulating Defendants must create certain 

records for 10 years after entry of the Order, and retain each such record for 5 

years. Specifically, Corporate Defendants and each Individual Defendant for any 

business that Individual Defendant, individually or collectively with any other 

defendant in this action, 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;

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

this Order, including all submissions to the Commission; and

E. a listing of all payment processors and lead brokers or generators used in the 

conduct of the business.

XII. COMPLIANCE MONITORING

IT IS FURTHER ORDERED that, for the purpose of monitoring Stipulating 

Defendants’ compliance with this Order, including the Financial Attestations upon 

Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 15 of 44 Page ID

#:4464
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 15

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which part of the judgment was suspended and any failure to transfer any assets as 

required by this Order:

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

Commission, each Stipulating 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 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 Stipulating Defendant. Such Stipulating 

Defendant must permit representatives of the Commission to interview any 

employee or other person affiliated with any Stipulating 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 

Stipulating Defendants or any individual or entity affiliated with Stipulating

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).

///

///

///

///

Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 16 of 44 Page ID

#:4465
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 16

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XIII. 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.

Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 17 of 44 Page ID

#:4466

II 
Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 18 of 44 Page ID

#:4467

1 ~O STIPULATED AND AGREED: 

2 

3 FOR PLAINTIFF FEDERAL TRADE COl\'11\iUSSION: 

4 

5 J.h3'7t {. ~ --

6 'te hen T. Fairchild, Attorney 

Richard McKcwen, Attorney 

7 Federal Trade Commission 

8 915 Second Avenue, Suite 2896 

Seattle, WA 98174 

9 (206) 220-4476 (Fairchild) 

lo (206) 220-4595 (McKewen) 

(206) 220-6366 (fax) 

11 sfairchild~yftc.gov 

12 rmckewen@ftc.gov 

Date: t,(t"(/zt 

13 

FOR STIPULATING DEFENDANTS AMERICAN FINANCIAL SUPPORT 

14 SERVICES INC., US FINANCIAL FREEDOM CENTER, INC. and.JAY 

15 SINGH: 

16 

:; ~.,,,, . ~ 

William R. Mitchell 

19 WILLJAM R. MITCHELL, INC. 

20 IO I Pacifica, Suite 155 

Irvine, CA 92618 

21 Telephone: (949) 679-6920 

22 Facsimile: (949) 398-7300 

Email: bill@wrmbizlaw.com 

23 

24 

25 

26 

27 

28 

- Date: C, · IJ ..;2.J, __ 

STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JlIDGMF.NT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC .. US FINANCIAL FREEDOM CENTER, 

INC .. AND JAY SINGH - 18 
Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 19 of 44 Page ID

#:4468

I 

2 

3 

4 

5 

STIPULATING DEFENDANTS AMERICAN FINANCIAL SUPPORT 

SERVICES INC., US FINANCIAL FREEDOM CENTER, INC. and JAY 

SINGH: 

Date: 6-11--Lci2 ... I 

Jay Singh, individually and as an officer of 

6 American Financial Suppo1t Services Inc. and 

7 US Financial Freedom Center, Inc. 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SlNGH - 19 
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 19

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UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

FEDERAL TRADE COMMISSION,

 Plaintiff,

 v.

AMERICAN FINANCIAL SUPPORT 

SERVICES INC., et al.,

 Defendants.

Civ. No. 8:19-cv-02109-JWH (ADSx)

ACKNOWLEDGEMENT BY 

DECLARATION PURSUANT TO 

28 U.S.C. § 1746 OF RECEIPT OF 

ORDER BY DEFENDANT

1. My name is Jay Singh, my job title is President and Chief Executive Officer, 

and I am authorized to accept service of process on American Financial Support 

Services Inc. and US Financial Freedom Center, Inc. I am a U.S. citizen over the 

age of eighteen, and I have personal knowledge of the facts set forth in this 

Acknowledgment.

2. I was a Defendant, and American Financial Support Services Inc. and US 

Financial Freedom Center, Inc. were Defendants, in Federal Trade Commission v. 

American Financial Support Services Inc., et al., which is the court case listed near 

the top of this page.

3. On ________________, 20__, I received a copy of the Stipulated Order for 

Permanent Injunction and Monetary Judgment as to Defendants American 

Financial Support Services Inc., US Financial Freedom Center, Inc., and Jay Singh, 

which was signed by the Honorable John W. Holcomb and entered by the Court on 

______________, 20__. 

Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 20 of 44 Page ID

#:4469
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 20

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4. On ________________, 20__, American Financial Support Services Inc. 

and US Financial Freedom Center, Inc. received a copy of the Stipulated Order for 

Permanent Injunction and Monetary Judgment as to Defendants American 

Financial Support Services Inc., US Financial Freedom Center, Inc., and Jay Singh, 

which was signed by the Honorable John W. Holcomb and entered by the Court on 

______________, 20__.

I declare under penalty of perjury under the laws of the United States of America 

that the foregoing is true and correct. 

Executed on _________________, 20__, at __________________.

___________________________________

Jay Singh, individually and as an officer of 

American Financial Support Services Inc. 

and US Financial Freedom Center, Inc.

Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 21 of 44 Page ID

#:4470
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 21

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UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

FEDERAL TRADE COMMISSION,

 Plaintiff,

 v.

AMERICAN FINANCIAL SUPPORT 

SERVICES INC., et al.,

 Defendants.

Civ. No. 8:19-cv-02109-JWH (ADSx)

ACKNOWLEDGEMENT BY 

DECLARATION OF RECEIPT OF 

ORDER BY A NON-PARTY

1. I, __________________________________, received a copy of the 

Stipulated Order for Permanent Injunction and Monetary Judgment as to 

Defendants American Financial Support Services Inc., US Financial Freedom 

Center, Inc., and Jay Singh in the case of Federal Trade Commission v. American 

Financial Support Services Inc., et al., on _______________________, 20___.

2. I was not a Defendant in that court case. My title or relationship with 

Defendant(s) ________________________________________ is: 

__________________________________________________________________.

3. I declare under penalty of perjury under the laws of the United States of 

America that the foregoing is true and correct.

Executed on _________________, 20___, at _______________________ [place].

Signed:

_________________________

Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 22 of 44 Page ID

#:4471
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AS TO 

DEFENDANTS AMERICAN FINANCIAL SUPPORT SERVICES INC., US FINANCIAL FREEDOM CENTER, 

INC., AND JAY SINGH – 22

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ATTACHMENT A

Case 8:19-cv-02109-JWH-ADS Document 172 Filed 06/14/21 Page 23 of 44 Page ID

#:4472
	
		
	
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