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UNITED ST A TES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. 17-CV-8961.9-WPD 

FEDERAL TRADE COMMISSION, 

P1aintiff, 

v. 

STRA TEGJC STUDENT SOLUTIONS LLC, et 

al., 

Defendants, and 

0G INVESTMENT PROPERTIES LLC, 

Relief Defendant. 

STIPULATED ORDER FOR PERMANENT INJUNCTION 

AND MONETARY JUDGMENT 

Plaintiff, the Federal Trade Commission ("Commission" or "FTC'), filed its Complaint 

for Permanent Injunction and Other Equitable Relief (''Complaint"), pursuant to Section J 3(b) of 

the Federal Trade Commission Act ("FTC Act"), IS U.S.C. § 53(b), the Telemarketing and 

Consumer Fraud and Abuse Prevention Act ("Telemarketing Act"), 15 U.S.C. §§ 6 IOl -6 l08, and 

Section 4IO(b) of the Credit Repair Organizations Act, 15 U.S.C. § l679h(b). The Commission, 

the Receiver, Defendants Strategic Student Solutions LLC, Strategic Credit Solutions LLC, 

Strategic Debt Solutions LLC, Strategic Doc Prep Solutions LLC, Student Relief Center LLC, 

Credit Relief Center LLC, and Dave Green ("Defendants") and Relief Defendant 0G Investment 

Properties LLC ( .. Relief Defendant") stipulate to the entry of this Stipulated Order for Pennanent 

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Injunction and Monetary Judgment ("Order") to resolve all matters in dispute in this action 

between them. The Receiver is entering into this Order on behalf of Corporate Defendants based 

upon the powers granted to him under the Stipulated J>reliminary Injunction (ECF No. 42). The 

Receiver notes that Corporate Defendants and Relief Defendant are not currently represented by 

counsel. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

. I This Court has jurisdiction over this matter. 

2. The Complaint charges that Defendants participated in deceptive acts or practices in 

violation of Section 5 of the FTC Act, 15 U.S.C. § 45, and violated the FTC's Telemarketing 

Sales Rule ("TSR"), 16 C.F.R.Part310, and the Credit Repair Organizations Act ("CROA''), 15 

U.S.C. §§ I 679• I 679j in connection with the marketing and sale of student loan debt relief and 

credit repair services, and that Relief Defendant has received funds that are traceable to funds 

obtained from the unlawful acts and practices at issue and has no legitimate claim to the funds. 

3. Defendants and Relief Defendant 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 and Relief Defendant admit the facts necessary to establish jurisdiction. 

4. Defendants and Relief Defendant 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. 

5. Defendants and Relief Defendant waive all rights to appeal or otherwise challenge or 

contest the validity of this Order. 

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DEFINITIONS 

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

A. "Assisttog others" includes: 

I. performing customer service functions, including receiving or responding to 

consumer complaints; 

2. formulating or providing, or aminging 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. fonnulating 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; 

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

6. acting or serving as an owner, officer, director, manager, or principal of any entity. 

B. "Credit repair product or service" means any product, service, plan. or program 

represented, expressly or by implication, to improve any consumer's credit record, credit history, 

or credit rating; or provide advice or assistance to any consumer with regard to any activity or 

service the purpose of which is to improve a consumer's credit record, credit history, or credit 

rating. 

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C. "Defendants" means the Individual Defendant and all of the Corporate Defendants, 

individually, collectively, OT in any combination. 

l. '"Corporate Defendants" means Strategic Student Solutions LLC. Strategic Credit 

Solutions LLC, Strategic Debt Solutions LLC, Strategic Doc Prep Solutions LLC, Student Relief 

Center LLC, and Credit Relief Center LLC, and their successors and assigns. 

2. "lndlvldual Def end ant" means Dave Green. 

D. "Financial product or service" means any product, service, plan, or program 

represented, expressly or by implication, to: 

I. provide any consumer, arrange for any consumer to receive, or assist any 

consumer in receiving. a loan or other extension of credit; 

2. provide any consumer, arrange for any consumer to receive, or assist any 

consumer in receiving, debit, credit, or stored value cards; 

3. improve, repair, or arrange to improve or repair, any consumer's credit record. 

credit history, or credit rating; or 

4. provide advice or assistance to improve any consumer's credit record, credit 

history, or credit rating. 

E. ..Person" means any individual, group, unincorporated association, limited or general 

partnership, corporation, or other business entity. 

F. "Receiver" means Charles H. Lichttnan, Esq. and Isaac M. Marcushamer, Esq. of Berger 

Singerman LLP, solely in their respective capacities as Receiver and Temporary Receiver, and 

their agents and professionals, including Berger Singennan LLP. 

G. "Relief Defendant" means 0G Investment Properties, LLC. 

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H. ..Rental Property Entities" means 18 Westgate LLC, 227 San Remo LLC, 4461 Squatter 

Home LLC, 4628 Concordia LLC, 4899 Tropical, LLC, 5819 Swordfish LLC, 17.50 NW Land 

Trust. 7893 La Mirada LLC, and Clafy Holdings LLC, and includes the respective fee title 

owners of properties owned or controlled by them, Relief Defendant, and/or Individual 

Defendant, including but not limited to Renaissance Land Trust, 5819 Land Trust, 6300 Falls 

Land Trust, 8911 NW Land Trust, 2701 Riverside Land Trust, San Remo Land Trust, 14212 NE 

Land Trust, 17343 NW Land Trust, 4158 lnverrary Land Trust. 4461 Land Trust, 500 Islands 

Land Trust (a/k/a 500 Three Islands Land Trust), 4628 Concordia Land Trust, 18 Westgate Land 

Trust. 6009 Land Trust, 4899 Tropical Land Trust, 11152 W. Sample Land Trust, 5280 Gate Lake 

Land Trust, 5961 Falls Land Trust, 4109 Bellasol Circle Land Trust, 7355 Woodmont Land Trust, 

2314 Johnson Street Land Trust, 1750 NW Land Trust. 

I. "Secured or unseeured 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, service, plan, or program 

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 collater.tl, any repoS8ession 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 

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amount of interest, principal 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 foredosure, 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 a 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, service, plan, or program represented, 

expressly or by implication, to: 

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

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

debts, or obligations. 

ORDER 

I. BAN ON SECURED AND UNSECURED DEBT RELIEF 

PRODUCTS AND SERVICES 

IT IS ORDERED that Defendants are pennanentJy restrained and enjoined from 

j!vertising, marketing, promoting, offering for sale, or selling, or assisting others in the 

~vertising, marketing, promoting, offering for sale, or selling, of any secured or unsecured debt 

relief product or service. 

11. BAN ON CREDIT REPAIR PRODUCTS AND SERVICES 

IT IS FURTHER ORDERED that Defendants are permanently restrained and enjoined 

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

advertising, marketing, promoting, offering for sale, or selling, of any credit repair product or 

service. 

III. PROHIBITION AGAINST MISREPRESENTATIONS RELATING TO 

FINANCIAL PRODUCTS AND SERVICES 

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. wbo 

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 financial product or service, 

are pennanently restrained and enjoined from misrepresenting, or assisting others in 

misrepresenting, expressly or by implication: 

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A. the tenns or rates that are available for any loan or other extension of credit, 

including: 

, I closing costs or other fees; 

2. the payment schedule, monthly payment amount(s), any baJloon payment, 

or other payment terms; 

J. the interest rate(s), annual percentage rate(s), or financ.e ch.arge(s), and 

whether they are fixed or adjustable; 

4. the loan amount. credit amount, draw amount, or outstanding balance; the 

loan term, draw period, or maturity; or any other term of credit; 

5, the amount of cash to be disbursed to the borrower out of the proceeds, or 

the amount of cash to be disbursed on behalf of the borrower to any third 

parties; 

6. whether any specified minimum payment amount covers both interest and 

principal. and whether the credit has or can result in negative amortization; 

or 

7. that the credit does not have a prepayment penalty or whether subsequent 

refinancing may trigger a prepayment penalty and/or other fees; 

8. that a consumer will receive legal representation; or 

C. any other fact maceriaJ to consumers concerning any good 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. 

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IV. PROHIBITION AGAINST MISREPRESENTATIONS RELATING TO ANY 

PRODUCTS OR SERVICES 

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, in connection with the 

advertising. marketing, promoting, offering for sale, or selling of any product, service, plan, or 

program, 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 I ikelihood 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; or, if consumers cancel, their ability to participate in other programs or 

services intended to meet the same goal; 

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 

non-commercial program; or any other program; 

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

service, plan, or program; or 

D. any other fact material to consumers concerning any good or service, such as: the 

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

aspect of its perfonrumce, efficacy, nature, or central characteristics. 

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V. PROHIBITION AGAINST UNSUBSTANTIATED CLAIMS 

JT 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 

rw:eive actual notice of this Order, whether acting directly or indirectly, in connection with the 

,; 

5f1e of any financial produc1 or service, are pcnnanently restrained and enjoined from making any 

~tesentation or assisting others in making any representation, expressly or by implication, about ~ 

die benefits, perfonnance, or efficacy of any financial product or service, unless the representation 

is non.misleading, and, at the time such representation is made, Defendants possess and rely upon 

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

aenerally 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. 

VI. MONET ARY JUDGMENT AND PARTIAL SUSPENSION 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of seventeen million, seven hundred and twenty nine thousand, 

four hundred and ninety three dollars ($17,729,493) is entered in favor of the Commission against 

Def cndants and Relief Defendant. jointly and severally, except that Relief Defendant's portion of 

the judgment shall not exceed $2,977,845 as equitable monetary relief. 

B. In partial satisfaction of the judgment against Defendants and Relief Defendant: 

l. All financial institutions holding accounts in the name of, on behalf of, or for the 

benefit of, any Corporate Defendant shall, within ten l ( 0) business days from 

receipt of a copy of this Order, transfer to the Receiver or his designated agent. an 

funds,. if any, in such accounts, including, but not limited to: 

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a. Within ten (10) business days of receipt of a copy of this Order. A&D 

Mortgage is ordered to transfer to the Receiver or his designated agent all 

funds in account number xxxx0013 in the name of Strategic Credit 

Solutions LLODave Green; 

b. Within ten ( l 0) business days of receipt of a copy of this Order, Applied 

Bank is ordered to transfer to the Receiver or his designated agent all 

funds, if any, in account number xxxx3387 in the name of Strategic Student 

Solutions LLC. 

c. Within ten (10) business days ofreceipt ofa copy of this Order, Bank of 

America is ordered to transfer to the Receiver or his designated agent all 

funds, if any, in the following accounts: 

i. account number xxxx 1785 in the name of Strategic Credit Solutions 

LLC; and 

ii. account number xxxxl 772 in the name of Strategic Student Solutions 

LLC. 

d. Within ten (10) business days of receipt of a copy of this Order, Cynergy 

Data/Priority Payment is ordered to transfer to the Receiver or bis 

designated agent all funds, if any, in account number xxxx3055 in the name 

of Strategic Doc Prep Solutions I.LC. 

e. Within ten l ( 0) business days of receipt of a copy of this Order, Francis 

David Corporation d/b/a Electronic Merchant Systems is ordered to transfer 

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to the Receiver or his designated agent all funds, if any, in account number 

xxxx6586 in the name of Strategic Student Solutions LLC. 

f. Within ten ( I 0) business days of receipt of a copy of this Order, Global 

Client Solutions is ordered to transfer to the Receiver or his designated 

agent all funds, if any, in the following accounts: 

i. account number xxxx0675 in the name of Strategic Debt Solutions 

LLC; 

ii. account number xxxx1064 in the name of Strategic Student Solutions 

LLC; 

iii. account number xxxxl088 in the name of Strategic Credit Solutions 

LLC; and 

iv. account number xxxx2535 in the name of Strategic Credit Solutions 

LLC. 

g. Within ten I ( 0) business days of receipt of a copy of this Order, Merrick 

Bank is ordered to transfer to the Receiver or his designated agent all 

funds, if any, in account number xxxx.3055 in the name of Strategic Doc 

Prep Solutions LLC. 

h. Within ten ( 10) business days of receipt of a copy of this Order, PayMitCo 

is ordered to transfer to the Receiver or his designated agent all funds, if 

any. in the name of Strategic Student Solutions LLC. 

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''.i 

i. Within ten ( 10) business days of receipt of a copy of this Order, TD Bank 

is ordered to transfer to the Receiver or his designated agent all funds, if 

any, in the following accounts: 

L account number xxxx4782 in the name of Strategic Student Solutions 

LLC; 

ii. account number xxxx6890 in the name of Strategic Doc Prep Solutions 

LLC; 

iii. account number xxxx8424 in the name of Credit Relief Center LLC; 

iv. account number xxxx8432 in the name of Student Relief Center LLC; 

v. account number xxxx8487 in the name of Strategic Debt Solutions 

LLC; 

vi, account number xxxx:4203 in the name of Strategic Credit Solutions 

LLC; 

vii. account number xxx.x.0665 in the name ofDG Investment Properties; 

viii. account number xxxx2432 in the name of 4899 Tropical LLC; 

ix. account number xxxx2854 in the name of Clafy Holdings LLC; 

x. account number xxxx6890 in the name of 7893 La Mirada LLC; 

xi. account number xxxx8101 in the name of 5819 Swordfish LLC; 

xii. account number xxxx8250 in the name of 4628 Concordia LLC; 

xiii. account number xxxx8268 in the name of 4461 Squatter Home LLC; 

xiv. account number xxxx8276 in the name of 18 Westgate LLC; and 

xv. account number xxxx8284 in the name of 227 San Remo LLC. 

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j. Within ten ( ! 0) business days of receipt of a copy of this Order, Titanium 

Payments/ Esquire Bank is ordered to transfer to the Receiver or his 

designated agent all funds, if any, in account number xxxx.5770 in the name 

of Strategic Doc Prep Solutions LLC. 

k. Within ten (10) business days of receipt of a copy of this Order, V1U1tiv 

(formerly known as Moneris) is ordered to transfer to the Receiver or his 

designated agent alt funds, if any, in the following accounts: 

i. account number xxxx2884 in the name of Strategic Doc Prep Solutions 

LLC; and 

ii. account number xxxx5885 in the name of Strategic Credit Solutions 

LLC. 

I. Within ten I ( 0) business days of receipt of a copy of this Order, Wells 

Fargo is ordered to transfer to the Receiver or its designated agent all 

funds, if any, in account number xxxx2700 in the name ofClafy Holdings 

LLC. 

2. All financial institutions holding accounts in the name of, on behalf of, or for the 

benefit of, Individual Defendant shall, within ten I ( 0) business days from receipt 

ofa copy of this Order, transfer to the Commission or its designated agent, all 

funds, if any, in such accounts, including, but not limited to: 

a. Within ten I ( 0) business days of receipt of a copy of this Order, TD 

Ameritrude is ordered to transfer to the FTC or its designated agent all 

funds, if any, in the following accounts: 

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i. account number xxxx5069 in the name of liberty Education Services 

LLC; 

ii. account number xxxx9.S94 in the name of Dave Green; and 

iii. account number xxxx0871 in the name of Dominique Green. 

b. Within ten I ( 0) business days of receipt of a copy of this Order, TD Bank 

is ordered to transfer to the FTC or its designated agent all funds, if any, in 

the following accounts: 

i. accow1t number xx.xx8479 in the name of Strategic Support Solutions 

LLC; 

ii. account number xxxx7898 in the name of Credit Security and Resource 

Centers LLC; 

iii. account number xxxx7905 in the name of Credit Investment Services 

LLC; 

iv. account number x.xxx7921 in the name of Credit Zone LLC; 

v. account number xxxx 7939 in the name of Capitol Credit Sources LLC; 

vi. account number xxxx7947 in the name of Credit Asset Solutions LLC; 

vii. account number xxxx3652 in the name of Dave Green Inc.: 

viii. accoW1t number xxxx1232 in the name ofN. Green FL, UTMA; and 

ix. account number xxxxl399 in the name ofT. Green FL, UTMA. 

c. Within ten l ( 0) business days of receipt of a copy of this Order, First 

Global Bank in Jamaica is ordered to transfer to the FTC or its designated 

agentall funds, if any, in the following accounts: 

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i. account number xxxx3323 in the name of DG Call Sales Solutions; and 

ii. account number xxxx0057 in the name of Strategic DG Loans. 

ten Within l ( 0) business days of receipt of a copy of this Order, Applied 

Bank is ordered to transfer to the FTC or its designated agent all funds. if 

any, in account number xxxx7022 in the name of Dave Green. 

3. Within seven (7) days of the date of entry of this Order, Defendants, Relief 

Defendant, and Rental Property Entities shall cooperate fully and take such steps as the Receiver 

may require, including executing any documents and providing any necessary information, to 

cause the transfer to the Receiver, or to his qualified settlement fund, possession and legal and 

equitable title to the real property described below (collectively, "the Rental Properties"). The 

Receiver is authorized to pay any required taxes and documentary stamps as needed to effectuate 

the transfers contemplated by this Order. Following transfer of title and possession, the Receiver 

shall be responsible for all maintenance, utilities, taxes, bomeowner's association fees, and all 

other expenses of any nature related to the Rental Propenies and is authorized to pay alJ such 

expenses as they come due from the Receivership Estate, including from ~ntal income and 

proceeds from sale( s) of one or more of the Rental Properties, or as may otherwise be necessary 

to maintain the Rental Properties. Defendants, Relief Defendant, and Rental Property Entities 

represent that there are no liens or encumbrances on the Rental Properties. Defendants, Relief 

Defendant. and Rental Property Entities shall not add any such encumbrances after signing this 

Order. The costs and expenses of transferring the Rental Properties shall be paid by the 

Receivership Estate without consideration of the source of funds used being related to the Rental 

Property so transferred. Defendants, Relief Defendant, and Rental Property Entities expressly 

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agree that the Rental Properties are not homestead property, and further hereby forever waive, 

release, discharge, and disclaim all right, title, and interest in the Rental Propenies described in 

this sub-paragraph. Until Defendants, Relief Defendant, and Rental Property Entities transfer 

title and possession of the Rental Properties, Defendants, Relief Defendant, and Rental Property 

Entities shall take no action to diminish the value of the Rental Properties, including any 

structures, fixtures, and appurtenances thereto. 

This provision applies to the 22 Rental Properties transferred to the Receiver pursuant to 

the June 6, 2017 Agreed Order on Receiver's Emergency Verified Motion, which includes the 

following properties: 

a. l Renaissance Way #304, Boynton Beach, FL 33426 

h. 5819 Swordfish Ct., Tamarac, FL 33319 

c. 6300 S Falls Cir., Dr. #109, Lauderhill, FL 33319 

d. 8911 NW 28th Dr. #8, Coral Springs, FL 33065 

e. 2701 Riverside Dr., #303-B, Coral Springs, FL 33065 

f. 227 San Remo Blvd., N. Lauderdale, FL 33068 

g. 14212 NE 4th Ave., Miami, FL 33161 

h. 17343 NW 7th Ave. #710, Miami, FL 33169 

1. 4158 lnverrary Dr. #503, Lauderhill, FL 33319 

j. 4461 NW 59th Court, North Lauderdale, FL 33068 

k. 500 Three Islands Blvd. #101, Hallandale Beach, FL 33009 

I. 4628 Concordia Ln., Boynton Beach, FL 33426 

m. 18 Westgate Ln. #18F, Boynton Beach, FL 33426 

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n. 6009 NW l st Street. Margate, FL 33063 

o. 4899 Tropical Gardens Dr., Boynton Beach, FL 33426 

p. 11152 W. Sample # 11152, Coral Springs. FL 3 3065 

q. 5280 Gate Lake Road #5280. Tamarac, FL 33319 

r. 5961 S. Falls Circle Drive, #309, Lauderhill, FL 33319 

s. 4109 Bellasol Cir. #l 114, Fort Myers, FL 33916 

t. 7355 Woodmont Terrace #102 Tamarac, FL 33321 

u. 2314 Johnson Street #24D, Hollywood, FL 33020 

v. 1750 NW 55th Ave. #203, Lauderhill, FL 33313 

Defendants, Relief Defendant, and Rental Property Entities are ordered to fully and timely 

cooperate with the Receiver in the maintenance, rental, sale or other transfer of any of the Rental 

Properties, including executing any documents necessary to transfer title of such properties upon 

their sale. The Receiver reserves all rights with respect to claims against any Person who has 

lived in or received rental income from the Rental Properties to recover rental income, 

reimbursements for funds advanced or other out-of-pocket expenses incurred in respect of the 

maintenance, care, administration. sale, or listing for sale of the Rental Properties. 

4. Within 7 days of entry of this Order, the Receiver shall assign all right, title, and 

interest to the non•interest bearing lien previously granted to the Receiver on the real property 

located at 8142 Banpo Bridge Way, Delray Beach, Florida 33446, pursuant to the Court Order 

dated June 6, 2017, as recorded in the records of Palm Beach County at OR BK 29170 PG 1306, 

to the Commission. The lien amount shall be $315,000. Defendants shall not challenge the lien 

or the assignment of the lien to the Commission. 

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C. Upon payment and all other asset transfers, as set forth in Subsection B above, the 

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

D. As set forth in Section VIII below, the Receiver is directed to liquidate assets held by the 

Receiver and. after satisfaction of any Court-authorized payments, transfer the remaining assets 

and net proceeds from the sale of these assets to the FTC. 

E. The Commission's agreement to the suspension of part of the judgment is expressly 

premised upon the truthfulness, accuracy, and completeness of Defendants' and Relief 

Defendant's sworn financial statements and related documents {collectively, "financial 

representations") submitted to the Commission, namely: 

l. the Financial Statement of Individual Defendant Dave Green signed on May 25, 

2017, including the attachment~ 

2. the Financial Statement of Strategic Student Solutions signed by Dave Green on 

June 8, 2017, including the attachments; 

3. the Financial Statement oflndividual Defendant Dave Green labeled .. Attachment 

A" signed on July J I, 2017, including the attachments: 

4. the Financial Statement of the Corporate Defendants labeled "Attachment B" 

signed by Dave Green on July t I, 2017, including the attachments; and 

S. the Declaration of Dave Green regarding Supplemental Financial Disclosures 

signed by Dave Green. undated, including Attachments A-H. 

F. The suspension of the judgment wiU be lifted as to any Defendant if, upon motion by the 

Commission, the Court finds that Defendant failed to disclose any material asset, materially 

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misstated the value of any asset, or made any other material misstatement or omission in the 

financial representations identified above, 

G, 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 consumer injury), less any payment previously made 

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

H. Defendants and Relief Defendant 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. 

I. 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. 

J. 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 coUatera.l estoppel effect for such purposes. 

K. Defendants and Relief Defendant acknowledge that their Taxpayer Identification Numbers 

(Social Security Numbers or Employer Identification Numbers) may be used for collecting and 

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

§7701. 

L. 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 

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consumer redress any and attendant expenses for the administration of any redress fund. lf a 

representative of the Commjssion 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 and Relief Defendant have no right to challenge any actions the Commission or its 

representatives may take pursuant to this Subsection. 

M. The asset freeze is modified to permit the payments and transfers identified in the 

Monetary Judgment Section. Upon completion of those payments and transfers, the asset freeze 

is dissolved. 

VII. CUSTOMER INFORMATION 

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, 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. Defendants represent that they have provided this redress 

information to the Commission. lf a representative of the Commission requests in writing any 

information related to redress, Defendants must provide it, in the form prescribed by the 

Commission, within 14 days. 

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

telephone number, email address, social security number, FSA ro, other identifying information, 

or any data that enables access to a customer's account (including a student loan account, credit 

card, bank account, or other financial account), that any Defendant obtained prior to entry of this 

Order in connection with the sale of student loan debt relief or credit repair services; and 

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

control within 30 days receipt after 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. 

VIII. TEMPORARY CONTINUATION AND TERMINATION OF RECEIVERSHIP 

IT IS FURTHER ORDERED that the Receiver shaU retain full receivership powers, 

including but not limited to those powers set forth in the Stipulated Preliminary Injunction entered 

by the Coun in this maner on May 26, 2017, and incJuding full liquidation powers. Upon entry 

of this Order, the Receiver shall liquidate an remaining receivership property and the Rental 

Properties, and dispose of all remaining files, records, and computers. The Receiver is directed 

and given authority to mke all necessary steps to oversee the sale of the Rental Properties, 

including the authority to retain one or more real estate agents. to enter into a contract for the 

private purchase and sale of each property, or to sell the Rental Properties in block sales, bulk 

sales, or individually, or, if in the Receiver's business judgment, to sell the Rental Properties 

( either individually, in blocks, or bulk sale) by way of public auction, to administer the sale 

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process, to maintain and preserve the Rental Properties in the interim, and to close the sale of each 

property. The Receiver is hereby expressly relieved from any obligations under 28 U.S.C. § 

2001 or 28 U.S.C. § 2004. The Receiver is directed to wind up the Corporate Defendants and 

liquidate all assets within 120 days after entry of this Order, but any party or the Receiver may 

request that the Court extend the Receiver's tenn for good cause. Upon termination of the 

receivership and finaJ payment to the Receiver of aJJ approved fees, costs, and expenses, the 

Receiver shall transfer to the FTC or its designated agent all remaining assets in the Receivership 

Estate and the proceeds of the sale of the Rental Properties remaining after payment of costs 

necessary for such sales. 

IX. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendants and Relief Defendant obtain 

acknowledgments of receipt of this Order: 

A. Each Defendant and Relief 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 S years after entry of this Order, Individual Defendant, for any 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: ( l) all principals, officers. directors, and LLC mauagers 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; 

(3) any and 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 

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persoMet For all others. delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which a Defendant delivered a oopy of this Order, that 

Defendant must obtain. within 30 days, a signed and dated acknowledgment of receipt of this 

Order. 

X. 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: 

l. 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 Defendant 

must describe ifbe knows or should know due to his 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, Individual Defendant must: (a) identify all telephone numbers and all 

physical, postal, email and Internet addresses, including aU residences; (b) identify all business 

activities, including any business for which such Defendant performs services whether as an 

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employee or otherwise and any entity in which such Defendant has any ownership interest; and 

(c) describe in detail such Defendant's involvement in each such business, including title, role, 

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

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

notice, sworn under penalty of perjury, within t 4 days of change any in the following: 

I. 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, Individual 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 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 ofany 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 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 

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is true and colTect. 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 DEbrieft~fkgov or sent by ovemight 

courier (not the U.S. Postal Service) to: Associate Director for Enforcement, Bureau of 

Conswner Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, 

DC 20580. The subject line must begin: FTC v. Strategic Student Solutions, et aL, matter no. 

Xl70038. 

XI. 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 

Defendants and 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 numbcrs;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, any and response; 

D. all records necessary to demonstrate full cornptiance with each provision of this Order, 

including all submissions to the Commission; and 

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E. a copy of each unique advertisement or other marketing material. 

XII. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendants' and Relief 

Defendant's compliance with this Order, i.ncluding the financial representations upon 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 Defendant and Relief Defendant must: submit additional compliance reports or other 

requested infonnation, which must be sworn under penalty of perjury; appear for depositions; and 

produce documents for inspection and copying. The Commission 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 and Relief Defendant. Defendants and Relief Defendant must pennit 

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 an other lawful means, including posing. through its 

representatives as consumers, suppliers, or other individuals or entities. to Defendants, Relief 

Defendant, or any individual or entity affiliated with Defendants or Relief Defendant, 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-l. 

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

agency must furnish consumer reports concerning [ndividual .Defendant, pursuant to Section 

604(1) of the Fair Credit Reporting Act, 15 U.S.C. § l68Ib(a)(l). 

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. 

SO ORDERED this 23.. day of ___ }'n.....:..A-....._~---'· ___ _. 

SO STIPULATED AND AGREED: 

FOR THE FEDERAL TRADE COMMISSION: 

~ fl/. tt/~· 

MIYA TANDON 

{Florida Special Bar No. A5502005) 

ADAM M. WESOLOWSKI 

(Florida Special Bar No. A5502 l 73) 

Federal Trade Commission 

600 Pennsylvania Ave., NW, CC-10232 

· W~ington, DC 20580 

(202} 326-2351 {Tandon) 

(202) 326-3068 (Wesolowski) 

mtandon@ftc.gov 

awesolowski@ftc.gov 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

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IVIDUAL DEFENDANT: 

FOR CORPORA TE DEFENDANTS Strategic Student Solutions LLC, Strategic Credit 

Solutions LLC, Stratepe Doc Prep Solutions LLC, Strategic Debt Solutions LLC, Student 

Relief Center LLC, ad Credit Relief Center LLC and RELIEF DEFENDANT DG 

Investment Properties LLC: 

~-~ Date: i/.: 3-/f 

Gavin C. Gaukroger, Esq. 7 

Counsel for the Receiver 

FJorida Bar No. 0076489 

BERGER SINGERMAN LLP 

350 East Las Olas Boulevard, Suite I 000 

Fort Lauderdale. Florida 333014 

Telephone: (954) 525-9900 

ggaukroger(@beTgersingennan.com 

Date: /t./..f/ /,,f/ 

Strate . Student 

, as an 

Solutions 

officer of 

LLC, 

Corporate 

Strategic 

Defendants 

Credit 

• ~ 

Solutions LLC, Strategic Doc Prep Solutions LLC. 

Strategic Debt Solutions LLC, Student Relief Center 

LLC, and Credit Relief Center LLC, and Relief 

Defendant DG Investment Properties LLC 

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